ML20206S041

Responds to NRC 870227 Ltr Re Violations Noted in Insp Rept 50-461/87-06.Corrective Actions:Concerns Re Differences Between Emergency Operating Procedures & Emergency Procedure Guidelines Clarified & Corrected Through table-top Review

ML20206S041
Person / Time
Site:	Clinton
Issue date:	04/08/1987
From:	Spangenburg F ILLINOIS POWER CO.
To:	Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
U-600894, NUDOCS 8704220321
Download: ML20206S041 (22)

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.N U-600894 6 L30-87(04-08)-L 1A.120 ILLINDIS POWER 00MPANY CLINTON POWER STATION. P.O. BOX 678. CLINToN. ILLINolS 61727 April 8, 1987 l

Docket No. 50-461 Mr. A. Bert Davis Acting Regional Administrator Region III U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137

Subject:

Response Requested in Regard to Inspection Report No. 50-461/87006.(DRS)

Dear Mr. Davis:

This letter is in response to the February 27, 1987 letter requesting information on the actions implemented to correct deficiencies in our Emergency Operating Procedures and the improvements we have made in our management systems to ensure all deficiencies identified by our corrective action system are corrected in a timely manner. A response was also requested to resolve the item identified in paragraph 4.b(1) of Inspection Report No. 50-461/87006 (DRS).

Attachment A provides Illinois Power Company's (IP's) responses to this request for information. On March 19, 1987 the Notice of Violation on this matter was transmitted to IP. Attachment B provides IP's Response to this Notice of Violation.

I trust that our response is sufficient to answer your questions.

Sincerely yours, 4.A.

F. A. S nge erg L '

J Manager - Licensing and Safety GSL/bsa Attachments cc: B. L. Siegel, NRC Clinton Licensing Project Manager j NRC Resident Inspector Illinois Department of Nuclear Safety . g ['

A 4220321 870408 G ADOCK 05000461 k\

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! )- LU-600894

..  : L30-87 (04-08)-L' ATTACHMENT'A' ILLINOIS POWER COMPANY CLINTON POWER STATION (1) ' Identified differences between CPS Emergency Operating-Procedures l (EOPs) and CPS Emergency Procedure Guidelines (EPGs).

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Following the recent NRC audit of' CPS-EOPs Illinois Power (IP)

. conducted a complete comparison of CPS-EOPs to CPS-EPGs. This " table-top" review was completed on February 11,.1987.- The table-top review consisted of three phases:-

i Phase I - A side-by-side,' line-by-line,~ word-for-word comparison of EOPs-to EPGs. Any differences

- noted were. documented.

Phase II - A technical evaluation of the differences identified. During this phase corrections were i recommended, and the differences were categorized as " Technical Accuracy" or " Written Correctness".

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! Phase III - A supervisory review of Phase II activities.

4 This phase reviewed the recommendations made in Phase II, and initiated the corrective actions required.

Table 1 shows the findings of the table-top review.

During the NRC Audit of E0Ps the Staff's concerns were categorized as

, "Potentially Safety Significant" or of " Minimal Safety Significance." The l Staff implied that the "Potentially Safety.Significant" concerns must be resolved prior to exceeding 5% Reactor Power. The concerns categorized as being of " Minimal Safety Significance" were to be corrected in a' timely manner. IP used the same plan for correcting all concerns identified by the table-top review.

The Appendix to the February 27, 1987 letter lists 13 specific concerns. Those concerns and IP's response to those concerns follow:

1) CPS No. 4402.01, Step 3.1.1 does not require scram on stuck open relief valve per P-STG.

! Response: CPS P-STG Step SP/T-1 states:

i Close all Safety Relief Valves (SRV's) not required to be

• open IF Any SRV cannot be closed and suppression pool i temperature reaches 110*F (technical specification 4

temperature limit with a stuck open SRV).

2 THEN Place mode switch in SHUTDOWN.

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ATTACHMENT A ILLIN0IS POWER COMPANY

. CLINTON POWER STATION The corresponding CPS 4402.01 step (3.1.1) states:

Close all Safety Relief Valves (SRV's) not required to be open.

BWROG Generic EPGs Rev. 3J step SP/T-1 states:

If any Stuck Open Relief Valve (SORV) cannot be closed (within 2 minutes (optional plant-specific time interval)],

scram the reactor.

CPS Technical Specifications do not specify a plant-specific time interval for scramming the reactor with a SORV. Also, current BWROG EPG committee thinking on this topic is that the reactor should not be scrammed unless Suppression Pool temperature exceeds 110*F, or l

exceeding 110*F is imminent. Subsequent E0P steps require a scram l before Suppression Pool temperatures reach 110*F. Therefore CPS l 4402.01 step 3.1.1 is correct as written. The CPS EPG will be revised to be consistent with the E0Ps and provide justification for this difference between CPS EPGs and generic EPGa.

2) The addition of Step 3.1.5 to CPS No. 4402.01 and Plant Specific Technical Guideline (P-STG) (Emergency Procedure Guidelines (EPGs) at Clinton Power Station) is not justified in P-STG.

