ML20137K462
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| ML20137K462 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 03/21/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20137K435 | List: |
| References | |
| 50-461-96-15, NUDOCS 9704070034 | |
| Download: ML20137K462 (200) | |
See also: IR 05000461/1996015
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U.S. NUCLEAR REGULATORY COMMISSION
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REGION lli
Docket Nos: 50-461 i
License Nos: NPF-62
Report No: 50-461/96015 (DRP)
Licensee: lilinois Power Company
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Facility: Clinton Power Station
Location: Route 54 West
Clinton, IL 61727
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Dates: December 13,1996 - February 14,1997 .
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inspectors: F.D. Brown, Acting Senior Resident inspector
R.L. Bywater, Acting Senior Resident inspector
M.J. Miller, Senior Resident inspector
K.K. Stoodter, Resident inspector
C.G. Miller, Senior Resident inspector - Quad
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Cities
D.E. Roth, Resident inspector - Dresden
D.E. Zemel, Resident inspector - lDNS
Approved by: Geoffrey C. Wright, Chief
Clinton Oversight Team
970407o034
PDR
970321
0 ADOCK 05000461
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CHRONOLOGY OF EVENTS
INVOLVING PROCEDURE ADEQUACY / ADHERENCE ;
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11/20/96 The inspectors identified that the HPCS integrated operability test was
not performed in the manner referenced in the TS basis. The I
inspectors identified that Eng!neering did not have readily retrievable
records documenting the adequacy of the test methodology. Suitable '
calculations were subsequently produced.
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12/5/96 The surveillance procedure for HPCS valve operability was inadequate !
in that it allowed the test to be performed under plant conditions
which prevented the operators from obtaining accurate test results.
The inspectors observed Operations initiate a HPCS valve stroke ;
surveillance when procedurally recommended prerequisites were not .
being met. l
12/11/96 A newly installed rupture disc in the Radwaste Transfer system failed l
during system operation. Numerous problems with rupture disc i
installation, post modification testing, procedural adherence, safety
perspective, and control of corrective actions were identified.
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12/29/96 An operator incorrectly positionod the Div.11 EDG maintenance switch
while performing a tagout. A second operator failed to perform an
adequate independent verification of the tagout.
12/30/96 An inadequate tagout resulted in the failure to vent a portion of the ;
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instrument air system which was subsequently opened by a
maintenance worker. No injury resulted. The licensee identified
several operator weaknesses associated with this event, including a
lack of familiarity with the current status of control room
instrumentation.
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1/5/97 An operator incorrectly drained down of a portion of the Spent Fuel
i Pool make-up line from the Shutdown Service Water system following
performance of a surveillance test.
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1/6/97 A damper in the Standby Gas Treatment System was found
mispositioned during performance of a surveillance. The inspectors
identified numerous opportunities for operators to have identified and
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corrected this condition prior to performance of the surveillance,
including normal control room panel walk-downs.
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1/26/97_ An incorrectly performed valve line-up resulted in a large spill of
feedwater. Two licensed operators were involved in establishing the j
line-up. The flow of feedwater from the incorrectly positioned valves !
was not identified for approximately two shifts, despite repeat control
room annunciators for high ECCS sump levels.
1/28/97 ' ' ' ' ' ' ' ' ' ' ' Partial plant stand down ' ' ' ' ' ' ' ' ' ' ' '
1/28/97 An inadvertent RPS scram was initiated when Operations removed
IRM "E" from service with IRM "F" already doenergized. This event
demonstrated the lock of a basic questioning attitude on the part of
licensed reactor operators who prepared and implemented a safety
tagout for RPS input equipment.
2/3/97 Operators started the "A" Spent Fuel Pool cooling pump without
achieving the procedurally required amount of cooling water flow to
the pump motor. The inspectors observed that the on-shift operations
crew had difficulty implementing the station's upper tier documents
for procedures and for procedure changes during this event. The
inspectors also observed an apparent communication lapse between
the Shift Supervisor and the control room.
2/6/97 * * * * * * * * * * * Return to full work schedule * * * * * * * * *
2/7/97 While performing reactor cavity drain down, operators performed
i valve manipulations in the spent fuel pool cooling system which were
i not in accordance with the applicable procedure. The inspectors
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concluded that the licensee's evaluation of this event did not identify
all the procedural adequacy issues involved.
2/9/97 A worker was contaminated when a Containment Equipment Drain
system check valve bonnet joint leaked while a valve line-up was
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being performed following maintenance on the check valve. The
inspectors considered the licensee's decision to reuse a metal gasket
in this joint to have been non-conservative.
2/10/97 Multiple errors in preparing, implementing, and clearing a tagout
restoration resulted in returning a Circulating Water pump motor 6.9
kV breaker to service with an open tagout. An operator subsequently
self identified the error.
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2/11/97 '""" * ' * * Second partial plant stand-down * "" * * "
2/13/97 * """" * " Return to full work schedule * """ * ""
2/14/97 The inspectors identified serious deficiencies in the licensee's upper
tier administrative procedure governing the use of procedures. The
inspectors concluded that the inconsistencies identified had -
contributed to the procedural nonconformances identified above. '
These deficiencies were of added concern because the licensee had
not identified or corrected them following the September 5,1996 RR
pump seal failure.
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EXECUTIVE SUMMARY
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Clinton Power Station
NRC Inspection Report 50-461/96015 (DRP)
This inspection included aspects of licensee operations, engineering, maintenance, and
plant support. The report covers a nine week period of resident inspection.
Onorations
e An incorrectly performed valve line-up resulted in a large spill of feedwater. Two
licensed operators were involved in establishing the line-up. The flow of feedwater
from the incorrectly positioned valves was not identified for approximately two
shifts, despite ropeat control room annunciators for high ECCS sump levels. Two
procedure violations were identified. (Section 01.1)
e An operator incorrectly positioned the Div.11 EDG maintenance switch while
performing a tagout. A second operator failed to perform an adequate independent
verification of the tagout. One procedure violation was identified. (Section 01.2)
e An operator incorrectly drained down of a portion of the Spent Fuel Pool make-up
line from the Shutdown Service Water system following performance of a
surveillance test. One procedure violation was identified. (Section 01.3) ,
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e A damper in the Standby Gas Treatment System was found mispositioned during ;
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performance of a surveillance. The inspectors identified numerous opportunities for
operators to have identified and corrected this condition prior to performance of the ,
surveillance, including normal control room panel walk-downs. One procedure ;
violation was identified. (Section 01.4)
e An inadequate tagout resulted in the failure to vent a portion of the instrument air
system which was subsequently opened by a maintenance worker. No injury
resulted. The licensee identified several operator weaknesses associated with this
event, including a lack of familiarity with the current status of control room
instrumentation. Two procedure violations were identified. (Section 01.5)
e An inadvertent RPS scram was initiated when Operations removed IRM "E" from
service with IRM "F" already doenergized. This event demonstrated the lack of a
basic questioning attitude on the part of licensed reactor operators who prepared
and implemented a safety tagout for RPS input equipment. One procedure violation
was identified. (Section 01.6)
e Operators started the "A" Spent Fuel Pool cooling pump without achieving the
procedurally required amount of cooling water flow to the pump motor. The
inspectors observed that the on-shift operations crew had difficulty implementing
the station's upper tier documents for procedures and for procedure changes during
this event. The inspectors also observed an apparent communication lapse
between the Shift Supervisor and the control room. One procedure violation was
identified. (Section 01.7)
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e While performing reactor cavity drain down, opcretors performed valve
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manipulations in the spent fuel pool cooling system widch were not in accordance
with the applicable procedure. The inspectors concluded that the licensee's
evaluation of this event did not identify all the procedural adequacy issuge involved.
Two examples of a procedural violation were identified. (Section 01.8)
e . Multiple errors in propering, implementing, and clearing a tagout restoration resulted
in retuming a Circulating Water pump motor 6.9 kV breaker to service with an open
tagout. An operator subsequently soif identified the error. One procedural violation
was identified. (Section 01.9)
e A newly installed rupture disc in the Radweste Transfer system failed during system
operation. Numerous problems with rupture disc installation, post modification
testing, procedural adherence, safety perspective, and control of corrective actions
were identified. Three procedural violations and a radiological survey violation were
identified.' (Section 01.10)
e Core alteration activities were effectively performed. An operator made a good
observation when he identified foreign materialin the reactor vessel. The
development and implementation of the foreign material retrieval plan was
effective. (Section 01.11)
e The inspectors identified serious deficiencies in the licensee's upper tier
administrative procedure governing the use of procedures. The inspectors
concluded that the inconsistencies identified had contributed to the procedural
nonconformances identified in Sections 01.8 and 01.10 of this report. These
deficiencies were of added concern because the licensee had not identified or
corrected them following the September 5,1996 RR pump seal failure. Two
examples of procedural violations were identified. (Section 03.1)
e The surveillance procedure for HPCS valve operability was inadequate in that it
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allowed the test to be performed under plant conditions which prevented the
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operators from obtaining accurate test results. The inspectors observed Operations
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initiate a HPCS valve stroke surveillance when procedurally recommended
- prerequisites were not being met. The invalid test was subsequently reperformed.
(Section 03.2)
e The inspectors observed the on-shift Operations crew respond promptly and
effectively to a sudden six inch decrease in the indicated level of the spent fuel pool
surge tank. A failed pneumatic actuator line was found on a system flow regulating
valve. The inspectors noted, however, that the crew did not exhibit a questioning
. attitude in determining how the regulating valve effected tank level .in a closed loop
- system. (Section 04.1)
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Msintenance
e- A worker was contaminated when a Containment Equipment Drain system check j
; valve bonnet joint leaked while a valve line-up was being performed following l
1 maintenance on the check valve. The inspectors considered the licensee's decision i
: to reuse a metal gasket in this joint to have been non-conservative. (Section M1.1) ;
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j e The inspectors observed surveillance tests associated with the 125 VDC Station
j Batteries. The electricians were knowledgeable, and performed the surveillance as l
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written. The inspectors noted a weakness in that the licensee was not performing
vender manuel recommended preventive retorqueing of battery connections.
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(Section M1.2).
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; e While transferring the spent fuel pool cooling medium frcm the Component Cooling
1 Water (CC) system to the Shutdown Service Water (SX) system, several SX to CC <
boundary valves leaked excessively. A rapid rise in the CC system expansion tank I
i demonstrated that the expansion tank level control system did not function. The
- inspectors determined that the level control system had been inoperable for many
i years, resulting in a nonconformance with the updated safety analysis report >
(USAR). A violation of 10 CFR 50.59 was identified. (Section M2.1)
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Engineerina
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e The inspectors identified that the HPCS integrated operability test was not
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performed in the manner referenced in the TS basis. The inspectors identified that
Engineering did not have readily retrievable records documenting the adequacy of
the test methodology. Suitable calculations were subsequently produced. One
violation of 10 CFR 50.59 was identified. (Section E1.1)
e The inspectors identified a change to the licensee's Safety Function Determination
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Program procedure which appeared to be inconsistent with the applicable TS. A
unresolved item was opened pending review of the associated 50.59 safety
screening. (Section E1.2)
e The licensee identified that some retaining bolts on the CRD HCUs had been over-
< torquod. All effected bolts were replaced. An unresolved item was opened pending l '
inspector review of the licensee's evaluation of the operability of the over-torqued !
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bolts. (Section E1.3)
. Plant Sunnort
- e The diesel driven fire water pumps experienced failures due to fuel filter clogging. l
Fuel filter clogging had been identified in July,1996, but corrective actions did not
prevent reoccurrence of fuel filter clogging in January 1997. The licensee
subsequently initiated a complete assessment of potential causes of the filter l
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clogging. One violation for ineffective corrective actions was identified. (Section
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F2.1)
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Report Details !
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Summary _ofRant Status !
The plant remained in Mode 5 throughout the reporting period. Procedural non-adherence
problems continued to occur during the period. The licensee identified many of the issues, ,
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but NRC interve. Won was required to address others. The licensee initiated a partial plant
" stand-down" on January 28,1997, as a result of the on-going procedural problems. j
During the partial star d-down, plant management briefed the plant staff on recent events l
and discussed techniques for self-checking. The plant resumed normal outage activities on i
February 6,1997. As a result of procedural violations and human performance errors -
during the first week after resuming work activities, a second partial stand-down was ;
entered on February 11,1997. Work activities were resumed on Februay 13, t 997.
Work continued on critical path activities through both partial stand-downs. ]
I. Ooerations
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01 Conduct of Operations
01.1 Failure to Pronerly Perform a Valve Restoration i
s. Inanection Scone (71707)
On January 27,1997, operators failed to close drain valves on the Feedwater (FW)
system as required by a valve restoration lineup procedure. The inspectors
attended the critique and reviewed the circumstances of the event.
b. Observation and Findinas
Following completion of local leak rate testing (LLRT), two operators were directed
to realign the FW system utilizing valve lineup procedure CPS 3103.01V001.
CPS 3103.01V001 directed that the "A" FW line drain valves be closed. However,
instead of going to the "A" line, the operator went to the "B" FW line drain, which
he had worked on earlier that week. Although he carried the procedure pages with
him, and compared the sheet to the valve tag, he did not notice that the last
character on the valve label ("B") did not match the last character listed in the
procedure ("A") for each of the two drain valves. The operator found the valves
closed, and checked them off the valve lineup sheet.
Upon exiting the auxiliary building steam tunnel (ABST), the first operator informed i
the second checker of an easier path to traverse the area and reach the "B" FW j
line, in providing this information, the second oporator's independent verification !
was compromised. The second operator proceeded to the "B" FW line and verified
the same wrong valves as the first operator. 1
Technical Specification 5.4.1 requires, in part, that procedures be established and
implemented for activities in Regulatory Guide 1.33, Revision 2, Appendix A.
Regulatory Guide 1.33, Apperidix A, paragraph 4.o requires, in part, procedures for
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; Foodwater systems. The operators' failure to close the "A" line drain valves as
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required by CPS No. 3103.01VOO1 was an apparent violation (eel 50-461/96015- i
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01a) of Technical Specification 5.4.1. I
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The LLRT restoration was completed by 2:52 p.m. on January 26, and the FW
system was filled and pressurized at 12:44 a.m. on January 27. The valve error ,
allowed water to flow from the FW system into the ABST valve pit. From the valve l
pit, the water drained into the reactor core isolation cooling (RCIC) room drain
sump. During the midrught shift, the control room operators received 3 emergency
i core coolmg system (ECCS) floor drain high leak rate annunciator actuations. The .
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i operators verified that the sump pumps pumped down the RCIC sump, but did not
send an operator to the sump to determine the source of the water.
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During shift turnover, the ECCS high leak rate annunciator alarmed repeatedly;
however, due to critical path work, the control room operator did not send an
{ operator to investigate. The valve alignment problem was finally identified at 12:00 l
p.m. on January 27 by operatcts who had entered the ABST for other reasons. !
1 These operators promptly notified the control room of water accumulating in the j valve pit. i
- The annunciator response procedure (CPS No. 5064.07) stated, as one of the
j operator actions for a ECCS high leak rate annunciator, "dispete'i en operator to the j alarming sump to determine the cause." The failure to send an operator to
investigate the cause of an annunciator, as required by CPS 5064.07, is an
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apporont violation (eel 50-461/96015-01b) of TS 5.4.1. In addition, the control > room operators' rational that the annunciator could not be investigated due to
- " critical path activities," and a shortage of available operators, demonstrated a
questionable safety focus on the part of the operators.
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Although the valve pit was designed to retain water until it could drain at a
i controlled rate to the RCIC room drain sump, some of the water leaked into the l RCIC room and into the basement of the auxiliary building via Bisco seals in the j
- walls of the valve pit. The Bisco seals formed a portion of secondary containment.
! The licensee initiated a condition report for the leaking Bisco seals, and was to
determine appropriate actions prior to establishing secondary containment.
An independent assessment by the inspectors identified that the "A" and "B" FW j
drain valves were easily accessible and required no climbing to reach. The valve !
labels were clearly readable under the existing lighting conditions. The inspectors ,
had been told by licensee management that they had been told by plant staff that !
j the valves were difficult to reach, and that the valves labels were positioned such ; 4
that the last letter of the label could not be easily road. The inspectors were 1
concerned that licensee senior management was not aware of the working I
conditions in the auxiliary steam tunnel, and had not performed their own !
- assessment of the conditions which had, or might have, contributed to the valve
position error.
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c. Conclusions j
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An incorrectly performed valve line-up resulted in a large spill of feedwater. Two
licensed operators were involved in establishing the line-up. The flow of feedwater
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from the incorrectly positioned valves was not identified for approximately two
shifts, despite repeat control room annunciators for high ECCS sump levels. Two .
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violations of procedures were identified.
01.2 Minnonitioned EDG Maintenance Switch
a. Inanaction Scone (71707)
The inspectors reviewed the circumstances related to a licensee identified tegout j
error.
b. Obaarvahons and Findings l
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On December 29,1996, maintenance personnel discovered that the Division ll
emergency diesel generator (EDG) maintenance switch was in the " operate"
position, contrary to the tagout in place on the EDG.
A review by the Operations Department determined that the reactor operator who i'
performed the EDG tagout had expected the maintenance switch to be in the
" normal" position. For this reason, the operator believed the switch would need to a
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be manipulated to place it in the " lockout" position. However, the switch had '
already been placed in the " lockout" position due to unrelated work on the EDG.
Because of the operator's mind-set, the operator rotated the switch from " lockout" )
to " operate", hung the tag, and initialled the block on the tegout indicating that the !
switch was in " lockout." q
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The licensee also identified weaknesses in the independent verification process.
The second checker indicated that he was physically too close to the operator
hanging the tags to be truly independent as required by CPS 1014.01. I
Regulatory Guide 1.33, Revision 2, Appendix A, Paragraph 1.c recommends l
procedures for equipment control tagging. CPS Procedure 1014.01 establishes the i
licensee's equipment control tagging program. The failure to perform an adequate I
independent verification of a tagout, as required by CPS 1014.01, was an apparent
violation (eel 50 461/96015-01c) of TS 5.4.1.
c. Conclusions
An operator incorrectly positioned the Div.11 EDG maintenance switch while l
performing a tagout. A second operator failed to perform an adequate independent !
verification of the tagout. One procedure violation was identified. ;
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01.3 Marhtion of Valve on Wrono Train of Fuel Pool Caalina System
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s. Inacection Scone (71707)
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The inspectors reviewed the circumstances related tci a licensee identified l
procedure violation.
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b. Obaarvation and Findings
- During restoration from CPS 9061.06, " Containment /Drywell isolation Valve Cold }
Shutdown 18 Month Operability," operations personnel noticed that a valve error
had occurred. Section 8.7.5 of this procedure was used t3 determine the stoke
time for the Shutdown Service Water to fuel pool makeup valve,1SXO168. Once i
i 1SXO168 had been successfully timed, step 8.7.5.7 of the procedure directed that
a rubber hose be connected to the low point drain valve,1FC1268, such that a
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i portion of the piping could be drained. However, when o.oerations personnel went
to disconnect the hose, a hose was found to be installed on valve 1FC126A instead i
! of 1FC1268. In addition,1FC126A was open which was centrary to the directions l ,
given in the procedure. The non-licensed operator closed 1FC126A, placed the ,
! rubber hose on the correct drain valve, and opened 1FC1268.
- Regulatory Guide 1.33, Revision 2, Appendix A, Paragraph 4.J.1, recommends
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procedures for maintaining containment integrity. The failure to drain the specified
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section of piping, as required by CPS 9061.06, was an apparent violation (eel'50-
} 461/96015-01d) of TS 5.4.1. ! ,
c. Conclusions
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- An operator incorrectly performed a drain-down of a portion of the Spent Fuel Pool
i fill from the Shutdown Service Water system following performance of a ! surveillance test. One procedure violation was identified.
01.4 Failure to Recoonize Minoositioned Damner Prior to Performina Surveillance
l a. Insoection Scone (71707)
The inspectors reviewed the circumstances associated with a mispositioned control ; damper in a safety-related system.
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! b. Observations and Findings
On Januory 6,1997, during performance of a surveillance using CPS 9067.01,
"SGTS flow / heater operability," Operations personnel discovered that the control
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switch for damper IVGO2YB of the Standby Gas Treatment system (SGTS) was in
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the "close" position versus the normal position of " auto". Upon identification of
this condition, the surveillance was suspended and the SGTS train was secured.
The licensee determined that the damper had been mispositioned during restoration
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from CPS 9432.51, " Containment Pressure PDT-VG145/PDT-VG147 Channel
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Calibration," on approximately January 3,1997. The inspectors noted that control
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room panel walkdowns by the licensed operators had not been thorough enough to
identify this condition between January 3 and January 6.
The inspectors reviewed the working copies of CPS 9432.51 and 9067.01. The
restoration esction of CPS 9432.51 directed that the system be restored per the
direction of the shift supervisor or assistant shift supervisor. This direction
consisted of circling the desired "as left" position for the components which were
manipulated during performance of this procedure. The "close" position was circled
in the working copy of CPS 9432.51. This position was not consistent with the
normal system lineup position of " auto." l
Additional problems were found with the performance of CPS 9067.01. ,
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Specifically, this procedure contained steps which should have restored the system
to its proper configuration. Prerequisite 5.4 stated that "the SGTS is in standby". j
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Standby was defined in section 8.1 of CPS 3319.01, " Standby Gas Treatment
System," as having all the prerequisites of section 5.0 of CPS 3319.01 satisfied. ;
Section 5.0 of CPS 3319.01 included a step to orwure that the electrical lineup for g
the SGTS was completed. As part of this electricallineup, the control switch for -
damper IVG02YB was to be placed in auto.
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The inspectors discussed this event with the operator involved, and determined that
the operator placed heavy reliance on the assurance that the system was left in the i
proper configuration following previously performed work. While the operator did
review the configuration of the system on the control room panels, he did not l
reference the procedure to ensure the system was in a " standby" condition. [
Regulatory Guide 1.33, Revision 2, Appendix A, Paragraph 4.u, recommends
procedures for standby gas treatment systems. The failure to ensure that the
SGTS was in " standby" condition, as required by CPS 9067.01, was an apparent l
violation (eel 50461/96015-01e) of TS 5.4.1.
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c. Conclusions
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A valve in the Standby Gas Treatment System was found mispositioned during :
, performance of a surveillance. The inspectors identified numerous opportunities for ! -
operators to have identified and corrected this condition prior to performance of the i
surveille ce, including normal control room panel walk-downs. One procedure {
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violation was identified.
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01.5 fr=damu te Taaout for the Instrument Air System l
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a. Insoection Scone (71707)
The inspectors reviewed the circumstances surrounding a perceived loss of
instrument air on December 30,1996, f
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b. Observations and Findanas
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Tagout 96-9234 was hung for reassembly of valve 1SA002 in the instrument Air
system. As part of this tagout, the main control room indication for plant air
system pressure was isolated. However, the impact of this tagout was not fully
understood by the control room crew. As the valve bonnet was loosened in
properation for disassembly, the main control room indication of plant air pressure
began to decrease as air trapped in the tagged out portion of the system was
vented.
The control room crew responded to the decreasing indication in accordance with
CPS 4004.01, " Loss of Instrument Air " until it was realized that the indication had
been isolated by tagout 96-9234, and that plant air had not been lost. Although a
caution tag had been placed next to the indication stating that the indication was
unreliable due to a tegout, the tag was unnoticed by the crew until it was
recognited by an extra reactor operator.
The licensee identified three weaknesses that contributed to this situation. First,
the tagout was sent to be hung without a proper review by the Line Assistant Shift
Supervisor (LASS) (the tagging authority) to ensure the impacts on all plant
equipment, including main control room indications, were understood. Secondly,
the panel walkdownd 7erformed by the control room operators were not thorough
since the caution tag on the indication was not recognized. Lastly, the tagout was
not sufficient in that the path to the tagged open vent valve was isolated by a
closed valve. As a result, the indication in the main control room continued to
display normal service air pressure until the bonnet was loosened to begin work,
and the portion of pipe to be worked was not vented. The failure to ensure that the
tegout vent path was appropriate prior to beginning work, as required by CPS
1014.01, was considered an apparent violation (eel 50-461/96015 01f) of TS
5 A .1. l
1
i
c. Conclusions
1
An inadequate tagout resulted in the failure to vent a portion of the matrument air
- system which was subsequently opened by a maintenance worker. No injury
l resulted. The licensee identified several operator weaknesses associated with this 1
event, including a lock of familiarity with the current status of control room
I
i instrumentation. One procedure violation was identified. l 01.6 ' inadvertent Scram due to inadeausta Taaout
I
a. Inanection Scone (71707) ]
The inspectors reviewed the circumstances associated with an inadvertent Scram
caused by an inadequate tegout (T/0).
i
9
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i
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b. Ohaarvations and Findanns
- .- \
On January 28,1997, en inadvartent scram was initiated when intermediate Range l
Monitor (IRM) "E" was rendered inoperable with IRM "F" alrosdy inoperable. The 1
unit was in Mode 5, and all rods were already fully inserted. ,
Tagout 97-9136 was issued on January 25,1997. This T/O was issued, in part, to f
'
support repairs to IRM "F." On January '28,1997, tagout 97-9136 was revised to
-
Irv:lude removal of IRM "E" from service. The Shift Resource Manager (SRM) who
prepared the T/O did not identify the need to use sensor bypass to prevent an
inadvertent scram signal if two IRMs were inoperable at one time. The control
room SRO and a reactor operator (RO) discussed the T/0, but failed to identify the
impact of removing IRM "E" from service with IRM "F" inoperable. The operator
'
doenergized IRM "E" in accordance with the T/0, and a RFS scram was initiated.
l
The licensee critiqued this event on January 28,1997. The inspectors observed
that the critique was effective in establishing the facts associated with the event.
Challenging questions were asked, antj management personnel from Operations and
Nuclear Assessment were in attendance.
r
Step 8.2.8 of CPS 1014.01 required, in part, that the impact statement of tagouts
'
be reviewed for adequacy by the Tagging Authority. The inspectors concluded that
the T/O impact statement for tegout 97-9136 was inadequate in that it did not
i identify the initiation of a scram signal if both "E" and "F" 1RM inputs into the RPS '
were inoperable. The licensee's critique reached a similar conclusion. The failure ;
of the Tagging Authority to identify that the impact statement of tagout 97-9136 l
i was inadequate was considered to be an apparent violat' e n (eel 50-461/960015- l
01g) of TS 5.4.1. l
l c. Conclusions i '
An inadvertent RPS scram was initiated when Operations removed IRM "E" from j
-
service with IRM "F" already doenergized. This event demonstrated the lack of a i
basic questioning attitude on the part of licensed reactor operators who prepared
and implemented a safety tagout for RPS input equipment. One procedure violation
was identified.
1
'
01.7 Inadean=ta Coolina Water Flow to FC System Pumo Motor
a. Inanaction Scone (71707)
1
The inspectors witnessed the licensee Operations staff disposition a problem with
inadequate cooling water flow to the motor of a FC system pump.
b. Observations and Findinas
On February 3,1997, the on-duty Operations crew attempted to switch from the
"B" FC pump to the "A" FC pump using CPS 3317.01, " Fuel Pool Cooling and
Cleanup," Revision 17. The "B" pump had been secured at approximately
10
.
_ . . __ __ _ _ . . - _ _ _ _ _ _ _ .______ _ _ _ _____ _ . . , .
'
:
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i
L 1:45 p.m., and preparations for starting the "A" pump were being made in ,
'
~
accordance with Section 8.1.1 of CPS 3317.01. Stop 8.1.1.4.4 required that
cooling water flow to the "A" pump motor heat exchanger be adjusted to between
27 and 33 gpm. The operators were only able to obtain a flow of about 22 gpm. )
At approximately 2:35 p.m., the operators requested a procedure change to allow
the starting of the "A" FC pump with the lower cooling flow. Also about this time,
i- the operating crew determined that a Condition Report (CR) had been initiated on ;
.
January 6,1997, when a different crew had been unable to obtain the minimum 27 )
gpm flow rate. The system had operated at approximately 22 gpm cooling water
flow to the in-service pump motor since January 6.
,
The inspectors entered the Shift Superintendent's (SS) office at approximately :
-
4:00 p.m.. The SS informed the inspectors of the FC pump problem, and indicated ;
that engineering was attempting to establish a new minimum cooling water flow. l
'
The inspectors remained in the SS's office and control room for approximately the
next two hours.
.
l The inspectors witnessed Engineering inform the SS that the pump would not
- normally be damaged if coolant flow was limited to 22 gpm, but they (Engineering)
I could not immediately determine whether there were plant conditions which would
require the full 27 to 33 gpm flow. The inspectors noted that there appeared to be
confusion over whether a temporary procedure change could be issued to allow
operation of the FC pumps with reduced cooling water flow in Modes 4 and 5. The
inspectors also observed that members of the crew disagreed about the need for a
procedure change. Specifically, one member of the crew referred to sections of
.
CPS 1005.01 " Procedures and Documents" which required adherence to
l procedures. Another member of the crew stated that a portion of CPS 1005.01
allowed deviation from procedures if plant conditions did not support procedure
- adherence (see Section 03.1 for ablitional discussion). This conflict was not
4
resolved in the presence of the inspedors.
4
At approximately 5:05 p.m., the "A" FC pump was started by the operators. The
required cooling water flow had not been obtained, and the procedure had not been
revised to allow pump start without completion of that step. The control room log
stated that the pump had been started on direction of the SS, but the inspectors did
4
not observe the SS give such direction.
- Regulatory Guide 1.33, Appendix A, paragraph 4.k requires, in part, procedures for
i
spent fuel pool purification and cooling systems. Failure on January 6,1997, and
again on February 3,1997, to establish the required cooling water flow in
4
accordance with CPS 3317.01, Step 8.1.1.4, was an apparent violation (50-
461/96015-01h) of TS 5.4.1.
j c. Conclusions
,
Operators started the "A" Spent Fuel Pool cooling pump without achieving the
procedurally required amount of cooling water flow to the pump motor. The
inspectors observed that the on-shift operations crew had difficulty implementing
the station's upper tier documents for procedures and for procedure changes during
11
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l
.
.
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this event. The inspectors also observed an apparent communication lapse
-
between the Shift Supervisor and the control room. One procedure violation was
-
identified.
01.8 Cavity Drain-down Valve Maninulations
-a. Inanection Scone
The inspectors observed portions of the refueiing cavity drain-down and routine ,
! shift turnovers.
. b. Observations arul Findings ,
At approximately 3:00 p.m., on February 7,1997, the inspectors entered the !
;
'
control room to observe activities associated with draining the refueling cavity to
the condenser. The operators informed the inspectors that the drain-down had
^
been suspended while contamination levels in the cavity were being reduced by r
lancing the cavity with water. The inspectors observed the day shift turn-over to
I
the swing shift, and noted that the day shift specifically identified, by drawing a
line in the working copy of the procedure, Ster 8.1.4.3.13 as being the next step
! to be performed in CPS 3317.01 " Fuel Pool Cooling &.~f Cleanup." 1 [ The inspectors left the control room during the shift turn-over and returned at : i
approximately 5:30 p.m. to observe the ongoing drain-down. Upon returning to the
. control room, the inspectors were informed by the Line Assistant Shift ! Superintendent (LASS), that the oncoming crew had identified a procedural error. J
Specifically, the day shift had closed the motor operated valve (MOV) 1FCO27
- when drain-down of the refueling cavity was suspended. Closure of 1FCO27 was
i not specified by the procedure until reaching Step 8.1.4.3.18. The swing shift had I identified this error. Closure of 1FCO27, out of sequence with the steps specified l
in CPS 3317.01, was considered to by an apparent violation (50-461/96015-011) of
3 { j Technical Specification 5.4.1. '
i
! The swing shift crew informed the inspectors that they had closed 1FC105 and l
1FC003A & B following discovery tt ist 1FCO27 had been shut out of sequence.
4 Closure of 1FC105 was covered by Step 8.1.4.3.16, and closure of 1FC003A & B ,
was covered by Step 8.1.4.3.17. ,
'
l
The inspectors reviewed CPS 3317.01, Section 8.1.4.3, " Drain Reactor Vessel Pool
,
to Condenser," and found the following Note between Steps 8.1.4.3.13 and
8.1.4.3.14:
"To reduce radiation levels from the Reactor Vessel Pool walls and FC piping
loadmg to the main condenser, it is desirable to flush the Vessel Pool walls and
drain piping."
The inspectors also identified that Step 8.1.4.3.14 required that condensate be
,
used to flush the FC system drain line from the refueling cavity to the condenser
" prior to secudng the drain lineup" (emphasis added). The inspectors considered
12
4 1
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, - - _ - - - - _ . - . . - . . - - - -- ...~.____ _ ____ _ - _ _ __
k
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the swing shift's closure of 1FC105 and 1FCOO3A & B without first flushing the :
-
drain line, as required by CPS 3317.01, to have been an apparent violation (eel 50- l
461/96015 01)) of Technical Specification 5.4.1.
The inspectors concluded that Section 8.1.4.3, as written, did not establish a
radiologically conservative method of suspending, such as for water lancing or for
shift turn-overs, the drain-down of the refueling cavity. On February 8,1997, the
inspectors discussed CPS 3317.01 with the shift superintendent and the Assistant
Plant Manager - Operations. During these conversations, the inspectors determined
that the plant staff still considered CPS 3317.01, as written, adequate to support
intermittent drain-downs and flushes of the refueling cavity. Following these
conversations, the licensee implemented Section 8.1.4.3 of the procedure, as
written, in a continuous sequence of steps. A member of the plant staff put the -
difference between the inspectors' reading of the procedure and the licensee staff's
reading of the procedure in perspective when they stated:
"We were looking to see if anything in the procedure prevented us from doing
what we wanted to do, you were looking to see if the procedure directed us to
do what we wanted to do."
c. Conclusions
While performing reactor cavity drain down, operators performed valve
manipulations in the FC system which were not in accordance with the applicable
procedure. The inspectors concluded that the licensee's evaluation of this event
did not identify all the procedural adequacy issues involved. Two examples of a
procedural violation were identified.
01.9 Circulatina Water Pumo Motor Breaker incorrectiv Returned to Service
a. Insoection Scope
The inspectors reviewed the events surrounding the improper removal of a safety
,
tag and the retum to service of a high voltage circuit breaker.
