View source for U-603058, Responds to Violations Noted in Insp Rept 50-461/98-09. Corrective Actions:Revised Plant Standing Order (PSO) 29, Emergency Security Notifications to Require That Security Activate ERDS Sys in Simulator

{{Adams
| number = ML20236Y619
| issue date = 08/05/1998
| title = Responds to Violations Noted in Insp Rept 50-461/98-09. Corrective Actions:Revised Plant Standing Order (PSO) 29, Emergency Security Notifications to Require That Security Activate ERDS Sys in Simulator
| author name = Macfarland W
| author affiliation = ILLINOIS POWER CO.
| addressee name = 
| addressee affiliation = NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
| docket = 05000461
| license number = 
| contact person = 
| document report number = 50-461-98-09, 50-461-98-9, GL-89-15, U-603058, NUDOCS 9808120355
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE
| page count = 10
}}

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Clinton Power Station P O. Box 678
    .            .                                                                                            Chnton. IL 61727 Tel 217 935-5623 Fax 217 935-4632 Walter G. MacFarland IV Senior Vice President and Chef Nuclear Officer ILLINSIS P(MNER An Illinova Company is"*
August Si 1998 Docket No. 50-461 Document Control Desk
                        - U.S. Nuclear Regulatory Commission Washington, D. C. 20555

==Subject:==
Response to Notices of Violation Contained in Inspection Report 50-461/98009 (DRS)
Dear Madam or Sir; i
This letter provides the Illinois Power Company (IP) response to the three violations discussed in the Notice of Violation (NOV) contained in Inspection Report 50-461/98009(DRS). IP admits that these three violations occurred.
The first violation is due to an untimely activation of the Emergency Response Data System (ERDS) after the declaration of an ALERT on February 13,1998, at the Clinton Power Station facility. The second violation is for lack of adequate Emergency Response Organization staffing for the February 13,1998, event. The third violation is for Emergency Response Organization (ERO) personnel not having their ERO access                                    l badges when they responded to the ALERT on February 13,1998, thus resulting in a                                   I delay of staffing emergency response positions.                                                                    !
1 In response to the deficiencies identified during the February 13,1998 ALERT and subsequent reviews, Illinois Power implemented significant improvement; io its Emergency Response program. These comprehensive improvements were initiated                                         l l                        prior to the NRC inspection and were in progress during the inspection. The non-                                    !
1 compliances identified in Inspection Report 50-461/98009(DRS) were typical of the deficiencies that were included in ongoing improvement efforts.
The attachments to this letter contain the following commitments:                                       !
* Illinois Power will design the ERDS to be activated from one location thus                               ,
simplifying the response required to meet the one hour time limit.
i 9808120355 980805 gDR     ADOCK 05000461 PDR
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U-602058 Page 2
* Illinois Power will review the regulatory requirements with regard to Emergency Planning to ascertain if any changes to the regulatory guidelines have an effect on emergency preparedness.
l                                                                                             e Emergency Planning will conduct at least one after hours drill per year which will specify that ERO personnel will need to use their ERO badges to gain access to the protected area.
                                                                                              . Emergency Planning will revise the Emergency Plan Implementation Procedure EC-09, " Security During Emergencies," to verify ERO qualifications by means of ERO badges or alternate methods to grant immediate access to the protected area or other emergency facilities.
S ce ely yours, W         J Walter G. MacFarland, IV Senior Vice President and ChiefNuclear Officer BGS/krk Attachments cc:      NRC Clinton Licensing Project Manager NRC Resident Office, V-690 Regional Administrator, Region III, USNRC Illinois Department ofNuclear Safety I
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       .                                                                                    Attachment A to U-603058 Page 1 of 2 Response to Notice of Violation 98009-02 The Notice of Violation states in part:
                       "10CFR50.72(a)(4), requires that the Emergency Response Data System (ERDS) be initiated as soon as possible following an Alert or higher emergency declaration, but within one hour in any case.
Contrary to the above, on February 13,1998, the ERDS system was not initiated vithin one hour of the declaration of the Alert. Specifically, ERDS was initiated one hour and seventeen minutes after the event declaration."