Response: CPS EPG step SP/T-5 is part of Generic EPG step SP/T-4 and needs no justification.

3) Step 3.3.2 of CPS No. 4402.01 is not in P-STG.

Response: This step and its justification will be added to the CPS-EPGs.

4) Caution statement #22 does not appear prior to Step 3.6.8 of CPS No. 4402.01 per P-STG.

Response: Caution statement #22 wcs added prior to Step 3.6.8 of CPS No. 4402.01 during a recent revision of this procedure, completed on 2/28/87.

5) Step 3.5 of CPS No. 4404.01 does not appear in P-STG.

Response: This step and its justification will be added to the CPS-EPGs.

6) Steps 4.5.5 and 4.7.7 of CPS No. 4404.01 state control rod drive differential pressures different from the P-STG.

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ATTACHMENT A ILLINOIS POWER COMPANY CLINTON POWER STATION Response: The values for control rod drive differential pressures used in CPS No. 4404.01 are correct. The values used in CPS-EPCs will be corrected.

7) Entry condition (b) of CPS No. 4406.01 uses fuel building exhaust radiation level vs. area radiation levels used in P-STG.

Response: The intent of taking action based on radiation levels is fully met by using the Fuel Building Exhaust Radiation level.

CPS 4406.01 is correct; the CPS-EPGs will be revised to reflect this information and justify this position.

8) Step 3.2.3 of CPS 4406.01 uses a condition of "a General Emergency has been declared" vs. "offsite radioactivity release rate approaches or exceeds the release rate which requires a General Emergency" as used in the P-STG.

Response: CPS 4406.01 step 3.2.3 was revised as of 2/28/87 to reflect the EPG step.

9) CPS No. 4406.01 uses an entry condition of secondary containment pressure differential of +0.125" paid vs. P-STG entry condition of 0" water gage (WG).

Response: The setpoint for the entry condition into CPS 4406.01 on Secondary Containment differential pressure has been revised to 0" WG. This revision was completed on 2/28/87.

10) The pressure range given in step 3.3.3 of CPS No. 4401.01 does not agree with that given in P-STG (RC/L4.b).

Response: The value used in step 3.3.3 of CPS No. 4401.01 is correat. The value in CPS-EPGs will be revised.

11) Step C2-1 of P-STG was not included in step 4.2 of CPS No.

4401.01.

Response: Step C2-1 states:

IF Contingency #2 is entered from the Containment Control Guideline or Secondary Containment / Radioactivity Release Control Guideline AND A reactor scram has not been initiated TIIEN Perform the following actions:

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i ATTACHMENT A L ILLINOIS POWER COMPANY CLINTON POWER STATION

1. Place mode switch in SHUTDOWN.

l- 2. Perform Reactor Scram off normal procedure concurrently with the remainder of this procedure.

The CPS-EOPs for Containment Control Guideline (CPS No. 4402.01) and Secondary Containment / Radioactivity Release Control Guideline (CPS No. 4406.01) each contain the contingency section for Emergency Depressurization. Therefore, the operator actions specified in C2 ,

l are carried out as part of the procedure that directed the operator to this contingency. No change is required.

12) Step 4.2.2 of CPS No. 4401.01 is not the same as Step C2-3 of P-STG.

Response: CPS No. 4401.01 Step 4.4.2 states -

E Any SRV's have been opened THEN Perform either of the following actions:

1. Shift the Containment Building HVAC System to the Continuous Containtient Purge Filtered mode-Per CPS No. 3408.01, CONTAINMENT BUILDING HVAC (VR).

2. Start Standby Gas Treatment train on Primary Containment-Per CPS No. 3319.01, STANDBY GAS TREATMENT (VG) and shutdown the Containment Building HVAC System-Per CPS No. 3408.01, CONTAINMENT BLDG. HVAC (VR).

l Step C2-3 states:

E Any SRV's are open THEN Perform the following actions l 1. Start SGTS

2. Shutdown VR j This step will be revised in both CPS No. 4401.01 and CPS EPGs to j read:

E Any SRV's are open or have been opened THEN Perform either of the following actions:

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ATTACHMENT A ILLINOIS POWER COMPANY CLINTON POWER STATION

1. Shift the Containment Building HVAC System to the Continuous Containment Purge Filtered mode-Per CPS No. 3408.01, CONTAINMENT BUILDING HVAC (VR).

gR 2 Start Standby Gas Treatment train on Primary Containment-Per CPS No. 3319.01, STANDBY CAS TREATMENT (VG) and shutdown the Containment Building HVAC System-Per CPS No. 3408.01, CONTAINMENT BLDG HVAC (VR).

l 13) The contingencies listed in Step 4.2.5 of CPS No. 4401.01 are not the same as those in the P-STG, Section C2-6.

Response: CPS-EPG step C2-6 states:

IF Contingency #2 was entered from Containment Control Guideline, Secondary Containment / Radioactivity Release Control Guideline, or Contingency #7 THEN Enter RC/CD, C00LDOWN CPS No. 4401.01 step 4.2.5 states:

IF

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Step 4.2, EMERGENCY RPV DEPRESSURIZATION was entered from step 4.6, LEVEL / POWER CONTROL THEN Enter CPS No. 4403.01, COOLDOWN-EMERGENCY Contingency #2, EMERGENCY RPV DEPRESSURIZATION is contained within CPS 4402.01, CONTAINMENT CONTROL-EMERGENCY, and CPS 4406.01, SECONDARY CONTAINMENT /RADI0 ACTIVITY RELEASE CONTROL-EMERGENCY.

