IR 05000461/1986064

Safety Insp Rept 50-461/86-64 on 860922-26 & 0929-1003.No Violations,Deviations,Or Safety Significant Issues Identified.Major Areas Inspected:Action Re TMI Action Plan Requirements,Ie Bulletins & Previous Findings

ML20215G849
Person / Time
Site:	Clinton
Issue date:	10/15/1986
From:	Gwynn T, Knop R, Sheibelhut C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20215G790	List: IR 05000461/1986064 ML20215G788
References
TASK-1.C.6, TASK-1.C.8, TASK-2.K.1, TASK-TM 50-461-86-64, IEB-79-05, IEB-79-5, IEB-86-002, IEB-86-2, IEIN-86-047, IEIN-86-064, IEIN-86-47, IEIN-86-64, NUDOCS 8610210147
Download: ML20215G849 (10)

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U. S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-461/86064(DRP)

Docket No. 50-461 License No. CPPR-137 License No. NPF-55 Licensee: -Illinois Power Company 500 South 27th Street Decatur, IL 62525 Facility Name: Clinton Power Station Inspection At: Clinton Site, Clinton, IL Inspection Conducted: *ept mb r 22- 6 and September 29-October 3, 1986 Inspector: C Sch ibelhut /#[/#/84

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T. P. Gwyn '

/d Da'te f!b Approved By: R. C. L p C Reactor Projects Section IB

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Date Inspection Summary Inspection on September 22-26 and September 29-October'3. 1986 (Recort No. 50-461/86064 (DRP))

Areas Inspected: Routine safety inspection by a NRC Contractor Inspector and the Resident Inspector of applicant actions on previous inspection findings, evaluation of applicant action with regard to Three Mile Island Action Plan Requirements, and IE Bulletin Results: Of the three areas inspected, no violations, deviations, or safety

significant issues were identified.

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8610210147 861015 PDR ADOCK 05000461 0 PDR .. -_ __ .

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I DETAILS

) Personnel Contacted Illinois Power Company (IP)

"J. A. Brownell, Licensing Specialist

1. J. H. Butler, Director (acting), Nuclear Scheduling

"T. J. Camilleri, Director (designate), Nuclear Scheduling

'R. E. Campbell, Manager, Quality Assurance

"W. C. Gerstner, Executive Vice President

' H. Greene, Manager, Nuclear Station Engineering

"D. P. Hall, Vice President, Nuclear i' *J. F. Palchak, Supervisor,_ Plant Support Services

!. "F. A. Spangenberg, Manager, Licensing and Safety

"J. D. Weaver, Director, Licensing

, WIPCO 'Soyland Power

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"J.. Greenwood, Manager, Power Supply

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'" Denotes those attending the exit meeting.

l The inspector also contacted others_of the licensee's staf . Applicant Actions on Previously Identified Items (92701, 92702)

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! (0 pen) Open Item (461/85005-32): " Verify that procedures to ensure

'- independent verification of system lineups are complete .before fuel load (TMI Item II.K.1.10)". In Inspection Report 50-461/85032, the inspector determined that the administrative control procedures appeared adequate to provide for independent verification of system lineups. One item identified by the licensee as requiring revision related to the notification of control room operators when operations personnel change system lineups. The inspector

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Identified inconsistencies and inadequacies in the valve and elactrical lineup sheets used by operations personnel to provide for independent verification of system lineups.

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It was the licensee's intent to inde:tni.sntly verify all manually operated valves-(excluding check TV veu .nd motor-operated valves with position indication-in th' c ' re oom) in the major flow

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' paths of systems important to s.(ety s ;aer than all valves in such eystems. This position was accepted by the Office of Nuclear Reactor Regulation (NRR) as indicated in paragraph 2.d below, i

The inspector reviewed CPS No. 1401.01, " Conduct of Operations", and

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found that paragraph 8.6.2.1 clarified the flow of r% formation between the various segments of a shift cre The inspector reviewed a random sampling of maintenance and 7 surveillance procedures to determine if appropriate independent verification of valve and electrical lineups was require In all

procedures reviewed, appropriate independent verification was f

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e required. The inspector reviewed a sampling of operating procedures.