} b. Observation and Findinas
On February 10,1997, two tagouts were in effect for the Circulation Water (CW)
pump "C" breaker. Work for which one tagout (97-9130) had been written was
complete. A Shift Resource Manager (SRM) reviewed tagout 97-9130 to identify
the sequence of restoration and restoration positions of equipment. During this
review, he did not check the CW tagout file or the computer tegout database to
ensum that the restoration positions would not conflict with other tagouts.
While removing the tagout 97-9130 tag from the CW pump C breaker, the first
operator removed a second tag associated with a different tagout (tagout 97-
9119). Once the tags were clear of the breaker, the operator proceeded to " rack -
in" (return the breaker to service by placing it in the motor contro! cabinet) the
- breaker as improperly directed in the tagout restoration.
13
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z
- CPS Procedure 1014.01, " Safety Tagging," Revision 22, Stop 6.1, required, in part, I
j - that red tags only be removed as provided in CPS 1014.01. - The removal of a red
tag for tagout 97-9119 using a restoration for tagout 97 9130 was not as provided l
- in CPS 1014.01, and was an apparent violation IEEI 50 481/9601541k) of TS l
5.4.1. i
A second operator provided independent verification of the restoration position of
'
the breaker. The second operator had no indication that tegout 97-9119 effected
- ' the breaker because the tag for that tegout had been removed. He verified that the '
'
97 9130 tag was removed, and that the breaker was racked in.
,
Neither the first operator, the second operator, or the line assistant shift supervisor
'
(LASS) inventoried the removed tags. Each subsequently stated that they assumed
someone else had performed the inventory. A proper inventory would have noted
the 97-9119 tag among the 97-9130 tags and quickly identified the error.
! , i Later in the shift, the first operator became concerned that he had removed two
tags from the CW pump breaker. He went back to the LASS and requested that
the removed tags be checked. This led to the identification of the error. The
'
control switch in the control room was still tagged in the pull-to-lock position which i
,
would have prevented remote actuation of the breaker. The breaker was racked ;
j back out and the tagout 97 9119 tag was rehung. A condition report was written i
- and a critique was held.
The inspectors considered this to be another example of a lack of attention to
detail. Although the tagout procssa had three barriors to prevent or quickly identify
i such an error, all barriers failed.
CPS Procedure 1014.01, " Safety Tagging " Revision 22, Step 8.6.10, required, in
'
part, that removed tags be inventoried by the Tagging Authority. The failure to
- properly inventory the removed safety tags, as required by CPS 1014.01, was an
, apparent violation (50 461/96015-011) of TS 5.4.1.
i
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c. ConclualG01
Multiple errors in preparing, implementing, and clearing a tagout restoration resulted
in retuming a Circulating Water pump motor 6.9 kV breaker to service with an open
. tagout. An operator subsequently self identified the error. One procedural violation
was identified.
01.10 incorrectiv installed Ruoture Disk
e. Inanection Scone
The inspectors reviewed the circumstances surrounding an event in which a rupture
disk for the Solid Radweste Transfer (WX) system was installed as a modification
and subsequently failed during service. An evaluation of the decision making
. process and procedure adherence associated with this event was made. In
addition, the inspectors evaluated the root causes for the problems observed, as
1
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14
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well as the licenses critique, and corrective action process. The inspectors
[
*
interviewed engineers involved with the modification, maintenance workers who
'
worked on the installation, operators in the radwaste operations center (ROC) and
the control room, radiation protection workers and supervisors, and station
- management,
i
b. Observations and Findings
i Summary of the Event
i On January 9,1997, workers inside containment notified operators in the control
- room that water was leaking into the suppression pool from an unknown source in j
the containment. The control room operators consulted the redwaste operations j
conter (ROC) about possible sources of the water, and determined that a likely
source of the leak was the WX aystem. Operators were sent to the containment
d and found that the water leaking into the suppression pool had diminished. An j
operator and a radiation protection technician were dispatched to the ABST to look
for the source of the leak. The leak source was confirmed to have been in the
ABST, in the area of a rupture disk in the WX system. l
', The WX system had been secured earlier by the ROC operator after a Reactor , i Water Cleanup (RT) system backwash receiving tank water transfer had been I -
completed. Licensee staff deduced that the water in containment had leaked from I
the area of the WX rupture disk during the transfer, and that the water leak had
i stopped when the WX system depressurized after the transfer was complete. The '
operators were not able to determine whether the rupture disk had failed or if the
flange connections r, ound the rupture disk were leaking.
The LASS and the "B" control room operator, in consultation with the radiation
, protection shift supervisor, determined that operators could determine the leak } source by repressurizing the WX system with pure water and observing the system ,
for leaks. The shift supervisor was made aware of the plan to repressurize the j
system. The B control room operator gave direction for the ROC operator to '
repressurize the system while another operator and radiation protection technician
went to the ABST to look for leaks. When the system was repressurized, the
workers in the steam tunnel observed water flowing out of the rupture disk area at
a rapid rate and notified the control room by radio. The ROC operator then
depressurized the system. Although reactor water cleanup domineralizer resin and
water were spread around the steam tunnel, no personnel contaminations or
3- excessive exposures occurred as a result of the test. ,
Licensee Cntious
.
The inspectors observed the event critique "OP97-002" which occurred on January
9,1997, and reviewed the critique report which was issued the following week.
The inspectors found that the critique was attended by a number of people involved
with the event but key operations personnel, including the shift supervisor and
J
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_ _ _ _
_ _ ___._._ __ ._. __ _ _ . _ . _ _ _ _ . _ -__ _ __
l , . _o
1
1
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LASS, did not participate. Many of the important facts were gathered at the
critique and were available for distribution to the rest of the site, but the inspectors
'
noted that distributed was not timely in some cases.
The critique discussion and report failed to discuss opportunities for conservative
-
decision making. This was especially noteworthy since there were non-
conservative decisions made by operators and radiation protection personnel.
During an interview with the inspectors, the critique chairman acknowledged that
the event involved problems with conservative decision. Procedure CPS No.
1016.05 " CONDUCT AND DOCUMENTATION OF CRITIQUES," step 8.2.7, required
nonconservative operations to be documerited in the critique report. Failure to
follow procedure 1016.05 was a weakness which did not violate Technical !
'
Specification 5.4.1 since the procedure was not covered in Regulatory Guide 1.33.
"
Although the critique and critique report discussed procedural noncompliance in the
4 operations area, it failed to discuss procedural noncompliance and missed
l expectations in the maintenance and engineering departments. These issues were
< evident to the inspectors when the work documents provided during the critique l
process were reviewed.
l ' l j Operations ' ! ! Through interviews, the inspectors identified that operators on this crew and other
- crews had not been made aware of the problems with operations performance
j during the event. These problems included nonconservative decisions, procedural '
noncompliance, and lack of system knowledge. This lack of awareness of the
- lessons to be learned was evident to the inspectors eight days following the event.
During the moming brief following the event, the shift supervisor made a brief )
statement that because of the event, operators had to be more careful to document
in operator logs when procedural steps were not followed as specified by CPS
1005.01 " CPS PROCEDURES AND DOCUMENTS." The procedural steps which
- were not performed during the rupture disk event had not been documented. No
other mention of operator performance errors was made during that brief, or during
the following week while the inspectors reviewed the event. The sole exception
was the ROC operator who was informed about his failure to notify his supervisor
, of a procedure change.
,
'
Operations management, when interviewed by the inspectors on January 14,1997,
indicated that more information had to be collected before corrective action could
be taken. On February 12,1997, the inspectors reviewed condition report (CR)
Nos.197-1-087, -094, -095, and -099, which dealt with the recommended
corrective actions from the Operations critique for procedural noncompliance and
improper handling of modification testing. The inspectors found that no Operations
'
corrective actions were documented in the CRs reviewed. The inspectors asked for
'
the due date of these actions since over a month had expired since the event. The
licensee informed the inspectors that since these CRs were marked "other" in the
I cover sheet classification block, no due dates existed nor were thev reauired.
16
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4
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; The inspectors found the following operational problems which were not adequately ,
:
'
addressed in the licensee's corrective action program:
,
i e Operators acted non-conservatively by deciding to repressurize the resin transfer ;
'
I line in order to verify the leak source, when there was no exigent operational
- requirement to do so, and other methods were available which would not have .
; posed a risk of spreadmg resin around the steam tunnel area or increasing personnel
l dose. The licensee acknowledged that maintenance workers would have had no
trouble verifying the rupture disk condition with the system depressurized;
however, maintenance was not called upon to help during the event.
i e Operations supervision interviewed did not understand the proper application of l
CPS 1005.01, including when and how procedure steps could be performed out of
I
sequence or skipped. See Section 03.1 of this report for further discussion of this
issue. ,
] ,
e The ROC operator set the CY system up independent of adherence to procedure
CPS 3909.02 " OPERATING PHASE SEPARATORS." On one cccasion on January
9, the ROC operator failed to perform step 8.12.10 (stopping the backwash
receiving tank [BWRT] pumps) of CPS 3909.02 before performing a flush in i
i accordance with step 8.3 of the procedure. On another occasion on the same date, I i the ROC operator used section 8.3 of the same procedure to pressurize vice flush ) i the system (a flush was the intended purpose of the section), but failed to ensure .!
the requirements of step 8.3.1 (BWRT in recirculation) were met. Regulatory Guide l
1.33, Revision 2, Appendix A, Paragraph 9.d(8) recommended procedures for l
domineralizer resin regeneration or replacement. The failures to follow CPS
3909.02 constituted examples of an apparent violation (eel 50-461/96015 01m) of
-
TS 5.4.1.
Since the ROC operator felt his supervisors did not understand the radwaste
transfer system, he did not think that telling them about the procedure change
!
would have had any benefit. Interviews with other operators indicated that this
- response for a ROC operator would not be atypical.
l l e Based on interviews with operators and operations supervision, the inspectors '
concluded that there was a general lack of understanding of the radwaste systems
on the part of control room operators and supervision. Control room personnel
-
expressed concem about the lack of training provided on the radwaste systems.
As noted above, this was a contributor to the procedural compliance issue by the
ROC operator. During the interviews the inspectors also found confusion as to who
was the supervisor of the ROC operator, and received answers such as the B
'
control room operator and the Line Assistant Shift Supervisor from different
operators.
,
o Operations had allowed the use of the WX system without performing post
i modification testing of the system.
- Engineering Change Notice 29915, which was used to install the rupture disk
- modification, required an operational leak check of the piping after installation of
17
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the rupture disk. However, the system was operated on at least four different
,
" occasions after the modification installation without the leak test being performed.
In addition, engineering reviews required by the installation maintenance work
request (MWR) No. D73731 were not performed prior to returning the system to
q service. Missed steps included: the operational leak check, specified in job step 10;
4
job step 11 which required a cognizant engineer to ensure all testing was complete
and satisfactory; and job step 12 which required the cognizant engineer to identify
all design impacts and resolve them. Regulatory Guide 1.33, Revision 2, Appendix
A, Paragraph 9.a recommended procedures for maintenance activities that can
; effect the performance of safety-related equipment. The rupture disk in the WX
system effected the operation of the reactor containment. Failure to perform steps '
4
10,11 and 12 of the MWR was an apparent violation (eel 50-461/96015-01n) of
- Technical Specifications 5.4.1.
Maintenance
The inspectors interviewed some of the maintenance mechanics and first line
supervisors involved with installation of the rupture disk. The mechanics indicated
'
that when the rupture disk pancake assembly was installed with flexitalic gaskets
on both sides and torqued, they realized that the 20 ft-lbs. torque on the flange
,
bolts specified in the package would be insufficient to get adequate gasket crush.
i
The inspectors found from the package review, and discussions with engineers
involved, that the mechanics initially increased the torque to 45 ft-lb., then
! contacted their group leader. After the mechanics contacted their group leader,
permission from engineering was obtained to increase the torque on the flange bolts
-
up to 55 ft4bs. This action was documented by lining out porions of the job step.
Regulatory Guide 1.33, Revision 2, Appendix A, Paragraph 9.e recommended
! general procedures for the control of maintenance activities. CPS procedure
1029.01 " Preparation and Routing of Maintenance Work Documents," section 8.5,
! specified the controls to be used in changing the work specified in MWRs. Using a ,
torque value other than that specified in the MWR and lining out portions of the
'
MWR were not in accordance with CPS 1029.01 section 8.5, and were an apparent
- violation (eel 50-461/96015-01o) of TS 5.4.1.
The inspectors also identified a problem with maintenance workers using a
'
" deficiency list" process to document changes made to the modification prior to
'
engineering approval of a change to the package. Maintenance workers considered
'
this a normal process, and not outside of the bounds of design changes. The
, inspectors found that this process had been used to modify the design of the
,
rupture disk installation by deleting a required "J-hook", and was also considered by
'
maintenance as the right mechanism for making the torque value changes (although
the workers informed the NRC that they had neglected to actually docurnent the
deficiency list process for the torque value change.) The inspectors found that both
- the torque change and the J-hook change were changes to the design that should
have received formal engineering review and approval. This discrepancy is
discussed in more detail in inspection Report 50-461/97003.
!. i l
18
i
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.-
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Engineerirw
The engineering issues associated with the rupture disk modification involve poor
initial design for a modification, poor design control when changing the
modification, and poor coordination with operations when putting the system back l
into service. The issues are described briefly below, but are addressed in more I
detail in inspection report 50-461-97003.
e The original rupture disk design was weak because the selected design pressure
. for the disk to rupture was too close to system operating pressure, and did not take
into account system pressure spikes such as those occurring during pump starts.
e The original design was also weak in that engineers did not consider the
consequences to the system if the rupture disk ruptured. Failure of the WX piping
during a resin transfer could have resulted in serious radiological consequences,
e Engineers failed to provide adequate package instructions for drilling an '
alignment hole in the flange.
e Engineers failed to check with the vendor when authorizing torquing the flange i
bolts to 275 percent of the vendor recommended value. ,
o Engineers verbally authorized maintenance to grind off a "J-hook" alignment pin ,
and delete procedure steps to drill a matching alignment hole in the flange, without '
making a design change.
o Operations failed to get engineering review of the design package before putting !
l
the system in service (as required by the procedure.)
The inspectors found that a week after the rupture disk failure, the engineering
department had not briefed all engineering personnel on the lessons learned from
the event. The inspectors also determined that condition reports which were j
expected to deal with corrective action for the event did not address engineering i
'
issues one month after the event. Some short term corrective action was taken to
redesign the system, and some department briefs of the event took place after
several weeks had elapsed.
Radiation Protection (RP)
The inspectors interviewed the RP technician (RPT) and RP shift supervisor (RPSS)
involved in the event. After being notified by operations of the apparent leakage,
the RPSS dispatched an RPT to evaluate the radiological conditions in the rupture
1
disk area. The RPT observed some standing water and generally damp conditions
on the floor and a localized pool of resin near the rupture disk. General
contamination levels ranged between 1000 to 30,000 disintegrations per minute
-
and about 20 millired per hour on the resin. Based on the radiological conditions
t
and the fact that the transfer was completed, the RPSS and RPT concluded that
pressurization of the line would not result in a more significant contamination
spread and gave approval to the operators. However, neither individual addressed
i
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the potential spread of resin that may be trapped in piping upstream of the rupture ,
-
disk. During the repressurization, the RPT and operator observed the rupture disk j
from behind a corner well to avoid being sprayed by water. Neither individual was I
contaminated during this event. I
!
As stated earlier, non-conservative decisions by the operations group contributed to )
this event. Specifically, the operators acted non-conservatively by deciding to ;
repressurire the resin transfer line without considering other methods which would
'
;
have minimized the potential spread of resin and the potential personnel exposure, )
and did not fully understand that the pressurization process went beyond the scope
of existing station procedures.
In addition, RP personnel exhibited a lack of conservative radiological safety ,
j perspective in not adequately challenging the Operations decision. After agreeing
,
to repressurire the transfer line, a survey to evaluate the radiological hazards in the )'
piping upstream of the rupture disk was not performed. The failure to adequately
evalusta the radiological haiards that may have been present in the upstream piping i
is considered a violation (50-441/96015-02) of 10 CFR 20.1501(a) for the failure
. to make en adequate survey to ensure compliance with the dose limits of 10 CFR l
20.1201(a). .
1
1
- Summarv
. Overall, the site corrective actions for this event were poor. The event highlighted '
procedure adherence problems in several departments, non-conservative decision
making across several departments, and process problems in modification control.
Additionally, the inspectors found that corrective actions did not appear appropriate
i to prevent recurrence in the short term, and that the corrective action mechanism
(CRs) did not specify when corrective actions should be completed even over one
i month after the event. 4
Operators made non-conservative decisions which had the potential for creating
4
serious radiological hazards when other reasonable and safe options existed.
Operators failed to properly implement procedure change guidance and performed
independent system manipulations when the procedure did not match the desired
,
system state. Operations supervision did not understand the nature of the system
manipulation to be performed by ROC operators, partially due to weaknesses in
- system knowledge. Operators failed to perform modification testing prior to placing
the WX system into service. Corrective actions for the event were weak, and failed
to inform station personnel of needed short term corrective actions.
Maintenance workers violated procedures by making changes to an MWR without
using the proper approval process. Maintenance corrective actions were initially
,
weak in that the issue was not brought up with the responsible crews or other
crews until after the inspectors pointed out the procedure errors. After the
inspectors spoke with the mechanical maintenance supervisor and informed him of
the procedure violations, the licensee appeared to take corrective action aimed at
preventing the same mistakes in other maintenance activities. However, the
inspectors noted that CR 1-97-1-087 which documented corrective action for
l
- 20 '
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, - - -
-- .
-_ _ -. .. - . . - .. . - - -_ . _- --- - - . - - _ . - - _ - - - - . -
, 2 (
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I
!
issues brought up in the Operations critique did not document any corrective
-
actions taken in the Maintenance area.
Enginsonne exhibited weaknesses in the original design activities involving the ;
'
rupture disk modification. Engineering also failed to ensure the adequacy of design
changes which it authorized Maintenance to perform, in that inadequate reviews of
tho' flange bolt torque value changes could have led to rupture disk damage and
premature failure. >
Radiation protection weaknesses included the lack of a conservative radiological
safety perspective by the RP staff. The staff allowed repressurization of the WX
piping without consideration for other methods of leakage detection with a lower
radiological consequence. Once the decision to repressurize the piping was made, j
~
the radiological conditions on the upstream piping were not evaluated.
1
c. Conclusions l
A newly installed rupture disc in the Radweste Transfer system failed during system 1
1
operation. Numerous problems with rupture disc installation, post modification
testing, procedural adherence, safety perspective, and control of corrective actions I
were identified. Three procedural violations and a radiological survey violation were
identified.
01.11 Core Alterations and Foreian Material Removal from Reactor Vassel
a. Insoection Scone
The inspectors observed portions of core alterations and reviewed actions taken
when a foreign object was identified in the reactor vessel. l
l
b. Observations and Findinas
The inspectors observed portions of core alterations and fuel handling activities ;
from the refuel floor and manipulator crane. Activities were directed properly by l
the Lead Refuel Senior Reactor Operator (SRO) and core components specified for
movement in the fuel transfer log were properly verified and logged. Good
'
communications were noted on the manipulator crane among the operators and
between the refuel floor and the control room.
On November 18,1996, while preparing to uncouple a control blade, the assistant
lead refuel SRO identified a piece of wire in a flow orifice. The licensee developed a
retrieval plan in consultation with outside technical experts. Considerable attention
was given to the shutdown cooling configuration and its affects on the retrieval
effort. The wire was successfully removed on November 23. The source of the
wire had not been determined at the conclusion of the period.
21
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.
.
,
c. Conclusions
Core alteration activities were effectively performed. An operator made a good
observation when he identified foreign materialin the reactor vessel. The
development and implementation of the foreign material retrieval plan was
effective.
01.12 Main Power Transformer Smidan Pra**me Trio and Subsaouant Activities
,
s. Inanection Scone
The inspectors reviewed portions of the licensee's activities following the January
19,1997, audden pressure trip of the C-phase main power transformer (MPT).
,
b. Observations and Findings ,
- At approximately 6 a.m. on January 19,1997, a sudden pressure trip alarm was
,
received in the main control room for the C-phase MPT. The "A" main fire pump
also autostarted and the fire protection system deluged the MPT. Operators
verified that there was no fire and secured the fire pump. The licensee determined
that a failure of the sudden pressure relay had occurred, and replaced the relay. ,
The MPTs were not in service as a source of offsite power at that time. The
reserve auxiliary transformer (RAT) and emergency reserve auxiliary transformer
- were available sources of offsite power, therefore no interruption of power to
essential loads occurred.
Approximately 2 hours after the MPT sudden pressure trip, the "A" fire pump again
autostarted on low system pressure. Operators identified that OFP 106, a fire
i protection system post indicator valve, was leaking. The licensee concluded that
the leak was initiated by the system pressure transient caused by the MPT deluge
! system activation. In order to isolate the leak, a substantial portion of the plant fire
- protection system had to be isolated. The plant fire marshall assessed impet on
fire fighting capabilities, directed the implementation of compensatory measures,
and reviewed offsite fire department availability in anticipation of additional system
- degradation.
l
'
On January 20, the licensee tagged out the "A" fire pump because the fuel filter
4 had apparently become clogged. This issue is discussed further in Section F2.1.
c. Conclusions
- Plant operators responded well to an unexpected MPT sudden pressure trip.
i
22
_
,. , .
03 Operations Procedures and Documentation
03.1 Review of Plant Proceduras Program
a. Inanaction Scoon (71707)
The inspectors reviewed the licensee's procedures program, including CPS 1005.01
" CPS Procedures and Documents," applicable portions of the Operational
Requirements Manual (ORM), and Technical Specification 5.4.1, " Procedures."
b. Observations and Rndinas
During a predecisional enforcement conference held on February 4,1997, the
licensee informed the NRC that a significant contributor to the poor operator
response to a leaking Reactor Recirculation (RR) pump seal on September 5,1996
(see inspection Report 50-461/960010 for details of the event), was that CPS
1005.01 contained procedural adherence guidance which led plant staff to believe
that procedures did not have to be performed as written. The licensee stated that
CPS 1005.01 had been revised so that it provided clearer guidance to plant staff.
While observing activities detailed in Section 01.7 of this report, and while
following-up on the event detailed in Section 01.10 of this report, the inspectors
noted that plant staff continued to struggle with identifying what procedural
adherence was required by CPS 1005.01. These observations were reinforced by
conversations with plant operators. The inspectors also noted that licensee
management response to other procedural violations during this inspection period
was predicated on an apparent acceptance that plant staff was not always required
to perform written activities as directed by their procedures.
As a result of the above observations, the inspectors reviewed CPS 1005.01 to
assess its adequacy.
The inspectors determined that Technical Specification (TS) 5.4.1 required, in part,
that waftten procedures be implemented for specified activities (emphasis added).
ORM 6.8.2, Rev. 5, required that procedures required by TS 5.4.1, and changes
thereto (other than editorial or typographical changes), be reviewed and approved
prior to implementation (emphasis added). ORM 6.8.3 required that temporary
changes to pf ocedures must not alter the intent of the procedure, must be approved
by two members of plant management, and must be documented.
The inspectors considered CPS 1005.01, Rev. 36, Stop 8.1.6, to be inadequate
because it allowed deviation from the step order specified in TS mandated
procedures if this was considered necessary by " personnel performing the
procedure and the applicable supervisor." ~ The inspectors considered this a
proceduralized method of allowing implementation of TS mandated procedures in a
manner other then as written, an apparent violation (eel 50461/96015-03a) of TS
5.4.1.
23
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< .
; ;
-
i
- The inspectors considered CPS 1005.01, Rev 36, Step 8.1.9, to be inadequate
' -
because it allowed required steps within a section of a TS mandated procedure to
- be "noted out" by a single supervisor, without the change process required by ORM i ,
6.8.2 or the temporary change process required by ORM 6.8.3, an apparent i
violation (eel 50-461/9601503b) of TS 5.4.1. l
I The inspectors considered the above inadequacies in CPS 1005.01 to be of
i porticular concern because they had not been identified by the licensee following
the September 5,1996 recirculation pump seal failure. In fact, the inspectors '
4 reviewed the training notes (RC82001-00) used in the Procedure Compliance
.
Seminars held following the September 5 event and found that the non-sequential
performance of steps and the non-performance of steps were specifically covered
as acceptable practices.
c. Conclusions
The inspectors identified serious deficiencies in the licensee's upper tier
administrative procedure governing the use of procedures. The inspectors
! concluded that the inconsistencies identified had contributed to the procedural
nonconformances identified in Sections 01.8 and 01.10 of this report. These
- deficiencies were of added concern because the licensee had not identified or
i corrected them following the September 5,1996 RR pump seal failure. Two
I
examples of procedural violations were identified.
l 03.2 Review of Normal Ooeratina and Surveillance Procedures ,
a. Irmaantion Scone (71707/61726)
<
The inspectors reviewed and/or witnessed portions of the following:
* CPS No. 9053.01, " Low Pressure Coolant injection (LPCI) B/C Operability
'
Checks," Rev. 24,
l * CPS No. 9053.04, " Residual Heat Removal (RHR) A/B/C Valve Operability i Checks," Rev. 37, a
*
CPS No. 9053.07, "RHR B/C Pumps & RHR B/C Water Leg Pump Operability,"
4
Rev.37,
!
* CPS No. 3302.01, " Reactor Recirculation (RR)," Rev.13, ,
*
CPS No. 9051.02, "HPCS Valve Operability Tests," F.ev. 33, j
'
l
b. Observations and Findinas I
I
'
CPS 3302.01
.
A table-top review of the 9053-series RHR procedures did not reveal any
weaknesses.
I ^
The inspectors witnessed the performance of CPS No. 3302.01 which was used for
filling and venting RR Loop A. The brief presented before the performance of the
procedure was thorough, and the observed portions were executed correctly.
l Execution of the procedure had to be stopped part-way through because failure of .
24
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.
.
,
,
3 I
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I
. the Dropped Fuel Bundle Warning System prevented entry to the drywell for a j
-
period of time. l
4 i
Whde reviewing CPS No. 3302.01, the inspectors noted that it had been
extensively modified prior to use, and that one recently added step was redundant. l
This was discussed with the LASS, who indicated that he was uncertain why the ;
!
repetitive step was added, and that it did not impact procedure execution. The
Inspectors considered the redundant step and the uncertainty about why it was !
'
there as an additional example of the need to increase attention to detail.
CPS 9051.02
,
'
The prerequisites of CPS 9051.02 stated that the required plant status for the test i
was that suppression pool level ahould be below the high level automatic ;
realignment setpoint. The plant conditions at the time the procedure was executed !
- included a high suppression pool level. Operatsas proceeded with the surveillance '
"
on December 5,1996, despite the high suppression pool level.
l
-
Because of the suppression pool level, the HPCS system was automatically aligned :
to take suction from the suppression pool and automatically isolated from the HPCS
storage tank. Additionally, due to this automatic isolation control logic, the storage
tank suction valves automatically shut immediately after being opened by manusi !
initiation. I
During the observed portions of the surveillance, the operator was unable to record
stroke times for two HPCS suction valves, and had to stroke two other suction
valves twice to obtain stroke times. The operator discussed the problems with the
-
supervisor, and noted the multiple strokes on the surveillance data sheet. A CR
was initiated to evaluate the validity of the surveillance. The licensee reperformed
the surveillance on January 11,1997. All stoke times were within the specified
limits during the second surveillance. The inspectors noted that as of January 11,
1997, CPS 9051.02's prerequisite for suppression pool level had not been
<
corrected.
. Regulatory Guide 1.33, Revision 2, Appendix A, Paragraph 4.h recommended 4 procedures for emergency core cooling systems. 'The inspectors considered CPS
9051.02 to be inadequate because it did not require that the HPCS valve operability
surveillance be performed with the plant conditions necessary for obtaining
accurate test results. This inadequate procedure was an apparent violation (eel 50-
- 461/96015 01p) of TS 5.4.1.
,
The inspectors considered Operations decision to proceed with the HPCS valve : stroke surveillance with out achieving a recommended prerequisite as being
e
indicative of a lack of safety focue.
l
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c. Conclusion
]
'
The surveillance procedure for HPCS valve operability was inadequate in that it
-
allowed the test to be performed under plant conditions which prevented the
i
25
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_-. ,
- - - -. . . =- - . . -. .- - ..- .- - . - . . - . _ . . _ - - - - _ . _ _ _ _ _ _ _
.. %
.
. operators from obtaining accurate test results. The inspectors observed Operations
-
initiate a HPCS valve stroke surveillance when procedurally recommended
prerequisites were not being met. The invalid test was subsequently reperformed. !
One procedure violation was identified. j
i
04 operator Knowledge and Performance 1
04.1 Onaratur Rcanonna to a pecreams in Surga Tank Level
l
a. Inapaction Scans (71707) j
During a routine tour of the control room, the inspectors witnessed the on-shift
Operations crew respond to a sudden six inch decrease in the Spent Fuel Pool surge ;
tank. ;
b. Obaarvatiana and Findinas
l
On February 5,1997, with the inspectors in the control room, the licensed operator
st the controls of the unit noted a sudden drop of approximately six inches in the I
spent fuel pool surge tank. The tank level dropped from approximately 18'- 7" to
approximately 18' - 1" in two rapid step changes. The operator observed this on a
CRT display and a strip chart recorder. The alarm set point for surge tank level was
not approached.
The operators responded to this indication by promptly dispatching personnel to ]
walk down the Spent Fuel Pool Cooling and Cleanup (FC) system. An operator
identified that the air supply tubing for the pneumatic actuator on the FC system
domineralizer bypass valve had failed. The FC domineralizer bypass valve had failed
open, as designed. No other problems were identified during the operators' system
walkdowns, and the surge tank level stabilized at the now equilibrium point. The
inspectors noted that the operators attempted to determine the quantity of water
involved with a six inch drop in the surge tank, but that they were unable to obtain
this information from the documentation available in the control room area.
The operators informed the inspectors that the surge tank level had dropped
because the amount of water in the FC system had increased when the FC
domineralizer bypass valve opened. The inspectors asked the Shift Technical
Advisor (STA) how an increased flow rate in the FC system (less backpressure from
the domineralizers) had resu!ted in an increased volume of water in the system
piping. The STA could not provide an immediate response.
. On February 7,1997, the STA informed the inspectors that the indicated surge , tank level was based on the static pressure in the tank drain line. The STA ,
concluded that the indicated drop in the surge tank was the result of increased line !
losses between the tank and the pressure transducer, and, possibly, additional
'
water in the pool and partially flooded pool drain piping to the surge tank. The
inspectors verified that tank level was determined indirectly, as described by the
l
- 26
,
w,-__., ...,,--9 -e,_ r, _ . , , -. ~ ,.- .. ..%._ .,
. . _ . . . . .- _ _ _ . . _ _ . _ __ _ _ _ . __ __. _ .. _ ___ _ - __
-
.g, t-
*
!
- STA, and concurred that this assessment adequately explained the indicated tank i
.
*
drop on en increase in FC system flow. The inspectors did not identify any .!
concerns with this instrumentation methodology for the FC system surge tank. !
;
,
The inspectors considered the overall crew response to the indicated drop in the ,
i spent fuel pool surge tank to have been good. The inspectors were concerned that l
l the operators accepted that the pneumatic actuator failure was the cause et the '
l
t tank drop, without being able to explain the causal relationship. There was no
4 safety significance associated with this event. ; <
>
c. Conclusions I
- .
.
The inspectors observed the on-shift Operations crew respond promptly and j
'
effectively to a sudden six inch decrease in the indicated level of the spent fuel pool j
- ' surge tank. A failed pneumatic actuator line was found on a system flow regulating i
valvs. The inspectors noted, however, that the crew did not exhibit a questinning :
j attitude in determining how the regulating valve effected tank level in a closed loop l
system. l
-
11. Maintenance l
1
i \
M1 Conduct of Maintenance !
i M1.1 Non-cor'== vative riarisian Landa to Contamination of Individual
- a. Inanection Scope (62703)
4 The inspectors reviewed the circumstances surrounding the disassembly and j reassembly of Containment Equipment Drain (RE) sump check valve 1RE0388. A J worker was contaminated during preparations of post maintenance testing of this
check valve.
- b. Observations and Findmps
i '
On February 8,1997, operations personnel initiated maintenance work request
- (MWR) D72611 to inspect and repair the RE sump pumps. A step was included in
i the MWR to inspect check valve 1RE0388 for proper operation. 1 1-
During reassembly of the check valve, the workers noticed that the installed valve
'
bonnet gasket (a flexitalic type gasket) was different in both construction and size
than the replacement gasket (a corrugated metal gasket). The mechanics
questioned this difference, and determined that the stock code given in the MWR
I for the replacement gasket was for a check valve which had been removed from
the RE system in the previous refueling outage. The Master Equipment List (MEL)
had not been updated for the newly installed check valve type. A CR was written
'
to document the MEL deficiency. )
l
Both mechanical maintenance and maintenance planning persamel searched the '
c parts database for an appropriate replacement gasket, but none were found. Based
27
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_ _ .. _ _ -. . _ . _ . _ ._ _ _ _ . _ _ _ _ _ . _ _ _ _ _ _ _ _ _
,
,
, .
,
.
.
, . upon information provided by maintenance personnel concerning the condition of .
-
the old gasket and the unavailability of a suitable replacement, the shift supervisor
decided that the check valve should be reassembled using the old gasket. The
2 licensee's procedures did not preclude gasket reuse. Technical support from plant
- engineering or the check valve vendor was not requested prior to making this i
decision.
1
Following reassembly of the check valve, operations personnel began clearing the
associated tagout and restoring the system to the proper configuration. Upon
,
opening the "B" RE sump pump discharge isolation valve, which was directly above
1RE0388, the water above the discharge isolation valve flowed down the pipe to !
the check valve. As the water entered 1RE0388, the valve bonnet joint leaked
profusely and contaminated the individual manipulating the discharge isolation
valve. Contamination levels up to 8000 corrected counts per minute were found on ,
'
the right pont log area of the individual; decontamination efforts were successful. '
On February 11, the licensee began reviewing the details of this event. The
'
licensee was unable to promptly identify the correct gasket for 1RE038B. In
addition, mechanical maintenance personnel identified that an attachment to the
MWR appeared to contain torque specifications to be us with a corrugeted gasket
instead of the flexitalic gasket found installed in the valve. Due to this discovery,
the inspectors questioned the adequacy of the work package and the torque values
used to reassemble the check valve. At the conclusion of the inspection, the
licensee was pursuing the purchase of the appropriate flexitalic gasket and the
resolution of torque values to be used for different types of gaskets. This item is
considered an inspection follow-up item (50-461/96015-04) pending inspectors
3
review of the licensee's resolution of these issues.