Therefore section 4.2 of CPS 4401.01 would never be entered from CPS 4402.01 or CPS 4406.01.

On February 28, 1987 revisions required to correct any technical concerns with CPS-EOPs that could be "Potentially Safety Significant" were completed. At this time revision to the CPS-EPGs is underway. This revision is scheduled to be completed by May 10, 1987.

All concerns with the E0Ps that were determined to be of " Minimal Safety Significance" will be responded to either by EPG revision in which the EPG will be updated, and justification for the change documented, or E0P revision. The EPG revision is scheduled to be completed by May 10, 1987. The E0P revisions to correct concerns determined to be of " Minimal Safety Significance" are scheduled to be completed by July 31, 1987.

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e ATTACHMENT A ILLIN0IS POWER COMPANY CLINTON POWER STATION (2) Inconsistencies between CPS-EOPs and CPS Writer's Guide.

The inspection report states:

The Plant Specific Writer's Guide (P-SWG) provides the details of how the E0Ps will be prepared. In part, it provides the control of human factors issues in E0P format and presentation.

The inspectors determined that the E0Ps had not been consistently prepared in accordance with the P-SWG. The examples are listed in the Appendix. The licensee was aware of this fact through an audit of E0Ps performed by the CPS Licensing and Safety Organization. The reason for the inconsistency was partially due to the fact that the current P-SWG was completed subsequent to the original revisions of the E0Ps. The licensee had decided not to upgrade the E0Ps to the P-SWG until Revision 4 of the Generic Technical Guidelines (GTG) was approved by the NRC since this would also require E0P revisions. The schedule for NRC approval of Revision 4 of the GTG is now indefinite. The licensee must upgrade the E0Ps to the current P-SWG on a definite schedule. The failure of the E0Ps to be maintained consistent with the P-SWG is a violation of Technical Specification 6.8.1.b (461/877006-02).

Response: IP is currently revising the CPS-Writer's Guide. This revision is to add additional clarification to the Writer's Guide I

criteria. The revision to the Writer's Guide is scheduled to be completed by April 10, 1987. The E0Ps will be revised to be in

' l accordance with the revised Writer's Guide. This E0P revision is scheduled to be completed by July 31, 1987.

(3) Inadequacies in CPS V&V of CPS-EOPs.

The inspectors identified three areas of concern with the CPS V&V program for E0Ps. They ares (a) The inspectors are concerned that the V&V effort was not adequate to provide assurance that the E0Ps are technically complete. The inspectors listed three examples of this concern. Below are listed these examples and IP's responses.

(1) Step 4.1.4 of CPS 4404.01 refers the operator to CPS No.

3314.01 to inject Boron via the RCIC Storage Tank. CPS No.

3314.01 contains no instructions for performing this activity.

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ATTACHMENT A ILLIN0IS POWER COMPANY CLINTON POWER STATION Response: This deficiency is not due to an inadequate V&V effort. CPS No. 3314.01 did contain a section on Boron injection from the RCIC tank. This section was mistakenly deleted from the procedure after the V&V program was complete.

IP is taking steps to assure information in other E0P referenced procedures does not get inadvertently removed. On January 30, 1987 revision to CPS No. 3314.01 was completed. This revision added the necessary guidance to CPS No. 3314.01 to direct Boron injection via the RCIC Storage Tank.

(2) Step 4.1.2 of CPS No. 4401.01 lists the HPCS. LPCS/RHR"A", and RHR"B/C" water leg pumps as alternative RPV injection systems.

No procedures are referenced for this action nor does the E0P l address the potential need to manually open the check valves downstream of these low head pumps.

Response: The ECCS Water Leg Pumps are not designed to inject into the vessel. The intent of the list of alternate injection systems is to provide a list of systems which could possibly inject following a loss of all ECCS and feedwater injection. The Water Leg Pumps do develop sufficient head to inject into the vessel and the E0Ps always require the vessel to be depressurized when alternate injection systems are used. Simple Operator Actions are directed in the E0Ps without procedure reference to avoid excessive clutter in the E0Ps. This is consistent with the Writer's Guide instructions which state, " level of detail for operator instruction should be consistent with operator knowledge and skill, complexity of tasks and importance of tasks". This action is considered simple enough that no procedure reference is necessary. There will be no change made to the E0P as a result of this concern.

(3) Step 4.2.3 of CPS No. 4401.01 references the use of the RPV head vent as a means of depressurizing the RPV. No instructions are given or procedure referenced for aligning the vent exhaust path.

Response Simple operator actions are directed in the E0Ps without procedure reference to avoid excessive clutter in the E0Ps. This is consistent with the Writer's Culde instructions which state, " level of detail for operator instruction should be consistent with operator knowledge and skill, complexity of tasks and importance of tasks". This action is simple enough that no procedure reference is necessary. No change to the E0Ps will be made as a result of this concern.