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to determine if independent verification was' required where appropriate. CPS No. 3315.01, " Containment Monitoring", did not require independent verification.on any of the valve or electrical lineup sheets. Since the, system was safety related, independent verification appeared to be needed. A more extensive review of operating procedures revealed that the operating procedures for the *

following safety related systems did not require independent verification on the valve or electrical' lineup sheets: -

Reactor Core Isolation Cooling Source Range Monitors-

-Average Power Range. Monitors

' Fuel Pool Cooling Drywell Coolin In addition, some nonsafety related systems such as the Instrument Air and Fuel Building HVAC contain components such as valves, alarms, and dampers that are safety related or important to safety . The lineup sheets for these systems did not require

, independent verification.

J In a meeting with the licensee to discuss these discrepancies, it-was concluded that the licensee would take the following steps:

• Review. the criteria for independent verification, as contained in. CPS Mo. 1401.01, and clarify .them if necessar * Based on th~e criteria, review the operating procedures

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containing valve and/or electrical lineup sheets-to determine if the criteria are met and make any necessary changes.

) Therefore this item remains open until a future inspection shows conformance with the requirements of TMI Action Plan Item

II.K.1.10. This item is considered a constraint on initial criticality of the reacto . (Closed) Open Item (461/85005-36)

" Inspect records and procedures on site to confirm that the requirements of NUREG-0737, Item

- II .K.1.5 have been satisfied prior to license issuance". TMI Action Plan Requirement II.K.1.5 in'vokes the requirements of IE Bulletin "

79-05. The bulletin requires that valve lineup sbeets be prepared for all Emergency Safety Feature (ESF) systems, the ' lineup validated, and the lineups ~used prior to declaring a system operabl (Independent verification of the lineups is covered by Item II.K.1.10.)

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Valve lineup sheets (and the system's operating procedures) were prepared for all systems prior to preoperational testing. The correctness of the sheets was verified during preoperational testing, during the procedure's review and approval, system

" turnover to' operations" review, system walkdown for Technical Specification operability, and by compliance with CPS No. 1401.01,

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" Conduct of Operations", requirements. Valve lineups are performed

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.and maintained in accordance with CPS No. 1401.01. Maintenance activities that result in temporary changes in valve lineups are controlled according to the provisions'of procedures CPS N .01, CPS No.1502.02, " Conduct of Maintenance", and CPS N .01, " Safety Tagging Procedure". Many surveillance procedures require temporary changes in valve lineups. These procedures were written in accordance with CPS No. 1011.05, " CPS Surveillance

, Guidelines", and contain a system restoration section providing for restoring all manipulated valves to their required positio The inspector reviewed the.above procedures and concluded that the licensee's administrative control procedures appeared adequate to provide for and preserve a correct. lineup of system valve Previous NRC inspections of CPS Operating and Surveillance i- procedures have been documented in previous Inspection Reports and l indicated that the procedures were acceptable. This item is closed.

f (Closed) Open Item (461/86042-01): " Staff augmentation drills are

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not required.at least annually". NUREG-0654 revision 1, " Criteria for Preparation and Evaluation of Radiological Emergency Response t Plans and Preparedness in Support of Nuclear Power Plants", in 1section II-B defines an. Emergency Response Organization (ERO) and in section II-N requires an annual exercise that in turn would require

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staff augmentation (the ERO) to perform the exercise.

Section 5.4.5.2 of the CPS Emergency Plan requires an annual dril Implementation procedure AP-04, "Preparatiens and Conduct of Emergency Drills and Exercises", section 4.2.2,'" Extent of Exercises

and Thcir Frequency", requires the conduct of an exercise once per year.

In addition, the licensee has issued Illinois Power' Company General Procedure GP'No. 2.8, "Clinton Power Station Emergency Response

. Organization Coverage", that further defines the ERO and requires semi-annual notification tests to ensure operability of the notification syste The inspector reviewed the three listed procedures and found that 4-staff augmentation drills are required annually as a minimum. The implementation procedure was in the process of being amended and

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will incorporate the requirements of GP No. This item is

closed.