' '
In conversations with the inspectors, the licensee maintenance staff acknowledged
i that experience has shown the reuse of gasket material to increase the probability
.
that gasketed ccnnections will leak once returned to service. Because of this, and
! the fact that the containment equipment drain sump is a contaminated system, the
licensee should have considered the possibility of spreading contamination to
additional areas of the plant or to an individual when determining the
- appropriateness of rousing the 1RE0388 gasket. In addition, the reuse of the
j gasket material resulted in re-work in a radiation and contamination area. Based '
upon this information, the inspectors considered the licensee's decision to reuse the
'
gasket material as non-conservative,
i i c. Conclusions '
A worker was contaminated when a containment equipment drain system check
valve bonnet joint leaked while a valve line-up was being performed following
maintenance on the check valve. The inspectors considered the licensee's decision ,
to reuse a metal gasket in this }oint to have been non-conservative.
1
l
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28 !
l
.
= y n-.m-,- , -,.-.y-y , - - - - -.
- - - - - . _ - . -.-- - - - - - - - - - - . _ - -- . - - -
I
, . i
, ,
*
-
l
i
. M1.2 Surveillance (61726)
*
!
a. Inanaction Scone j
The inspectors observed the performance of Surveillance Test CPS 9382.01, "125 l
VDC Battery Pilot Cell Test." This surveillance verified the operability of the station
safety related betteries, i
The inspectors also' reviewed all other surveillance procedures pertinent to l
determining bettery operability and vendor manual recommendations. Those ;
included:
K2988-0001 Installation and Operating instructions for Stationary
Batteries (C8tD Batteries)
9382.01 125 VDC Battery Pilot Cell Test
9382.02 125 VDC Battery ICV & Battery Chgr Cks
9382.04 125 VDC Batt Conn Resistance Check
9382.08 Div i 125 VDC Battery Charger Load Test
9382.12 Div i 125 VDC Battery Service Test
9382.16 Div i 125 VDC Battery Capacity Test
b. Obaarvations and Findinas
!
The inspectors observed the performance of the subject test on the Division 1
battery bank. The electricians assigned to perform the task were very 1
'
l<nowledgeable about the assigned task and surveillance procedure to be
implemented. They were able to properly respond to questions pertaining to this
test as well as to answer questions pertaining to the other surveillance tests
performed on the same batteries. They followed other applicable procedures
pertaining to this test, specifically the requisitioning of Measuring and Test
Equipment (M&TE). The surveillance procedure was properly released for work by
the Control Room prior to the commencement of work.
The inspectors reviewed the vendor recommendations (manual K2988-0001) for
battery maintenance, and identified one discrep ncy with the licensee's procedure.
The vendor recommended checking "all electrical connections associated with the
battery" on a quarterly basis and "retorquing as required to the torque values"
provided. Other surveillance procedures for the batteries provided testing to
determine the voltage drop across these connections (which, if high, could be
indicative of a loose connection) but none specifically required a torque check.
The inspectors concluded that the licensee was relying on surveillance test results
to identify when battery connections were loose, rather than proactively
'
retorqueing the connections to prevent them from becoming loose. The inspectors
considered this to be a weakness in the licensee's battery program.
,
29
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___--__N____-- - - - - - +
- . .- . .
-
,
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. - , ,
,
!
!
c. Conclusions :
'
The inspectors observed surveillance tests associated with the 125 VDC Station
Batteries. The electricians were knowledgeable, and performed the surveillance as :
written. The inspectors noted a weakness in that the licensee was not performing
vender manual recommended preventive retorqueing of battery connections. ,
r
- M2 Maintenance and Material Condition of Facilities and Equipment
.-
M2.1 Transfer of Fuel Pool Coolina (FC) System from Comoonent Coolina Water (CC) to
Shutdown Service Water (SX) System
a. Insnection Scone
The inspectors reviewed issues involving the liconaae's attempt to transfer cooling
of the FC system from CC to SX. Documents included in the review included
Safety Evaluation Log No. 96-085 and Condition Report 1-96-11-362.
:
*
b. Observations and Findinas
On November 24,1996, the licensee attempted to transfer cooling of the "A" FC
heat exchanger from the CC system to the SX system to demonstrate shutdown
cooling capability using the SX system via FC. When this was attempted, the level
in the CC expansion tank increased approximately 5 inches in 4 minutes. The
licensee determined that SX was leaking into the CC system through FC heat
exchanger isolation valves 1CC075A and 1CC076A. The "B" train isolation valves,
1CC075B and 1CC0768, had open work orders because of seat leakage also. The
licensee determined that the opersbility of SX was not effected, and replaced the ,
four leaking isolation valves during the current outage. l
The operations staff identified that USAR Section 9.2.2.2 described that the CC
expansion tank had a level control system and automatic drain valve that would
i
prevent overfilling the expansion tank and an automatic fill valve that would provide
makeup to the expansion tank on low level. The shift supervisor informed the
inspectors that this system had not worked for " years." Condition Report 1-96-11-
362 was initiated to document this USAR discrepancy. The licensee allowed a l
nonconformance of the CC expansion tank drain and automatic level control system
to exist for sufficient duration that it represented a change to the operation of the
facility as described in the FSAR. The failure to maintain a written safety
evaluation documenting the basis for determining that this change did not involve
an unreviewed safety question is considered a violation (50-461/96015-05a) of
10 CFR 50.59. The inspectors did not consider the USAR discrepancy to be an 4
unreviewed safety question because of the continued operability of the SX system. l
! In order to operate the FC system with SX for cooling in place of CC, the licensee
revised procedure CPS 3203.01 to provide instructions to isolate the CC surge tank
and filter domineralizer to prevent overfilling the CC expansion tank and lifting its ;
relief valve. A 10 CFR 50.59 safety evaluation was written to justify the adequacy
of this procedure change (96-085). It was reviewed and approved by the Facility
4
30
. -. _. ., _ _ _ _ __ _ __
l
.. ..
4
.
,
Review Group on November 27,1996. The inspectors reviewed the licensee's
-
safety evaluation, and found it technically acceptable.
c. Conclusions
While transferring the spent fuel pool cooling medium from the Component Cooling ,
Water (CC) system to the Shutdown Service Water (SX) system, several SX to CC- l
boundary valves leaked excessively. A rapid rise in the CC system expansion tank
demonstrated that the expansion tank level control system did not function. The '
inspectors determined that the level control system had been inoperable for many
-
years, resulting in a nonconformance with the updated safety analysis report
(USAR). A violation of 10 CFR 50.59 was identified.
!
lil. Engineenng <
E1 Conduct of Engineering
E1,1 Weakna==== identified in ECCS Tastina Accentance Criteria
a. Insnaction Scone (37551) l
The inspectors observed ECCS integrated response time testing for the Di.eision 111 l
'
system. The inspectors reviewed sections of the USAR, TS, and current plant
procedures to ensure that requirements were appropriately identified and met.
b. Observations and Findinas
The inspectors noted that CPS Procedure 9080.23, " Diesel Generator 1C ECCS
Integrated," identified surveillance acceptance criteria that was not consistent with
USAR Table 6.3-2. USAR Table 6.3-2 was referenced by the TS basis section for
this surveillance. Specifically, CPS 9080.23 stated that the time from the loss-of-
coolant accident (LOCA) initiation signal to the HPCS injection valve being full open
must be less than or equal to 27 seconds. The USAR stated that the time from the
'
initiation signal to the HPCS pump reaching rated speed must be less than or equal
to 27 seconds. The inspectors determined that the HPCS surveillance during the
outage which ended in May,1995, had been performed using the time to injection
i
valve open acceptance criteria.
, The inspectors informed the licensee of this discrepancy. The licensee initiated '
Condition report (CR) 1-9611-386 to document the discrepancy and the concem
with potentially inadequate test methodology. An individual in the Procedures
,
group who was not familiar with the testing requirements for the HPCS system was
assigned the action of resolving'CR 1-96-11-386. The individual in the procedures
~
group closed the CR by reference to an engineering work request (EWR) (94-
00065). Because this CR was downgraded from "potentially significant" to
"other," no independent verification of the CR response was required prior to
closecut. The inspectors reviewed EWR 94-00065, and found that it failed to
,
resolve the issue on the acceptabi!ity of the current acceptance criteria. The
inspectors considered the quality of the answer to CR 1-96011-386, and the lack
31
.
*_ . - _ _ _ - . _ . _ -
4 __ __ ,____ . _ - . __ _ . __ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ ~ _ _ _ _ _ _ , - - - -m --., - -<.4 ,.. -
-. _ _ _ _ - _ _ _ . . _ _ _ _ . _ _ . . . __ _ _ _ _ . _ .- _ _ _ _ _ __ _._ __ _ . _ _ _ _ _
l
, . - . ,
.
. of technical review for the answer, to be indicative of a weaknesses in the
-
licensee's corrective action program, i
i
. In January 1997, engineering personnel provded new documentation to the ;
'
inspectors which comonstrat9d that the HPCS surveillance, as performed, satisfied
the requiremontr of the TS. Specifically, the engineers were able to demonstrate - I
'
that system flow tests verified the absence of mechanical problems with the
pumps, that the CPS 9080.23 surveillance measured the bounding electrical j
component stroke times, and also verified that all electrical generation and
J
distribution systems functioned properly. '
The inspectors were satisfied that Engineering had demonstrated the adequacy of j
- the ECCS surveellence acceptance criteria, but noted that some of the supportmg
j documentation had been reconstructed after the inspectors had identified the !
*
casem. The inspectors considered it a weakness that the licensee had not been i
able to retrieve records and calculations that demonstrated the adequacy of an
',
ECCS integrated surveillance. -
i
l The licensee planned to correct the inconsistencies between CPS 9080.23, the TS i
l bases, and the USAR by completing the associated paperwork to change these !
] documents. This included performing a 10 CFR 50.59 screening / evaluation prior to
entering a mode of reactor operation which required that HPCS be operable. ] - The completion of the h*ey,1995 outage HPCS surveillance using acceptance
- criteria which was diamr.t than that described in the USAR without having i
completed a written safety evaluation was considered to be a violation (50- )
, 481/98015-05b) of 10 CFR 50.59. !
c. Conclusions
The inspectors identified that the HPCS integrated operability test was not
performed in the manner referenced in the TS basis. While investigating this issue,
the inspectors identified that Engineering did not have readily retrievable records
- which documented the adequacy of the test methodology. Suitable' calculations
- were subsequently produced. One violation of 10 CFR 50.59 was identified.
l E1.2 Procedural Revision for Safetv Function Determination Proaram
a. Inanection Scone
! The inspoctors reviewed the plant's administrative procedure for implementing
Technical Specifications (TS) 3.0.6 and 5.5.10, the Safety Function Determination
Program.
b. Oh==rvations and Findinas
Technical Specification 3.0.6 allowed the licensee to declare " supported" systems !
inoperable, but not enter the applicable Limiting Condition of Operation (LCO) l
Action statement,if the only reason for the system's loss of operability was that a l
,
32 ;
!
- ' l
:
_ _ _ _ _ _ - - - - - - - - - - - - , _ - - ,- -
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____ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ - _ _ _ _ ~ _ .
. .
. . ;
!
-
. !
. required " support" system was inoperable and there was no loss of safety function {
-
as determined by the Safety Function Determination Program (SFDP) defined in TS :
5.5.10. TS 3.0.6 further required that if a loss of safety function was identified, ;
then the LCO action statement for the lost safety function was to be entered. l
1
Technical Specification 5.5.10 defined TS 3.0.6 " safety functions" as being those j
safety functions assumed in accident analysis. The inspectors conferred with a !'
representative of the Technical Specifications Branch in the Office of Nuclear
Reactor Regulation, and confirme' . net " safety function" under the SFDP and TS i
3.0.6 clearly encompassed the functions of both " support" and " supported" i
systems. ;
A member of the licensee's staff described to the inspectors a February 13,1997, i
revision to the plant's administrative procedure for implementing the SFDP. The '
inspectors were concerned that the revision, as described, was not in compliance
with TS 5.5.10 because the SFDP did not evaluate supported system safety
functions. The inspectors requested a c.opy of the approved administrative ,
procedure change, and the supporting 10 CFR 50.59 screening. The inspectors l
2
consider the adequacy of the licensee's SFDP to be an unresolved item (50-
461/96015-06) pending receipt and review of the procedure change and its 1
associated 10 CFR 50.59 screening. !
l
c. Conclusions )
i
The inspectors identified a potential concern with a recent revision to the licensee's ;
Safety Function Determination Program administrative procedure. An unresolved
item was opened pending review of the licensee's procedure change and the
associated 10 CFR 50.59. !
I
E1.3 Control Rod Drive (CRD) Hvdraulic Control Unit (HCU) Fastener Toraue
I
a. Insnaction Scone (37551)
1
,
The inspectors reviewed the circumstances and documentation pertaining to
) assignment of torque valves for CRD HCU Upper mounting bolts during initial '
installation.
i
b. Observations and Findinas
On November 19,1996, utility maintenance personnel questioned the as-found
l torque values of the upper HCU mounting bolts. The specified torque appeared to ! be high for the size of bolt and material (reference Condition Report (CR) 196-11- ' 295). En0 ineering determined that the bolts were over torqued. The effected ;
equipment was declared inoperable and an event notification was made. The
'
inspectors noted that detection of this condition by Mechanical Maintenance
personnel was beyond the original scope of work, and indicated a good questioning
attitude and awareness of all aspects of the job at hand.
L
l
1
I
33
1
9 $1 .. I
-
,
.a - , ,
.
- 1
. The licensee replaced all over torquod 3/8 inch bolts during the current refueling )
-
outage. When replacing the bolts, the licensee installed washers that the supplier i
subsequently identified might not meet all purchase specifications. The licensee j
replaced all suspect washers. This conservative decision ensured all bolting !
'
materials met the appropriate specifications.
[ ) '
As part of the engineering analysis being performed to determined HCU operability
between hitial start-up and discovery of this condation, a random sampling of 3
*
removed bolts was sent to an outside laboratory for testing. This testing data was ;
used in a licensee engineering evaluation retrospective operability determination.
! This engineering evaluation determined that each HCU would have remained secure
and operable, even dunne the design seismic event. This engineering evaluation ,
i had not yet been reviewed by the inspectors. t
i The inspectors review of this issue identified concerns with historical design control
1 and corrective action processes. The inspc: tors consider this issue to be an
unresolved item (50461/96015-07) pending review of the licensee's retrospective ;
operability determination for the HCUs. ,
.
l
4 , q c. Conclusions
- The licensee identified that some retaining bolts on the CRD HCUs had been over
- torqued. All effected bolts were replaced. An unresolved item was opened pending '
- inspector review of the licensee's evaluation of the operability of the over-torquod
1 bolts. i
i
i IV. Plant Suonort l F2 Status of Fire Protection Facilities and Equipment
i
l'
F2.1 Renested Failures of the Diesel Driven Rre Pumns j
i ! >
n. Inanection Scone (71750) ;
i
The inspectors reviewed past failures of the diesel driven fire pumps, the current i
2
failure mechanism, and the licensee's short and long term corrective actions.
i
b. Observations and Rndings ,
4 l
The diesel driven fire pumps have had repeated failures due to fuel filter clogging.
,
A November 1991 violation was issued for repeated engine failures attributed to 1
fuel filter clogging. In that case, the filters clogged after continuous operation of l
24-36 hours. The cause of the clogging was debris produced by bacteria in the fuel j
'
tank. An October 1994 violation was issued for failing to have a procedure in place ,
'
to change the fuel filter on the "B" fire pump. The filter had not been changed for
approximately two years.
l
In July,1996, the licensee experienced additional fuel filter clogging on the "A" ;
diesel driven fire pump. At that time, the licensee inspected the "A" fuel tank and
]
!
34 j
!
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__ . - _ _ _ _ _ . -
._ -. - - - . - -
, -.
_ _ _ _ _
_ _
. .. . .
l
i
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,
. found very little particulate on the bottom. Based on the results of the fuel tank j
- '
inspection, and an unexpected pump speed increase which occurred in the middle j
of a poet filter change surveillance, the licensee attributed the engine problem to .
l
the governor / fuel pump assembly. The throttle was replaced. The cause of the
fuel filter clogging was not resolved. ;
On January 19,1997, the "A" diesel driven fire pump was started and ran !
'
continuously for 18 hours before the engine speed was observed to be decreasing
(the filter had approximately 68 total hours in service). On January 24, the "B" ;
diesel fire pump ran for approximately 107 hours before the engine speed dropped. t
in both cases the licensee initiated condition reports, and identified fine particles of [
rust as being the cause of the filter clogging. l
!
On January 24 the "A" fire pump again experienced reduced speed after 69.5 hours
'
of operation. No condition report was written. Operations requested Maintenance
initiate the preventative maintenance task that changed the filter, and a log entry ;
was made. However, the engineer responsible for fire pump performance was not j
informed that another filter had become clogged. :
:
The licensee's immediate corrective action for the January 1997 problems was to .
limit the service time of the fuel filters to 40 hours. inspection of the fuel tanks I
and fill lines revealed rust on the top section of the tanks and a thin oxide film on
most other surfaces. At the conclusion of the inspection, the licensee had cleaned !
one tank and fill line. Post cleaning inspection revealed that all loose rust had been i
removed but a rust film remained. The tank was refilled with new fuel. Cleaning of l
the "B" fuel tank and fill line was scheduled for February 1997. j
.
In 1996, fuel filter clogging was documented, but corrective actions taken did not I
i address that clogging. In January 1997, failures of diesel driven fire pumps l '
occurred due to fuel filter clogging.10 CFR 50, Appendix B Criterion XVI I
. " Corrective Actions" requires that measures shall be established to assure that , conditions adverse to quality, such as failures, are promptly identified and
- corrected. The failure to promptly identify and correct the cause of the July 1996
j fuel filter clogging on the diesel fire pumps is a violation (50 461/96015-08) of 10
- CFR, Appendix B, Criterion XVI.
! The inspectors noted that towards the end of this inspection period the licensee had
'
initiated prosctive efforts to thoroughly evaluate all potential filter clogging
i mechanisms and was discussing modifications to the fire pump fuel system which j would address allidentified clogging mechanisms. The inspectors considered this a
positive indication of possible performance improvement.
- c. Conclusions
! !
The diesel driven fire water pumps experienced failures due to fuel filter clogging.
Fuel filter clogging had boon identified in July,1996, but corrective actions did not
prevent reoccurrence of fuel filter clogging in January 1997. The licensee
'
subsequently initiated a complete assessment of potential causes of the filter
clogging. One violation for ineffective corrective actions was identified.
.
35 i
!
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. . -- . . - . _ - - -_- - .__ . - . - . - - . -.
d !
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,
.
. . V. Management Meetinas
1 .
X1 Ealt Meeting Emi
The inspectors presented the inspection results to members of licensee
management at the conclusion of the inspection period on February 14,1997. The
licanoes acknowledged the findings presented.
- The inspectors asked the licensee whether any materials examined during the
; inspection should be considered proprietary. No proprietary information was
identified. ;
, X2 Pre Decisional Enforcement Conference Summary
On February 4,1997, a pre-decisional enforcement conference was imid at the NRC
Region lli office to discuss potential enforcement issues identified in Inspection
2 Reports 50-461/96010 and 50-461/96011. The issues were related to the
i operators' actions prior t6 and following, the failure of the "B" reactor recirculation
i pump seal on September 5,1996. Handouts used in the licensee's presentation at
the conference have been included as Attachmsnt A to this report.
; X3 Management Meeting Summary
4
A management meeting between the licensee and the NRC was conducted on
December 16,1996. The meeting discussed the Clinton Power Station Recovery
'
Plan. The licensee discussed its assessments, required actions prior to startup, and
long term improvement plans in the Operations, Engineering, and Nuclear
Assessment areas. The meetire was productive and provided the NRC an update
l# of actions the licensee had taken and intended to take to improve performance.
Handouts used in the licensee's presentation have been included as Attachment B
to this report.
!
X4 Management Visit Summary
l i' On January 23,1997, Mr. L. Joe Callan, Executive Director for Operations, and Mr.
A. Bill Beach, Regional Administrator visited Clinton Power Station. A management
- meeting was held at the site to discuss the licensee's progress towards improving
i overall plant performance following the September 5,1996, reactor recirculation
, pump seal failure. Mr Callan and Mr. Beach acknowledged the actions taken by the ! licensee and pointed out the importance of ongoing improvement initiatives. ; ! i
! I
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b .
36
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,. t.
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}
.
- l - usSPECTION PROCEDURES USED i . .
IP 37551: Oneite Engineering }
IP 61726: Surveillance Obeorvations
!
IP 62703: Maintenance Observation
IP 71707: Plant Operations i
IP 93702: Prompt Oneite Response to Events at Operating Power Reactors .l
ITEMS OPENED, CLOSED, AND DISCUSSED l
:
l
Opened
50-461/9601541a eel Failure to follow feedwater valve lineup procedure. j
l
50-461/96015-01b eel Failure to follow actions in annunciator respoase l
>
procedure.
:
^50-461/96015-01c eel Failure to perform an adequate verification of a tegout. l
50-461/96015-01d eel Failure to maintain containment integrity. The failure to !
drain specified piping as required.
50-461/96015-01e eel Failure to ensure that SGTS were in " standby"
condition. ;
50-461/96015-01f eel Failure to ensure that tegout vent path was appropriate ,
prior to b-<3i nning work. (
r
'
50-461/96015-01g eel Failure of _ Tagging Authority to identify that impact
statement of tegout 97-9136 was inadequate.
50-461/96015-01h eel Failure to establish required cooling water flow. :
i
50-461/96015-011 eel Failure to follow procedure, closure of 1FCO27 out of (
sequence. 1
;
50-461/36015-01) eel Failure to flush the FC system drain line " prior to j
securing the drain lineup". ;
50-461/96015-01k eel Failure to use appropriate controls when removing a j
tag. >
:
50-461/96015-011 eel Failure to properly inventory removed safety tags.
50-461/96015-01m eel Failure to follow procedure CPS 3909.02.
50-461/96015-01n eel Failure to follow procedure of " Maintenance Work
Request".
i
!
37 '
!
1
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.. * .
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1
1
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, 50-461/96015-01o eel Failure to follow procedure " Preparation and Routing of
= maintenance Work Documents". ;
;
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50-461/96015-01p eel Failure to provide adequate HPCS surveillance )
'
procedure. i
. 50-46./96015-02 NOV- Failure to perform radiological surveys !
50-461/96015-03a eel Failure to follow proceduralized method of allowing
j implementation of TS mandated procedures.
50-461/96015-03b eel Failure to perform temporary change process.
1
4
50-461/96015 04 IFl Pursuing the purchase of flexitalic gasket and resolution i
of torque values for different types of gaskets.
i
50-461/96015-05a NOV The failure to maintain a written safety evaluation
document.
l
50-461/9601545b NOV HPCS surveillance using acceptance critoria different )
that described in the USAR, without having proper
.
documentation.
! l , 50-461/96015-06 URI Adequacy of the licensee's Safety Function i Determination Program. l 50-461/96015-07 URI Concerns with historical design control for HCUs. ; .
50-461/96015-08 NOV Failure to promptly identify and correct the repetitive
failure of the diesel fire pumps.
,
1
.
PERSONS CONTACTED I
i j Licenses :
- W. Connell, Vice President
i P. Yocum, Manager - Clinton Power Station l D. Thompson, Manager - Nuclear Station Engineering Department i R. Phares, .Yr=c=r - Nuclear Assessment ,
J. Palchak, Manager - Nuclear Training and Support
D. Morris, Director - Radiation Protection
A. Mueller, Assistant Plant Manager - Maintenance
M. Lyon, Assistant Plant Manager - Operations
D. Antonelli, Director - Plant Support Services
J. Hale, Director - Plannmg & Scheduling )
M. Stickney, Supervisor - Regulatory interface
,
38 s
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* ;
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UST OF ACRONYMS ,
'
ABST Auxiliary Busiding Steam Tunnel
BWRT' Backwash Receiving Tank >
CR Condition Report ;
CRD Control Rod Drive
CST Condensete Storage Tank _ i
CW Circulation Water .;
DRP Division of Reactor Projects l
ECCS Emergency Core Cooling System !
Emergency Diesel Generator
>
EDG.
EWR Engineering Work Request
FCR Field Change Request J
FSAR Updated Safety Analysis Report (at Clinton) ;
FW Feedwater l
HCU Hydraulic Control Unit 1
-lDNS lilinois Department of Nuclear Safety 1
LLRT Local Leak Rate Testing
LOCA Loss-Of-Coolant Accident
LPCI Low Pressure Coolant injection
MEL Master Equipment List
MPT Main Power Transformer
NRC. Nuclear Regulatory Commission
PDR Public Document Room
RCIC Reactor Core isolation Cooling
RHR Residual Heat Removal i
ROC Redweste Operations Center i
'
RPT Radiation Protection Technician
RR Reactor Recirculation
SFDP Safety Function Determination Program
SGTS Standby Gas Treatment System ,
TS Technical Specification i
USAR Updated Safety Analysis Report i
Attachments: l
A. Enforcement Conference Presentation
'
B. Handouts of Presentation
!
.
1
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.4.
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Illinois Power Company
i
Clinton Power Station
-
Enforcement Conference Presentation
Februt y 4,1997
I i '
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AGENDA
.
Introduction W. Connell
Vice' President - '
- Clinton Power Station
Assessments and Recovery Plans P. Yocum
Manager-
Clinton Power Station
Procedure Adherence and Adequacy M. Lyon
Assistant Plant
Manager-Operations
i
50.59 Evaluations D. Thompson i
Manager-Engineering i
Concluding Remarks W. Connell
Vice President -
Clinton Power Station
-
.-. -. .. -. - - _. _.
_ _ . . . . . . -.
. . .. .- . - - _ - - - .. . .
s
.-
-
J
INTRODUCTION
. September 5,1996 Event was a Wake-up Call
. Thorough Self-Assessment
. Comprehensive Recovery Plan ;
- Startup Readiness Plan
- Long-Term improvement Plan -
. Safety as the Clear Top Priority ,
!
!
,
.
!
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-_ _-. .. _. - -
.
-
.
ASSESSMENTS
.
. Thorough Assessment by both Clinton Power Station and Outside
Groups
-
. Nuclear Assessment Department Evaluation of September 5 Event
. Root Cause Analysis of September 5 Event (INPO and Pil Assistance) . Independent Assessment of Engineering
'
. Nuclear Assessment Evaluation and independent Review
. Systematic Assessment of Clinton Power Station Performance
. INPO Human Performance Assessment
. Independent Safety Engineering Group Reviews
---____-____ _ _ _ _ _ _ _ _ - _ - - - _ _ -
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.; '
Summary of Assessment Results
i
. Nonconservative Operation and Oversight
. Procedure Noncompliances Due to Weak Standards and Enforcement
.
-
. Inadequate Planning of Complex Evolution
i
. Tolerance of Equipment Problems
. Compliance Problems and Non-Conservative Operation Not initially
Recognized
. Problems Cross Departmental Lines
:
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4
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e,e, - p. ,o-W n--m> ~ se A ,
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.
CPS Recovery Plan c
Nuclear
Assessment
Evaluation of
Sept. 5 Event
Startup Readiness
Root Cause Assessment
investigation of Undependent Pre-startup Checklists
Sep. 5 Event Performance a Redness
Startup Mehrs) Measures Cematon
Independent Readiness
Review Action Plan: q y
Y 'Y
= Conservative
' Decisions
v re n + Stadup
s me t of Imp e t rr a e Reviews Boards Approval
Engmeering Plan = Management
OversL3 ht
O
= Material O
.
Condition
NRC Special Confirmatory Hold Points
inspection + Action Letter and
and OSTI Response in-progress
Nuclear Assessment
Verification of Action Assessment
"
INPO Human
Performance
Assessment
Assessment of
Nuclear Nuclear
Assessment 4 Assessment
irrprovement
independent Plan ,
' '
Review Long Term
> Improvement
. Plan
Systematic i
Assessment j Management i
Comprehensive
of CPS a Progress Progress
Performance Reviews Review (6/97)
,
Application of r
Pil
1
r
>
ISEG Reviews
Technology
_
.- 2._ _ _ _ - . _ . _ - . - . _ . _ ___i.-. .- m ___ _ ._ - . _.. _ .- _ __ - ___u_______________-m. - _ _ _ _ _ +1 * e dv # *---T
. - _ . -. - . - -
,
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Recovery Plans
'
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- . Startup Readiness Action Plan
,
- Incorporates Results of Assessments as well as NRC Special
,
.
Inspection and OSTI
! l - Addresses Actions Warranted Prior to Restart
i
!
- Performance Measures and Formal Evaluation Process to Ensure
Readiness for Restart
- Deliberate Startup Plan and Approach .
'
. Elements of Startup Readiness Action Plan
! - Procedure Compliance and Adequacy
- Conservative Decision Making / Human Performance ;
'
- Management Oversight
- - Plant Material Condition
.
-. - - . - . - . - - - -
. ,
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A
l .
C
Startup Readiness Actior: Plan Status
, .
. Weekly Progress Meetings .
- e 40 of 53 Actions Completed and Verified
. Startup Readiness Assessment Results ,
e Gauged by Performance Measures
. Management Review Boards .
,
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___________________.___________________________________.m_.__
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_ _x____m m_____ -__m___ ______ _ _ ____ _ . _ . _ _ _ _ _ _ _ _ _ _ _ ___m -__ _____--_.
- .- .- . . . _ -. -
_
.
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.
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Lona Term improvement Plan
. Based on Assessments and NRC inspections
. Continues Efforts Begun Under Startup Readiness Action Plan
. Includes Performance Measures and Periodic Progress Assessments
. Comprehensive Progress Assessment
1 t
. - - - _ - - _ _ - - - - - _ - - _ _ _ . - - _ _ - _ - - _ - - - - - _----_-_-----_-.-_______-_-_-____-___-____.-___--_-._____-_--_...__L
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_
:. -
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Description of September 5,1996 Event
i
. Degradation of Reactor Recirculation Pump Seals and Plant Condition
. Management Decision to go to Single Loop Operation
. Previous Crew Simulator Training
. CPS Procedure 8.2.4: Idle RR Loop -Isolating
- Meaning of Asterisks in Procedure
- Decision to Perform Step 8.2.4.5
- Decision to Perform Step 8.2.4.6
i ! - Interaction of Normal and Off-Normal Procedures
.
_______ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ , _ _ _, _ . . ___
.
a
-
.
.
.
Procedure Noncompliance
. identified by September 5 Event, OSTl/Special inspection, and CPS
Assessments
- Root Causes:
Vague or Unclear Expectations
Lack of Rigor in Procedure Compliance
Weaknesses in Management Oversight
Inadequate Procedures
e
__ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ - _ _ _ _ - _ _ _ _ _ - - _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ . _ _
._ _. ._ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ . . _ _ _ . - . . .
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Corrective Action for Procedure Noncompliance
l
. Seminars for Operations Department and Other Key Site Personnel
and Management
i
- Conservative Decision Making
. I
- Lessons Learned from the September 5 Event
- Procedure Compliance / Adherence
- Operations Roles and Oversight Responsibilities
- - Review of Resultant Procedure Changes
.!
. Upgrade of CPS Procedure No. 1005.01, " Procedures and Documents"
.
i
,
. Upgrade of CPS Procedure No. 1401.01, " Conduct of Operations"
i
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Corrective Action for Procedure Noncompliance: Continued-
i
. Simulator Practice and Training
. Creation of CPS Operations Principles and Standards
- . Management Monitoring Program
* Revision of CPS Critique Process .
- - Condition Reports
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Inadequate Procedures 4
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. Root Causes:
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- Lack of Understanding of Procedure Adequacy Standards
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- Reliance on Tool Box Skills
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- Inadequate Guidance on Drafting of Procedures
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Corrective Actions For inadequate Procedures
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. Review of Policy Statements and Procedures J
- Conservative Decision-Making and Procedure Cohipliance
- Limited Review of Station Procedures in September / October 1996
. - Subsequent in-Depth Review of Operating Procedures
. Surveillance Procedure Review Process
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Failure to Perform 50.59 Evaluations
. Description of Violations:
- Cycled Condensate isolation Valve - Water Leg Pump Check Valve Action Plan -- Weekly Test of Water Leg Pump Check Valve Action Plan - CRD Pump Test .
. Root Causes:
- Lack of Understanding of Meaning of a Test
- Lack of Understanding of When a Safety Evaluation Must Be
Performed
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Corrective Actions For Failure to Perform 50.59 Evaluations-
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. New Site Procedure for Action Plans (now Coordination Plans)
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. Short Term Measures
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- - Training for All Reviewers
- Reviews of Previous Evaluations / Screenings
- In-Line Review by Specially Trained Core Reviewers
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. Long Term Measures
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- In-Depth Training
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- Audits
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Concludina Remarks
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. Corrective Actions Thorough and Comprehensive
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. Strong Commitment to Continued Self-Assessment'
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. Safety as Overriding Priority
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._ _. ._ .. . . . ~ . . . . , _ . . . . _ . - _..-.. -.......----- -- --. t, s ATTACHMENT B $"[$o'u'En*25tk sir 7ef :
1 o * P.O Box 511 i
Decatur. IL 62525-1805 :
'
Tel 217 424 7152
Larry O. Haab
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Chairman, President
and Chief Execut.ve Ofi cer
i d ~
December 16,1996
!
CUNTON POWER STATION EMPLOYEES:
i
As you know, the electric utgity industry is facing a great deal of. change.
To meet increased competition, employees have worked throughout the
! Company to chart a direction for making Illinova the best. We have ,
i
spent much effort this year communicating our desire to serve our
customers better, to practice teamwork, and to become more efficient. 4
All the while, we have said that safety is our first priority at Clinton
< Power Station.
!
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Perhaps our messages have been confused. On one hand, we have said i
! we need to be a low cost producer of electricity. We need to become i more efficient. We need to reduce our costs to become more
- competitive. On the other hand, we say we will operate CPS in a safe
and conservative manner.
Many high performing nuclear plants are both the safest and most
economic plants today. The key to their success is recognizing that safe
' i
and conservative operation of the plant comes first - because without
i a safe and conservative operating philosophy, the plant simply does not ! operate. ! l t would Eke to make clear my position. I am fully committed to operating i Clinton Power Station in a safe and conservativa manner. This has been I true in the past. It is true today. And it will be true in the future. ) '
Operating CPS safely and conservatively is part of making us the best.