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' O ATTACHMENT A i ILLINOIS POWER COMPANY CLINTON POWER STATION Additionally a fourth V&V concern was listed in the Appendix to the inspection report:

Table 1 in Step 3.2 of CPS No. 4402.01 references a dryvell temperature of 545*F. A temperature of 545'F cannot be read on existing control room instrumentation.

Response: The intent of this caution is to indicate that Wide Range, Narrow Range, and Fuel Zone level instruments are reliable for trending information over the entire indicating range, for temperature beyond the maximum expected drywell temperature (545'F). This caution was reworded to make this clear. The operator does not need temperature instrumentation for temperatures above 330*F; the E0Ps do not specify any additional operator actions to mitigate an accident with drywell temperatures in that range.

A program for V6V of all E0Ps associated with DCRDR is scheduled to be completed by April 10, 1987. Additionally, if a V6V program is required after completion of the upcoming EOP revisions, it will be completed by August 31, 1987.

(b) The inspectors are concerned that V&V activities are not being conducted or controlled as required. The inspection report states (1) CPS Condition Report No. 1-85-11-107 dated November 8, 1985, documented the fact that Emergency Operating Procedure (EOP) revisions were not receiving verification or validation consistent with the original E0P. The licensee revised the procedure controlling E0P revisions, CPS No. 1005.01 (Revision 17), to require that E0P revisions receive the applicable V6V or that the reason for not performing V&V be documented in the safety evaluation for that revision. The licensee identified seven revised E0Ps which had not received the required V&V. As of January 30, 1987, the V6V activities had not been performed and CPS CR No. 1-85-11-107 remains

, open.

(2) NRC Inspection Report No. 461/86072, Paragraph 12 " Emergency Procedures Review," identified in Unresolved Item 461/86072-04 that E0P revision package CPS No. 4401.01, Revision 7, had not been processed in accordance with CPS No. 1005.01, Revision 17 (procedure revision issued as part of the corrective action for CR No. 1-85-11-107). Specifically, the licensee failed to document the basis for omitting the V&V review on CPS No.

1005.06F001, Safety Evaluation Form (10CFR50.59 review).

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G ATTACHMENT A ILLIN0IS POWER COMPANY CLINTON POWER STATION The licensee, in response to the NRC finding, performed a review of other E0P revision packages processed after the issuance of Revision 17 (CPS No. 1005.01) and determined that the Safety i Evaluation Form for revision to CPS No. 4402.01 also lacked the l required basis for omitting the V6V review. The licensee l documented these deficiencies (4402.01 and 4401.01) on CPS Condition Report No. 1-87-01-069.

The inspectors' review of this Condition Report and E0P revision packages identified additional deficiencies. CPS No. 1005.01, Appendix C requires that the results of the E0P revision review be documented on CPS No. 1005.01F001 (CPS Procedure Review Form). The results of the revision review were not documented on the procedure review forms for revisions to CPS No. 4401.01, Revision 7 and CPS No. 4402.01, Revision 5.

IP responses to these concerns aret I (1) CR No. 1-85-11-107 was closed on February 19, 1987. Most of the corrective actions were identified in October of 1986 and completed at that time. The CR remained open until the Writer's Guide was revised and a backfit review was done to identify E0P changes which require V&V by a vendor. The vendor V&V on identified chaages is in progress and being tracked by Centralized Commitment Tracking.

l (2) As a part of the corrective action to CR 1-87-01-069 the revision review performed on CPS No. 4401.01, Rev.7 and CPS No.

4402.01, Rev. 5 will be fully documented. Discussion with the second reviewer of these revisions revealed he believed that his signature on the cover sheet was to document the V&V revision review was performed and the changes meet the criteria in the Writer's Guide. Additional clarification on how the review is

, to be documented will be incorporated into the Writer's Guide by l April 10, 1987.

l (c) Concerns with CPS-EOP supporting calculations.

The inspection report states A licensee audit performed by the Licensing and Safety Organization indicated various problems with the use of the calculations supporting the P-STC and E0Ps which were not identified during previous V6V efforts. These problems are documented in the licensee's audit report. (Interoffice memo Y-203729).

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C ATTACHMENT A ILLINOIS POWER COMPANY CLINTON POWER STATION The problems identified in the audit included differences between the results of calculations performed in support of the E0Ps and the actual values used in the E0Ps. In some cases this may have rssulted from the undocumented addition of margins.

Other problems included differences between calculated results and values included in the technical specifications and inaccurate reproduction of graphs in the E0Ps.

l The inspectors found no additional problems in this area.

l The completion of corrective action of this item is considered an Unresolved Item (461/87006-05).

l IP Response to this item Revisions to the E0P supporting calculations were completed on March 27, 1987. Any E0P/EPG revisions required by changes to l

these calculations were assessed for safety significance. One revision was determined to be safety significant, it will be l

completed prior to exceeding 5% power. All revisions not l

completed prior to 5% power will be justified and completed with the scheduled major revisions to E0Ps and EPGs.