, (Closed) Deviation (461/86048-01): " Independent verification of system lineups was not required for all equipment important to sa fe ty" . The Clinton Power Station Final Safety Analysis Report (FSAR) identifies commitments to provide independent verification of safety related system lineups. FSAR chapter 6, paragraph 6.3.2.8, requires that the position of each manually operated valve will be identified in a valve lineup sheet and for safety related systems, the. lineup will have independent verificatio ESAR chapter 13, paragraph 13.5.2.1.1, requires independent verification of safety related system valve and electrical lineups for isolation of components for maintenance, for restoration of components following-4-

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. maintenance, and for surveillance procedures. FSAR Appendix D, TMI

fActionPlanItemsI.C.6,II.K.1.5,andII.K.1.10stateinpart:

"Clinton Power Station Procedure No. 0AP1014.01N, " Safety Tagging Procedure", and No. 0AP1405.01, " Performance of Operational Activities", assure that independent verification of system lineups is applied to valve and elect.rical lineups for all equipment important to safety, to surveillance procedures, and to restoration following maintenance. The inspector found that all valves did not require independent verification in certain Emergency Core Coolin Systems (ECCSs). In addition, discrepanc!.es existed between system valve lineups such that valves of similar function required independent verification in one ECCS and not in the othe The licensee stated that the intent was to provide independent verification of valve position for valves in the major flow paths of '

i safety related systems to ensure proper lineup where valve misalignment could prevent the system from performing its intended safety function. This was done to maintain personnel radiation

exposure as low as reasonably achievable ( ALARA). .This change in

independent verification criterion and notice of intent to revise the FSAR to change the criterion was presented to the NRC (Letter l' U-600674, dated 8/8/86).

The results of the NRC review of the letter and attached r

documentation (valve lineup sheets and Piping and Instrumentation Diagrams (P& ids) for the ECCSs) are documented in a memorandum dated September 10, 1986 from the Chief, Reactor Systems Branch, Division of BWR Licensing, to the Director, BWR Project Directorate #4, Division of BWR Licensing. The memorandum stated that the licensee's position was justified and independent verification of all valves in a system other than in the main flow path is not mandatory. The discrepancies noted by the inspector did not involve valves in the main flow path (i.e. several vent, drain, and test

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connections) and, therefore, were not of concern.

a- On IP Centralized Commitment Tracking (CCT) No. 043168, the licensee

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committed to amend FSAR sections 6.3.2.8, 13.5.2.1.1 and Appendix D (I.C.6, II.K.1.5 and II.K.1.10) to reflect the changed criterion for l independent verification by January 31, 198 Since the NRC accepted the revised criterion for independent verification of valve positions, this item is closed.

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' (Closed) Open Item (461/86054-15): "Within five days of fuel load,

, the NRC will verify that the appropriate postings are established in

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accordance with 10 CFR 19.11". 10 CFR 19.11 requires the posting of certain documents or if not practical, to post a notice which describes the document and states where it may be examine '

The licensee issued Licensing and Safety Procedure L.9,

" Notifications required by 10 CFR 19.11", to control tne t distribution of the notifications and provide semi-annual verification of the notifications. The licensee posted notices in 18 locations throughout the plant. The notices described the i -5-I _ . - _ _ _ . _ _ ._ . _ _ _ _ . _ _ _ _ _ _ - _ . . _ _ . . _ . _ . _ - .. _. __ _ .

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required documents and indicated where (two locations) they could be examine In addition, special training was given to the personnel in the two locations containing the documents to assure easy access to the documents. To assure semi-annual verification, item N was entered into the Centralized Commitment Tracking (CCT)

syste The inspector determined by direct observation that the notices were posted in six of the 18 locations. While making this inspection, the inspector also noted the correct posting of notices required by 10 CFR 2 The inspector visited one of the designated locations and found all of the required documents and determined that the personnel were aware of the notice and the requirement for access to the documents. The inspector reviewed procedure L.9 and found that s it implemented the requirements of 10 CFR 19.11. This item is close f. (Closed) Violation (461/86055-01): " Failure to promptly correct training deficiencies and implement corrective actions". In Inspection Report 50-461/86055, the inspector reviewea the actions taken by the licensee to respond to the findings of an internal IP audit that found deficiencies in the training of mechanical maintenance personnel to procedure revisions. The inspector ,

concluded that the actions taken corrected the deficiencies and would preclude recurrence in the maintenance department. One of the actions taken was a revision (No. 17) to CPS No. 1005.01,