Thank you for your efforts this year and season's greetings.
1
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Larry D. Ha'ab !
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AMemorandumfrom *" sum that Personnel are
ready to operate the plant .. ,' l
Wilfred Connell.... with a strons focus on -
,
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conservative decision making *
As i sat in my ornce recentiy, amidst many decisions .
and procedurai compiiance. 1 ,g, ;
cnd much activity at the Clinhn site, I glanced at Rich
Eimer's message in the last Energy Supply News. The
put that struck me was his comment that he has been in
Secondly, the plant material -
condition must support -
( - ('
restarting the plant. To put it
his position for ten months. Well, I feel quite qualined simply, we must be ready to .
,
to tell you that ten months can bring a lot of change and run the business, and the S.
challenge.
ne plant events of early September have changed my
business must be ready to be
run.
ylgn
views regarding where we need to focus our resources at
I truly believe that if the early September events had
Clinton. Prior to September, I was conGdent that we not occurred, the problems identined since that time ;
operated our plant quite conservatively, and I believed would have surfaced in some other way. We are i
we had a solid foundation from which to redesign our pursuing our two-phase recovery plan that addresses !
processes and become more efficient. Numerous issues
both the immediate actions needed prior to plant startup
have surfaced during and since the event that are making and the long-term actions that will strengthen areas for
me rethink just about everything we do at the plant. j
overall plant success. Both of these plans will focus on
A few weeks ago, I was confronted with a decision on procedure compliance / adequacies, conservative decision
how to address the issues facing us while undertaking an making / human performance, management oversight,
aggressive refueling outage. While I believe we have an and plant material condition.
excellent team working at this site, I also believe we The challenges of operating a nuclear plant in a
hive limits. I decided to extend the outage to allow competitive environment will not go away. However,
tdditional preparation time prior to some of the mcre
we will never become competitive without maintaining
complicated evolutions so we are mentally ready to do the highest nuclear safety standards possible. I have
the work. I also wanted to reevaluate the surveillance faith in our team and am confident we are taking the
program. This was the right thing to do. Ifit means we right steps towards becoming a leading nuclear plant. I
proceed at a slower and more deliberate pace, then that appreciate all the effort that each one of you in the l
is what we must do.
Nuclear Program is contributing. I am also grateful for
But while we are progressing through our refueling the many offers of assistance from the rest of you in our
4
outage, the outage itself is not necessarily my primary business group. Thank you for your continued support,
area of concern. At the present time, I am focused on
,
two overall issues that must be resolved before we will ^^j
rest:rt the plant following the outage. First, we need to #
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For employees of the Canton Power Staton
December 4, 1996
SPECIAl. EDIT 10ll
The Futureof ReenginsedngatCPS
;
After the increased leakage from the degraded reactor recirculation seal, our attempt to go to single loop
operation in early September, and the results of the NRC inspections which followed, many of you have
asked about the future of our reengineering efforts and Focus 2000. I would like to give you my answer.
4
Reengineering is radical. It requires a substantial investment of time and resources. And, if done well,
it promises great rewards in terr.is ofjob satisfaction, efficiency, and improved performance. suid that's
what we all want, right?
' But, before doing anything radical at a nuclear power plant, one must always consider the safe operation '
of the plant. We embarked on process reengineering earlier this year only after believing we had the
necessary attitude towards nuclear safety. We would not have started reengineering if there were doubts
cbout our conservative operating philosophy. Even when reengineering was in full swing earlier this year,
we continued to say that safe operation of the plant is our first priority...as it must be.
'
But, the events of the last couple of months have caused us to rethink the future of reengineering at
CPS. I believe that process reengineering is one tool we can use to improve at CPS. We believe that
continuing to involve workers in developing better ways to get the work done is the right approach, which
is what reengineering is all about.
110 wever, in light of recent events, we will approach implementation of reengineering a lot more ,
cautiously and more slowly in the future. When making decisions about reengineering, our first question
will be How willplant safety and conservatism be maintained or enhanced by movingforward?
The plans and schedules for future reengineering activities are being re-examined. Recommendations
regarding the future will be presented to me and the management team for consideration yet this year.
You will be informed as planning decisions are made.
We will continue our reengineering efforts only if we can ensure safe operation of the plant. This is
nothing new...but it is more resolute.
c(/ hw
Wilfred Connell
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PMSO - 084
MANAGEMENT OVERSIGHT INSTRUCTIONS
1.0 PURPOSE
To provide instructions and guidance to Management Oversight
personnel concerning their role in asspring the safe and
conservative operation of the Clinton Power Station. Management
Oversight personnel are management personnel not part of the shift
operating crew assigned by line management to observe plant
operations during special plant conditions or operations.
2.0 DISCUSSION
The purpose of Management Oversight at Clinton Power Station is the
assurance of plant operations in a safe and conservative manner that
protects the health and safety of the public, Illinois Power
personnel and the plant.
The Shift Supervisor is charoed with the responsibility for
maintaining the broadest perspective of operational conditions
potentially affecting the general public, Illinois Power Company
personnel, and the safety of the plant. Maintenance of this broad
perspective is the highest priority at all times. An intrinsically
conservative and prudent philosophy should govern the Shift
Supervisor's decision making activities. The Shift Supervisor
should never become so involved in any single operation that he is
unable to provide adequate direction to the shift crew when multiple ;
operations are required.
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Management personnel providing an oversight role must clearly
understand that they are to take a similar broad overview of plant
operations. They are to ensure that the Shift Supervisor is
maintaining the broad overview perspective and is not focused on a
single issue or problem. Management Oversight personnel should also
ensure that. management expectations regarding conservative
operational philosophy, procedural compliance, communications, i
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teamwork, annunciator response and safety focus are met.
Each person in the Main Control Room has a role to perform. It is
important to recognize that once a person assumes a responsibility
of a subordinate, he effectively relibves the subordinate of that
responsibility and assumes the role of the subordinate. The same
holds true of a person providing Management Oversight. Oversight
personnel must understand the details of the problem, but must not
get involved in the details of the problem solution.
I
ILUNOIS POWER COMPANY
DOCUMENT CONTROL
OCT 0 41990 I
7 Page No. 1 of 3
h POWER STATION Rev. No. 1
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3.0 DEFINITIONS .
Management Oversight is defined as the monitorin'g of plant
operations by assigned management personnel who are not members of
the shift operating crew.
4.0 DIRECTIVE
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4.1 The Manager - CPS or Assistant Plant Manager Operations will brief
management personnel on the requirements of this PMSO prior to each
assignment to a Management Oversight role.
4.2 The following actions are appropriate for a person filling the role
of Management Oversight:
*
Obtain a situation briefing from the Shift Supervisor.
*
Make presence known to the operating crew.
*
By observing activities in the Main Control Room, ascertain
that group dynamics, communications, command and control are
. appropriate for the situation.
*
Ensure the crew approaches problem solutions by using proper
problem solving techniques, including input from all crew
members.
*
Communicate concerne to 'the Shift Supervisor outside of the
Horseshoe area.
*
Maintain independent viewpoint oriented toward prediction
rather than reaction.
*
Ask questions and confirm that the Shift Supervisor's decisions
are appropriate and in keeping the Station's conservative
decision making policy.
*
Provide management direction and guidance to the Shift
Supervisor on site level issues, as appropriate.
*
Alert the Shift Supervisor and line management to situations in
which the broad perspective is not being maintained.
*
Maintain an oversight role until the responsibility is formally
. turned over to a replacement, or ended.
Page No. 2 of 3
Rev. No. 1
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The following actions shall be avoided by the person providing the I
Management Oversight function:
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Involvement in the details'of a problem, including long i
discussions of options with the Shift Supervisor if it
distracts him from his oversight role.
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Involvement in the performance of shift activities.
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Interference in direct plant operations. t
* Giving direction to the shift crew.
"
REFERENCES
Nuclear Policy Statement No. 7
USAR - Chapter 13
CPS No. 1001.05, AUTHORITIES AND RESPONSIBILITIES OF REACTOR
OPERATORS FOR SAFE OPERATION AND SHUTDOWN
CPS No. 1401.01, CONDUCT OF OPERATIONS
c CCT No. 064398
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Originated By-
Reviewed By: / ve
Approved By: '
Effective Date: / 4 - '/' -
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Rev. No. 1
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Clinton Power Station
. Operations Department Table ofContents
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Principles and Standards
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Introduction 2
i Mission 2 .
< LMph 2
Principle 1-Safety I 4
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Nuclear Safety 4
Conditions Adverse to Safety 5 ,
RadiologicalSafety 6 l
IndustrialSafety' 6 l
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Principle 2 - Compliance and Adherence 7
Procedures 7
ITS/ORM 7
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Principle 3-Ownership of the Plant 9. .
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Procedures 9
d
Plant Equipment and Areas 9
Monitoring 10
i Station Logs 11
Command and Control 12
3 .
* Principle 4-Pawfessionalism 14
4 Personal Accountability 14
Operating Discipline 15 i
Vital Operating Skills 15
Verification Practices 16
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ShiftTumover 17
Communications 18
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Principle 5-Leadership . 19
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Operations Standards -
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Station Management 21
All Operations Personnel 21
ShiR Supervisor 22
Line Assistant ShiR Supervisor 23
,
ShiR Resource Manager 23
Reactor Operator 24 -
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Rod Verifier 25
ShiR Fr.pr_x, Technical Advisor '25
Nuclear Equipment Operator 26
MCR Formality 26
*
Annunciator Response 27
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Cli2tos Pow:r Station I trod:ctica
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Operations Department Mission
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Principles and Standards Principles !
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INTRODUCTION
' Mission
- Our mission, as the Operators of Clinton Power Station, is to operate the plant in a
i professional mannar with a commitment to safety. By operating with a commitment to
safety, we will achieve reliable operation of the plant.
i
PRINCIPLF.S
J In the performance of this mission, we use five important principles to guide our actions.
,
* Safety - Our highest priority is to maintain nuclear safety to protect the health and ;
i safety of ourselves, er co-workers, and the public. Nuclear, personnel and
'~
radiological safety are inseparable. Safety and quality have clear priority over
- production, schedule and co-t.
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e Compliance and Adherence - As operators of a nuclear power plant we are required
to adhere to administrative controls to ensure safe and efficient operation of the plant
and to comply with our license limitations and all other regulations.
e. Ownership of the Plant - Operations owns and is responsible for the plant. It is our
,
responsibility to ensure procedures, equipment and . plant operating spaces are w maintained in the highest quality condition. We must identify and prioritize
'
deficiencies and ensure corrective action is pursued until the issue is resolved.
j e Professionalism - We must hold ourselves to the highest standards of performance
- and personal ir.tegrity to ensure the plant is operated safely. We shall constantly
challenge ourselves to achieve error-free operation. As nuclear professionals, we will
project the pride, positive attitude and confidence that displays our skills and training.
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i e Leadership - We must set the example and pmvide direction to achieve excellence in 1
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Operations. Our efforts will result in our becoming the leader in the industry.
With the exception of safety, which is our highest priority, these principles are ranked in
no particular order. 'Ibese principles complement each other in achieving the high levels
of success required of all CPS employees. Station ownership and work ethics define our
daily work activities. During the performance of these work activities, we use the l
principles of safety, compliance and adherence, ownership, pmfes-ionalism, and j
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leadership, to teach our goals in the desired manner. !
The Operations Department Principles and Standards should be used as a tool to identify
and communicate our own expectations as the operators of CPS. These standards are
intended to be living standards, and as such, are expected to continuously evolve to raise
.
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Cil:tos Pow;r Station I trod:ctio2
Operations Department Mission
Principles and Standards Principles ,
CPS to a level of perfonnance better than that of the industry's best. 'Ihis manual is to be
used in conjunction with CPS procedures. Those procedural controls me in no way
superseded by any of these requirements.
.
As a member of the Operations Department, acceptance of the challenge to achieve these
principles and standards is required.
_
Michael,W. Lyon f Russ Bedford#'
Assistant Plant Manager - Operations Assistant Director- Operations
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John P. Earl P. T ung W
ShiftSupervisor Assis@tantShipSupervisor
. GI -
a Kennetfi W. StieffWid ffrey G. Gerard
Reactor Operator Nuclear Equipment Operator
- ManualOwner
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- Operations Department Safety
Principles and Standards
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PRINCIPLE #1 - SAFETY L
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Safety, be it nuclinr, radiok gical, or personnel, is the number one priority in operating ,
i ('llatan Power Station. 'Ibese three aspects are inseparable. Safety and quality have clear ;
priority over pr4% schedule and cost. ' Ibis approach minimimaa the ultimate long- ,
,
' tenn cost. Our safety and the safety of the public are of paramount importance within the
Operations Department. In all cases, safety is everyone's job and everyone has the
i murharity, responsibility and duty to maintain safety. Suw=Gug this principle are the
following standard <,: ,
NUCIZARSAFm
* Nuclear safety shall be maintainad by placing the highest levels of control and j
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monitoring over any activity that could affect reactivity, fuel p.e = 2--6 power, ;
! reactor pressure and inventory, or involve the potantial release ofradioactivity. l
4
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1 = All activities shall be conducted in a manner that ensures the Line Assistant Shift i l Supervisor (LASS) has command and control. All activities are conducted under i
- positive control What is *-*M to happen is the only thing that happens. When
"
positive control is lost, the process is stabilized, then stopped, until positive control is
-
regained.
* * The plant work schedule shall not place the operating crew in a position in which
combined effects of multiple evolutions can have adverse effects. If plant conditions
! change, the LASS is responsible for preventing incompatible evolutions. 'Ihe LASS
. shall always have the ability to prevent conditions adverse to nuclear safety unsed by
' '
multiple evolutions.
* Reactivity is changed on'y in a conservative, deliberate and controlled manner. All
- sctione and variables that have the potential to affect reactivity and core power are
- understood, monitored and controlled. Any unplannad, mWM or adverse events ,
involving reactivity, power distribution, their control or their meast.rement are
i considered to be reactivity management events. Such events are serious events
i
adverse to nuclear safety. They shall be promptly investigated and actions taken to 4
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prevent recurrence.
!
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e Conservative Operational Decision Making shall always place safety before !
- production or cost. 'Ihese type of decisions are a-tM and consistently supported
by managamant Conservative Operational Decisions are: risk averse, timely, favor
- caution over boldness, based on the best available information, involve team input,
consider additional barriers and anticipate the na=nar*M Operators' decisions shall
consider potential risks and strive to maintain margin from plant limits. Operators
.
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Cli tos PowerStation Principb #1
Operations Department -
Safety
Principles and Standartis
will continually reevaluate decisions made previously by themselves and others to
ensure that appropriate limits and margin to the limits are maintainad
* It is each ofour responsibility to assure that the scope of the task, its overall objective !
-
and potential problems are known and understood. None of us shall proceed with a
,
task or activity with any doubt about what the WM outcome or possible
consequences will be. ,
* Operations recognizes that per d must make decisions on a real-time basis with
the available information that is on hand. 1
0 Reactor Operators are authorized and expected to take timely appropriate
conservative actions, iW% reactor scram, to protect the plant. l
0 In general, Reactor Operators should manually indate a reactor scram when i
they find themselves in a situation that jeopiud!L. a safety function, is out of
positive control or appears to require extraordinary intervention to recover.
'
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O Reactor Operators are authorized and er;-*M to manually actuate any
protective device immadiemly when the setpoint for the protective action has
been e=adad by the corresponding process indication or when the operator
is confident the setpoint will be passed.
0 'ihe Reactor Operator should fully communicate his concern to otlier shift
perwnnel to involve them in the decision process unless time-critical actions
, are needed. ,
CONDmONs AnysaSE To NUCLEAR SAFETY
hi spite of efforts to the contrary, things sometimes do not go as planned. Adverse 1
'
experiences must be dealt with appropriately and used as improvement opportunities.
* Any hazardous condition to perwnnel or degradation of plant equipment that may
- reduce unit availability or safety margins shall be reported to the SS immediately. .
>
* Conditions adverse to nuclear safety are corrected or interim compensatory measures
are deployed to restore adequate margins of safety.
* Interim compan==tary rocasures shall have a dermed lifetime.
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* Interim M- g==wy measures shall be continuously challenged to ensure conditions
adverse to nuclear safety have not become accepted.
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Clintos Power Station Pri cipl3#1
Operations Department Safety
Principles and Standards
RADioWGICALSAFETY I
e it is the responsibility of all of us to protect the public and minimim the release of
radioactivity.
E
e We shall communicata changes in system status which may change plant radiological
conditions to RP g+:==!
* We shall respect even small amounts of radiation.
* We shall comply with all radiological work controls. l
. We shall closely follow procedures and other administrative requirements to .
minimi= personnel dose. I
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INDUSTRIAL SAFKrY
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* .We shall set the example for safe work practices. We will be alert for unsafe
conditions and enforce safe work practices ilueughout the plant.
, . * Tagouts protect personnel and prevent equipment damage. We shall maintain an
uncompromising standard of adherence to all tagout procedure requirements.
r,
e No safety rule is a complete substitute for common sense. Judgment will be used in *
, every work situation. We shall approach every task in a safe manner which will allow
- us to go home at the end of each work day in the same condition as we came to work.
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e We shall comply with all company and site personnel protective equipment
! requirements. ! - l
* We will demand excellence in plant he-%ing and cleanlinana from ourselves and ,
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Clinton Power Statio2 Prizeipb #2
Operations Department Compliance and '
Principles and Standards Adherence
PRINCIPLE #2 - COuruANCE AND ADHERENCE
Operation of Clinton Power Station is governed by the conditions set forth in our license
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and the actions prescribed by our procedures to safely operate the plant.
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PROCEDURES
e Operating procedures are written and iesd to assure maintenance of our safety
margins and to minimi= challenges to the plant, personnel and equipment. Plant -
operating or system conditions may not support the perfonnance of the procedure as
written. These conditions should be ra===i=d prior to b=ianing the evolution, and in
these cases, the procedure will be revised or supervision will authorize non-performance
of selected steps or sections as authorized by station administrative procedures.
When difBeul*ies are encountered during the execution of an evolution and procedures
must be changed, caution of the highest level shall be exercised, to prevent reductions in
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safety trargins.
e Procedure review is required prior to performing an evolution.
O Procedures shall be verified to be appropriate to accomplish the task required.
* Compliance with procedures is required.
* When difficulties are encountered using a procedure:
0 Operators shall stabilize the task and consult supervision.
O An appropriate change to the procedme shall be performed as necessary.
O The evolution shall not re-commence until the operator is 100% sure the change is
correct for the required task.
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- * Procedures are followed with ' alertness, thoughtfulness, and questioning of all actions
and responses. The user understands the intent and anticipated i+r.r.doutcome of ,
each step or action.
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IMPROVEn TECHNICAL SPECmCAMONS (ITS) AND OrgaAMONS REQUIREMENTS
MANUAL (ORM)
Operations department personnel shall review and comply with ITS and ORM
requiremente during all phases of plant operation. Operators must develop the practice of
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reviewing the 113/ORM prior to execution /ini.dyulation of plant activities or equipment.
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* All licensed operators are responsible for complying with the ITS/ORM.
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CliIto2 Power Statio2 Pri cipb#2
Operations Department Compliance and
Principles and Standards Adherence :
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* The SS sball be notified prior to i Rs li.g any activity that could cause not ir4 l
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a f imi*ia: Condition for Operation (LCO), and shall be notified immadiataly if an
LCO is not met.
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* As a routine iwe.ctice, we shall be prepared for and understand the consequences of
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my an LCO/OR action prior to entry into the action. 'Ibe only exception to this
is the result of unanticipated plant transient or equipment failure.
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e 'Ibere should be an independant review of situations requiring entry into LCO actions
to enrure the correct LCO actions are entered. l
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* The SS shall be involved for difficult w ing e decisions. i
e Repeat entries into LCO actions shall not be used to effectively bypass ITS
requirements. *
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Clinto2 Pow:r Statira Pri ciple #3
Operations Departenent Ownership of
Principles and Standards the Plant
PRINCIPLE #3 - OWNERSHIP OFTHE PLANT i
We, as the Operations Department, own the plant. The pride and responsibility of !
. ownership is an essential ingredient for station operations. Plant ownership includes
problem ownership. We M'y dc6ciencies and take corrective actions that are
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appropriate. We involve supervision and pursue ruolution of the identified de6ciency.
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PROCEDURES .
Operations Pmcedures govern system operation, Technical Specification operability -
testing, Lt ,4 plant operation, alarm response actions, off-normal condition response, '
emergency response and m<iministruive controls. Maintaining these documents to the ;
highest level ofquality is the responsibility of each operator.
. System experts are expected to work with the respective system engineer, procedure l
writer and operations trainers to maintain their assigned procedures and help i
communicate procedure change impact and significance to the department.
* All operators are expected to document procedure deficiencies and pursue either an
immediate resolution or routine update as appropriate for the circumstances.
PLANT EQUIPMEPfr AND AREAS
# The quality of the plant materiel condition is directly proportional to the plants margin of
nuclear safety. We shall not accept plant materiel conditions that challenge the margin to
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nuclear safety or our ability to safely operate the plant. We will:
. Identify plant materiel problems. Pursue problem investigation to obtain as accurate
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an understanding of the condition as practical for the circumstances.
e Report conditions to supervision for assistance in evaluation and compensatory
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actions as nanaa<ary. Involving supervision does not relieve individuals of problem .
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ownership.
. Denmant deficiencies in the appropriate operator logs, on Maintenance WoA
Request (MWRs) and/or Condis ,n Reports (CRs). Dc-station shall be in a clear
precise manner and contain sufYlent information to assist in:
0. Amaaaamantofplantstatus.
O Root cause and corrective action determination. !
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O Development ofjob steps for trouble shooting and repair. ;
* Pursue resolution of deficiencies by placing proper focus on priority. Ensure the
proper focus is maintained on resolution of workarounds and Main Control Room
j . (MCR) deficiencies.
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l . . j . . . I: , i Clixto2 Power Statios Principle #3 t-
Operations Department Ownership of
Principles and Standants the Plant
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. Ensure the equipment and work are acceptable, per our standards, for retum to
i service.
i e MoNrrORU4G ,
Ownership of each of our w=*che*=tiana is a===ti=1 and anything occurring within it is
- our businosa, Thorough tours or observation ofcontrol panels will provide early detection
1 : of abnormal conditions. Good monitoring techniques require the use of all senses,
awarawss of change, good systems ud component knowledge levels and time. A vital -
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rr;,ponsibility is to properly conduct reqM rounds that include accurate and timely
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observation, sw4 and, if appropriate, reporting.
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e We shall perform rounds immediately aSer shift turnover, unless otherwise directed,
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to allow fori<tantification ofpossible pmblems early in the shift.
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e We shall scrutinize the plant during rounds and at all other times when in the plant to
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. identify and/or rectify deficiencies and abnormalities.
e Tours shallinclude:
0 Wiping down equipment to facilitate leakage trending.
O Noting and reporting scaffolding and other portable equipment.
O Ch~+ing walkways and doors clear of obstructions.
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* Tours will include all areas on a watchstation r.pbu of log-taking requirements;
however, radiological conditions and ALARA me will be given consideration.
* We will remain aware of all events occurring within our assigned areas of
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responsibility.
Establishing a baseline with all senses for how a component or system responds and ,
monitoring for any change are the essence of good watch -'== ling practices. Baseline
conditions and plant response change with various component alignments, different
' power levels and different environmental conditions. In addition, we initiate change
through deliberate Operator actions. All changes are carefully planned and, once
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imphat carefully monitored to detect i&~I risks and outcomes. No risks are
taken inadvertently. We not only recognize change when it occurs, but also anticipate
change.
* Critical parameters are important operating properties that must be controlled to avoid
equipment failure. It is incumbent upon us to frequently observe critical parameer
indications, compare them with established boundary values, and respond to
, abnormalitiesindicated,
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Clinton Power Statio3 Prirciple #3
Operations Department Ownership of
Principles and Standards the Plant
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We shall maintain hoM% standards and demand the same standards of others. ,
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* We shall monitor conditions for any changes and aggressively pursue why a change
has occurred.
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* ' We will increase monitoring of equipment =vM of abnormal behavior, potential
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malfunction or operated under abnormal conditions. We shall resolve and document *
identified problems. .
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* We are prepared to respond to anticipated changes in plant operating parameters. We
identify contingency actions when :..:165 change. AAer * .JG.Gug a change we
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shall monitor for WM and un== *M iegense.
. We understand the consequences of component manipulations. We take the time to '
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conduct pre-job briefings to ensure team understanding of what to do, what to expect, '
and what to anticipate, as well as needed support.
STATION Locs
i Shift logs and doctunentation are legal, narrative, chronological records of performance
e at CPS. They help provide continuity of control by permitting operators to review the
events of previous shifts. They convey information and alert others to problems. Many
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people mistakenly think of a log as their own. His leads to entries that are based on
varying levels of experience or knowledge. But logs really belong to the watchstation, of
which the individual is merely a custodian for a short period of time. To really
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understand the relevance oflogs, we must become a historian and try to recreate an event
in time based solely on what was written down about that event. Without this historical
recofd of performance, we must rely on conjecture, assumptions, and logic to ascertain j
what happened. nese logs: )
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e Are timely, complete and concise written statements.
* Provide a picture ofwhat happened.
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* Shall answer the questions:
0 - What was done?
O When was it done?
O Why was it done?
, 0 What was the outcome ofwhat was done?
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Clintos Pow:r Statin Prizeipla #3
Operations Departinent Ownership of
Principles and Standards the Plant
* May answer the following questions as situation:: require:
0 Where wasit done(ifnot obvious)?
0. Whodidit(ifnotobvious)? l
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Describe activities surmanding any deficiency to provide as much information as
possible.
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COMMAND AND CONTROL l
Another integral part of our efforts is Command and Contml. Command and Control
manna making sure operations are accomplished successfully, especially if they. affect 1
reactivity, fuel psm., reactor pressure and inventory,' or involve the release of '
radioactivity.
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The Shift Supervisor (SS) shall be responsible for the control room command function.' ,
The SS should report to the MCR and remain in a monitoring role during off-normal i
operation unless the SS d@ !== the Line Assistant Shift Supervisor (LASS)is not able
to deal with the situation. In such a case, the SS shall assume the Contml Room
Command Function and direct the control room staff. This would be an extraordinary !
situation, and it is expected that in all but extreme cases the SS should remain in a 1
monitoring mode ensuring that required tasks are being directed by the LASS.
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e The SS is required to maintain a broad perspective of operational conditions'and is
not to be encumbered with excessive administrative duties that can be performed by
other departments or staff. Maintenance of this broad perspective is the highest
priority at all times.
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Decisions shall be governed by a conservative and prudent philosophy.
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The SS maintains a review /appmval role.
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The on-shift SS shall have the authority to organize resources to accomplish the I
overall safe activities ofCPS.
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The LASS acts as Command and Control for operating the plant. The LASS must be
aware of all evolutions and monitor the evolutions for their desired res.ilt. Even during
routine evolutions, the LASS provides a check that " things are going right."
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The LASS :shall direct the Reactor Operators and Non-licensed Operators in
manipulation ofplant systenu to combat the casualty unless relieved by the SS.
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Clinton Power Statio2 Pri cipla#3 l
Operations Department Ownership of
Principles and Standards the Plant
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* & LASS shall uphold the Operations Department Principles and Standards for the i
personnelin the MCR. l
: * h LASS shall maintain order and tiecorum in the MCR.
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. Command and Contml must be visible. W standard for the Operations Department is !
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. error-free perfonnance.
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Clinto2 Power Statiom Prizeipla N l
Operations Department Professionalism 1
Principles and Standards
PRINCIPLE N - PROFESSIONAIJSM
'Ihe idea of professionallem is more than knowing how to do a job. It is an attitude and
can be the key to job perfonnance and ==tief=<dian Professionaliern is also the image we
strive to project. Many attributes contribute to professionalism. Included are:
I e- A positive attitude that reflects pride in the performance of operational activities,
personal appearance and sense of plant ownership (m' cluding identifying and
WJug responsibility for plant problems.)
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e ' A commitment to Wag only the highest standards of both personnel and
equipment performance.
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e Credibility supported by knowledge of procedures, Technical Specifications, station l
policies, and regulatory requirements.
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* Acemtebility that includes the performance of self-checking to ensure confidence in l
the quality and accuracy ofour work. !
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Teamwork encouraged through open communications, cooperation, trust and respect.
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a e ' A willingnans to accept, without defensiveness, feedback from internal and external
sources.
PERSONAL AccotwrABILrrY
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Professionalism includes personal accountability.. All of us, as members of the
Operations Department, are responsible for our individual and crew operating
performance. Personal accountability is:
} e The initiative to make sure the job gets done right.
* Knowing how important ourjob is to the overall missio$
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* Challenging those who do not meet our standards. l
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Sharing factual knowledge of goals, standards, plant and equipment status, not rumors
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Maintaining a professional and respectful relationship with other departments.
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Clirtoa PowerStation PriIcipb #4
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Operations Department Professionalism '
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Principles and Standards
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. Maintaining a professional personal appearance. i
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. Striving to alwaysimprove.
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Our work ethic damands the performance of our duties to the best of our ability and with
high personal standards of honesty and- * .;,,,ity. As Operators, we strive to exceed ;
i established performance standards in all of our duties. In order to be effective in the
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performance of our duties, we utilize three-part communications that are clear and simple,
i and establish command and control methods that are direct and provide protection from
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error.
OrzRAUNG DIscams
l Even in the best teams, complacency and !='--y aft-tion to detail can subtly creep
- into the operating environment. Perhaps the most important trait of truly great operations
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crews is their commitment and vigilance in avoiding complacent operation.
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- The best crews
$ = Have well-rh.ed, clearly defined operating habits and roles that are performed
relentlessly, day-in and day-out, even when it seems unimportant to do so.
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. Are committed to continuous performance improvement, both as individuals and as a
i team.
* Have learned that continuous improvement is achieved through review by themselves,
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their peers, and theirleaders.
. .Have teamed that solving complex problems is often a team effort, relying heavily on )
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i evaluative communication. . ,
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. VrrAL Orr.aAUNG SKHM
. In order for Operations to mW each of us must practice the following fundamental
skills of process and equipment control for a systamatic approach to nuclear power plant
operation. ;
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l Each ofus must be able to: I
* Conduct pre-job briefings.
* Understand and use operating policies and procedures.
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CIhto2 Power Statio2 Prirciple #4 i
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Operations Department Professionalism
^
, Principles and Standards !
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* Monitorcriticalparameters.
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* Performindependent veri 6 cation.
. cammuniassa essemial plant information.
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e Keep logs and record data clearly, completely and precisely.
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* Rext L and respond to ' quipment
e abnormalities.
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e Combat equipment emergencies and casualties.
* Oversee == int , modification and testing.
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* Isolate energy hazards.
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j e Train on-the-job. 4 * Perform shiA turnovers.
* Take responsibility for resolving identified deficiencies.
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VERWICATION PRACTICES
l Any individual, no matter how proficient and conscientious, can make a mistake. It is i
expected that all evolutions and activities shall receive some level of verification. The
. techniques used at Clinton Power Station include self d+Mg (using the STAR
, process), double and m ' dependent verifications.
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SelfchW is a personal accountability behavioral practice. It is an Operations goal to ,
- ' make self-sdisg an ingrained, automatic behavior. Use of this process promotes a
heigh *W level of attantion to detail and tninimisma mistakas - 'Ibe STAR process is a
work practice consciously and deliberately initiated by an individual before, during and
aAer performance of a task.. It is visible and easily mi=1 by others. 'Ibere are few,
if any, caeos where we do not have time to perform an adequate self-check. We must
remember, the above self. check process (STAR) is intended to be a continuing sequence.
Ifinterruptions occur during this sequence, then we will start over.
* Stop Identify the item to be manipulated / worked by:
0 Pausing before performing to enhance attention to detail.
0 Eliminating distractions.
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Clinton Power Station Principia N
Operations Department . Professionalism >
Principles and Standanis-
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* Think Consider the indandarl and expected nsponses by: !
0 'Ihinking about the task.
0 Understanding what is to be done before manipulating any equipment.
0 Askingyommele
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= Areyoupropmed? ,
, o Do you have sufficient instructions? '
= Have the prwious steps been completed?
= Have possible contingacies been considered? *
= Isit safe to perform this task?
. Act Manipulate theitem by:
0 Identifying the device by placing a hand or finger on it (if possible).
O Comparing the idaneirvarian label to the procedure.
O Physically performing the action without losing the hand contact
antahlinharl earlier.
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e Review Observe the results by:
0 Revk4 the response. .
O Being alert for any'vM response.
O Being prepared to take action based on previously considered
contingencies.
* 0 Ensuring the action was successfully performed.
0 Ensuring the actions are conservative.
Management expects each task to be done right the first time. We are all expected to
check our work before, during and aAer execution. Self hking is an integral part of
every task.
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i SurrTURNOVI.R !
. Shift turnover is a critical part of a continuous watch-standing sequence. It is the
exchange of pertinent information betw off-going and ona:oming crew members, as
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well as interim watch relief. It is important that turnover be a complete and accurate
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exchange ofinformation.
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A period of quiet time or low activity should be enforced, following shift brief, to
- accomplish turnover without distraction.
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, Quiet time shall be of sufficient duration to a'llow a thorough exchange of
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information.
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Clintos Power Station Principia #4 i
Operations Department . Professionalism i
Principles and Standards !
e h "B" Reactor Operator (RO) shall tumover to all oncoming control room
vtars, followed by the off-going "A" RO turning over P6g0 to the on<:oming "A"
RO. l
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e Changes in watch standers shall be communicated to the Line Assistant Shift
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- Supervisor.
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- e Changes in Command and Control shall be clearly communicated to the control room
team and acknowledged.
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- COMMUfGCATIONS
Verbal communications play a significant role in everyday operations. Good
, communications help to avoid unsafe or ambiguous conditions. All communications are ! ! canducted with scrupulous integrity; inferences, presumptions, and extrapolations are , labeled as such. Every team member's word is absolutely reliable. '
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Informal conversation is part of a normal work environment and is neled to discuss and
! understand activities. Formsl communications shall be used when direction is being
provided to operate plant equipment, when iepordug critical plant information and during
abnormal operations. Elements of formal communication include:
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- e Three-part communication based on the following principles
0 The sender of the message has the attention of the intended, receiver prior to the
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beginning of the message.