(4) Concerns with Operator Training and Procedure Useability The inspection report statest The inspectors evaluated the adequacy of the operator's ability to implement the E0Ps. This was accomplished by witnessing a control room crew respond to three accident scenarios using the plant l simulator and a control room walkdown to detetmine if control room labeling and E0P terminology were consistent.

l The operators were able to use two E0Ps with no difficulty and i appeared to be well trained in their use. No control room - E0P terminology differences were identified. The inspectors l

determined that in general the operators had received training consistent with that described in the Procedure Generation Package (PGP). The inspectors identified one concern in the training area.

The E0P training commitments included in the PGP were not made a formal constraint on the operator initial training program. The l

licensee agreed to correct this by including the PGP as a reference in the formal training program description. This will be tracked as an Open item (461/87006-06).

Resolution of this open item will be accomplished by the followingt 10 l

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Ca ATTACHMENT A ILLINOIS POWER COMPANY CLINTON POWER STATION

1) Revise the Nuclear Training Department (NTD) Lesson Plan No.

95503, " Principles of Emergency Operating Procedures," to include information from the current E0P revisions; include the E0P revision numbers and the CPS PGP in the reference section of the lesson plan; and include objectives that cover the learning objectives from the E0P Operator Training Program.

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2) Revise the NTD Lesson Plan No. 95002, " Safety Parameter Display

System," to include the information outline in E0P Operator Training Program, and includo the CPS PGP in the reference section of the lesson plan.

Completion of these items is scheduled for June 30, 1987.

Paragraph 4.b(1) of Inspection Report 50-461/87006 (DRS) statest Plant-Specific Technical Guidelines l

l The P-STC provides the controlled technical basis for the E0Ps, and the l E0Ps should be consistent with that basin. If a licensee based his P-STG on the Generic Technical Guidelinen (GTC) previously approved by the NRC, they were required to identify in the PCP any potentially safety I

significant deviations from the GTC and provide justification for each deviation. Deviations made subsequent to PGP approval were subject to the provisions of 10CFR50.59. The process for effecting a change in the E0P l la to revise the P-STG under the provintons of 10CFR50.59 and then revise

the E0P to be consistent with the P-STG. Practically, these are l concurrent changes and the critical aspect la the documentation of the l justification and basis for the change to maintain a current basis for the l E0Ps. The innpectors found many examples where the E0Ps did not reflect i the content of the P-STG. These examples are listed in the Appendix. The l most significant example is an entry condition into CPS No. 4406.01,

" Secondary Containment / Radioactivity Release Contro) Emergency." The P-STG (and GTG) list one of the entry conditions as " secondary containment dif ferential pressure 0" water gage (WG) (referenced to atmosphere)."

(The inspection report incorrectly stated this value an 0" paid.) Revision 2 of CPS No. 4406.01 lista this entry condition as "difforential pressure i

at or above 40.125" WG." A documented justification or basin for thin difference could not be found. A review of the 10CFR50.59 evaluations for this procedure indicated that any evaluation of thin difference had not been documented as part of those evaluations. The innpectors were

! particularly concerned with this example in that loss of secondary

containment integrity (rupture) would preclude reaching a positive pressure differential. The failure to prepare E0Pn in accordance with the P-STG and properly control changen thereto is considered a l violation of Technical Specification 6.8.1.b (461/87006-02).

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ATTACHMENT A ILLIN0IS POWER COMPANY CLINTON POWER STATION As noted above, the licensee failed to explicitly address this issue in 10CFR50.59 evaluations performed for this E0P. Therefore, no documented basis existed for concluding that no unreviewed safety questions were generated as a result of the change. This represents another example of the failure to meet the requirements of 10CFR50.59 as depicted in violation 461/86053-02d documented in Inspection Report No. 50-461/86053 and underscores the scope of this problem within the licensee's organization. The specific example noted above appears to have the potential for presenting an unreviewed safety question, and its resolution will be tracked as an Unresolved Item (461/86007-03) pending completion of a documented licensee evaluation of this issue.

Response The following information was presented at the NRC Enforcement Conference held March 13, 1987.

UNREVIEWED SAFETY OUESTION EVALUATION Issue - Entry condition into E0P 4406.01 is 0.125" WG vs 0.0" WG, No unreviewed safety question exists.

Questions

a. Increase the probability of occurrence of an accident previously evaluated in the FSAR7

- No impact on probability of occurrence of accident previously evaluated. Secondary containment pressure is not an accident initiator.

b. Increase the consequences of an accident previously evaluated in the FSAR7

- No impact on consequences of FSAR evaluated accidents.

Neither the isolation of VF nor initiation of SCTS is affected by the entry point of the E0P. Positive .125" setpoint established to avoid spurious trips and to assure no structural damage to secondary containment. FSAR accident analysis remains valid.

c. Create the possibility of an accident of a different type than any already evaluated in the FSAR7 12

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ATTACHMENT A ILLINOIS POWER COMPANY CLINTON POWER STATION

- No new accident type identified associated with E0P entry condition of .125" WG vs 0.0" WG. Entry condition of .125" WG t

pressure will not impact structural integrity and is consistent I with design basis VF trip setpoint. Structural integrity can withstand 2.0" WG.