Background and Cause ofEvent On February 13,1998, at approximately 0340 hours, operators received multiple annunciators that were indicative of a loss of the Division II Nuclear Systems Protection System (NSPS) bus. The Reactor Water Cleanup (RT) system isolated and operators observed indications that the RHR suction valve, IE12F009, was going in the closed direction. Operators immediately shut down RHR "A" train to preclude damage to the pump in accordance with appropriate procedures. Operations entered the Clinton Power
,             Station (CPS) Off-Normal procedure CPS 4001.02, " Automatic Isolation." Operators l             entered Off-Normal procedure CPS 4006.01, " Loss of Shutdown Cooling," performed l              steps to evacuate the drywell, turned on the Automatic Depressurization System (ADS) safety valve temperature recorder, and commenced CPS procedure 9000.06D001, "RPV Heatup/Cooldown Log," for tracking reactor coolant temperature.
At approximately 0410 hours, the on-duty Shift Supervisor (SS) declared an Alert to l              obtain additional resources in restoring shutdown cooling capabilities. The shift supervisor made this declaration based on his judgment and the guidelines of section 13.6 of procedure EC-02, " Emergency Classifications," which states that other plant conditions could exist which warrant activation of the Technical Support Center (TSC). An ALERT l              requires activation of the ERDS as soon as possible but no longer than one hour following l              declaration.
l Activation of the ERDS requires two computers to be activated. One computer is activated by the Shift Technical Advisor in the Main Control Room while another computer must be activated by a computer operator in the Emergency Operating Facility who must go to the training simulator where the computer is located.
I             At 0532 hours, the Emergency Response Data System (ERDS) was activated.
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     -                                                                                   Attachment A to U-603058 Page 2 of 2 At 1000 hours, the Alert was terminated.
The cause of the untimely activation of the ERDS was that the requirements of 10CFR50.72 were not reviewed when the procedure for implementing ERDS was created.
The ERDS system was implemented at CPS in 1993. The ERDS system was discussed in Generic Letter 89-15, " Emergency Response Data System," to solicit the participation of all applicable licensees and applicants in the ERDS program. Subsequently, the ERDS system was referenced in several NRC correspondences to aid the industry in implementing the program. It was during this implementation period that CPS did not recognize the time requirement to activate the ERDS system within one hour of an ALERT declaration. A contributing factor is that the ERDS must be activated from two different places on site.
Cctrective Actions Taken and Results Achieved An immediate corrective action was to revise Plant Standing Order (PSO) 29, " Emergency Security Notifications," to require that Security activate the ERDS system in the simulator. This will utilize on shift responders so that the time requirement will be met.
Corrective Actions to Prevent Recurrence During the annual review of the Emergency Preparedness Program, a review of the regulatory requirements that effect Emergency Planning will be included. This is a long term corrective action that will ensure regulatory changes are reviewed for possible impact on Emergency Planning.
CPS initiated an Engineering Work Request (EWR) to' design the ERDS to be activated from one location. This change will result in a simplified means of activation of ERDS.                I Emergency Plan Implementation Procedure (EPIP) EC-01, " CPS Emergency Response Organization and Stafling," Form 33, will be revised to include the one hour time requirement to activate ERDS.
Date When Full Compliance Will Be Achieved Illinois Power is in full compliance with the activation of the ERDS system due to the revision to PSO-29 completed on July 24,1998.
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Attachment B to U-603058 l                                                                                                      Page1of3 Response to Notice of Violation 98009-03 l
The Notice of Violation states in part:
                                "10 CFR 50.54(q) requires that a licensee authorized to possess and operate a nuclear power plant shall follow and maintain in effect emergency plans which meet the standards in 10 CFR 50.54(b) and the requirements of Appendix E to 10 CFR Part 10.
                             ' The Clinton Power Station Emergency Plan, Section 2.1, " General," indicates that dedicated attemates in sufficient quantities have been assigned to fulfill primary emergency response positions and to perform their functions on a continuous (24-l                              hour) basis Section 2.2.7, "24-Hour Shift Complement," provides numbers and types of normal shift personnel assigned to emergency response positions during power operation, startup and hot shutdown, and references Tabb 2-1. Table 2-1 indicates that two electrical maintenance personnel, able to respond te emergencies, will be on shift.
Section 5.4.2, " Emergency Response Personnel Training," states: It is the responsibility of the personnel assigned to the Emergency Response Organization (ERO) to become familiar with their CPS Emergency Plan assigned authority and responsibility so that planned actions will be taken in the event of an emergency..          j It is the responsibility ofIP department managers to ensure that their personnel attend assigned Emergency Preparedness training.... Personnel who are to function in the IP Emergency Response Organization for Clinton Power Station are provided initial training and annual retraining regarding their emergency -related duties and responsibilities.... The types ofindividuals who receive training shall include, but are not necessarily limited to.... Repair and damage control teams Contrary to the above, on the morning of February 13,1998, there was only one electrical maintenance personnel on shift, who was trained and assigned as a member of the emergency response organization. Specifically, one of the two electrical maintenance personnel on shift was not trained."