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0 The message is concise and accurate. !
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0 The message was received and repeated back with technical content intact. i
0 The sender provided feedback to the receiver regarding the accuracy of the
_ message.
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. Canmunications shall use accepted standard terminology, as defined by the plant
operating procedures. _
e A higher level of awareness is needed when communication is with other
departments. Formality of communications beria operators and non-operators are
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conducted to the same standards as for operators communicating with each other.
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All of us should i+x-yha that standard technical terminology may not be clearly
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understood by non-technical depi.uocats or groups, and it is our responsibility to ensure
) the message transmitted is understood.
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Clixtom Pow:r Station Prirciple #5 ;
Operations Departinent Leadership i
Principles and Standards ;
PRINCIPLE #5 -12ADERSEP I
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# ~ ij_. , All of us in the Operations Deparenant will ensure a high level of plam and individual
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performance through effective individual and team leadership and a commitment to ,
, excellence. All of us expect and accept nothing less than full accountability for the !
success of each work activity. Imders in the Operations Department, regardless of i
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c'--- T =d=. provide the example and encourage a sense of pride in operations, a sense
of ownership of the plant and the commitment to accept only high standards of -
performance.
All of us in the Operations Department are WM to act as site leade. As such, each
of us should strive to improve the following leadership characteristics:
e Vision - Iaaders see the whole picture and articulate that broad perspective with !
others. By doing so, leaders create a common purpose that mobilizes people in the
Operations 46 cat and cou Aww their efforts into a single, coherent, agile
enterpriae. His vision extends across dep-em.as.
i s * Trust - Without trust, vision becomes an empty slogan. Trust binds people together, l creating a strong, resilient department. To build trust, leaders are predictable, sharing
- both information and power. The goal is a culture of candor.
e
* Participation /reamwork - The energy of our department is the effort and
participation of the people. The leader's challenge is to unleash and focus this energy,
i inspiring people at every level of the Operations department to pitch in with their
minds and hearts.
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e Learning - Leaders need a deep understandmg of themselves. Rey must know their
shortcomings, which requires a lifelong process of discovery, and they must be able
to adapt to new circumstances. So too with the Operations organiintion. . It must ,
i promote constant innovation, and the leaders must encourage their people to refresh
their skills and renew their spirits.
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e Diversity - Successful leaders know the power of diversity and the poison of
. prejudice. Bey understand their own biases, and they actively cultivate an 4
appreciation of the positive aspects of people's differences. In Operations, we insist
on a culture of mutual respect.
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Clinton Pow:r Station Principb #5 ~
Operations Departinent Leadership
Principles and Standards
a Creativity - In a world where smart solutions outpace =Mve wodt, creativity is
crucial. Ienders in Operations must pay close attention to individuals' talents,
leaning on their strengths and managing around their w=h Leaders encourage
3%. challenging 'hiaWa-sand they invest in the technologies that facilitate
the efforts of theirpeople,
f
* Integrity - A leader in Operations must stand for dia . As a public citizen and
a private person, he/she knows what-is important in life and acts by 4W .
principles. Every wise leader has a moral compass, a sense of right and wrong. Good
leaders understand that good ethics is good business.
* Community - Community is mutual commitment, and it inspires the highest
performance. It is human nature to go the extra mile for one's co-workers and fellow
employees, and a mature leader stresses the organization's responsibility to the
surrounding Sm.cr.ts. A leader also acts as a steward of the natural environment.
*
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Clintom Power Statio2
<
Operations Department Operations
] Principles and Standants Standards i J
OFF. RATIONS STANDARDS
, ' Ibis section contains standards which did not tie directly to one of the five principles.
; 'Ibese standards may tie strongly to more than one p.'. dy.e, or may just be an item that
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m.yyu.. the department mission.
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STATION MANAGEMEFfr -
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; * Will arnwre to and support the standards listed above. !
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* Will clearly communi.cate additional expectations not found in this d==ne
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- * Shall support prioritization of work naadarl by Operations through the use of the work !
week schedules and daily planning meetings.
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* Will keep the Shift Supervisor informed of Nuclear Amaaaament reports, signi6 cant
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safety review group issues, knportant indsby operating events and issues, and
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p decst results of CPS iaWon activity.
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* Is committed to a standard of full on-shift manning.
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ALL OPERATIONS PERSONNEL
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* Must be satisfied they have received and understood unit status, equipment problems,
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previously noted trends, and evolutions in progress prior to taking the shift. Once on
l shift, we are responsible.
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* Shall reinforce good practices and adherence to standards, as well as coach others to .
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! improve performance which does not meet our standards. We will encourage each l
other and operate as a team. . .
* Shall answer telephones by stating station or title and name.
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! * Ensure the ans is clean and equipmsat put away before ded.dsg the work complete. I -* Do not accept low standarda from anyone in or outside of the Operations Department. ! * Shall be on time for scheduled training. While in training, opemtors will maintain a ,
professional appearance and attitude and will help to maintain the training facilities
. neat and clean.
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Operations Department Operations
Principles and Standards Standards
i * Are accountable for knowing the content ofinfonnation presented in training whether
requalification or departmentally related.
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SurrrSurzavison ,
' * Leads the station by focusing site-wide attention on Operations priorities.
.
. * Ensures '. hat a thomugh and meaningful pre-shift briefing is conducted, which
includes cafety, priorities, and - ;+M+ns for the shift.
1
1
* Monitors pre-job briefings of major evolutions to ensure the proper focus is !
4
maintained on personnel and nuclear safety. )
'
!
* Works closely with Training management to ensure operators are getting the level of I
t Lisg neaw to be able to perform to the highest standards. This includes feedback
on content and style ofdelivery. The SS:
0 Monitors operator perfir.mance in the plant and provides input to scheduled
. requalification training.
O Monitors scheduled initial and requalification training and provides feedback to
the Training department and instructors.
. a: 0 Monitors on-thejob (Oyf) training and provides feedback to the trainee, trainer , and the training deg m' .ent
* Owns the performance of his crew during training weeks. The SS:
0 Sets eqectations for crew performance at the beginning of the week and reviews
'
results with the crew at the end of the week.
O At the beginning of the training week, reviews with the crew performance
, _ problems observed both during training and plant operation.
O From performance observed during the training week, develops goals for desired .
-
improvement during plant operating shifts.
. * Focus on standards implementation, as well as input received from any other source
to encourage continuous impmvement with the crew.
* Is a role model for excellence in speech, actions, demeanor, and standards.
* Is a ch ybn of the Operations Department Principles and Standards to strive for and
achieve excellence.
.
page 22
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Clintoa Pcwer Station
Operations Departinent Operations
Prine'ples
..
and Standards Standards l
l
'
. Spot checks operator performance during evolutions and ensures that Wadons am
beiv met.
l e Anticipates upcoming activities and ensures resources and personnel are available and ,
applied to.iccomplish thesn.
1
i e Maintains the SS journal in a way consistent with Operations log-keeping standards.
* Conveys mangement initiatives to his operating crew.
* Rem. sins on-duty until the oncoming crew has completed the pre-shift briefMg. l
l
e Shift Supervisor relief shall be announced to the plant.
1
LINE ASSISTANT SHIFrSUrERVISOR
,
e Maintains configuration control in accordance with station provxtures and Operations
Department Principles and Standards.
* Conducts and/or monitors pre-evolution briefings. Obtains input from experienced
a operators and technical experts so that potential problems are anticipatei Ensures
players understand their role in the evolutions.
. Communicates clear priorities and Wadons for the shift to the ROs. 'Ibese shall
include any time-limit vadons and contacts to be made with outside l
departments.
. Tracks the status of assigned tasks and communicates progress to the SS and
applicable departments. , l
,
e Prepares surveillance pmcedures for the upcoming shift. .
SurrRESOURCE MANAGER (SRM)
< . . Keeps the MCR and SS informed of work authorizations.
. Keeps the SS involved in decisions to not allow performance of a scheduled
maintenance nctivity. i
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Clintoa Pow:r Station
Operations Department Operations 1
Principles and Standards ' Standards !
* Serves as the interface for Operations with other site organizations.
* Ensures tagouts are prepared for the upcoming shift
'
l
e Takes charge of field activities as m*===ry, j
l
e Reviews the plant condition schedule and ensures Operations is prepared to support
its execution. .
l
l
* Participates in pre-evolution briefs as required by the LASS or SS. l
* May be called upon to pmvide breaks for the LASS.
REACTOR OPERATOR
e Pmvides turnovers that convey current plant status, trend changes, significant alarm
status and major ugosing or completed evolutions.
* Ensures turnovers are confirmed by the relief person before stopping duties.
I
o e Announces RO relief to the LASS.
;
.
* Exhibits professionalism in all communications.
* Understands his primary rer.ponsibility is to protect the health and safety of the I
public.
* Questions anything that deviates from the norm.
.
.
. Treats every activity as non-routine.
* Trends and monitors indications to catch problems before they alarm.
* The "A" RO
0. The A RO shall be formally designated by the LASS and will not engage in
activities that distract his attention.
0 *Ihe major function of the 'A' RO is to monitor the plant status via annunciators
and indications provided on P680 in the MCR.
.
page 24
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Clintoa Pow:rStation
l
Operations Department Operations
Principles and Standards -
Stande-ds
* The "B" RO 6
0 The "B" RO will have responsibility for the MCR Log. He will also ,
direct / acknowledge each activity and evolution originating from the control room i
e
and will detennine what level of control is needed to ensure his complete :
,
understanding and control.
-
i e Both ROs
i
;
0 Frequently look at the mq)or plant parameters. .
.
O he should be an overall observation of the control panels several times an hour.
O A detailed walk down of MCR panels should occur every two hours and be
d
docu:=dM in the RO Journal.
O The "A" and "B" ROs are responsible for communicating with each other to ,
ensure the "A" RO is aware of those evolutions which may impact his panels or
- controls.
4 h _ "
Roo VERIFIER
- * A-= no other concurrent functions, is totally focused on control of rod
manipulations.
. .
- o
- shirr ENGINEERffECHNICAL ADVISOR
j e
* Maintains a broad perspective of activities throughout the plant. '
*
.
Maintains an independent viewpoint that is oriented towards predictions, rather than
-
reactions.
.
'
* Assists in troubleshooting plant and equipment problems. .
,
*
Participates in pre-evolution briefs as required by the LASS or SS.
*
Informs the LASS and SS ofimportant changes in core thennal par n e m.
.
.
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page 23
. .. - - . . .-- . -. - -. - - . - . . - -- . - -
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a' 'a
' ' '
Cit tm Pow:rStatin
Operations Depart nent '
Principles and Standards Operations !
.
' Standards !
NucutAnEQUtrMmerOrsaATOR
*
Displays pride and ownership for the plant and all equipment. !
* j
Exhibits professionalism in all communications. ;
* j
:
Is conscientious and meticulous about all aspects ofhis work a .
*
.
Keeps and thetasks MCR informed ofprogress of toursems and assigne
4
i cocountered completed.
*
.
Maintains congizance of activities aJug in his assigned area. , \
<
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,
MCR FonMALrrY
'
: *
Only bh discussions of an operational nature wille be permitte
controlt area of the Main Control Room (MCR). Short convers
'
nature that do not detract from the monitoring and control of the s .
*
0MCR and the at the controls area acce s:
a
.
Routine access to the at the controls area will b
team.
O team All other individuals must have verbal permission from a
to enter the at the controls area. I
-
. 0 Northwest
0
Entrance cQ of tothe the at controls
at the the controls
area. area for e other th
i
opening of the at the controls area to conduct W i
;
0 Anyone entering the back panel area of the MCR
0
am.
shall first no
, 2
in the at the controlsareaoithe MCR.Only those activit!j
.-
.
0 *Ihe LASS shall
being maintainnelat ensure that adequate monitoring
all times. are
and control )
!
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The
O normalMCR
ShiA Superdsor
team consists of the: \
O
Line Assi.Want Sh!A Supervisor
0
"A" at the costruts Remetor Operator
0 "B" Reactor Operator ,
.
O
ShiA Resource Managn
, . O ;
ShiA Engineer /Shia Technical Advisor '
!
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page 26
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6 .
- " Cil:ts:i PowerStatiom
.Operati nsDepartiait
Principles and Standards Operations
.
Standards
*
The nonnel MCR at the centrois compliment will be the "A" Reacto
"B" Reactor Opermeer and the Line Assistant ShiA Supervisor.
O
,
Short breaks, such as lunch or rest room breaks, may reduce the n
ReactorOperators to one.
O The LASS shall ensure these' breaks occur during low-activity pe
O
reduce the ability to monitor or contml the plant.
O During shifts with a high activity level additional RO support shall
The "B" RO may leave the at the controlr swa for brief periods for a
the backpanels orOSC area.
*
The MCR envirr==nant shall be quiet and t= * - N.
*
Eating in
authoriand the at the
by tbcLASS. coneair area is not the norm. Light snacking is .
*
Use of the personal computers will not impact operators effecti
elated work shall be perfonned while in use. .
*
MCR working spaces should be free ofclutter at all times.
*
5 Only reading
contralr m'ea. materials that are specific to operating the plant are allo ~
, e
Operators will only accept professional .yr w.e and attitudes in the con; .
,
. ANNUNCIA10sREsFONSE
,
All alarm conditions and the reason 'for them will be announced by a R '
acknowledged by the LASS. Operators shall know the status of all an
or that have MWR's written against them.
,
. F
Wd annunciators for planned activities or evoludons will be announced
" expected" when received by the RO and acknowledged by the LA
for expected annunciat<ws may be discussed at the ,
. 'Ibe pre evolutio
annnanishw response procedure should be reviewed during the pro
reasons for expected annunciators shall be con 8M upon initial receipt o .
.
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Clinto2 Pow:r Statio2
Operations Department Operations ;
Principles and Standards Standards
. Repetitive maannaiatars with short intervals that are generated during testing or !
integrated plant operation evolutions do not have to be announced, provided the
LASS and the ROs have pnMefed tle stanns to be generated prior to the
perfonnance of the test or evolution.
0 For sunmillaana or maintaamaaa testing a list of all W alanns must be '
I
written down and be in the possession of the RO and LASS prior to the start of the i
test. l
0 'Ibe first time an alarm is generated; it shall be announced by the RO and l
antraawledged by the LASS.
0 'Ibe control room team shall remain sensitive to potaatial repetitive annunciators
occurring he to valid conditions. '
. UTM anananlatars will be addressed by.use of the appropriate ann =niatar !
'
response procedure. Actions and/or investigations of the alann shall be initiated per
the applicable anananiatar pmcedure. ;
'
i
. During transient conditions:
0 Will make a conscious decision on each annunciator to distinguish the
signih ofeach actuation orreset.
O Significant annuncisqprs must be announced.
O Groups of annunciators may.be combined and the underlying cause reported
a rather than addressing each individual annunciator.
O The LASS shall acknowledge the receipt of the information.
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CLASS CODE: NNNN2
CPf, No. lOMe.olF010 M
( P.e v . d) M# '
g3
e .,; J r.o
PROCEDURE / DOCUMENT APPROVAL FORM
G f'[ '
_1 N !'ORMAT I ONA L . .f..'.A.T.A : _
.
PROCEDURE /TCCUMENT *?O. 4001.01 PEV. No.
PROCEDURE / DOCUMENT TITLE:
BEAR: TOR Cool.IsNT f.EAKAGE
- - - -
_ _ - - . . . - . . ,..- ._ .
................................ - . . _ - -
- . . . _ . .
................................ ........................................
. .....
..................................
TRAINING: NEY: X Yes ik)
I i
i ays i o Carr.p ! c t.e _R.
OTHER: Yes X No lo be n aplet ri wi t h ::. t.
weeks
o! Issue Date
.................................... ....................................
.................................... ....................................
PRELIMINARY APPPOVALS..: -
ORIGINATOR: T. J. LANDIN
3[3 S'$
.
_ _ _ 2.. _ . _ _ _ _ _ DATE:
ITR: /' /
./ DATE- .3h.t3
RESP. GROUP SUPERVITOP: .f
NSED: o N /A
,_
_ . _ , _ _ , . _ _ DATE:
e[tk5 _
s
DATE:
QA:
N/A
DisTE .
PSS:
, t .:
DATE.
FRG:
N/A
_
PATE:
....................................................................
................................................................... .....
......
FINAL AFPROVA1.. '
e
" .
ti
DEIAkTMENT liEAD U/A ' //
?[[fl_
_,
/j', -
_1, q . -
p : ATE:
wsNAaER - cps. -
i i
_ _ _ . . _ . _ . _
_gg _6 _/. . _ . . . . . _P^TE .SEP_.1 0.893 g
NOTE: T}ilS APPROVI.t 1,
PROCEDURE / DOCUMENT WiiEN VAULTED.F0kM t ,.,.4
MUST 14E COMPLETED A
.
.E.N13 M. t.11.6
.h T 11*ft:Is
DEC 2 71993
. ::.u:.s:.t o T,u.
, l$6-33 ViOJ
i
_ _ _ _ - _ _ _ _ . _ _ _ _ _ - _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _
.
c
a
. CPS No. 4001.01
^
CLINTON POWER STATION
^
PROCEDURE TITLE: REACTOR COOLANT LEAMAGE
t
1
SCOPE OF REVISION: Periodic revision, total rewrite to eliminate
redundant actions, sirnplify logic flow, eliminated
non-significant operator immediate actions, '
incorporated lessons learned from EOPs, V&V, and f
human factors. No revision bars used. ;
I ? l
=== -
_.
:
CLASS CODE: SNNN p
;
ORIGINATED BY: Thomas J. Landin
I.
WORD PROCESSING BY: J. Van Valev .
SEP 101993 j
APPROVAL DATE- }
.
i
PDR INEVRMATION: -
1
PDR NO. ORIGINATED BY: DATE:
#
PE'. NO. ORIGINATED BY: DATE:
PDR NO. _ ORIGINATED BY: DATE: I
t
PPR NO. ORIGINATED BY: DATE:
'
PDR 110. , ORIGINATED BY: DATE:
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cl.0 SYMPTOMS
1.1 Any of over 50 annunciators indicate possible leakage from:
* CNMT/Drywell Areas
* ECCS Systems / Rooms
* RWCU System / Rooms
* AB/ Steam Tunnel Areas
* RR Pumps
1.2 Presence of water or reports of high pressure / fluid
escaping noises from primary systems. ;
..
2.0 AUTOMATIC ACTIONS
2.1 All equipment / floor drain sumps start on high level.
2.2 Possible group isolations on MSL/ Drains, RHR, RCIC, RE/RF
and RWCU due to degrading conditions. Refer to CPS No.
4001.02, AUTOMATIC ISOLATION for detailed set points and
group descriptions.
2.3 Possible reactor scram due to high drywell pressure
(1.68 psig) or MSIV group 1 isolation.
2.4 Fission product monitor system isolates on high drywell
pressure (1.68 psig) or RPV level 2 (-45.5 in.)
3.0 IMMEDIATE OPERATOR ACTIONS .
Evacuate affected areas.
,
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kev. No. 7
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CPS No. 4001.01
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,
4.O SUBSEQUENT ACTIONS ,
4.1 Classify the event per EC-02, EMERGENCY CLASSIFICATIONS.
_
4.2 Monitor:
" Critical plant parameters for possible EOP entry. ;
* CNMT/DW sump inlet flow on 1E31-R551, CNMT & DW FLR DRNS
-
-
INLT FLOW RATE on 1H13-P855.
5
* Drywell atmosphere on lE31-K610(1,2), FISSION PRODUCT
MONITORS on lH13-P632.
.
4.3 Refer to Tech Spec 3.4.3.2.
Table 1 lists allowable isolation valve leakage criteria. j
i
_7
4.4 Notify RP and request area samples and/or AR/PR trending
information to assist in detecting the location / source of
the leak. ,
_-
Refer to CPS No. 4001.02, AUTOMATIC ISOLATION for possible 7;
4.5 -
group isolation verifications. 4
7
4.6 Attempt to locate and isolate the leakage. Refer to CPS
No. 3315.02, LEAK DETCCTION (LD) for assfstance. I
0-
c4.7 IF Leakage source is unknown,
I
TilEN Shut both IE12-F008 and F009, Shutdown Cooling Outbd d'
(Inbd) Suct Isol Vlv. i
4.0 Refer to CPS No. 3408.01, CONTAINMENT BUILDING /DRYWELL HVAC =
(VR, VQ) as necessary to purge CNMT/DW airborne activity. { .
4.9 Refer to the radiological Off-Normal series (4979.xx) as 1
necessary for degrading conditions. ,
w
5.0 FINAL CONDITIONS l
i
5.1 Leakage identified and isolated, or l
5.2 Leakage limited to Tech Spec 3.4.3.2 limits, or
_.
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5.3 Tech spec 3.4.3.2 action statements resulting in a plant :
shutdown and cooldown. .
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Rev. No. 7
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CPS No. 4001.01
TABLE I
REACTOR COOLANT SYSTEM PRESSURE ISOLATION VALVES
(Reference Tech Spec Table 3.4.3.2-1)
VALVE NAME
,
SIZE ALLOWABLE
LEAKAGE
lE12-F008 Shutdown Cooling Outbd Suct Isol Viv 18" 5 gpm
1E12-F009 Shutdown Cooling Inbd Suct Isol Viv 18" 5 gpm
IE12-F041A Testable Check Valve D.isc 12" 5 gpm
1E12-F041B Testable Check Valve Disc
-
12" 5 gpm
IE12-F041C Testable Check Valve Disc ,
12" 5 gpm
lE12-F042A LPCI Fm RHR A Shutoff Valve 12" 5 gpm *
IE12-F042B LPCI Fm RHR B Shutoff Valve 12" 5 gpm
1E12-F042C LPCI Fm RHR C Shutoff Valve 12" 5 gpm
1E12-F023 RHR B Supp To Rx Head Spray Valve 4" 2 gpm
1E12-F050A
RHR A SDC Return Line Check Valve 10" 5 gpm
1E12-F050B
RHR B SDC Return Line Check Valve 10" 5 gpm '
1E12-F053A RilR A To Feedwater S/D Cooling Rtrn Vlv 10" 5 gpm
IE12-F053B RilR B To Feedwater S/D Cooling Rtrn Vlv
,
,
IC" 5 gpm
',
1E21-F005 LPCS To CNMT Outbd Isol Valve 10'I 5 gpm
1E21-F006 Testable Check Valve Disc .
10" 5 gpm
IE22-F004 HPCS To CNMY Outbd Isin Valve 10" 5 gpm
IE22-F005 Testable Check Valve Disc 10" 5 gpm
lE51-F013 RCIC Pump Disch To Rx outbd Isol Vaive 6" 3 gpm
IE51-F066 Testable Check Valve Disc 4" 2 gpm
)
*
.
P a'J e No. 4 of f,
key. No. 7
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. CPS No. 4001.01
.
I
6.0 DISCUSSION / DEFINITIONS ,
6.1 Reactor coolant system leaks present a hazard to both
personnel and the reactor plant. Small leaks in the
pressure boundary can become larger and more of a problem.
Leaks must be found as soon as possible and corrected when
plant conditions permit.
6.2 The methods for finding a leak are varied, but the best
indicators are: increase in temperature of a specific i
area; increase in drywell pressure, temperature and/or ,
moisture level; increase in airborne or gaseous activity;
. drain sump inflow and pumping requirements. The operator
must be constantly aware of any abnormal changes in the
above indications in order to take appropriate action.
6.3 This procedure provides guidance for actions to be taken .
for small leaks which are within the RPV level control y
system's capability. CPS No. 3315.02, LEAK DETECTION (LD)
will help locate and isolate a process system leak or a
ventilation system heat exchanger tube Icak. ,
:s
7.0 REFERENCES
(
c7.1 USAR Table 13.5-5/CCT 4012457 (1.0)
c7.2 ISEG Review 90-01, Recommendation H2/CCT N054937 (4.7)
c7.3 SER 7-87/CCT N049342 (4.7)
7.3 Tech Spec 3.4.3.2 +
7.4 CPS No. 3315.02, LEAK DETECTION (LD)
'
7.5 CPS No. 3408.01, CONTAINMENT BUILDING /DRYWELL HVAC (VR, VQ)
7.6 CPS No. 4001.02, AUTOMATIC ISOLATION
7.7 EPIP EC-02, EMERGENCY CLASSIFICATIONS
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Rev. No. 7
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' CLASS CODE: NNNN2 ; 5 ' * '
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1C.200
. ,.; e , ' CPS No.:1005.01F010- W2 '.1 *. .-m 2 - w
'
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(Rev. 4) .yO
+.1 a f.-
- . PROCEDtJRE/ DOCUMENT APPROVAL FVRH
4
a . CPS No. REVISION No. CLASS CODA
C
k '
3302.01 18 SNNN
3302.01E001
_
f, 3 11 (f! #/r3/94 SNNN1
3302.01VOCWQ. W h6 / f>r',/>13,5 SNNN1 "
N/A
-
N/A
N/A '
N/A 3
N/A ;
N/A l
N/A ['
N/A 5
N/A )
N/A
N/A ~
;
N/A ;
t
TPA !1!.'"i: NO YES COMPLETION T;ME
KEY: X Days i
OTHEh: X 6 weeks of I .< . .: e I.ar.. !
:
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Uk;GINANR: Thomas J. L ',7
Page , , .* i
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CPS No. __3302.01
7
.
CLINTON PCTviER STATION
.
PROCEDURE TITLE: REACTOR RECIRCULATION (RR)
SCOPE OF REVISION: Incorporated PAC 0393-95 (RF-5 flow data updates) .
Section 8.2.4 - Isol RR loop layout restructured to
address loop cooldown and seal leakage concerns.
New step 8.2.6.3: Implements USAR 15.4.4.2.1.1(3)
criteria for idle loop restart.
New section 8.3, RR PUMP SEAL PROBLEMS - RESPONSE
ACTIONS created to simplify and consolidate seal
responses while expanding response scope to include
degraded injection flow and single pump responses.
.
Section 8.4.3, Fill / Vent RR Loop: Incorporated TPD
95-0245 (and feedback comments) used during PO-7
Standardized ICll-F026 noun name/ location.
Updated NSED team contact points. ~
_ _ __, _ - - --
_ .- - - - -
CLASS CODE: SNNN
- ORIGINATED BY:
_.s
Thomas J. Landin
. , . - . - - e wn
WORD PFOCESSING BY: Connie Baker
APPROVAL DATE: FEB 26 1996
. . _ , .. .
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0 Cilld1GE !JO. PAGES
k
O CHA!JGE NO. PAGES
_ _ _ _ _ .
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0 CilIJJGE NO. PAGES
O Cilld1GE NO. PAGES
_ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ .
O Cli/JJGE No. PAGES _ _ _ , . . _ _ , _ _ _ _ _ _ . _ _ _
O Cl!IdlGE No. PAGES
O cilA!!GE I:o. PAGES
O Cl!ANGE No. PAGES _ _ _ _ _ _ . , _ _ _ . , . . . . _ _ _ ,__
O CilANGE t10. PAGES
O t ilA nia. 11 i. , , , . , PAGES
l'iim No . 1 o! 30
Rev. No. 16
. _ . _ _ . . . . .
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dh r.Ny.- . . . , - c. . ,. ., .;a., bb4.?b$d24... bo c. .- .. CPS No.- 3302.01 . , . _ s. . . ,f/h a ' '
TABLE OF CONTENTS ;
/. (Section 8.0 only)
p:!- .
Page
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8.1 Normal Operations
8.1.1 RR Pump - Startup 10
*
8.1.2 RR Pump - Transfer To Fast Speed 12
-
e
8.1.3 RR Pump - Transfer To Slow Speed 14
4
8.2 Infrequent Operations
8.2.1 RR Loop Shutdown - during plant operation 15
8.2.2 RR Loop Shutdown - when plant shutdown i t,
0.2.3 RR Loop Emergency Shutdown /'RR Pump Trip 16
,-
8 . 2 . ,4 Idle RR Loop - Isolating 17
8.2.5 Idle RR Loop - Unisolating 18
8.2.6 Idle RR Loop - Restart 16
O 8.3 RR PE4P SEAL PROBLEMS - RESPONSE ACTIONS 19
8.3.1 RR Pump Seal Monitoring for Degradation / Failure 19
R ****#^**- Table 1: ARR PUMP-SEAL * KEY PARAMETERS 20- ^
8.3.2 Degrading RR Seal Injection Flow 21
8.3.3 Rising Temperatures on RR Seals 22
8.3.4 Loss of RR Seal Injection and/or CCW 23
8.4 Abnortnal Operations
8.4.1 FCV Lockout / Reset 24
8.4.2 FCV Runback Reset 24
H.4.1 Fill / Vent RR Loop 25
H . .) , 4 Draining RR Loop 2 'l
*
a.4.'- f:intainment Isolation Recovery .
.
I t jur it_l : STABILITY CONTROL & POWER / FLOW OPEFATING MAP 30
Page No. 2 ci to
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CPS No. 3302.01
1.0 PURPOSE
Provide direction for placing the Reactor Recirculation
(RR) system into various normal operational modes and
provide corrective action in the event of abnormal system
operation. This satisfies Improved Tech Specs (ITS) item:
ITS SR 3.4.11.3/4 (8.1.1.4) (RR Pump Start AT Limits)
.
2.0 DISCUSSION / DEFINITIONS
2.1 RR circulates cooling water through the reactor core and I
controls reactor power over a limited range by varying the
flow rate of the reactor coolant.
RR consists of two loops external to the reactor vessel
(RPV) each containing a pump, two shutof t' valves and a Flow
Control Valve (FCV) (IB33-F060A/B) . The FCV is positioned
by means of electronic signals to a hydraulic actuator.
I The Hydraulic Power Un'.ts (HPUs) are discussed in CPS No.
3302.02, REACTOR RECIRCULATION FLOW CONTROL HYDRAULIC
SYSTEM.
RR flow can by changed using FCV position or pump speed.
RR pumps can operate at either 25%, 445 rpm (slow) speed
from the Low Frequency Motor Generator (LFMG), or at 1001,
1780 rpm (fast) speed from the 60 Hz supply.
'
c2.2 RR startup consists of starting RR pumps in slow speed fron
o, . . , .the.LFMGs. At .,35% power,_ RR FCV. cavitation interlocks e
are bypassed. Placing a FCV in rainimum for RR upshif t
results in a 3 - 4% drop in power. RR pump shift at - 304
power minimizes the potential for creating conditions
favorable to core ir. stabilities.
2.3 For operation of the Recirc Pump Trip (RPT) Bypass switch
and its effects on the RR system, refer to CPS No. 3305.01, '
REACTOR PROTECTIVE SYSTEM.
c7.4 Component Cooling Water (CCW) to the RR pump isulates on
high drywell pressure or RPV Level 2. Although the
transfer from CCW to SX can be manually initiated upon loss i
I
of offsite power or unavailability of CCW, cut t er.t plant
philosophy prohibits the use of SX tor cooling to PR pump i
seals and motor bearings. SX isolates on high drywel1
pressure or RPV Level 1. Special care must be taken te
correctly ascertain the type of isolation that has occurred
and the proper actions to b. - follow.! in r e a t . > r .it i . n .
:
0 ...
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Volumettie RR loop flow which produs:..s luo m i:o s .. I ! .,s ..t
lauf thermal power is: 32,418 gpm tor each loop.
Total core flow with both kk purnpu at rated speed ami
minimum FCV position is 30 mlb r/h- .i t 3 5.} r rated : 1<w.
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CPS No. 3302.01
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, a 3.O RESPONSIBILITY
r Director - Plant Operations shall be responsible for
~
, ensuring the proper implementation of this procedure.
'd s
V 4.0 PRECAUTIONS
4.1 If at any time during either start sequence, control power
is lost, the incomplete sequence relays will actuate and
trip the RR pumps.
c4.2 Consideration should be given to operating the moisture
separator reheaters in MA!C.IAL to preclude instability when
tripping a RR pump.. Refer to CPS No. 3106.01, MOISTURE
SEPARATOR REl! EATER.
c4.3 Loop flows should be checked against FCV position, as a
reduction in RR loop flow from the established FCV position
could be indicative of IB33-F067A(B), Discharge Viv disc
becoming separated from the valve stem. CPS No. 9041.01,
JET PUMP OPERABILITY TEST provides the needed graphr..
c4.4 RPV bottom head drain temperature canriot be reliably
determined unless there is flow through the bottom head
drain (e.g., RT pumps running).
4.5 Care should be taken when reducing RPV water level to
insure a runback of the FCV's does not occur. Runback will
occur with a trip of a TDRFP and a RPV water Level 4. ,
n ... w som . a. .:m
c4.6 Thermal stratification sufficient to exceed RPV
pressure / temperature limits could occur at saturated
conditions and no forced RR flow. After a scram from full
~
power, natural circulation is insufficient to prevent
bottom head area thermal stratification due to cold water
(specifically: E'd , RCIC, ilPCS & RWCU Return. CRD is rg a
stratification concern) being injected into the core.
O c4.7 Inadvertent FCV movement can occur due to failures in the
flow controller or hydraulic control system (!!PU) . IIFU
lailures often result in the FCV opening, resulting in .
rise in reactor power. Fast FCV opening (3na stroke /sem
results in a scram at - 1.1 sec with a 309: p.uk r:eutron
flux. Lesser stroke times can result in a transient
exceeding 1001 RTP. The allowable design drift of .i !..-b.i
out FCV is 15V. stroke / minute,
l 'u e to the real potential for itPU 1ailure, prior to any
~
operation of the FCV or its !!PU units; the FCV:: , cose ! low
.ind reactor power shall be closely monitir...! for .in t v ;i n t
.lue to operation of the FCV or ilPU.
P.ote No. 4 of 30
Rev. No. 18
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. CPS No. 3302.01 :
4.0 PR.ECAUTIONS (cont'd)
c4.8 CPS RR pumps have been identified as being susceptible to
failure of the upper wear ring bolts. This results in the
upper wear ring coming loose from the stuffing box and
falling into the upper impeller region. The upper impeller
l area then equalizes with pump discharge pressure and
overcomes the normal up thrust of the pump, causing the
lower thrust shoes of the motor bearing to carry the thrust
load. The upper wear ring is free to ride on the impeller,
usually " banging around" and causing a loose parts alarm.
The following indications can be used to determine if a
wear ring drop on a RR pump has occurred.
*
Reverse loading of the motor thrust bearing; the lower
thrust bearing temperature may increase in response to
being loaded, and the normally loaded upper thrust
bearing temperature will decrease. (Best indication of
this condition)
*
May receive Loose Parts Monitor alarm and see changes
in vibration.