I d. Increase the probability of a malfunction of equipment important to safety previously evaluated in the FSAR?

- No increase in probability of a malfunction of equipment l important to safety identified. No equipment, including VF l

and SGTS fans, affected by secondary containment prensures in this range.

e. Increase the consequence of a malfunction of equipment important to

. safety previously evaluated in the FSAR?

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- No increase in consequences of a malfunction of equipment important to safety identified. Operator entry into E0P at

.125" WG affects neither the isolation of VF nor the initiation of SGTS, thus no impact on FSAR accident analysis assumptions.

Entry at .125" WG consistent with design basis VF system trip setpoint to avoid spurious trips and to protect secondary containment structural integrity.

l I f. Create the possibility of a malfunction of equipment important to safety different than previously evaluated in the FSAR?

l - No possibility of a different malfunction of equipment important to safety created. No equipment, including VF and SGTS fans, affected by secondary containment pressure in this range.

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g. Reduce the margin of safety as defined in the baats for any i technical specification?

- No margin of safety as defined in the basis for any technical speciftention reduced. Accident analysis assumption of auto l

start of SGTS not impacted by E0P entry condition.

The Staff at the Enforcssent Conference gave verbal approval that the l previous statement closed unresolved ttom 461/86007-03 13 i

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TABLE 1 FINDINGS FROM E0P VS. EPG TABLE-TOP COMPARISON I

E0P 4401.01 4402.01 4403.01 4404.01 4406.01 TOTAL Condition Basis for E0P state- 26 31 11 4 2 74 l tent not in E0P Words underlined in 15 8 2 14 2 41 E0P but not in EPG Steps / notes / cautions 12 3 1 1 2 19 in different order in E0P vs. EPG Wording in E0P 21 29 9 6 9 74 different than EPG Stepa/ notes /enutions 9 29 2 21 6 67 in E0P not in EPG Steps / notes / cautions 2 3 0 4 2 11 in EPG not in E0P Reference for step 8 5 4 0 1 18 missing from E0P Information in E0P 3 6 1 5 4 19 different from EPG TOTAL 96 114 30 55 28 323 I

" Written Correctionn" 44 60 9 20 15 148 "Techntent Accurney" 23 19 9 12 5 68 E0P changen required 8 7 3 0 2 20 EPG changes required 18 36 2 8 8 72 I

E0P changen required 1 2 1 0 3 1 before 5% Power

O I U-e ATTACHMENT B ILLINOIS POWER COMPANY CLINTON POWER STATION

SUBJECT:

Notice of Violation 50-461/87-006 The Notice of Violation states in part As a result of the inspection conducted in January 26 through February 3, 1987, and in accordance with the 10CFR Part 2, Appendix C - General Statement of Policy and Procedure for NRC Enforcement Actions (1986), the following violations were identified:

l 1. CPS Technical Specification 6.8.1.b states, in part, that written i procedures shall be established, implemented, and maintained covering l the applicable procedures required to implement the requirements of NUREG-0737 and Supplements thereto. Paragraph 7.1.e of Supplement 1 to NUREG-0737 states that the licensee implement upgraded Emergency Operating Procedures (EOPs). Paragraph 7.1.c of this supplement further states that the licensee upgrade the E0Ps to be consistent with Technical Guidelines and an appropriate Procedures Writer's Guide.

Contrary to the above, as of the date of this inspection, the following upgraded Emergency Operating Procedures (EOPs) were not consistent with either the Clinton Plant-Specific Technical Guidelines or the Plant-Specific Writer's Guides

a. Although Clinton Power Station (CPS) Emergency Operating Procedure No. 4406.01, " Secondary Containment / Radioactivity Release Control Emergency," required entry at a secondary containment differential l pressure of +0.125 inches, the corresponding Technical Guidelines specified 0.0 inches paid.

b. Although step 4.1.4 of CPS Emergency Operating Procedure 4404.01, l " Reactivity Control Emergency," specified that procedure CPS. No.

l 3314.01, " Standby Liquid Control " be used to inject Boron using l the RCIC Storage Tank, the E0P was not maintained in that this method for Boron injection is not addresned in CPS No. 3314.01,

c. Although Step 3.1.1 of CPS Emergency Operating Procedure No.

4402.01 " Containment Control Emergency," does not require a scram j if a relief valve is stuck open, a scram is specified in the corresponding Technical Guidelines.

d. The control rod drive differentini pressures specified in steps 4.5.5 and 4.7.7 of CPS Emergency Operating Procedure No. 4404.01,

" Reactivity Control Emergoney," are different from those specified in the corresponding Technical Guidelines.

e. CPS Emergency Operating Procedure No. 4401.01, " Level Control Emergoney " does not include the intent and scope of the E0p as required by the Procedure Writer's Guide.

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O ATTACHMENT B ILLIN0IS POWER COMPANY CLINTON POWER STATION This is a Severity Level IV Violation (Supplement 1).