Background and Cause of Event l-                 On February 13,1998, at approximately 0340 hours, operators received multiple L                  annunciators that were indicative of a loss of the Division II Nuclear Systems Protection System (NSPS) bus The Reactor Water Cleanup (RT) system isolated and operators observed indications that the RHR suction valve, IE12F009, was going in the closed direction. Operators immediately shut down RHR "A" train to preclude damage to the pump in accordance with appropriate procedures. Operations entered the Clinton Power Station (CPS) Off-Normal procedure CPS 4001.02, " Automatic Isolation." Operators l
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      .                                                                                     Attachment B to U-603058 Page 2 of 3 entered Off-Normal procedure CPS 4006.01, " Loss of Shutdown Cooling," performed steps to evacuate the drywell, turned on the Automatic Depressurization System (ADS) safety valve temperature recorder, and commenced CPS procedure 9000.06D001,"RPV Heatup/Cooldown Log," for tracking reactor coolant temperature.
At approximately 0410 hours, the on-duty Shift Supe: visor (SS) declared an Alert to obtain additional resources in restoring shutdown cooling capabilities. The shift supervisor made this declaration based on misjudgment and the guidelines of section 13.6 of procedure EC-02, " Emergency Classifications," which states that other plant conditions could exist which warrant activation of the Technical Support Center (TSC). Activation of the TSC requires that on shift technical support personnel, who are emergency response qualified, man the TSC to provide assistance for radiological and technical situations.
At 0418 hours, the Emergency Response Organization (ERO) Notification System was
;             activated.
At 0422 hours, the first all-call page was completed.
l             At 0500 hours, the ERO Notificee.m System was shutdown. The first individuals to augment the shift staffing goals of Table 2-1 of the Emergency Plan came from extra personnel already on shift. Table 2-1 requires that one electrician be on shift and one electrician to respond within 30 minutes. Review of this event indicated that of the two electrical maintenance technicians required, only one was properly qualified. In addition, other discrepancies were discovered in the manning of the TSC. The Supervisor-Technical, a 30-minute responder, was not available in the TSC for over an hour, and there were not enough Radiation Protection technicians on site to meet the 30-minute and 60-minute goals.
t l             At 1000 hours, the Alert was terminated.
l The cause of this violation is that management did not ensure that the staffing of backshift personnel met the requirements of the Emergency Preparedness Program.
Corrective Actions Taken and Results Achieved CPS senior management published a memorandum to all ERO personnel explaining management's expectations regarding participation by ERO personnel in Emergency Plan pager tests, training seminars, and ERO drills.
Radiation Protection technicians, mechanics, electricians, and control and instrumentation technicians that were 30-minute responders per Table 2-1 were put on shift. This action restored the backshift augmentation to meet the guidelines of Table 2-1.
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      .                                                                                      Attachment B to U-603058 Foge 3 of 3
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Corrective Actions to Prevent Recurrence l
Table 2-1, "Clinton Power Station Minimum Staffing," of the Emergency Plan was j              submitted to the NRC for revision to provide a more realistic shift augmentation goal.
Date When Full Compliance Will Be Achieved l
!              Illinois Power is in full compliance with regard to staffing of the Emergency Response l              Organization.
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Attachment C .
to U-603058 Page 1 of 3 Response to Notice of Violation 98009-05 l
The Notice of Violation states in part:
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L                                                                                                                                 "10 CFR 50.54(q) requires that a licensee authorized to possess and operate a i                                                                                                                                 nuclear power plant shall follow and maintain in effect emergency plans which meet the standards in 10 CFR 50.54(b) and the requirements of Appendix E to 10
!                                                                                                                                  CFR Part 10.
The Clinton Power Station Emergency Plan (Plan) at Section 1.3.1 states that the L                                                                                                                                Plan and supporting documents are gplicable to CPS personnel, IP personnel and emergency response assignments and responsibilities, and vendors or contractors.
The Plan at Section 1.4 states that the Appendices of the Plan contain supporting documents. Appendix B to the Plan contains Emergency Plan Implementing Procedure (EPIP) EC-09 " Security During Emergencies."