*
Possible changes in lower seal cavity pressure.
O If a irop is suspected, contact the NSED - ECCS &
Reactivity Systems Team immediately. 11 teverse thrust
conditions are confirmed, the affected RR ptmp should be
shutdown as soon as practical to minimize secondary
component damage. (These indications may be less clear in
the event of a partial wear ring drop.)
4.9 RR PUMP SEAL CONCERNS
c a) RR pump seals must be vented prior to starting the pump
if the pump casing has been drained.
b) Substantially increasing RR pump seal CCW cooling flow
above the normai value to correct a high temperature
condition may cause seal failure due to thermal stress.
c c) Securing CBD injection to a RR pump which has baen
secuted and isolated due to a seal l ea ). will cause an
increase in drywell airborne activ2ty as the loop
depressurizes to atmosphere through the seal
ell Prior to plant st at t up and heat up w t ? h in 1: . . l a ' <.a PP
loop, insure the noal put <so t1..w a n. t .al : aqinq t 1..w
ate secuted,
c e) When the idle loop is isolated, the pump seal purge
flow should be isolated atter tbo temperature i n t h.-
1solated loop dectcases t.o ." u " F . -
Thi- w:11 a. ' .? t r. i
keeping the pump seal cool.
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CPS No. 3302.01
Pf,n
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4.0 PRECAUTIONS (c( . 1)
t.,
4.10 TRIPPING RR'Pt JNSIDERATIONS
c a) Lowering pot to < 50% prior to tripping one RR pump
from fast spee_ may cause the other RR pump to
downshift to slow speed due to low feed flow. It is
recommended to paintain feed flow > 40% (- 5.0 mlbm/hr)
prior to trippir.g a RR pump from fast speed.
b) Due to the AT Cavitation (steam dome / pump suction AT)
and Low FW Flow interlocks, the operating pump may
transfer to slow,
c c) Lowering level prior to tripping is considered prudent.
c d) At - 52% Rx power & 70% rod line, a trip of one RR pump
results in power stabilizing at - 33%.
5.0 PREREQUISITES
5.1 Component Cooling Water system operating per
CPS No. 3203.01, COMPONENT COOLING WATER (CC).
5.2 Control Rod Drive system operating per
CPS No. 3304.01, CONTROL ROD HYDRAULIC AND CONTROL (RD).
L.3 Instr. ament Air system operating per
CPS No. 3214.01, PLANT AIR (IA & SA).
',1 Shutdown Service Water syrtem available por
' ~'
ec. "'" CPS No. 3211.01, SHUTDOWN SERVICE WATER (SX).
L.5 Electrical power distribution available per:
CPS No. 3305.01, REACTOR PROTECTIVE SYSTEM
CPS No. 3501.01, HIGH VOLTAGE AUXILIARY POWER SYSTEM
CPS No. 3502.01, 480VAC DISTRIBUTION
CPS No. 3503.01, BATTERY & DC DISTBIliUTION
CPS No. 3507.01, STATION LIGHTING AND LOW VOLTAGE "YrT N
5. e. Following RR system lineups completed:
a) CPS No. 3301.01V001, NUCLEAR BOILER VALVE LINEUP
b) CPS No. 3302.0lV001, REACTOR RECIRCULATION VisLVE LINEUi'
c) CPS No. 3302.01V002, PEACTOR kECIRC INSTH VA!,VE I,1NEUP
d) CPS No. 3302.01E001, REACTOR RECIPCUI.IsTloN E!.ErTF ICist
LINEUP
'+.I RR FCV liydraulic system operating per CPS No. 13 u. . 0 7,
HEACTOR HECIl<CUI.ATION FI,0W CC.NTROL llY!)RAUI,lr NYSTEM.
.'..H hk pump oiI temperature should bo 7u"F p los 1o .tattinq l
tho pump (poot lubsicating qua1itied at low temper it u: c) . j
l
'4
,
Complete CPS No. 2214.01, CORE FLOW VS. RECIRCULATION FLUW
THENDINr; ilur t nq the t eqisming sit o.ich fuel cycle.
Page No. 6 ot 30
Rev. No. 18
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CPS No.
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3302.01
6.0 LT!!ITATIONS
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c6.1
Prior to and during rod / flow changes, refer to Figure 1:
STABILITY CONTROL & POWER / FLOW OPERATING MAP (page 30).
;
6.2 Following Improved Tech Spec criteria apply:
e a) ITS LCO 3.4.1: OPERATING RR Loops / Single Loop
'
* Natural circulation
permitted and requires mode when inshutdown.
a reactor MODE 1/2 is not-
b) ITS SR 3.4.1.1: RR Loop Flow Mismatch >
c) ITS SR 3.4.1.2: Power / Flow Operating Limits (6.1)
d) ITS LCO 3.4.2: OPERABLE FCV in operating RR Loop
e) ITS SR 3.4.3.1: RR Loop, Drive, & Jet Pump Flows
f)
ITS SR 3.4.11.8/9: Single Loop AT Limit (8.1.3.7 NOTE)
c y)
!
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ORM TR 4.3.1.5: Reactor water conductivity must
I be continuously recorded.
i #
The RR conductivity monitor serves as a backup to
i
the RT conductivity sample point. If both RR & RT
systems cannot. provide continuous conductivity
recording, in-line samples must be taken.
6.3
Due to heating of the motor windings, caused by startino '
current, the following pump start limitations shou bt be r
to1 lowed: .swm
a c. .,,,,
n
a) With windings at ambient temperature, the motor can be
started and brought to speed two times in succession.
b) With windings at rated temperature, the motor can be
started and brought to speed once.
,
c) Motor windings can be assumed to have returned to
ambient temperature after 45 minutes de-energized,
or
to rated temp after 15 minutes running at ratoit speed,
te . l
To extend RR pump seal life and minimize downtime, the
following limitations should be followed:
a) Minimize the number of times the kh pump:: a t .: < t a t t o.1
or shiited to fast or slow speeds.
.
In order to
accomplish this some preplanning and coordination of
work activities /survoillance', will I.e no v <oy.
..
.
Io Minimaze HR pump uperation when hPV p:ee ure. aun
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psig.
The pumps can be operated in low speed for up to
- one week at low system pressuie. For ext eniin,i
j
j
..nt a.n.:. tieyon.1 on" wret,
:Im t . l. mn ...line .h, u l t t.
entabitsbed and the RH pumps shutdown.
Page No. ;/ o; to
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[' CPS No. 3302.01
A.,
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&s.,s 6.0 LIMITATIONS (cont'd) .
iff
J. 6.5 RR pump motor winding temperatures shall not exceed 248*F
F continuously or 266*F intermittently.
~-~
6.6 RR pump motor bearing temperatures shall not exceed 194*F
i ,
continuously or 203*F intermittently. ;
l
c6.7 During refueling operations: I
a) Combined RR A and B loop flow should not exceed 4644 f
gpm, when LPRM and TIP tubes are not surrounded on all
four sides by either fuel assemblies or blade guides. '
b) When blade guides are installed, do not exceed 4 psid
core plate op to prevent blade guide lift.
.
c6.8 Recorder 1B33-R613 (B21NA001) core flow input is based on a
derived formula from CPS No. 2214.01, CORE FLOW VS.
REJ1RCULATION FLOW TRENDING for each new core. This
fo:mula should not change appreciably between core Joads
and will not normally need to be updated. Check with the
STAS for the current formula validity.
O CF (mlbm/hr) = 2.7628 (AP) + 34.662
c6.9 Limitations exist for reactor water cleanup (RT) flows from
the RR loops and bottom head. Refer to CI'S No. .U n i . 01,
, ,,% REACTOR. WATER., CLEANUP ',RT)nfor any changes that- can a f f ect
these flows. :
a) Stcady state 2 pump /2 F/D operatson 1imit:
RT suction from each non-isolated RF loop 2 30 gpm.
,
b) hR flow to RT can be determined using F/D flows and
bottom head drain flows:
RR loop flows = (total RT F/D flows) - (Bottom heai flow-
.'
i
t.10 SINGLE LOOP /RR PUMP OPERATION CONSIDERATIONS
a) Observe ITS LCO 3.4.1.B, Single Loop Condi t tons a rid
ITS SR 3. 4. l l . ti/ 9, S 2toJ l e Loop AT Limit:,
b) The cavitation protection line which forms the s::.g'.e
loop operating boundary on Fi qui e 1 is < f o t e t rn i no. i 1 '.
':i, Power = 2 . 's X ("',. Co r e Flow) - 90
c) Minimize the number of times a Rk loop is i solated .m i I
. on i ... I a l. .wn in on elot t in pi ev nt a vi.iIati..n ,t ...!. ,
l
sttea> and tatigue et2tetla t ', o cycles per luopt. '
d) Single Loop Operating limits are controlled per the
appropriate 300x.01 int egr at e<l operat ire; pr weelur o.
Paoe No. _H pt W
Rev. No. ,
in =
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,c-- . ,., 4. J CPS No . - '3302.01 a.. ..
6.0 LIMITATIONS,(cont'd) ;
c6.ll Stability control concerns [ Refer to Figure 1: Page 30]
a) Core Thermal Hydraulic Instability: abnormal neutton 5
flux oscillations caused by axial / radial peaking,
critical power, inlet subcooling, and flow parameters
near the RESTRICTED ZONE which could lead to divergent
peak to peak APRM oscillations in excess of 10%.
Instabilities have been observed in areas not currently
defined as the RESTRICTED ZONE.
1) At low power, stable reactor performance is assured
"
by maintaining boiling boundary (BB) sufficiently
high in the core. BB 2 4.0 ft provides significant
stability margin. When BB is maintained, the ,
contribution to instability due to axial / radial )
peaking and inlet subcooling become secondary.
2) Detection of instability may be difficult due to the
localized nature of the phenomenon.
*
LPRM upscale /down-scale alarms may be the only or
best indication of the condition. .
*
Period may show strong positive / negative swings.
*
Evidence of instability should bu veritied by
other installed instrumentation. l
*
DCS may not adequately display true parameter
peak to peak oscillations and should not be usen
to discredit other evidence of instability. ;
3) An immediate manual SCRAM is the appropriate action
""
when instabi1'Tt'ies are observed.
'
b) RESTRICTED ZONE: 2 80% rod line (P:h) and C 4 M'. flow
(38.0 mlbm/hr, 3.:' psi core plate dP)
The reactor shall not be operated :n this zone. Power
and flow should be maintained such that the margin to .
the restricted zone is maximized. Time spent near the
restricted zone should be minimized.
c) EXIT REGION: 2108% FCL and $ SOY. flow
(42.2 mlbm/hr, 4.2 psi core plate dP)
Deliberate entry ir.to this reginn ' c. not per mi t t ml. l
Promptly exit via core ! low, r ods, or FPidi APPAY .
d) CONTROLLED ENTRY REGION: 2 *10'P. FCl, a nd i 4 0", tlow
(33.8 mlbm/hr, 2.2 ps2 core plate dP)
Controlled entry is only permitted as part of a planned
powe r ch.inge . Inadvertent or ! e i t e.1 i n i y : ".pa i s .- .i
prompt exit. via cote l'ow ot t egv. t se s oil sequent e.
1.H MATERIALS AND/OR TEST EOUIPMENT
c 15 micron absolute filter (step R.4.3.')
Page No. __9 of 30
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CPS No. 3302.01
6; 8.0 PROCEDURE
P..V
H.I N_ormal Operatiog
8.1.1 RR Purap - Startup
O U.1.1.1 (Local) Unless checked during drywell close-out, check RR
pump motor oil levels 11 the drywell is accessible.
Reference MS-08.00 for proper RR Pump A(B), IB33-C001A(B;
oil level determination criteria.
O ca.l.l.2 (Local) S1;0WLY open ICll-F026A(!!), CRD Supp Isol To lut
Pump A(B) and verify CRD supply to the RR pump seals is
3 - 5 gpm on flowmeter ICll-D020A(D) . If required, adjust
ICl l-D012A (B) , Flow Control Valve to obtain 3 - 5 gpm.
Flow regulator, ICll-D012A(B) is used to adjust flow as
follows (per K2801-0009): [CNMT ~155' AZM 189'].
a) Loosen locknut and rotate stem until desired flow is
attained. (Clockwise for decreasing flow, counter-CW
for increasing flow)
b) Lock stem in desired position by holding stem
steady while re-tightening locknut.
NOTE
When starting pumps at low power / low teed Ilow conditions, the
white light above the Cavitation Interlocks switch will stay on
and the pumps will start in slow speed.
--
c0.1.1.3 Depress following reset buttons ta clear interlocks / alarms:
a) FCV A/D Motion Inhibit Reset.
Verify the lead HPU becomes operational,
and FCV motion is no longer inhibited.
b) Pump A/!l Vibrat ion l<eset .
c) Cav Intlk A/B Reset / Rx Run Back Reset.
d) Low Level Intik A/B Reset.
cli . l . l . 4 Within 15 min prior to starting the AtH) 104 pump, verify
following ITS SR 3.4.11.3/4 temperature limits are met,
and log the data in the MCR Journal:
a) Difference between bottom head coolant temperature and
the RPV coolant temperature is t 200"F.
to Di11erence between the Rx ca iil ant t emper a t u n e in t h..
HR loop to be started and the l< l v c< .o l a n t t empe r .it ur e
i s s 50*F.
o.l.l.5 Place IBJJ-F000/U D), bectic FV in mi n i n om even p. :itain.
*
H.1.1.6 Verify CRD supply and seal staging flow has been in
eip.a r a t ion for at least one hour prior 'o pump starr to
ensuse the pump nealn .o e ven t e.l .
Page No. 10 of 30
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RR Pump 7Startup :(cont'.d) .
^
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l CAUTION ~
Do noj simultaneously start both PR pumps.
*B.1.1.7 Close the following P680 breakers in order:
a) Recirc[PumpA(B) Mtr Bkr 3A(38).
b) Recirc Pump A(B) Mtr Bkr 4A(4B) .
t
NOTE
If FW flow is < 30% (~ 3.74 mlbm/hr), then:
.
a) RR pump will' accelerate on the 60 cycle source.
b) The IA(IB) breaker will close at the same time
the SA(5B) breaker closes,
c) When pump speed'is > 95% (1691 rpm),
the SA(SB)Cbreaker will open.
d) When pump speed drops to 20-26% (356 -463 rpm),
the 2A(28) breaker will close.
If W flow is > 30% (~ 3.74 mlbm/hrk , then RR pump
speed will accelerate directly to 100% (1780 rpm).
8.1.1.8 Notify security that perimeter lighting may go out
for - 2 to 6 minutes due to the pump nr.stt.
u . l . i . 's Monitor reactor power and RPV water level
during the starting of a RR pump.
'" 8.1.1.10 StartRR'm pump w , A(B) by closing
Recirc Pump A(13) Drive Motor Bkr SA($B).
8.1.1.11 If RR pump startup was directed from section 6.2.6,
Idle RR Loop - Restart (step 8.2. 6. 6) , return to ;t ep
8.2.6.7. Otherwise continue in this section.
NOTE
A 40 sec incomplete sequence timer starts when the
CB-5 breaker is closed. If after 40 sec, pump
;
speed is not 20-26% or CB-2 is not shut, the
incomplete sequence relay will trip CB-1 I, CB-5.
8.1.1.12 After the RR pump is in service on the LEY.G,
open the FCV to full open ponit ion.
O #
OK to shutdown FCV llPU while in slew speed Hi< pump
operation to prevent inadvertent FCV unbock,
H.l.l.I1 Monitor Table 1, RR Pump _ Se1 1 Key ,pa r .imet air :. (p.np- Joi
11 they approach or teach the maximum allowable,
,
corrective action should be taken.
R.1.1.14 To start the other pH pump. r epe.it :a- t i..n n 1.1.
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'8.1.2 RR Pump - Transfer To Fast Speed
.
CAUTION
The FW Flow FCV cavitation / RR pump downshi f t.
I interlock is bypassed during this section.
Maintaining FW flow 2 3.13 mlbm/hr (- 29.4% RTP)
I
will insure FCV cavitation protection is providi.1
, while RR pumps are in fast speed. _ . 1 l '
The time the plant is operated with the interlock
bypassed should be minimized whenever possible.
Reducing core flow near the RESTRICTED ZO!JE
increases the potential for thermal hydraulic
instabilities. If instability is observed, a
manual SCRAM is required.
8.1.2.1 Notify security that perimeter lighting may 90 out
for - 2 to 6 minutes due to the pump transfer.
.
H.1.2.2 (I.oc; 1 ) At IB33-P001A and B, LFMG Aux Relay Panel,
place following keylock switches to BY Pteis -
a) S126A, Power Interlock (Both on FB 781' East)
, . , ,
b) S127A, Total Feedwater Low Flow Interlock
c) S126B, Power Interlock ( Bo t h on FB 7 H 1 ' West)
d) S127B, Total Feedwater Low Flow Interlock
8.1.2.3 Place IB33-F060A(B), Recirc FCV in minimum open position,
c8.1.2.4 Depress following reset buttons to clear interlocks / alarms:
a) FCV A/B Motion Inhibit Reset.
Verify the lead ilPU becomes operational,
and FCV motion is no longer i nh i bi t ent .
b) Pump A/B Vibration Reset,
c) Cav Intlk A/B Reset / Rx Run Back Reset.
d) 1.ow Level Intlk A/B Reset.
*
'
ft.1.2.5 Veri f y AT between RR purrp suction and HPV dam- t f4 . 6 * F .
H.l.'... V. a f y closed itecia e l' ump A(It) tot : liti: t/. g it< t .o n i 4 A ( ali >
Pace !J4 1. of Jo
Rev. flo . __.18
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*8.1.2 RR Pump - Transfer To Fast Speed (cont'd)
8.1.2.7 Monitor reactor power and RPV water level durir.g ;
transfer of the RR pump to f ast speed.
CAUTION
"
Do not simultaneously transfer
both RR pumps to fast speed. - i
8.1.2.8 Transfer the RR pump to fast speed by closing Recirc Pump
A(B) Drive Motor Bkr SA(SB), and observe that the LFMG A(B)
Gen Bkr 2A(2B) opens prior to the SA(SB) breaker closing.
8.1.2.9 Verify that the LFMG A(B) Mtr Bkr 1A(IB) opens.
8.1.2.10 Monitor Table 1, RR. Pump Seal Key Parameter.s (page 20).
If they approach or reach the maximum allowable, -
corrective action should be taken. -
8.1.2.11 To transfer the other RR pump, repeat section 8.1.2.
8.1.2.12 When > 35% RTP:
a) Verify low Total FW Flow input clear by having
E/C&I verify at 1H13-P612 an open c2:cu : h.:t w en
_,, .DD-6 & DD-7,,and DD-9_.& DD-11.
(Ref.: E02-1RR99-28/29)
b) Then, at IB33-P001A and B, LR4G Aux Relay Panel,
return following keylock switcher. to NOR. MAL:
1) S126A, Power Interlock (Bot h on FH h l ' E.m t )
2) S127A, Total Feedwater Low Flow Interlock
3) S126B, Power Interlock (Both on FB 761' West)
4) S1278, Total Feedwater Low Flow Interlock
l l l l l l I ! l l
Page No. 13 of .i : >
hev. No. la
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:* CPS No. 3300.01
*B.1.3 RR Pump - Transfer To Slow speed
CAUTION
The FM Flow FCV cavitation / RR pump downshif t
l interlock is bypassed during this section.
Maintaining EW flow 2 3.13 mlbm/hr (- 29.4% RTP)
will insure FCV cavitation protection is provided
I while RR pumps are in fast speed. i
The time the plant is operated with the interlock
bypassed should be minimized whenever possible.
Reducing core flow near the RESTRICTED ZONE
increases the potential for thermal hydraulic
instabilities. If instability is observed, a ;
l
manual SCRAM is required.
8 1.3.1 (Local) At IB33-P001A and B, LEEG Aux Relay Panel,
place following keylock switches to BYPASS:
a) S126A, Power Interlock (Bott. on FB 781 ' East)
b) S127A, Total Feedwater Low Flow Interlock
c) S126B, Power Interlock (Both on FB 781' West)
d) S1278, Total Feedwater Low Flow Interlock
8.i.3.2 Start both LENGs by closing LENG A & H Mtr Bkrs IA 1. 1 14
6.1.3.3 Place both IB33-F060A & B, Recirc FCVs
in minimum open position.
8.1.3.4 Transfer the RR pumps to the LEEG by depressing both
TRANSFER TO LFMG A and B push-buttons simultaneously.
8.1.3.5 Observe that the SA and SB breakers open and when pump '
speed decreases, the 2A and 2B breakers close.
N .1, t . 6 (Local) At IB33-P001A and B, LFMG Aux Relay Panel,
place following keylock switches to NORMAL:
a) S126A, Power Interlock (Both on FB 781' East)
b) S !. 2 7 A, Total Feedwater 1.ow Flow I n t e r l i ed,
c) S126B, Power In'.erlock (Both on FB 781' West) ;
d) S127B, Total Feedwater Low Flow Interlock
e NOTE
For single loop operation, comply with ITS SR
3.4,11.8/9 within 15 minuter, prior to . pe o a no 1 h.-
FvV t ul!y at ter down shi t ting im nump.
O H .1. 3 . */ Place both FCVs in their fuli open position. <
'r OK t o shut down FCV llPit whi l e 'n ; l ow speed bP p.q-
operation to prevent inadvertert FCV runbacks.
T'a g e No . J 4 pj 3n
lev. No. _ _ 11
o - - . - . . .- . . . _
t
.'... ..-.. a .. ,n _ . , CPS fio. 3302.01 _
. ,
,
8.2
'
Infrequent Operations .
* * * R . .' . 1 ,RR !.oop Shutdown - during plant oporation
~
l
c CAUTION
Core flow near the RESTRICTED ZONE increases the
potential for thermal hydraulic instabilities. If
instability is observed or the restricted zone is
entered, an immediate SCRAM is required.
Do not operate with partial FW heating when only
one RR pump is operating.
Single Loop Operating limits are controlled per the
appropriate 300x.01 integrated operating procedure.
O 8.2.1.1 Reduce Power & Flow to s 70% RTP, and within Figure 1
(page 30) Single Loop Envelope restrictions.
* Single Loop Envelope bounded by volumetric RR
flow which produces 100% core flow at 100% RTP
(32,418 gpm), and RR pump /FCV cavitation limits.
8.;'.l.2 hower RPV water level to just above 30.8 i ii .
(Maximum low level alarm setpoint value for 5002-20.)
8.2.1.3 Trip the RR pump from fast speed by opening Bkr SA(LB), ,
or from slow speed by opening Bkr 2A(2B).
*
c8.2.1.4 Shut IB33-F067A(B), Discharge Viv.
It the loop is not to be isolated, re-open
the discharge valve after - 5 minutes.
8.2.1.5 Fully open IB33-F060A(B), Recirc FCV to prevent
thermal stratification of the idle loop.
8.2.1.6 Stop the LH4G by opening LR4G A(B) Mtr Bkr lis ( I B) . 4
H.2.1.7 Open Recirc Pump A(B) Mtr Bkrs 3A(3B) L 4A(4B). >
NOTFj
'
!! t h.. loop in being isolated due to u*ra l tallust ,
consideration should be given to allowing the lcc p
to cool before shutting IC11-F026A(B) to prevent
;t cam t 19] r eact or coolant. Lo the drywe11 a t eno:,1.h. r e ,
H.7.1.A When the plant has stabilized:
a) Itet urn ItPV water level to notmal, j
b) Adjust reactor power to the der. ired level.
Page No. 15 or 30
Rev. No. 18 _
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CPS No.- 3302.01
,J4 :. y
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c8.2.2..a..RR Loop Shutdown ~ 'when plant shutdown ' <- - ""--
ysa *
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r ,[ ,
CAUTION
' n ytime RR is secured with the steam separator in
M57 ' A'
jp place, RPV water level should be maintained above ;
--. %.
the natural circulation level (44 in: shutdown '
i
'
range or 61 in: upset range (cold conditions).) ,
RR pumps should be left running for as long as '
possible .after reactor sh'utdown to maintain forced
-
3, circulation. Refer to Limitation 6.4 criteria.
8.2.2.1 Verify both RR pumps running in slow speed.
8.2.2.2 Verify decay hea't removal is available or
..
in operation as required by ITS LCO 3.4.9/10.
,,
8.2.2.3 Place both 1833-F060A & B, Rccirc FCV's in min position.
'
-i
8.2.2.4 When RR flow is no longer needed,
stop the RR pumps by opening LTMG A and B Gen Bkrs 2A & 28.
,, c8.2.2.5 Shut 1833-F067A(B), Discharge Vlv.
If the loop is not to be isolated, re-open
, the di.acharge valve after - 5 minutes.
8.2.2.6 IB33-F060A & B, Recirc FCVs may be re-opened "
rn enhance natural circulation flow. j
U.2.2.7 Stop the LFMGs by opening LRHG A and B Mtr Bkrs IA and IB. !
8.2.2.8 OpenA' ecire Pump A(B) Mtr Bkrs 3A(3B) and 4A(48,. (
_
,
c8.2 ,3., RR Loop - Emergency Shutdown / RR Pump Trip
1 '
g, c CAUTION
L
, !
-
Core flow near the RESTRICTED ZONE increases the
potential for thermal hydraulic instab:11 ties. If
instability is observed or the restrict ed zone is ',
2
entered, an immediate SCRAM is required.
' Do not operate with partial FW heating when only ;
one BR pump is operating.
.
Single Loop Or eating limits are contrclied per the {
appropriate 3m'x.01 integrated operatirg procedure. (
3 H.'.1.1 Tr i p RR Pump A (B) , ensutinq purap .unp : ..nd :: pre.1
::how .i c .inp l e t ' l unip t: ip:
l
from fast speed by opening Bkr 3A(3B), 4A(48) or LA ( ',3) ,
or f rom slow speed by opening Bkr 1 A(18) or 2A(28).
c H . J . 4 . ;' Shut 183 3- F0 67A (B) , i)ischarge Vlv.
I
b.2.3.1 Enter CPS No. 4008.01, ABNORMAL REACTOR COOIJ.NT FLOW.
-
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Page No. 16 of 30 !
Rev. No. 18
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. CPS No. 3302.01~
,
O -
*8.2.4 Idle RR Loop - Isolating
CAUTION
With the RR pump shutdown and injection flow stopped, seal
cavity will reach 185'F in - 30 to 60 minutes. Seal damage .
will occur at 250*F and the time necessary to reach 250*F
will be dependent upon the seal leakage rate and ir.itial
cavity temperature.
Securing CRD injection to a RR pump which has been secured
and isolated due to a seal leak will cause an increase in
drywell airborne activity as the loop depressurizes to
atmosphere through the seal.
With any idle loop valve shut, establish normal water
chemistry limits for power operation before closing any
second valve (i.e., isolating the idle loop).
8.2.4.1 Shut 1G33-F100(F106), Recirc Loop A(B) Suct. [RT valves)
8.2.4.2 Shut 1B33-F067A(B), Discharge V1v.
8.2.4.3 ~
IF Loop suction isolation is required due to
an emergency condition (system / seal leak),
THEN a) Shut 1 B33- F023 A ( B) , Pmp Suction Viv.
b) Shut 1833-F075A(B), Pmp A(B) Seal Slag Shutoff V!v.
8.2.4.4 Prior to isolating CRD Seal Injection Flow,
allow the idle loop to:
*
Normal conditioy
Csoldown to < 250*F.
*
Emergency Conditions (loop shutdown trom 8.2.3)
Cooldown to < 250* F; or_ in the event the RR seals are -
failed, loop depressurized to - drywell pressure.
R.2.4.6 Shut 1833-F075A(B), Pmp A(B) Seal St ag Shutof f Vlv.
e.2.4.6 (Local) Shut IC11-F026A(B), CRD Supp Isol To RR Pump is(B)
[Ct:MT 755' AZM 189*).
'r Faiture to shut F02', when t h. kh :.ra l: ase int act can
result i ti the loop being pre w ur1:eil to IMO pstg when
F075 & F023 are shut.
n. 1.1 .;ho t l itt.t - F02 I A (10 , l'inp ':uc t n on Y 1 v it not pr cv i ous 1 y :. hut .
ca.2.4.8 11 the loop is to remain isolated for > one hour while in
MODES 1 or 2, record the date & time of isolation in the )
McR Joutnal & notify tJSED - ECCS !. i<eactiv21y Syntemn Team.
Page tJo. 17 of 30
Rev. tio . 18
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CPS No. 3302.01
5f 'eu *B.2.5
'
.<.
Idle RR Ix>op - Unisolating
.e.
Q.G ' *
CAUTION
tjbj z
r.;
%n
.
For single loop operation with the idle loop's
f- valves open, maintain normal chemistry limits.
'
If RR pump was drained during period of isolation,
- it will be necessary to wait one hour after
establishing CRD supply and seal staging flow to
.
ensure RR pump seals are sufficiently vented prior
to attempting RR pump start.
'
,,
Maximum loop heatup rate permitted: 100*F/h r .
,
8.2.5.1 Ensure the RR loop is-filled and/or
warmed prior to proceeding with this section.
: 8.2.5.2 Open IB33-F067A(B), Discharge V1v.
'
, 0.2.5.3 Open IB33-F023A(B), Pmp Suction V1v.
8.2.5.4 Open 1G33-F100(F106), Recirc Loop A(B) Suct.
O c8.2.5.5 (Local) SI4WLY open, IC11- F026A (B) , CRD Supp Isol To RR
Pump A(B) until 3 - 5 gpm CRD injection flow is
established [CNMT 755' AZM 189'].
8.2.5.6 Open 1833-F075A(B) , Pmp A(B) Seal Stag Shutoff Viv.
* e . 2 . t, Idle RR Loop - Restart
NOTE
To facilitate loop recovery in minimum time, maintain:
11 AT between operating and idle loop s S0"F.
2) AT betweer' RPV bottom head and steam dome s 100*F.
8.2.6.1 If AT between RPV bottom head and steam dome is > 100*F,
increase RT flow from the bottom head region per
CPS No. 3303.01, REACTOR WATER CLEANUP (RT).
ti . 2 . is . 2 Place ' he idle loop's 1833-F060A(B),
Reci' r.CV in the minimum position.
O H.?.6.3 Adjust operating loop flow rate to s 16,209 gpm ( 5 0 '*. ra.ea).
h.
*
.*-4 It AT between operating and idle loop is > So"F, . lowly
operi the idle loop'. FCV to dectease the AT to? S n" V,
insuring that a 100*F/hr heatup rate is not exceeded.
I
4 .e' . '. Adiust rod pattern / power as recommended by t he IJF
H./.i.... St a r tup t.he idle RR pump per section u.1.1.
H . / . i . . "1 M,i tr h loop f lows to attain t he desi r ed power level.
Page No. 18 of 3d
Rev. No. lH
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a .%' ,s e . 3302.01
,
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CPS Mo. ..a., ~,,
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E3: .
(? .
RR PUMP SEAL PROBLEMS - RESPONGE ACTIONS _
JJ i " 9 8.3
8.3.1 RR Pump Seal Monitoring for Degradation /Failuro
8.3.1.1 Monitor seal staging pressures, temperatures, and flows for
any indications which would indicate pending seal failure.
* Reference Table 1, RR PUMP SEAb KEY PARAMETERS (page 20).
* Seals usually degrade slowly during steady state
operating conditions. Adverse trends are the best
indication of a degrading seal.
* Severe pump transients (loss of seal flow /coolin.j)ewill
usually result in rapid seal f ailur e requiring prem, t
A failed RR pump
actions to limit the seal leakage.
seal will leak - 50 gpm into the drywell.
the
" HH pumps can be operated indefinitely wit h eit her
inner or outer seal failed, providing the remaining seal
is capable of holding system pressure.
O 8.3.1.2 Refer to sections 8.3.2/3/4 while continuing here.
CP 8.3.1.3 Notify the NSED - ECCS & Reactivity Systems trends Team and or
Operations Management of any adverse seal
lir : sting par ameters.
for
*
An evaluation for corrective action should be made a
slowly degrading seals. This could include a MWH,
planned outage, ops Night Orders, and/or specific action
plans based on existing plant and seal conditions.
8.3.1.4 Determine seal condition f rom DCS seal pressure display.
a) Failure of No. I seal only (lower sea]) (5003-SE(5L)]:
11 o . 2 seal pressure will approach flo. I wal pressure,
causing alarm on excessive flow through staging 1.no
b) Failure of No. 2 seal only (outer seal) l5003-4E(4L)l:
No. 2 seal pressure will drop (depending on magn: rude),
causing alarm on excessive flow through leakage line.
c) Failure of both seals ( 5003-5E ( S L) and Ln03-4E!4L)):
Pressure in both seal cavities will drop (depending c:
magnitude) and excessive flows will cause bot h a la r:-r
H . l . l . ', IF Gross seal failure is indicated or 1: r . .o h. !,
Any Table 1 Pump Shutdown I.itai t
6.2.3, and
O THEN a) Perform an Emergency Loop Shutdown per
be prepared to isolate the loop per 4.?.4. ,
b) Ref er to CPS 110. 40u1.01, k Err T OP O i)l.At:T LEAEAGE
3 CPS 110. 4008.01, A1WORMA!. BF.trTok * vn.rsMT FLOW .
i
Page No. 19 o,1 30
Rev. !Jo. 18
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CPS No. 3302.01
O 9.3 RR PUMP SEAL PROBLEMS - RESPONSE ACTIONS (c:nt' d)
=
TABLE 1: RR PUMP SEAL KEY PARAMETERS
O . rends available on recorder and STA RR data tracking logs)
~ .
Pump
Max Allowable Pump Shutdown
ID Farameter/Menitored Points Normal Value without an Limit
Pt
Evaluation
DOS 4A: FCMP A(B) 1 SEAL PRESS 1020 psig 1200 psig n I
pg
B33DA005(El: RECIRC PMP A'.B) SEAL DP 1 N/A U ' I.
a .q_
PUMP A(B) 2 SEAL PRESS Lo: 100 psig ' 4
DCS 4A:
B33 DA007 ( 8 ) : RECIRC PMP A(B) SEAL DP 2
psig Hi: 980 psig .jp
%;
Recorder IB33-R601, Pt 9(21): W/ injection: 115'F 160*F (Alarm) -
'
AtB) Pump No. 1 Seal Cavity W/O injection: 150*r 4*F/ day rise '.I'
Peccrder IB33-R601, Pt 8(20): W/ injection: 127'F 160*F (Alarm) 250*F
'
I I
'"* 3
AtB) Pump No. 2 Seal Cavity W/O injection: 153*F 2*F/ day rise ,l 't'
;;
Rec der IB33-R601, Pt 10(221: , 146*F (Alarm) 1
" ^ 4 *F/ day rise !