I. Corrective Actions Taken and Results Achieved a) The setpoint for the entry condition into CPS 4406.01 on Secondary Containment differential pressure has been revised to 0" WG. This revision was completed on 2/28/87.

b) This deficiency is not due to an inadequate V6V effort. CPS No.

3314.01 did contain a section on Boron injection from the RCIC i tank. This section was mistakenly deleted from the procedure l after the V&V program was complete. IP is taking steps to assure information in other E0P referenced procedures does not get inadvertently removed. On January 30, 1987 revision to CPS No.

3314.01 was completed. This revision added the necessary guidance to CPS No. 3314.01 to direct Boron injection via the RCIC Storage Tank.

c) CPS P-STC Step SP/T-1 states:

l Close all Safety Relief Valves (SRV's) not required to be open l IF Any SRV cannot be closed and suppression pool

! temperature reaches 110*F (technical specification temperature limit with a stuck open SRV).

TilEN Place mode switch in SilUTDOWN.

l The corresponding CPS 4402.01 step (3.1.1) states:

Close all Safety Relief Valves (SRV's) not required to be open.

l BWROG Generic EPGs Rev. 3J step SP/T-1 states:

l If any Stuck Open Relief Valve (SORV) cannot be closed l [within 2 minutes (optional plant-specific time interval)].

I scram the reactor.

CPS Technical Specifications do not specify a plant-specific time interval for neramming the reactor with a SORV. Also current BWR00 EPG committee thinking on this topic is that the reactor should not be scrammed untens Supprennion Pool temperature exceeds 110*F. or exceeding 110'F is imminent. Subsequent E0P steps require a neram before Suppression Pool temperatures reach 110*F.

Therefore CPS 4402.01 step 3.1.1 is correct as written. The CPS l EPG will be rovined to be consintent with the E0Ps and provide

! justification for thin difference between CPS EPCs and generic ,

EPCn. j 1

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ATTACHMENT B  !

ILLINOIS POWER COMPANY CLINTON POWER STATION l

! d) The values for control rod drive differential pressures used in l CPS No. 4404.01 are correct. The values used in CPS-EPGs will be=

corrected..

e) :IP is currently revising the CPS-Writer's Guide. This revision is

. scheduled to be complete by April 10, 1987. The EOPs will be revised to be in full compliance with the Writer's Guide. These revisions will include adding the intent and scope to CPS 4401.01 and are scheduled to be completed by July 31, 1987.  ;

II. Corrective Action to be taken to Prevent Further Violation .

CPS management decided to revise the CPS EPGs and Writer's' Guide, with E0P revision to follow. After that time CPS intends to maintain their E0Ps, EPGs and Writer's Guide in accordance with the most accurate guidance available.

III. Date When Full Compilance Will Be Achieved Illinois Power will be in full compliance by September 30, 1987.

t i

I Page 3 of 6 ,

o ATTACHMENT B ILLINOIS POWER COMPANY CLINTON POWER STATION

2. 10CFR Part 50, Appendix B, Criterion XVI, Corrective Action, as implemented by Illinois Power Operational Quality Assurance Manual, Chapter 16, requires that measures shall be established to assure that conditions adverse to quality, such as nonconformances, are promptly identified and corrected. In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition.

Contrary to the above, the fo110 win 8 examples of failure to implement Criterion XVI of 10CFR Part 50, Appendix B, were identified

a. CPS Condition Report No. 1-85-11-107 dated November 8, 1985, documented that the licensee's administrative controls failed to provide for proper verification and validation of revisions to Emergency Operating Procedures (EOPs); however, this nonconformance was not promptly corrected. As of January 30, 1987, the seven procedure revisions identified by Condition Report No. 1-85-11-107 had still not received the required verification and validation and the condition report was still open. In addition, the licensee's corrective action van not effective in preventing recurrence in that E0P revision packages for Revision 7 to CPS Procedure 4401.01 and Revision 5 to CPS Procedure 4402.01 failed to implement the corrective actions specified for CPS l Condition Report No. 1-85-11-107.

l l b. Although Condition Report CR 1-86-10-169 identified the fact that modifications TS-7 and IA-12 resulted in the need to revise seven control and instrumentation surveillance procedures which were not l identified on the " Detailed Impact Assessment Form" as required by CPS No. 1003.01, the condition report van invalidated without determining the cause of the failure to properly identify the required revisions or effecting any corrective action to preclude repetition.

This is a Severity Level IV violation (Supplement 1).

1. Corrective Actionn Taken and Ranutta Received 2.n. CR No. 1-85-11-107 was closed on February 19, 1987. Most of the corrective actions were identified in October of 1986, and complete at that time. The CR remained open until the Writer'n cuide van revised and a backfit review was done to identify E0P changen which require V6V by a vendor. The vendor V6V on identified changen is in progrens and being tracked by Centralized Commitment Tracking.

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m 9

O ATTACHMENT B ILLIN0IS POWER COMPANY CLINTON POWER STATION 2.b Revision No. 1 of Condition Report (CR) No. 1-86-10-169 was issued on January 29, 1987, to document the fact that Revision No O was incorrectly invalidated because of the inadequate investigation.