'                                                                                                                                                                                                                                       i Emergency Plan Implementing Procedure (EPIP) EC-09, " Security During Emergencies," Section 4.5, "ERO Personnel Identification," specified that members of the Emergency Response Organization (ERO) were issued emergency                            )
access badges to allow entry into the protected area and emergency facilities in the event of an emergency.
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Section 4.6.2 of EPIP EC-09 indicates that an Alert or higher emergency declaration, Security Force Members control access to the Operations Support Center and Technical Support Center. Section 4.6.3 states that " Security Force Personnel or EOF Access Control Coordinator shall grant access to the Protected Area and emergency response facilities to the following individuals: " Emergency Response Organization Personnel."
Contrary to the above, the issued emergency access badges did not allow entry in the event of an emergency because on the morning of February 13,1998, following the declaration of an Alert, several reporting emergency response organization members failed to have the badges in their possession. This required other means of access identification to be utilized, delaying emergency facility access and activation. Specifically, Technical Support Center activation was delayed."
Background and Cause of Event On February 13,1998, at approximately 0340 hours, operators received multiple annunciators that were indicative of a loss of the Division II Nuclear Systems Protection System (NSPS) bus. The Reactor Water Cleanup (RT) system isolated and operators observed indications that the RHR suction valve, IE12F009, was going in the closed direction. Operators immediately shut down RHR "A" train to preclude damage to the W               .. ..

            . . ,                                                                                                           Attachment C to U-603058 Page 2 of 3 l
i pump m accordance with appropriate procedures. Operations entered the Clinton Power Station (CPS) Off-Normal procedure CPS 4001.02, " Automatic holation " Operators entered Off-Normal procedure CPS 4006.01, " Loss of Shutdown Cooling," performed l
steps to evacuate the drywell, turned on the Automatic Depressurization System (ADS) .
safety valve temperature recorder, and commenced CPS procedure 9000.06D001, "RPV l                         Heatup/Cooldown Log," for tracking reactor coolant temperature.
At approximately 0410 hours, the on-duty Shift Supervisor (SS) declared an Alert to l                         obtain additional resources in restoring shutdown cooling capabilities. The shift
:                         supervisor made this declaration based on misjudgment and the guidelines of section 13.6 of procedure EC-02, " Emergency Classifications," which states thai other plant conditions could exist which warrant activation of the Technical Support Center (TSC).
Personnel began arriving at the Operations Gate House for entry into the protected area of the facility. Security force members required that personnel show their ERO badges to gain entry during the ALERT in accordance with Section 4.6 of Emergency Plan Implementing Procedure (EPIP) EC-09, " Security During Emergencies." Many personnel did not have their badges so the security members were required to look at a printout of authorized people. This is a very cumbersome and time consuming method which caused a delay in responding to the situation.
At 1000 hours, the Alert was terminated.
The cause of this violation was due to lack of effectively communicating and reinforcing management's expectations that all ERO members shall carry their ERO badges at all times. A contributing factor was that the event of February 13,1998, was a unique situation in that ERO personnel had to identify themselves to security force members prior to entry into the protected area. Historically, ERO personnel have not had to produce their ERO badges for entry into the protected area during drill scenarios.
Corrective Actions Taken and Results Achieved The emergency Response Organization issued a bulletin to all ERO personnel to address the need for all members to carry their ERO badges at all times. This will reinforce the expectation that during a response the individual will not have any delays to reach their required ERO position.
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            ,                                                                                     Attachment C to U-603058 Page 3 of 3 Corrective Actions to Prevent Recurrence CPS has revised Nuclear Training and Support procedure 3.94, " Access Processing," to require that all personnel wear their Owner Controlled Area (OCA) badges when on site.
The OCA badges have the ERO identification on the back if the individual is ERO qualified. This ensures that ERO members will have their ERO badges easily accessible at any point during the day.
Emergency Planning will conduct at least one after hours drill per year which will specify that ERO personnel will need to use their ERO badges to gain access to the protected area.
Emergency Planning will revise the Emergency Plan Implementation Procedure EC-09,
                      " Security During Emergencies," to verify ERO qualifications by means of ERO badges or alternate methods to grant immediate access to the protected area or other emergency facilities.
Date When Full Compliance Will Be Achieved l
Illinois Power is in full compliance with respect to the Emergency Response Organization identification badges.
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