A(B! Pump Seal Ccoler Water Discharge
"
...
Seal Leakage per !ndirect Peasurement 1 gpm/ day S/D Limit * k
J
rise, or
> 6.5 gpm
When 'i
FE-BA 01: DN EC'.*1? DRN SUMP FLOW N/A ITS LCO 3.4.5 !
/2
ccepletion
0.3 gpm/ day times -
rise, or
PF-BA301: DW FLO 5 DRN SUMP FLOW exceeded.
> 1.5 gpm
60 - 105'F 21S*F N/A *
l --
CC-IA013: 20 WTF MX OUTL HDR TEMP
PaTe No. ,20 ef 30
Rer. No. 16
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CPS No. 3302.01 ,, , , ,
h' O 8.3 RR PtHP SEAL PROBLEMS - RESPONSE ACTIONS (cont'd)
8.3.2 Degrading RR Seal Injection Flow
l
NOTE
'
Degrading RR Seal Injection' flow can be caused by
clogged seal line filters, Seal Line leakage (i.e.,
Relief Vlv leakage), and/or problems with RD.
.
Sustained operation with injection flow < 3 gpm is
consi'icred a Loss of RR Seal Injection and section
8.3.4 should be referred to for response actions.
i
8.3.2.1 Monitor RR pump seal temperatures. If temperatures are
rising, refer to 8.3.3 while continuing in this section.
8.3.2.2 Monitor DW and CNMT floor and equipment leakage rates.
8.3.2.3 a) (Local) Verify CRD injection flow to pump (s)
is 3 - S gpm (CNMT 755' AZM 169*). 6
If necessary to establish 3 - 5 gpm flow,
perform step 8.1.1.2 (pg. 10).
[1Cll-F026A(B) & ICll-D012A(B), ,
Flow Control Valve adjustments)
b) As necessary, shift RR Pump Seal Filters per
CPS No. 3304.01, CONTROL ROD HYDPlsULIC 6 CONTROL (RD). .
8.3.2.4 g Se .1 Line leakage results in operational concerns, :
,
THEN (Local) Isolate affected RR sea 1 injeet2en 1 ne
@~RR pump operation may continue due to internal !
seal flow and external cooling provided by ecx
a) Shut I CI 1 - F02 6A ( B) , CRD Supp 1801 To RR Pump.Is00.
b) Shut IC11 - F02 4 A ( B ) , CRD Supp To Rb Pump is tin
Page No. 21 of 30
Rev. No. _ 1R
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3302.01 "
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O 8.3 , RR PUMP SEAL PROBLEMS - RESPONSE ACTIONS (cont' d)
,
8.3.3 ' Rising Temperatures on RR Seals
. CAUTION
Substantially increasing RR pump seal CCW cooling
flow above the normal value to correct a high
temperature condition may cause seal failure due to
thermal stress.
U.3.3.1 Verify proper operation of CCW and RD.
Refer to section 8.3.4 as necessary.
'
CAUTION
With the RR pump shutdown and injection flow q
3
stopped, seal cavity will reach 185'F in - 30 to 60
minutes. Seal damage will occur at 250*F and the
time necessary to reach 250*F will be dependent 1
x
upon the seal leakage rate and initial cavity [
temperature. I
'
m .. =e , , . . }
8.3.3.2 PRIOR to RR Pump A(B) Seal temperatures reaching 250*F, _
f
a) Shutdown RR Loop A(B) per section 8.2.1.
t
4
b) Evaluate the need to isolate the RR Loop to prevent j{
seal damage. Idle loop isolating is performed per
section 8.2.4. ]
i
8. 3. 3. 3 E RR Pump A(B) Seal temperatures exceed 250*F,
(pump O-rings (, seal failure possible) (
,
a) Perform an Emergency Loop A(IH Shutdown
-
THEN
per 8.2.3, and isolat.e the loop per 8.2.4.
b) Shut IB33-F075A(B), Pmp A(B) Seal Staq Shut of f Viv. ;
i
n,. i t in3 i.nmp , !
c) If unniny, stop 1C11-cuno, lu pe Aux .
d) If shut, open IC11-F370, RCRC Aux Seal Prnp Vlv. ;
.
l' age !!u . 22 at 30
Rev. flo . 18 _
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CPS No. 3302.01
0 8.3 RR PUMP SEAL PROBLEMS - RESPONSE ACTIONS (cont'd)
c8.3.4 Loss of RR Seal Injection and/or CCW
8.3.4.1 Verify / restore proper operation of CCW and RD.
U.3.4.2 Monitor RR pump seal temperatures. If temperatur.ts are
rising, refer to 8.3.3 while continuing in this section.
8.3.4.3 Monitor DW and CNMT floor and equipment leakage rates.
8.3.4.4 E CCW Cooling Flow is lost to RR Pump A(B),
TilEN Within one minute, perform an Emergency Loop A(B) '
Shutdown per 8.2.3, and isolate the loop (s) per 8.2.4
8.3.4.5 g RR Seal Injection is lost
(sustained operation with flow < 3 gpm),
TilEN a) RR pump operation may continue due to internal
seal flow and external cooling provided by CCW.
b) If the pump trips when no RR seal injection flow
is available, immediately shut IB33-F075A(B),
Pmp A(B) Seal Stag Shutoff V1v.
c) Restore RR Seal Injection Flow per CPS No.
3304.01, CONTROL ROD flYDRAULIC & CONTROL (RD).
8.3.4.6 g Only RR Seal Injection is lost to both BR pumps &
the pumps are both secured, and
RD flow cannot be re-established wit hin ono hour,
TilEh Perform Recirc Pump Auxiliary Seal Injection
Pump Operation per CPS No. 3304.01 (RD). ,
,
H.l.4.7 g Both RD Seal Injection and CCW Cooling Flow :s I c .: t ,
(pump O-rings & seal failure possible)
TilEN a) Immediately perform Emosq.ncy h<,.>p A i. It ';hu t h,wns
per U.2.3, and isolate the loops per 8.2.4.
b) Shut I B3 3- F07 5A ( B) , Pmp Atii) Seal St ag Shut of f Viv. .
l
c) If running, stop ICI1-C100, RCRC isux Feal I ri j Pump. l
d) If shut, open ICI1-F170, prkC Aux f-:ea1 Irp v1v.
Page No. J3 of 10
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CPS No. 3302.01
,1** 4 .
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g,4 . ABNORMAL' OPERATIONS "'
8.4.1 Ftv Lockout / Reset \
,
,
a) Maintain steady state power and balanced recirc loop
T flows, if possible, by adjusting the operable FCV.
'
b Determine the cause of the lockout from alarm indicators
on 1H13-P614 and/or the annunciators on lH13-P680.
c) Correct the cause and restore the HPU A(B) equipment
to normal operation per CPS No. 3302.02, REACTOR
RECIRCULATION FLOW CONTROL liYDRAULIC SYSTEM.
c # Do not attempt to reset the RR FCV HPU units until
l positive plant control has been established, and the 'k l HPU reset evolution is being monitored for possible l RR FCV movement.
d) Reset any FCV runback signal per section 8.4.2.
1
e) Zero the A(B) loop SERVO ERROR. _
,
f) Reset the FCV A(B) Motion Inhibit Reset.
Verify the lead HPU becomes operational,
and FCV motion is no longer inhibited. I
!_
8.4.2 FCV Runback Reset
O wr.
;
NOTE
During plant operation, if a TDRFP trips and RPV
water level lowers to programmed Level 4, t.he RR _
FCVs t.ill partially close to - 191 indicated open
(- 50% core flow or - 54% drive flow).
A FCV runback is within the capacit y of on. Timi'l*
and 1 :, outside of the RESTRICTED ZONE.
l
'
a) Verify the runback initiat ion slynal is c ; e.i r . -
i~
b) Zero both Loop A and D LIMITER ERNORs.
'
H Ii.ptens both Cav Int 1L A (anil It ) i< e n . t /
Rx Run Back Reset. push-buttons. '
d) Verify both annunciators $001-11' and F.,
FCV AIB) Partial Closure Due To RFP T.tip clears.
Page No. 24 of 30
Rev. No. 18
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. . ..., w . . . . ~ . CPS No. , 3302.3L . .j.. .S,
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8.4.3 Fill / Vent RR' Loop
,
t
O
f10TE
The most convenient source of CY for this section
is in the CfMT. In order to utilize this source,
the DW Personnel Access !!atch interlock will need
to be defeated using appropriate administrative -
controls for the current plant status.
O
c8.4.3.1 Flush the CY supply line to be used in step 8.4.3.2
until an acceptable DI sample is obtained.
c8.4.3.2 (Local, DW) Downstream of 1G33-F422, RWC Suct lidr
Vent Isol, remove the cap, install a
hose, and attach it to a flushed CY supply
with a 15 micron absolute filter.
8.4.3.3 (Local, DW) Verify shut (Normally locked shut):
a) 1833-F051A(B) & F052A(B), Recirc Loop A(B) Dr n Isol.
b) IB33-F065A(B) & F066A(B), Recirc Flow Cont V1v A(B)
Drain Vlv.
O 8.4.3.4 If RT is in operation, shutdown RT per
CPS !Jo. 3303.01, REACTOR WATER CLEA!JUP (RT).
U . 4 . .i . 5 Shut 1G33-F102, RWCU Recire Suct Throt.
8.4.3.6 Shut the RR suction valve which is unisolar.ed,
1G33-F106(F100), Recire Loop B(A) Suct.
d.4.3.7 Open the RR suction valve which is isolated,
1G33-F100(F106), Recirc Loop A(B) Suct.
O 8.4.3.8 (Local) Station an operator at. IC11-F026A(A), CRD Supp
Isol To RR Pump A(B) . (CtMT 755' AZt4 189*]
Establish communications with the f4CR.
a.4.4.9 open/vera!y open IB33-F075A(B), Pmp A(B) Seal St ag
Shutoft Viv to provide a vent path.
O .. 4 i.In closely monitor the flo. 1 Seal Pr ea.s u r e for the
14 H loop b,3ing fi1 led (!w S m r c. n 4A, it4iliAnt.',(e.))
Page !Jo, 25 of 30
Fev. flo . lA
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. , . CPS No. 3302.0L -
.:. < -
_
_
L'.'<;i.: - 8.4.3 Fill / Vent RR Ioop (cont'd)
'li : O
5. .
E CAUTION
C
No. 1 Geal Pressure may increase quickly if -
the RR loop is not completely drained.
.
To prevent loop overpressurization, IC11-F026A(B)
and 1B33-F075A(B) must be shut immediately when .
No. 1 Seal Pressure reaches - 40 psig o_r_ is equal
to the idle loop pressure.
O 8.4.3.11 (Local) SLOWLY open IC11-F026A(B), CRD Supp Isol To RR
Pump A(B) and verify CRD supply to the RR pump seals is
3 - 5 gpm on flowmeter 1C11-D020A(B). If required, adjust
1C11-D012A (B) , Flow Control Valve to obtain 3 - 5 gpm.
Flow regulator, IC11-D012A(B) is used to adjust flow as
follcw Wr K2001-0009) : [CNMT 755' AZM 189*].
a) Loosen locknut and rotate stem until desired ficw is ,
attained. (Clockwise for decreasing flow, countet-CW
for increasing flow)
b) Lock stem in desired position by holding stem
steady while re-tightening locknut.
O 8.4.3.12 (Local, DW) If required, open 1G33-F421 t. F422, MWC Suct .
.
Ildr Vent Isols 1. commence t' i 11 i ng RP Loop A(10
0 8.4.3.13 (Local) WHEN No. 1 Seal Pressure reaches - 40 psig .3
-* .
is equal to the idle loop pressure, .
THEN Immediately shut / verify shut: !
a) IC11-F026A(B) - ChBT 755' ,
b) IB33-F075A(B) - DW '
c) IG33-F421 and F422 - DW.
8.4.3.14 (Local, DW) Remove the hose and tilter, and re-install
the cap on the RWCU suction header vent.
E.4.3.15 Shut the RR suction valve which was opened u s' ep
8.4.3.7, 1G 3 3- F100 ( F106) , Recirc Loop Is(Bi Suct.
H.4.3.16 Open IG:53-F102, RWCU Recire Suet Throt.
H . 4 . 'i . I 1 To itinure the loop and pump no.il .i t e vent ed,
uit isoltst e the loop .ite t ou t .it,i i :.h Cl li t.. the
seals per section 8.2.5.
O a . .l . i . l u it de.s n ini, t ens .n e t RT per
CP:3 No. 3303.01, REACTOR WATER Cl.EAfJUP ( l' T )
Page No. 26 or 30
Rev. No. _ 18
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!a
j 8.4.4 Draining RR Loop
:
4 CAUTION i
- Maintain RPV water level as constant as possible
j prior to the start of draining.
j Once draining has begun, any increase in RPV makeup
i or any RPV level decrease will be due to inadequate
1 loop isolation for draining.
i
8.4.4.1 Verify RR Pump 1A(IB) is secured.
3
- 8.4.4.2 Isolate RR Loop A(B) per section 8.2.4.
.
i 8.4.4.3 (Local, DW) Open IB33-F051A(B) & F052A(B), Recirc Loop
A(B) Drn Isols. (Normally locked shu*.)
! 8.4.4.4 Ensure RPV water level is not decreasing. 1 . IF Level is decreasing, l THEN Shut ,lB33-F051A(B) and F052A(B). ! i 8.4.4.5 (Local, DW) Open IB33-F065A(B) & F066A(B), Recirc Flow { Cont Viv A(B) Drain Viv.
(Normally locked shut)
i j 9.4.4.6 (Local, DW) Open the following to vent the locp: 1 l I H 3 3-F001 A (B) , Recide Pump A(B) Seal Supp Line Vent l [AZM 140*(AZM 135/295*) OB 8' above 123'] I j and ! I H 3 3- F002 A (B) , Recirc Pump A(B) Seal Supp Line Vent l [AZM 140*(AZM 135/295*) OB R' above 723')
I
i b.4.5 Containment Isolation Recovery
a) Refer to CPS No. 4001.02, AUTOMATIC ISOLATION.
l 1) Refer to section 8.3.4. '
c) When the prerequisites of the AUTOMATIC ISOLAT:ON
procedure are satisfied, re-open IF.33-Fo19 and Fli: ,
H. .ict or Recirculation Sa'rple Int 4o.ird . uni out tu i .: i
- Isolation valves respectively, as necessary.
! i j 'J . G ACCEPTANCE CRITERIA - None i '
10.0 FINAL CONDITIONS - None ,
k l Page No. 27 of 3tJ_ [ Rev. No. 18 l t _ _ _ _ _ _ __ _ - . _ _ _ _ _ . - _ -. - . - . _ _ . ___ _ _ _ _ _ _
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3302.01
*
* ' CPS No.
3l*
- . . -. . . . . ,
,
11.0 REFERENCES
- 11.1 Procedures
i: a) CPS No. 2214.01, CORE FLOW VS. RECIRCULATION
*
-
FLOW TRENDING
[ b) CPS No. 3106.01, MOISTURE SEPARATOR REHEATER
c) CPS No. 3203.01, COMPONENT COOLING WATER (CC)
d) CPS No. 3211.01, SHUTDOWN SERVICE WATER (SX)
e) CPS No. 3214.01, PLANT AIR (IA & SA)
f) CPS No. 3302.02, REACTOR RECIRCULATION FLOW CONTRub
HYDRAULIC SYSTEM
g) CPS No. 3301.01V001, NUCLEAR BOILER VALVE LINEUP
h) CPS No. 3303.01, REACTOR WATER CLEANUP (RT)
1) CPS No. 3304.01, CONTROL ROD llYDRAULIC AND CONTROL (RD)
j) CPS No. 3305.01, REACTOR PROTECTIVE SYSTEM
k) CPS No. 3501.01, HIGli VOLTAGE AUXILIARY POWER SYSTEM
1) CPS No. 3502.01, 480VAC DISTRIBUTION
m) CPS No. 3503.01, BATTERY & DC DISTRIBUTION
n) CPS No. 3507.01, STATION LIGHTING AND LOW
VOLTAGE SYSTEM
o) CPS No. 4001.01, REACTOR COOLANT LEAKAGE
p) CPS No. 4001.02, AUTOMATIC ISOLATION
q) CPS No. 4008.01, ABNORMAL REACTOR COOLANT FLOW
r) CPS No. 9041.01, JET PUMP OPERABILITY TEST
11.2 General Electric
c a) GE SIL N203 Category 3 (6.4.b)
b) GE SIL N303 Category 4 Recommendation kl
c c) GE SIL N406, CHM-87-017/CCT N045934 (6.7)
c d) GE SIL H528 (4.3)
e) GE Tech Manual K2801-0004: RR Pump Motors
f) GE Tech Manual K2801-0005: RR Pump
g) GE Tech Manual K2801-0009: Flow Begulator
h) GE lirawing Nos. 22A3112, 22A4071, 851E'100
i) GE 24A1921, Single Recirculation Pump Operation
11.3 Industry Events
e a) SER 12-83/CCT N00!320 (8.1.1.2, 8.2.5.5)
c b) SER 04-28/CCTs NOL"938 (6.2.a) and #000939 (6.1:
c c) SER 05-93 (4.4)
: d) SOER 81-07/CCT N002061 (4.9.a/e, 5.8, 8.2.1,
8.2.2 H.2.3, 8.3.4)
.- el SOER 84-07 (8.2.1.4, H . 2 . ' . , H . ' . 3 . .' )
<- t) INPO Eval N90-18, Finding OA.1-2a/CCT N054/20
( H .1.1. 3, 8.1.2.4)
e q) SER 5-93/GE-NE-B1100582-01 [TMEl-94-0010) (4.6)
e h) BWROG Stability Interim Guidelines, 6/6/94 (6.11)
l
Pmje l'o . 28 et .hi
Rev. No. la
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+ CPS No. 3302.01
11.0 REFERENCES (cont'd)
11.4 Tech Specs (ITS/ORM)
a) ITS LCO 3.4.1: OPERATING RR Loops / Single Loop
b) ITS SR 3.4.1.1: RR Loop Flow Mismatch
c) ITS SR 3.4.1.2: Power / Flow Operating Limits
d) ITS LCO 3.4.2: OPERABLE FCV in operating RR Loop
e) ITS SR 3.4.3.1: RR Loop, Drive, & Jet Pump Fiews
f) ITS LCO 3.4.5: RCS Operational LEAKAGE Limits
g) ITS LCO 3.4.9/10: RCS - RHR Requirements
c h) ITS SR 3.4.11.3/4: RR Pumps AT Start Limits (8.1.1.4)
c i) ITS SR 3.4.11.8/9: Single Loop AT Limit (0.1.3.7 NOTE)
c j) ORM TR 4.3.1.5: Reactor water conductivity (6.2.g)
11.5 Condition Reports
c a) CR1-88-12-072/CCT N049840 (4.2, 4.9.c, 4.10.a/c/d))
e b) CR1-89-05-098/CCT N051144 (6.2.g) _
_
c c) CR1-89-06-066/CCT N051290 (6.4.b)
c d) CR1-89-11-038/CCT N055436 (6.9)
c e) CR1-89-11-045 (6.8, 8.2.1.1/8.2.3.1 CAUTION: Item 2,
8.2.4.8)
c f) CR1-94-04-054: Use of 15 micron filter (7.0, 8.4.3.1/2)
c g) CR1-94-04-025: RR FCV Drift (4.7, 8.4.1.c Supp Info)
11.6 NSED Items
c a) Field Alt M-F013/CCT N048601 (2.4)
b) NSED Design Record File No. 338
e c) NSED Memo Y-100151 to operations dated 08-21-92,
"RH Pump Wear Ring Failure indications" (4.H)
c d) NSED Ltr Y-103113, N37-93(11-18)-6, Stability Control
Interim Corrective Action: Shifting RR Pumps (2.2) :
c e) NSED Ltr Y-94348, UO90-90(06-27)-6, ANR-90-047,
REACTOR RECIRCULATION PUMP SEAL PARAMETERS (Table 1)
12.0 APPENDICES - None
13.O DOCUMENTS _
CPS tJo, 3302.01E001, REACTOR RECIRCULATIO!J ELECTk!CIs!. L!?!EUP
CPS t!o. 3302.01V001, REACTOB BECIRCULATIOt1 VALVE lit:EtJP l
CI'S No. 3302.01V002, REACTOR RECIRC lt!STk VAL'IE L!?;EMP
Page !Jo. 29 01 30
kev. !!i i . le
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. _ _ _ _ _ _ _ . . _ _ _ _ . . _ _ . _ . . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . . _ _ _ _ _ _ _ _ _ _ _ _ _ . . _ _ . . - _ _ _ _ ___ ___ m
.
- ?
O CPS : 0. 3302.01
}.
t ,
Figure 1
i PCWER
M" 2 STABILITY CONTROL & POWER / FLOW OPERATING MAP
l
IIOO#78I IIOUIIO7I
2894.0 100 -- - - -- _ _ . ..
2604.6 DO -
,,315 ' 80 -
-
20058 70
E /g
1736.4 60
#
>
1447.0 50
'
'
1157.6 40
868 ' 30
.
'
! 5?fi a 20 ; :n-^ - - - - -
j, x
*
l U SINGLE LOOP - CAVITATION l
ENVELOPE PROTECTION l .
,/ :
2 tits 4 10 / LINES '
CONTROLLED-! * l SPEED2 (HIGH PUMP , l
OPERAY!ON)
;
Oi 0
ENTRY REGION
/ ;
l l
*-
'
O 10 20 30 40 50 60 70 80 90 100 1101
0 8.4 16.9 25.3 33.8 k U.2 50.7 59.1 67.6 76.0 84.5 9 92.9
10 %
CORE FLOW
Core f l o ., indication as available via several means (Jet pump flows. core plate dP, 3D/CD-3 cales).
When 'wJ RR purps are runn1ng, the most accurate and preferred indication
'
of tot *1 core flow as via 3ct pump flow (computer point B33DA024).
When ey RR pump running, the only valid indication of total core flow .s via core plate dP
tromputer point B21ND001. DCS screen 4E/147). due to reverse loop / Jet pump flow a naccu ra :t e s .
1
T .2 E h . *
, _., }
'
b d '# - *'
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...........,..-.7..,. .. .. mum -
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ __ _ _ _ _ _ _
.
.
2/3/97
Renttor Recirculation Pump Seal Failure Special Inspection Violatiors
Root Cause Corrective Action
Violation # Violation Description
"
r Streng- aw---:=* for pt- - 9-; " eand p , M
9601042a CPS 1005.14,"Formadng of Procedures and Dww. ets," Step 8.1.11.4, Vague er U --lear E---:=:aat for Feure 'P-: guidance.
s tates that if a spexific order of perfonning the procedure is required, an tack of Rigor in Complying with Procedures
astensk (*) should be placed at the beginning of the section to annotate All on-shift and active licensed and non tv-d individuals attmW
t hat the steps are to be performed in the sequence they are wrinen. t raining which consisted of a series of armmnr 1) a review of the
3302.01, *Rx Recirculaten,* Sec. 8.2.4. had an asterisk at the begramng September 5 event by the Accmas Plant Macager Operations,2)
of the section. The failure to perform the procedure in the order mitten 1 -= Imarned from the September 5 event maducted by the Shift
is an apparent violation of TS 5.4.1." Procedure." Supervisor involved in the September 5 event,3) Proadural
f'a-F== and Adherence andTrmning on Appendix B, Criteria V,
4) Conservative Decision Making presented by each crews Shift
Supervisor 5) a presentation on Management Oversight and Roles
conducted by the Plant Manager and 6) Specific treining was provided
on procedure changes.
Plam or equipment conditios limits have been provided to ensure
mnservatis n. Operation of the plant at power, with Reactor
Recistulation pump seal degradation mwding wr.scrvatively
estabhshed limits will not be permitted by revising CPS No. 3302.01
Practor Rectrculatien proceduralizing that the reactor be shutdown on
indication of a failure of either of the 2 - 100% tedundant seals on the
, Reactor Recirculation Pump.
Conservative decision making emphn< iring safety of operation and
procedure camp *- has been inwrporated into accredited continuing
training programs
CPS Operations has implemented a" _ - - ; ==t monitoring program
(la Plant Crew Observation and Monitoring Program) to ensure and
enfarce nunagement s c :.-a for procedurst adherence and
conservative decision making
A follow-up seminar on conservative decision maing emphasizing
safety of operation, including lessons learned from CPS and industry
expenence, will be provided to Site Managers, Plant Staff
Directors / Asst. Director-Operations. Work Control Team traders,
PageI
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Reactor Recirculation Pusan Seal Failure Saecial Tesnection Vietation 2/3/97 i
VWh # Violaties Description Rest Canoe Corrective Ac*me i
Facihty Review Group Messbers, Lirased and Non f w t
W-W, ShiR Teh Advisors, Syunsa Engineens
Active operaser hcense helders, and & W
l
Fonowing namn to normal 5-hour shiAs aAcr RF4, the Plant Manager *
will begin a pracace of W having informal conversatsens with ,
ear-goins *r w aopereness per===d. nas win enh===
,
between crew enembers and the Plam Manager, and to
essene swammens of-_ - ,
rma== and . _ .. decamon
indiae ;
1 ,
7
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Reactor Recirculation Pumo Seal Failure Special Inspection Violation 2/3/97
Violation # Violation Description Reet Cause Corrective Action 9601042b The closing of tir seat injecuan vahe was a second example of. Vague or Unclear E=-wh= for Pwedure r '~aalam Strengthened *==~a= for predare , '-- and primded
procedural steps not being performed in sequence for a procedure section Lack of Rigor in Comolymg with Procedures gundm
proceeded by an astensk (3302.01, section 8.2.4). The failure to perform
the procedure in the order wrinen is an apparent violation of1115.4.1 All on-shift and active bcensed and non licensed indmduals attended
Promdures.* training which consisted of a series of seminarr I) a review of the
September 5 event by the Acmract Plant Manager Operanons,2)
- Learnal from the September 5 event conducted by the Shift
Supenisor involved in the September 5 event,3) Procedural
rW- and Adherence and Training on Appenas B, Criteria V,
4) Conservative Decanon Making presented by each crews Shift
Supervisor 5) a presentation on Manage = ear Oversight and Roles -
conducted by the Plant Manager and 6) Sp=E training was provided
on pmcedure changes.
Plant or equipment condition limits have been provided to ensure l
conservatism. Operation of the plant at power,with Reactor
Recirculation pump seal degradation *=wwhng-.aJ,dy
established limits will not be permitted by revising CPS No. 3301.01
, Reactor Recirculation ;---- t-- S5 that the reactor be shutdown on
indication of a failure of either of the 2 - 10C*A rabimiant seals on the
Reactor RGch Pump.
Conservatin decision making emphasizing safety of operation and ,
procedure _--_--91=== bas been incorporated into accredited continuing
training programs
CPS Operations has implemented a -- =; --- monitoring program
(In Plant Crew Observation and Monitoring Program) to ensure and
enforce -- - - ; - - expectations for promdural adherence and
cxmservatin decision making.
A followw2p seminar on conservative decision making craphasizing
safety af operation, including lessons learned from CPS and industry
experience, will be provided to Site Managers, Plant Staff
Page 3
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IV-
Reactor Recirculation Pump Seal Failure Special Inspection Violation 2/3/97
W!ation # Violation Description Root Caese Corrective Action
-
DirectorsfAsst. Director % . ions, Work Control Team Leaders,
Facility Review Group Members, lacensed and Non-Lacensed
Operations personnel, Shift Technical Advisors, System Engineers,
Active operator license holders, and management monitors.
Following return to normal 8-hour shifts after RF-6, the Pfant Manager
will begin a practice of routinely hasing informal conversations with
off-going midnight operations personnet This will enhance
communication between crew members and the Plant Manager, and to
ensure awareness of operational conditions and conservative decision
making.
9601041b An Unusual Event was declared due to =aideeine d leakage > 5 gpm. In Inattention to Detail, Lack of Rigor in Compl3 ing with Strenginened expectations for procedure compliance and provided
addition, the appropnate TS LCO was entered which allowed 4 hrs to Procedures. guidance.
raluce the leakage to <5 gpm. 4001.01,"Rx Coolant System Irakage,*
was also emered due to the abnormalleakage condition. The hcensee All on-shift and active licensed and non licensed indisiduals attended
identified tha* 4001.01, Step 4.4, directed the MCR staff to notify RP to training which consisted of a series of seminars I) a review of the
help in the iden:ification of the source ofleakage. This was not September 5 event by the Assistant Plant Manager Operations,2)
performed. The failure to perform this step of the procedure is an lessons learned from the September 5 event conducted by the Shift
apparent violation of 10CFR50, APP B, Criterion V, Instructions, Supervisor involved in the September 5 event,3) Procedural
'
Procedures and Drawings. Compliance and Adherence and Trair'eg on Appendix B, Criteria V,
4) Conservatin Decision Making presented by each crews Shift
Supervisor 5) a presentaten on Management Owrsight and Roles
conducted by the Plant Manager and 6) Specific training was provided
on procedure changes.
CPS Operations has implemented a management monitoring program
(In Plant Crew Observation and Monitoring Program) to ensure and
enform management expectations for procedural adherence and
consemitive decision making
.
Pace 4
- _ - - - _ _ _ _ - _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - - _ - - _ _ _ ___- - _ _ - _ - __ __--.
]
.
Reactor Recirculation Pump Seal Failure Special Inspection Violation 2/3/97
Violation # Violation Description Root Cause Corrective Action
960lO41c Between 0228 and 0310 hours Rx pwr was reduced from 55 to 38% Inattention to Detail;1ack of Rigor in Complying with Strengthenest e=Ww=s for procedure - ;h- - and provided
3005.01, step 6.1.b, requires that a gaseous sample be taken when Procedures. guidanc:e.
thermal pwr changes exceed 15% Ahhough pwr had been reduced by
17%, the bcensee identified that a gaseous sample was not obtained due All on4hift and active beenmi and non licensed individuals attended
to operations failure to notify the Chernistry Dept. This is an additional training which consisted of a series of seminars: 1) a review of the
example of an awarent notation of 10CFR50, APP B, Criterion V, September 5 event by the Assistant Plant Manager Operations,2)
* Instructions, Procedares, and Drawings.* 12ssons Learnos from the September 5 event maderd by the Shift
Supervisor involved in the September 5 event,3) Procedural
Caa'ati=* and Adherence and Training on Appendix B, Criteria V,
4) Conservative Decision Making presented by each crews Shift
Supervisor 5) a presentation on Management Oversight and Roles
conducted by the Plant Manager and 6) Specific training was provided
on procedure chinees.
CPS Operations has implemented a manageraent monitoring program
(In Plant Crew Observation and Monitoring Program) to ensure and
enforce management expectations for procxdural adherence and
costservative decision making.
>
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Pace 5
_ _ _ _ _ _ _ _--__. __- -- - _-___- _ __ - --_- - _ _ _ _ _ _ _ _ _ _ _ _ _ - - _ _ _ _ _ - _ _ - _ _ - _ - _ - - _ _ _ _ - _ . . - .
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Reactor Retirculation Pump Seal Failure Soccial In pection Viciation 2S/97
Violation # Violation Description Root Cause Corrective Action 96010-Old Dwicg the event, the @ ors hM 1m_ a,g...: and the SS Vague or Unclear Expectations for Proceduree,=nnsiance; Strtngthened m : G-- for procedure comphance and prmided
directing acsnities in the MCR rather than remunmg in a snonitoning Lack of Rigor in Complytng with Procedures. guidance.
role. I401.01. "Conducs of Operations," step E.3.3.1, states that "the SS
should report to the control room and remain in a monitoring mle during
All on-shift and active li<vnsed and noa 1svn=ed individuals attendM
off normal operation unkss the SS determines that the line Asst. SS is
trunmr which nmaaed ofa acries of scanner 1) a review of the
not able to deal with the situauort This is an huary situation, and
--
September 5 event by the Assistant Plact Manager Operations,2)
it is expected that in all but extreme cases the SS will remain in the
Lessons Learned from the September 5 event conArtM by the Shift
monitoring roode? The failure of the SS to remain in a monitoring role Supervisor involved in the September 5 event 3) Procedarat
during the event was an apparent violatson of 10CHt30, AFP D,
re==nli- and Adherence and Tomme on Appendix B, Criteria V.
Cnterion V, " Instructions, Procedures and Drawings? 4) Conservative Decision Making presented by each crews Shift
Super <uor 5) a preernatian on M-=-anae Oversight and Roles
cenducted by the Plant Manager and 6) Specific training was provided
on promdure changes.
Conservative decision making emphauring safety of operation and
procedure a=npfi== bas been incorporated into accredited cortinuing
training programs
*
CPS Operations has implemented a = ; - 2 suunitoring prog +am
-
(la Plant Crew Observation and Monitoring Program) to casure asi
enforce management expectations for pic:= dural adherence and
conservative decision making.
Foilowing return to normal 8-hotcr stufts after RF4, the Plant Manager
will begin a practim of routinely having informal mnversadans with
off-going midnight operations personnel 11.is wi I enhance
communication between crew rnemters and the Plant Manager, md to
ensure awa.eness of operational conditions and conservative deci.. ion
making.
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Reactor Recirculation Purno Seal Failure SpecialInspection Violation 2G/97
Violation # Violation Description Root Cause Corrective Action 96010-Olf On the following day, the inspectors discovemi that the twenwe was not Vague or Unclear 0;- r- a for Proadure Ce==fi , Training has been provided to clarify tlus leakage rate is Total f edare
trwunr identified leakage Juring the event. At the inspectors request, lack of Rigor in Complying with Procedures. which is a sum of Identified I ed are (RE) and Unidentified leakage
the hcensee finally performed the required calculauons and determined (RF). Emergency Plan Implementing Proadure EC-02 was revised to
that the Alert cnteria of 50 gpm had been not exceeded (highest total clarify totalleakage.
leakage was 48 gpm). 1401.01, step 8.1.6.2a states that *during off
normal conditions one of the pnmary duties of the STA is to assist the SS Training was conducted on the ID027 Martificerion
m the idaahea of the proper EAL cl=efe The lack of
evaluating conditions both during and following the event, specifrally The leak detection system has been repatred and a new bulkler system
within the first 30 min. following the seal failure, in order to monitor IE028 is being installed this refuehng outage to prtmde more reliable
possible entry into an emergency classification mndition is an apparent indication act susaptible to biological fouling.
violatson of 10CFR50, APP B, Cnterion V," Instructions Procedures and
Drawings * Strengthened expectations for pmcedure camalin=* and prtmded
guidance.