The Assistant Plant Manager issued memorandum JCG-0657-87, dated January 30, 1987, halting the processing of modifications for impact assessment by the Maintenance Department until those personnel who perform the assessments are trained on the requirements to evaluate all department procedures for impact.

This training was provided on January 31 and February 2, 1987. On the basis of this training, the Plant Manager authorized the resumption of impact assessment reviews and the release for Operations of modifications.

Additional corrective action consisted of a review of closed modifications. This review was performed in two phases. During the first phase, the reviewers looked at a computer summary of each modification to determine if further information would be needed to assess a modification for surveillance procedure impact.

Of the 294 modifications, 208 were determined not to have any impact on surveillance procedures. The remaining modifications l were examined in greater detail. The reviewers performed investigations of those modifications by looking at the vaulted modification packages. The second phase discovered 8 modifications which required maintenance surveillance procedure revisions. The procedure changes required for the 8 modifications were found to have either completed prior to the release for operation date or a Temporary Procedure Deviation was used to perform the test.

As presented in the CR, all procedure changen had already been completed and implemented on a timely basis. No surveillance tests were invalidated due to this investigation.

On February 17, 1987, it was identified that 9 closed modifications had not been reviewed during the Revision 1 evaluation of CR #1-86-10-169. The 9 modn were vaulted but not statuned as closed on the computer listing supplied for the l backfit review on Rev. 1. J i

Revision No. 2 of CR #1-86-10-169 was innued to document this deficiency and the 9 mods were reviewed for impact on proceduren.

The review found no procedural impact as a renuit of thene modificationn.

On March 9. 1987, the Qua11ty Annurance (QA) Manager initiated the following actionn in nupport of the corrective action programt l Page 5 of 6

1 o

ATTACHMENT B ILLIN0IS POWER COMPANY CLINTON POWER STATION Action 1: Provided training for those QA personnel involved in the final review of condition riports emphasizing the need for a detailed review of the validity of the basis and justification for invalidating condition reports.

Action 2: Performed a review of previously invalidated CRs to determine if the invalidation was adequately justified, the basis for validation was correct, and the CPS procedures for invalidation were followed.

Corrective Action Action Item 1: Training was provided to personnel in the Quality Operations and Maintenance Quality Technical Services and Procurement Quality Asnurance Groups an directed by the Manager - Quality Assurance.

Action Item 2: Approximately 400 Condition Reports (CRs) initiated over a three-month period were reviewed to determine those CRs which were procenned for invalidation. Only 8 CRs were identified an being proconned for invalidation. A review of the 8 CRn verified that adequate justification for invalidation van provided and attached to the CRn. With the exception of CR l-87-01-169, the originator of the CR won notiflod of the invalidation by being copied on the invalidation letter / request.

II. Corrective Action to be taken to Prevent Further Violation a) CR No. 1-85-11-107 van closed on February 19, 1987. Mont of the corrective actionn were identified in October of 1986, and completed at that time. The CR remained open untti the Writer's Guide van rnviand and n backfit review was done to identify E0P changen which requira V6V by a vendor. The vendor V6V on identified changen in in progrena and being trncked by Centralized Commitment Tracking. 1 1

b) Training wan provided for those personnel in Plant Staff for impnet annonsmont evnluntion and to QA and Compilance for evaluating Condition Heports to annure a thorough underntnnding of their renponnibility in the invalidation procons.

III. Date When Full Comp 1fnnee W111 ho Achtnved Illinois Power in in full comp 11anca.

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e I

c ATTACHMENT B ILLINOIS POWER COMPANY CLINTON POWER STATION Action 1: Provide training for those QA personnel involved in the final review of condition reports emphasizing the need for a detailed review of the validity of the basis and justification for invalidating condition reports.

Action 2: Perform a review of previously invalidated CRs to determine if the invalidation was adequately justified, the basis for validation was correct, and the CPS procedures for invalidation were followed.

Corrective Action Action Item 1: Training was provided to personnel in the Quality Operations and Haintenance Quality Technical Services and Procurement Quality Annurance Groups na directed by the Manager - Quality Annurance.

Action item 2: Approximately 400 Condition Reports (CRn) initiated over a three-month period were reviewed to determine those CRn which were procenned for invalidation. Only 8 CRs were identified as being proconsed for invalidation. A review of the 8 CRs verified that adequate juntification for invalidation van provided and attached to the CRs. With the exception of CR l-87-01-169, the originator of the CR wan notified of the invalidntion by being copied on the invalidation letter /requent.

II. Corrective Action to ho taken to Provent Further Violation n) CR No. 1-85-11-107 was closed on February 19, 1987. Most of the corrective actions were identified in October of 1986, and completed at that time. The CR remained open until the Writer'n Guide was ravined and n backfit review wan done to identify E0P chnngen which require V&V by a vendor. Tha vnndor V&V on identified changes in in progrenn and being tracked by Centralized Commitment Trncking.

b) Training van provided for thone pornonnel in Plant Staff for impact ansonament evaluation and to QA and Complinnce for evalunting Condition Reportn to annure a thorough understanding of their renponnibility in the invalidntion procann.

111. Data When Full Cenpliance Will he Achieved Illinoin Power in in full compliance.

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