All on-shift and active licensed and non lirenevi individuals attended
training which consisted of a series of seminars: 1) a review of the
September 5 event by the Assistant Plant Manager Operations,2)
Lessons Ixarned from the September 5 event conducted by the Shift
. Supervisor involved in the September 5 event. 3) Procedural
Complianm and Adherena and Training on Appendix D, Criteria V,
4) Conservative Decmon Making presented by each crews Shift
Supervisor 5) a presentation on Management Ostrsight and Roles
conducted by the Plant Manager and 6) Specific training was prmidal
on procedure Changes.
CPS Operations has implemented a - - - ; --- -4 monitoring program
(In Plant Crew Observation and Monitoring Program) to ensure and
enforce management expectations for procedural adherence and
conservative decision making
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Reacter R*eieculaties Pasan Seal Failure Snecesilassection Violation - 2/3/97 ,
I
. Vielsenen Descriptism Root Canse Corrective Action
Violatsen # -
i
t
96010-01g A review of the RO log showat that no entry had been made to i=hente Plant Matenal Cemdatana Defiaemcy; lack of Rigor in - Matenal r'h reymund for IFWO21,
the opennag of the main flow vahe. Although PMSO-43 requued a log Cosmplying with Procedures.
- - and psovided j
entry to be mande, the iw deter ===as that PMSO-43 was met Strengthemed *=l=r*=h== for precahme
!
apphadde to the ainsation. However, 1401.01, stepg.4.4.10e, separts all gh.
absonmal plant coedstness to be logged la both the SS and MCR logre i
liie RO who was E , ' '- for log keeping adesrand that he should All on-shift and active tire ==ad and mon licensed indmenals asa= dad i
;
have minde the log entry. The failure to etm entry into na absonmal training which h of a series of =====s: 1) a seview of the
3
plant condation is an apparent violation of 10CFR50, APP B Cntenoa M 5 event by the Assastamt Plant Manager C,-- _ 2)
,
V, *lestructions, Prr==hwes, and Drawings? I ==== IAarmed front the bysa=d=< 5 event tw==h=ed by the Shit
Supervisor envohed in the br==d=r 5 event,3) Procedural l
C_ - and Adhesessa and Traamang en Appendix B, Cnteria V,
4) Conservative Decision Making pe===aat by each csews ShiR '
Supervisor 5)ra .--. en Ma==ge==ar Overaght and Itales
'
conducted by the Plant Manager and 6) Specdic traumag was provided
ce proemdure W
- CPS Operations has : , " a ====ge==* mismatonag pungram
(la Plant Crew Observations and Mosatones Programa) to emane and
'
- , emforce ====g -*=' *=ra'="aae for procedural adhesence and
manervative dedsson masking.
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Reacter Recirt=Imelan Pusan Seal Failure E=aci=I I===~eia= Violation 2B/97
Reet Cause Corrective Action
Wietion # Violassen Description t
:
On byse-her is, the "A" RO, dear ==ned to be the "at the coatmis lacitof AnentsontoDetail,Managenem E .-^ - for Per== net involved taaerviewed ami ====8=d by his ShiR L, ._,
96011 42
RO," leR the ares hg==aad by 1001.05, as the "at the controls * portion Procedere Campinance act Emibreed.
,
11me "A" CRO was also M by the Aammam Plant Manager , ,
of the control room for approximately 3 mantes without the knowledge *
Operatanas and the Plant Manager.11 mis included an *=Th=== on the
of other coment room operators without conducting any turnover
., of the i nrwanad Operseer At The Contiels, j
"
10CFR50.54(m)2iii proper inseria watch termover and the une of -
10CFR50.54(m)2iii ansees when a nuclear power ue t is la na
" mode other than cold shutdown or refuehag, as stefina4 by three part <=====sr=riam
C---
the unit's Tarh=ar=1 Specincations, auch lirwaeae shall have a pernos
habhne a Senior Rancear Operater (SRO)lirwaar for the enclear power
Strengthened & for procedere immpliance and ttvec part 6
comu===runan, provided g=d==rw in CPS 140I.01 Rev. 25 to f
unit in the courrel seem at an ei=*= la additten to this SRO, for each
reinforce proper bne6ag pner to turnover of waarhamasas d; ties,
fueled narlear power unit, a Ino===t RO or SRO shall be present "at the
coatmis" at all tinies. Centrary to the above, the"at the controls RO sacheding short teret selief. t
left the at the desig==aat controis area without a proper relief. This was ,
an apparent violation of 10C11t30.54(m)2iii. '
All on-shiR and active lirwa=ad and men licemand individaals a tiended
training which <====nad of a series of seminars- 1) a review of the ;
bree-hee 5 event by the Assistaat Plant Manager Operuname, 2)
I -learned fican the S tee-her 5 event h by the Shift !
Supemaer involved in the Septe= hee 5 event,3) Premharai !
,
e and Amnerence and Training on Appendix B, Critens V,
f
4) ca==*rvative Decisen Making ynnemend by each crews ShiR
Supemmor 5) a presemessian. on Manage =new Oversight and Roles ,
conducted by the Plant Manager and 6) Specine treams was i
Pmvuled on premiere changes.
CPS Operanons has * ^ " a management monitoring pmgram
(la Plant Crew Observatica and Monstertag Program) to ennore and l
caforce manage ==e evy-+=eiens for procedural adhesence and
conservatrve decision making, .Waarhenanaa turnover and reliefis
specificauy evaluated in this prograre. t
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Reactor Recirculation Pumn Seal Failure Special Inspection Vinfation 2/3/97
Wistion Description Root Cause Corrective Action ,
Wistion #
96011 4 2 CPS 1401.01, Section 8.4.3.13, states that the RO *At The Controls" Lack of Attennon to Detail; Lack of Rigor in Complying with WCs-d expectations for r ide % and three part.
amt the LASS may be rehewed for short periods of time for persceal Procedures. ^ - Pmvided g=d==a in CPS 1401.01 Rev. 25 to
reasons. As a minimum, the person being relieved shall inform the reinforce psoper bne6ag prior to turnover ofwatchstaban duties,
relief of the current plant status, operations in progress and work to be including short term relief.
perfonned in the immediate future. Failure to perform an adequate
turnover ofcurrent plant status was an apparent violatico of TS 5.4.1. All on4hin and active licensed and nos twn=t indmduals attended
trauung which consisted of a series of senunars 1) a review cf the
September 5 event by the Assistan: Plant Manager Operations,2)
Lessons Learned front the September 5 event conducted by the Shin
Sopemsor involved in the September 5 event.3) Procedural
r -- a:ad Adherence and Training on Appendix B, Cnteria V,
4) Conservative De=a= Making presented by each crews ShiA
,
Supervisor 5) a &wiaa on ?" _
- Oversight and Roles
conducted by the Plant Manager and 6) Specific tr=ining was
provuled on procedure changes.
CPS Operations has : ,' =-- ? a management monitoring program
On Plant Crew Observanon and Monitoring Program) to ensure and
, enform _ - - Pdian= for procedural adherence and
-..G., decision making. Watchstauon turnove~ and reliefis
specifically evaluated in this program.
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Reactor Recirculation Pumn Seal Failure Specist Inspection Violation 2/3/97
Violatien # Violation Description Root Cause Corrective Action.
~
96011-03b Dunng startup of control room veneitstwm train "B' on September 18 a iluman Ener, Lack of Rigor in Ca=F== with Praxdures. De Shift Supervisor discussed this error with personnel incotved -
non-bcensed operator failed am follow CPS 3402.01. Dunng fdling of
the Centrol Room Makeup Filter OVOD95B Moisture Separator Imop Valves OVC043B and OVON6B were restored to speczfied positions
Seal, step 8.1.1.1.1.a required the moisture separator drain valve and the Main Control Room Prefilter was checked to assum no carry
,
0VC044B to be closed, step 8.1.1.1.1.b required the loop seal fdl valve over of water into filter.
0VC096B to be opened for one nranite and then reclosed, and step
8.1.1.1.1.c required the moisture separator drain valve OVCD43B to be Strengthep-d *=~~- for proadure ==9*= and pronded
reopened. While waiting for the icop seal to fill, the operator proceeded guidance.
with other cxrttrol room ventdatica panel vertScations later in the
procedure. However, the operator tSen failed to return these valves to Pronded additional training on human error prevention techniques
their original positions as required in steps 8.1.1.1.1 b and c. De error during site wide stand-down.
was eventually identified during the hcensee's innstigation ofincreased
inputs so radwaste due to the resulting increascxi flow into the control All on-shift and active hcensed and non li-et individus!s attended
building equipecnt drain sump. De involved operator iMicated that training which consisted of a series of armin=s: 1) a review of the
work load or fatigue were not factors in the error. De failure to follow September 5 event by the Assistant Plant Manager Operations,2)
the procedure while fdling control room ventilation loop seals was an Lessons Izarned from the September 5 event conducted by the Shift
apparent violation of TS 5.4.1. The specific safety significance of the Supervisor involved in the September 5 event 3) Procedural
ervor was mmimat . namely increased drain flow. Elowever, the error raam!6- and Adherenm and Training on Appendix B, Cnteria V,
could have resulted in wetting of the matrol room charmal filter. The 4) Conservative Decision Making presented by each crews Shift
inspectors also noted that several days after the error, the involved Supervisor 5) a pr-titinn on Management Oversight and Roles
operator had not been made aware of the specific steps and actions that conducted by the Plant Manager and 6) Specific training was
had not been accomplished correctly. prv.ided on procedure changes.
CPS Operations has implemented a inanagement monitoring program
(In Plant Crew Observation and Monitoring Progryn) to ensure and
enforce ice 46 expectations for procedural adlerence and
conservative decision making.
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Reactor Recirculation Pusan Seal Failure Snecial Inspecties Violation 2/3/97
i
Violation Description Root Cause Corrective Arei==
Violation #
Human Error, lack of Rigor in C - with Pr==kwes. The Aeneraar Deressor Plamt Operations emend this error was -
960ll-03c The maparters concluded that the twe==ae demonstrated poor artenuon
to detail when addnessag the packing leakage form IFCD04A. neviewedbyallcrews. '
;
spar,ncety, IF0004A, was alloned to contiene amkine n at a rate of 1000
The syntesa was nsenred to st=rin e!d =ar- as seqaired by CPS
gallons per day without verifying that the system was property aligned in '
acusadance with CPS 3317.01. This is an apparent v=sarma of TS 3317.01.
5.4.1.
Addanomat traising provuled on t= man erser prevention N
during site wide senadfown.
4
c-: f ----v=.ons for procedme .
- and provuled ,
;
an= tant.
All ca-shiR and active lirwa==E and non lina ===I indeve&aale attended
tranung which na==iard of a series of aa===arr 1) a review of the !
Sepeceber 5 event by the Aa====r Plant Manager C, 12) -
r m Imarned Roma the Septendier 5 event conducted by the ShiR !
Superviner involved in the W 5 event,3) Pmoederal
e. = and Amerence and Training on Ant ==A= B, Critena V,
,
4) Conservauve Dar==== Malung presented by each casws ShiR
Supervisor 5) a pummammanan on Mm=ar===r Overught and Roles
na=h by the P' ant Manager and 6) Specine training was
provuled on procedure ^==cae
CPS Operations has ' - "a management unomatonag program ;
(In Plant Csew Observanos and Monnonag Prograni) to ensee and
enfone manernwns Pe=a for prdiral adherence and
conservative deamon making.
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Reactor Recirculation Purne Seal Failure Special Insocction Viointion 2/3/97 .
t
Vielstaos # Violation Description Root Cause Corrective Action
,
3 96011 44 CPS TS 5.2.2.3 saanes * Controls shall be included in the preadures such Lack of Rigor in iWE-w with Procedures; I.ack of Insuated recumag sien ter CCT (8063352) to provide a resanadw to-
that indrvidual OT shall be reviewed monthly by the Pit Mgr. or has Anearma to Detail. perfonn the overtime reviewt Person now . , is awareof
,
designee, to ensure that ewe ==ve hours have not been assigned? The review . , therefore no trainingis regered
==g==*=s review of CPS 1-1.01 revealed that step g.7 requires at least
nionthly review ofindmdual OT records by a, :-. ..: : --- - _ ---- ---- *r q u e- =
a - for procedure raairlinare and prmided
A note in CPS 1001.01 allows a group supervisor *s review / approval of g= * ar* ,
bi-monthly Time Control Reports as a vacane of satisfymg these OT
record review . ----- Theinapartarsintervieweiar- All on-shift and active licensed and aan ke===t indmduals areemead
managers and desernuned most Mm were perfanning a cursory training which eviam*M of a series of sesmnars- 1) a review of the
check of bi-monthly time control reports to venfy that individuals had September 5 event by the Assistant Plant Manager Operassoas,2)
act exow ted the workang hour limits. The inger*ws request to review r essaae IAarned from the Sepneadier 5 event coadw*at by the ShiR
the niethods used in the operauons department to sneet the TS caused the Supemsor mvolved la the September 5 event,3) Prarentural
I===ar to ideanfy that a review ofindividual overtune was not being N Ha-~ and Adherence and Training on Appenha B, Criteria V, ,
, perfonned for operatacas personnel De failure to perform monthly 4) Conservative Decision Making presented by each crews Shift
review ofindividual overtime for operations per== net who performed Supervisor 5) a preseararion on Mar.egemear Owrmght and Roles
safety related funcuans is an apparent vmlauan of TS 5 2.2.e. conducted by the Plant Manager and 4 Sperine training was provided
on procedure changes-
s CPS Operanons has i--f " a management inomitoring program
(la Plant Crew Observanon and Monitoring Program) to ensure and ;
enforce management expedations for procedurnt adherence and
,
conservative de=,<== anaking.1.ar+==ad Operator Overtime Con:rol is
specifically evaluated in this program. ,
,
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Reactor Recirculation Pump Seal Failure SnetialInspection Violation 2/3/97-
Violation # Violation Description Root Cause Co..Mve Action
The inspectors noted that this Il.RT and others very smuist had tren 8==hl uate Procedural Ch Ixk of Understanding of Revision to CPS 9861.02 that prmides in=h for operating-.
960114Bd
Adequacy Standards; Brh== on Tool Box Skills IB21-F016 ard IB21-F019 with a low vacuum Group I isolation signal
done previously and yet the prw=We did not contain steps to arpport
bypassing and resetting the Group I isolanon sign.l. The inspectors present.
asked the operaton why they were having such difficuby and the
Review conducted of other ll_RT procedures for adequate instmetions
operators stated that they were doing the right thing this time
(documenting the problem to get the pmxdure changed) because. the prior to use in RF6.
NRC was watching. He inspectors concluded the failure to p ovide
Station surveillance pmcedures are being reviewed as an ongoing effort
steps in CPS 9561.02D019 regardmg the bypassing and resetting of the
Group I isolatien signal was an apparent violation of'IS 5 4.1. prior to their ;xrformanw to ensure procedural adcquacy and to
identify potential precxmditioning.
Strengthencd expedations for procedure =naH=- and provided
guidance.
All on-shift and active hcensed and non bcensed individuals attended
' training which consisted of a series of senunars 1) a review of the
September 5 event by the Assistant Plant Manager Operations,2)
Lessons learned from the September 5 event conducted by se Shift
, Supervisor imolwd in the September 5 event,3) Proadural
Compliance and Adherence and Training on Appendix B, Criteria V,
4) Conservative Decision Making presented io each crews Shift
Supervisor 51 a p esentation on Man =&ar Oversight and Roles
conducted by the Plant Manager and 6) Specific training was pmvided
on proadure changes-
CPS Operation = has implemented a - ===; -- rmonitoring program
(la Plant Crew Obsc vation and Monitoring Program) to ensse ami
enforce sw+~a expectations for procedural adhesence and
conservative d< cision unding
Page 14
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Reactor Recirculation Pump Seal Failure Special Inspection Violation 2/3/97
Wlation # Wlation Description Roet Cause Corrective Action
96011-0}e ne inspectors identified CPS 9080.01 step 5.1I and CPS 9080.02 step - Inadequate Pmcedural Gindance; lack of Uadermadiag of Added rm@ws in pmcedures to not prime engine. Revned CPS
5.1I caused the operators to prime the fuel oil system anut pump h U - -5 Pmadure No. 9080.01, and 9080.02 to remove steps that prime &c
discharge pressure stabilized for 30 seconds pnor to performing the Emergency Diesel Generators (EDGs).
diesci generator surveillance. Tne inspectors considered this constituted
preconditioning. Initially the licensee's engineering staff stated this did Performed a review of all EDG surveillances for other -. mas of
not constitute precondmoning, but later agreed with the inspectors. The EDG p--- v- :- g Statica surveillarus procedures are being
procedure revision which incorporated the prereqmsite was added during reviewed as an ongoing eHort prior to their performance to ensure
1994. De inspectors determined the pmcedures were inadeqt. ate in that procedural adecuacy and to identify potential e- -- " -:-- iag.
the procedures caused e - 2-- :--g of the EDGs such that the testing
did not demonstrate the EDGs would perform satisfactorily in service. Brief plant engineers on lesscms learned.
This is an apparent violatme ofTS 5 4.1.
Increased station sensttivity toeMLang.
Strengthened expectations for procedure w Jh and pnmded
guidams
All on-shill and active hcensed and non liansed individuals attended
training which consisted cf a series of sennnars 1) a resiew of the
, September 5 event by the Assistant Plant Manager Operations,2)
Lessons Izarned frorn the September 5 event conducted by the Shift
Supenisor involved in the September 5 event,3) Procedural
r%=af a= and Adherence and Training on Appendis B, Cnteria V,
4) Conservative Dectsma Making presented by each crews Shift
Supervisor 5) a presentation on Management Ontsight and Roles
conducted by the Plant Manager and 6) Specific training was provided
on procedure chinp
CPS Operations has implemented a management tuonitoring program
(In Plant Crew Leservation and Monitoring Program) tu ensure and
enforce iswma expectatens for procedural adherence and
conservative decision making. Conduct of Daily Surven!!ances are
specifically evaluated in this program.
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Reactor Recirculation Pusan Seal Failure Snecial Insnecties Yaolation
Violation Description Reet Cause Corrective Action
Violaties f
Revised all E-c .-1Diceet Generator p- that the dieseis - i
9601143f Dunng observanon of the ateve described serveillance tests perfonned inadequate Procedural Guulance; Lack of Understanshag of
M ; are to be barred over 1-2 revoluuons. Clarify all EDG procedures to
on September 21 and 22 (test performed with preconditioning steps
stang "venfying no leakage can be perforrned while barring over the [
deleted), the inspecnons ihhfied a sacand p, "----5 concern.
EDG or aner it is cxunplete. ;
Procedure 9080 01 step 5.14 and procedure 9080.02 step 5.5.4 allowed
the operators lo precondition the EDGs by excessively barring the l
Station servedlance prees are being reviewed as sa ongomg cffast
generators. The step states "Bar over the EDG at least oee revolution."
prior to their perfonaance to ensure pr=whwal adequacy and to l
Operators west observed on one er==onbemag over the EDG about to '
revolutions using a hand held air motor. The bemng over was
identify peal preconditioning. Increased station sensattvity to
contmued while performing steps 5.15,5.5 6, and 5.17 of the proconditioning. ,
procedure. De practice of using the airmotor had been in effect since
about 1991. Turning over the EDG also primed the fuel system via the h.gu m w m for procedure - , - = and provided 1
shaft driven fuem pump. From about 1991 to September 1996 procedures
gman- ,
t
CPS 9080.01 and CPS 9080.02 were inadequate in that the pacedures
allowed pm:enditioning aithe EDGs such that the testing did not All on-shift and active tir===I and non thA indmduals atW
demonstrate the EDGs would perform satisfactorily in servia.11 mis is training which co===d of a series of seinmars: 1) a review of the
September 5 event by the Assistant Plant Manager Operm 2)
an apparent violation ofTS 5.4.1.
12ssons Learncxl from the Septesnber 5 event conducted by the Shin
Supervisor involved in the Septeinber 5 event, 3) Procedural
,
c- f - and AdherenceandTrainingon AppendixB,CnteriaV,
4) C, _,_.. Decision Making presented by each crews Shin
Supervisor 5) a presentanon on i" . - Overwght and Roles '
condurted by the Plant Manager and 6) Specific training was provuhd
on procedme changes.
CPS Operations hasimplemented a - _ -"nionitoringprogram
(la Plant Crew Observauon and Monitoring Program) to ensure and
enforce _ ,- C-e for proceduraladherence and !
h..L.. decision making. Conduct of Daily Surveillances are
specifically evaluated in this program
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Reactor Recirculation Pumn Seal Failure St ceial inmeetion Violation 2/3/97
Violation Description Root Cause Corrective Action
Wistion #
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inadequate Procedural Guidance; Lack N Understandmg of Revise CPS No. 3506 01,9080.02,9080.10,9080.14 and 9080.23 to
96011-033 The inspectors mncluded that the hcensee inapproprutely ansidered
Prescribed Actions note that during performance of surveillances the Emergency Diesel
EDG 10 operable when a speed droop of approximately 3 penznt had
Generators shall be considered inoperable. Add a note to minimize the
been set to accommodate paralleling the EDG to the grid for routine
time with droop at 50%
testing. De inspectors further concluded that this practice appears to
have been in place since the begirming of plant operations. Because
setting a speed droop of approximately 3 percent on EDG IC affected
the ability of the IIPCS pump to respond to a design basis accident and
the test procedi.e did not requ V diesel generator be declared
inoperable wlule the speed droop was set, the test procedure was
ii=&quate. This is an apparent violation of TS 5 41.
De vahing option was not perceived as a test by Operations Plant Manger i sued a directive to stop the use of action plans to dinct
9601I43h On August 1,1996, the lacensee performed a test to venfy that there was
no negative impact on emergency core cooling systems when cycled personnet it was considered acceptable to close this CY operation or manipulation of plant equipment.
valve out of the context of the procedure without benefit of a
condensate (CY) to containment was isolated.
safety evaluation. De-tioped, briefed and issued plant staftprocedure to crm rol action
The hcensee had performed the test using a marked-up drawing and log
plans, CPS No. 1070.01 Coordination Plans, to ensure that no actions
entrus. Performing the test for CY isolation impact on RIIR without a
reviewed and approved procedure is an apparent violation of TS 5.4.1.
to manipulate equipment are directed by documents (lut hrw not
receiwd proper Safety Screening or Eva'uation.
* Strengthened expectations for procedure compliance and provided
guidance.
Operator crews briefed and instructed not to manipulate equipment
using action plans.
Formal training was conducted to selected Operations and Engineering
p.- t ennel in errors and lessons learned in 50.59 Safety Evaluation
Program.
50.59 program improvements per the *$0.59 Action Plan" dated
01/17/97 (Lacensing).
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All on-shift and active licensed and non liansed individuals attended
training which consisted of a series of seminars: 1) a resiew of the
September 5 event by the Assistant Plant Manager Operations,2)
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Reactor Recirculation Pusan Seal FaBure Special Inspection Violation 2/3/97
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Violation Description Root Canse Corrective Action
Violation #
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ussoas Learned freen the S.,Q $ event coM hy the ShiA
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Supemsor invohed in the Sepw-her 5 event,3) Piccaderal
ev-and Adherence and Traianas en Apread== B, Cuena V, ;
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4) Theervative Deenmon Malang pienessel by each ezews $biR
Supervisor 5) a praemensaan on Manage ===8 Oversaght and Rates -
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conducted by the Plant Man.ger and 6) Specafic trassing was psovuled
on procedure changes. ,
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CPS Operations has ' . ^ed a samangessent =a==aring program
(la Plant Crew Observation and P 4 Programa)to ensure and i
caforce managessent erl=*=ria== for procedural aessence and I
conservative decisace =*mt [
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Lack of strativity on the past of both Operations and Plant Manager issued a dhwa to stop the use of u plans to abrect {
960ll-03i On August I,1996, the hcensee performed troubleshooting of the WLP
chesi uhe, IE12F085A. Engineering that the test perceived required a safety operatica or ,
of plant espapment. l
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The systeni engineer stated that since each step of the L _ ___ evaluation.
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"--#ng plan did mult Dewtoped, briefod and i===ad plant staff proceduse to control action
plan was part of a different procedure,the b-_-
require a safety evaluation. Each of the troubleshooting plan steps The Action Plan procedure had evohtd in-usage as a method plans, CPS No. 1070.01 Coordination Plans, to casuse that no actions
individually snight have wuw.kd to a step somewhere in a to specify - operation outside the bounds of a to nnanipulate equipment are directed by documents that have not
procedure. The evolution, mrsstmg of a particular sequence of steps procedure. recened proper Safety Screening or Evaluation. ;
with its own overall expected systers response, however, was
The Action Plan procedure was inadequate. Assessment conducted on the use of Action Plans wrified operability in ['
courplicated enough to require a specific procedure. Performing the
Wif check vahe troubleshooting without a reviewed and approved eqmpment, and used information gathered to incorporane isso new
procedure is an appaient violation of TS 5.4.1. proadure.
L
Forinal training was ra=A=**I to h Operstname and Engineering
personnel in errors and lessons learned in 50.59 Safety Evaluation i
Progrant i
50.59 pmgram i_7_ per the *SO.59 Action Plan" dated
0t/17/97 (Licensing).
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Reactor Recirculation Punio Seal Failure Soecial Inspection Vieistion 2/3/97; .
Violatiem # Violation Description Root Cause Corrective Action
'
9601143j Since August 2,1996, the turnsee had performed a wrificatson plan IM of senntmty on the put of both Operations and . Plant Manger inneed a dareouve to stop the use of 6 plans to duect
weekly to provide assurance that the RHR A WLP dieck vahe contiused Engineernag that the test perceived stquamt a safety operatson or maarnpulation of plaat apW
to funcima. evalustson.
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The licenate had a separate survemmare to verify the %U chedt vahes Developed, briefed and innaed plant staff prarmaare to cuatrol action
would open; however, the verification plan was need to verify proper De Action Plan procedure had evched in-usage as a siethod plans, CPS No.1070.01 Coordination Plama, to coeure that no actices - j
operation of IE12F085 A. Perfonning this su:wm==re activity for the so specify equiprocat operation outside the bounds of a to manipulate equipreent are directed by h that have not !
WIP check vahe without a reviewed and appromi procedme is an procedure. received proper Safety Scraanar or Evaluation. ,
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apparent violance ofTS 5.4.1.
ne Action Plan promdure was ! Aewa==nentM on the une of Action Plans venflod operability in
egepeneet, and used intornistaan gathered to incorporate into new i
ph ,
Fennal training was conducted to selected Operations and Engineering
personnel in errors and lessons learned in 50.59 Safety Evaluation ,
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50,59 program im .._.e per the"50.59 Action Plan * dated
01/17/97(licensing)
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u_m._._- __1.______.__.m._m_._.______._.___.__.-m _______.m.m m.;__...m._ . _ __ _ _ _ _ - _ _ _ _ . _- ,.- .- , W.. . . . . . , . . . . . , _ o,-. -.-. .,..1, .-n- ,. ...-.w-.
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Reactor Recirculation Pusan Seal Failure Sneciallasnecties Violation 2S/97 .
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Violatics # Violation Description Root Cause Corrective Action ,
4
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960lI43k On May 3,1995, the Isoensee perfonned a test of the costsel rod drive - lack of seautmry on the part of hash Operanens and Plant Manger issued a duettsve to stop the use danian plans to daect .
operaties or P of plant myip-=# ;
, (CRD) pasept Sevenseen steps of an engineensg action plan were Engineering that the test peranved restuned a safety
perfonned to deterndae whether a drop in CRD pressure was due to evaluatient j
lambing vahes or pusep degrarlarvut Tbc action plan was conducted at DeM briefed and issand plaat staff procedure to metrol action
power, prior to cw= hap 40 percent power, and irmdving shutting The Action Plan promdure had evched ifHasage as a inethod plans, CPS No. 1070.01 Comedi==sia= Plans,to ensure that so actions
harharge elur* valves, nune==*n flow valves, and recording desa. The to specify c: pup =-=s operstaca cuiside the bounds of a to ===y I=aa ayap-=* ase dueceed by h that have not
affected train was then ressored and the other train tested. 7 : ; procedere. seceived proper Safety Saeessag er Ev=h==n== ,
this CRD pensp test without a reviewed and appnned pr=wh=e is an .
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apparent violauon of TS 5.4.1 The Action Plan procedure was inadequate. A=======8 conducted on the use of Action Pleas venSed operabday in
equnpeness, and used informasson gathered to incorporate into new ,
Procedure. .}
Fennst traneang was copa=*dto =a : Operanens and Fngs martag
pew is errors and 1*==a== learned in 50.59 Safety Eval ==sean
programi, ,
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30.59 programaimprovesnesasperthe"50.59 ActionPlan" dated -
Otn7/97 (12censins). [
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Reactor Recirculation Pumn Seal Failure Special Inspection Violation 2/3/97 4
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Root Cause Corrective Action
Wistion # Violation lkscription
The books mataining the Annunciator Procalures for 111131%s0 hast
On Septenber 17, the inspectors obserseJ that annunciator response Inattention to detatt.
9601145c been renutd from both the Main Control Room and Sinnlator pand
books were in=mmaed on top of some of the control room panels. The
tops
inspedors determined that a safety evaluation to determine the efIcct of
the books falling onto the control panel cather from permanel error or a
sekmic event had not been Conducted.
UFSAR 3.1.2.2.1.0,I stated that time control r9om had been designed to
meet seismic Category I requirements. Failure to perform a written
safety evaluad.m for this change in the fac'taty as described in the
UFSAR is an aw.; violation of 10CFR50 59(bXI).
Tlacridure CPS 3317.01 and the Safety Evaluation which was . [
9601145d in approximately 1989, CPS 3317.01 was updated to allow both FC liWuate .a of USAR. written in 1989 vere inadequate. The procedu:e change and safety
pump inlet valves to be opened during normal operations. UFSAR evaluation nixessary to correct this condition will be completed prior to
Figure 9.1-4 showed a normal vaht 'ineup with the idle train contrary to plant startup. ,~
the prxedure revision. A safety evaluation was not perfonned for the .[
pera coure revision. Failure to perform a written safe:y evaluation for ,
this change in tie facility as described in the UFSAR is an apparent
dotation of 10s.TR50 59(bXI)
Lack of sensitivity with regard to the USAR rcquirement to Nr e safety evaluation to evaluate the matosi.J condition and
9601I-05b The inspccters ider Wd that engineers failed to perform a safety
i
the NACE Standard as it applied to the diesel fuel on fdl potential for USAR change. ,
evaluation after deLmining, in August 1995, that cathodic protection
system design did not provide suffdent corrosion protection. lines.
Long Ternr 50.59 Program implements per the "50.59 Action Plan"
UFSAR 9 4.5 2 stated that the prevailing soil conditions at t% sne
Cathodic protection was perfornuxi as it was originally dated 01/17/97 (l icensing).
estabhshed the need for cattridic protection, therefore, an impressed-
current type cathodic protection system consisting of a d< power napply, install.xi. but spectfic cnteria for cathodic protection on the
control cabinet, and a number of di<tnbuted anode beds would be used. dicsci fuel oil fill lines was inut recngnized (i.e., NACE ,
& determination by bcensee enguiests that insufFiciem cathodic Standard).
I
protection existed in certain areas was a change for the UF3AR
descnption that implied protection of underground piping by a cathode
system was provided. Faslure to perform a untten safety enluation for
this change in the facihty as descnbed in the UFSAR is an apparent
violation of 10CFit50 59tbX1)
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Reactor Recirculation risnio Seal Failure Special Insnection Violation 2/3/97
Wistion # Wlation Description Root Cause Corrective Action
960ll-07b The inspectors review of the evaluatson indatal that the control room An inadequate operatality 4 .. C-. led to untimely Prior to Startapa .
ventilation chillers may automatacally restart after a loss of offsite power corrective actions. Winmal auto re-starting of the didsion _
,
esent about 2.5 aninutes aAer the c*ent. liowever, UFSARTable 3.3-13 I VC challer is r==,d by an out of calibration or tw closely Calibrate the Div i 480 valt bus A time delay scquencing Relay
stated the chillers are manually started 20 minutes after the event. The set timing relays. A geactic issue regarding lack of a formal
inspectors conadered the turnsee's engtacenng evaluation minimally operatahty program is also a cause of this violation. Img-Ternt -
acaptable foi an initial pronipt operability deternunation. Although
potentially atta.s.ng d ecet generator loading, the evaln=tiana was not Verify existing PMs or write PM requests for all EDG sequencing time
performed by the cs,enime diesel generator engineer. The evaluation relays
stated *1he fact that the chillus sm.ar auto-restart appears to be in Pcview other EDG sequencing for possible auto restart condithes
contradiction to the UFSAR table 8.3-13. ahich were desagned for lockout and mannal restart.
Followiag the initial hemia= and despite three years passing in
the interun, the hcensee had not attempted to supplement the initial OE Genenc Img Ternt
with a more rigurous, inwiepth review of diesel generator loads and
related quantitatne calculations. Furthermore, despite completion of a Develop and implement a formal OE program prior to startup.
refuel outage in the interim, the licensee had not resolved ihe issue
through either a piant snodsficatnon or completion of a 10CFR50.59 Install design change to remow auto start feature for the chiPers.
safety evaluadon (and UFSAR revision) to determine the non-
conforman6e was not an -.u d safety que= tion. Furthermore, there
were no plrts to prmide such iesolution prior to exiting an upcoming .
refuel outage, less than one month away. 'Ihe system engineer had
submitted a design change to remove the auto-start capabihry for the
control room chillers but this proposal was rejected by the WRB just
prior to the inspection period.
The timeliness of hcensee plans and progress to date regarding the
control rwrn chiller start UFSAR design discrepancy was inadequate
.
and is an apparent notation of 10CFR50, APP B, Critenon XVI.
! Following identification of this concern by the inspectors, the licensee
initiated a condition report and perfarnal a more rigorous, quantitative
OE. This new OE, concluding the equipment remained o;crable, was
considered adequate by the it yttors.
,
l' age 22 ;
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