" Preparation, Review, and Approval of Station Prccedures and Documents". The revisions (paragraph 8.1.8 and 8.3.1.4) required that training of key personnel be conducted prior to issuance of the procedure (or revision) and that training of appropriate personnel be completed within six weeks of issuance. The above training was to be documented in accordance with CPS No. 1017.02, " Training Records". The inspector attempted to verify compliance with the revision to CPS No. 1005.01 by other departments. The following were found:

• The licensee could not document the training for a revision of a kcy operations procedur * The method used to control training of " appropriate personnel" did not meet the six-week-after-issuance requiremen * No documentation or procedure changes had been made to implement the revisions to CPS No. 1005.0 These findings showed that the corrective actions r, ken to address the generic implications of the audit were not prc/ptly taken to preclude recurrence and were not implemented prior to closure of the audit finding The licensee took the following corrective actions:

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• CPS No. 1095.01 was revised (No. 18). The revision requires each new or revised procedure to be accompanied with a roster of Key and Other personnel requiring training (or indicate that

.no training is required). Training of key personnel must be completed before the effective date~ of the procedure (or revision). Other personnel must complete training within six weeks of issuance. The Plant Staff Compliance Group verifies that key personnel training is complete prior to-informing the Plant Staff Administrative Group that the procedure may be issued and also assures that other personnel training is completed within the six week perio * All of the procedures (263) issued during the effective period of revision 17 were reviewed for training requirements and training documentation. The review showed that 133 were not evaluated for training requirements. Of these, 14 required training. The applicable personnel requiring training to these procedures were trained and the. training documented. Of the remaining 130 procedures, five were identified as being delinquent in the required personnel training. Activities performed in accordance with^ those procedures will be controlled by'supeivision such that only trained personnel will be utilized until all are traine To prevent future occurrence, in addition to revision 18 to'. CPS N .01, the licensee issued a letter to all. Plant Staff Department -

Heads reiterating that Plant Manager Standing Order, PMS0-007 and CPS No. 1018.02, " Response to External Audits", define the mechanism for responding to audit and surveillance findings.~ PMS0-007 requires the Plant Staff Compliance department to ensur.e that responses properly address cause, remedial and generic cor'rective

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actions, and timeliness, and require notification of the Plant Manager of potentially late response The inspector reviewed the training records for the 19 procedures identified as requiring training or delinquent in training and found satisfactory evidence that training was completed or entered as a commitment in the CCT. The inspector reviewed revision 18 to CPS No. 1005.01 and found that satisfactory controls existed to control training to new or revised procedures in a timely manner. . The

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inspector reviewed PHS0-007 and CPS No. 1018.02 and found that they provided satisfactory control over the responses to IPQA surveillance or audit findings. The inspector visited the Plant Staff Compliance Group to determine the implementation of revision 18 to CPS No. 10G5.01 and found the following:

• A file was kept for each new procedure or procedure in the revision proces * For approved procedures or revisions, training records of key personnel were accumulated until all key personnel, as indicated on a roster for the procedure, were traine '

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The training records'were forwarded to the training department (copies were kept in the folder):for storage and the Plant Staff Administrative Group informed. that the procedure could be issue *- Training records for appropriate personnel, as indicated on a roster for the procedure, were accumulated in the file and a calendar kept indicating, by procedure, when the six week limit was ende *

Completed appropriate personnel training records were forwarded to the training department for_ storage (copies were kept in the file).

If appropriate personnel training was not completed within the six week period, a Condition Report (CR) was written to rectify the conditio Based on the reviews and inspection, this iten is close (Closed) Open Item (461/86057-01): " Verify change of security locks within five days of fuel load". The security.-locks on doors leading to.the protected and vital areas were to be changed within five days of fuel loa The inspector reviewed worksheet 1701.58 F002, " Lock, Core, and Key Change Worksheet", to procedure CPS No. 1701.58, " Security Keying",

and found signed evidence that all cores of locks on doors leading to the plant protected and vital areas had been changed within five days of initial fuel load. The> inspector determined by direct observation of a random sampling of protected and vital area door lock cores that the cores bore the numbers corresponding to those on

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the worksheet. This item is close ,

Tha violations or deviations were identified.

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Evaluation of Aoplicant ' Action with Regard to Three Mile Island '(TMI)

Action Plan Requirements (25401)

The NRC Office of Inspection and Enforcement issued Temporary Instruction i (TI) 2514/01, Revision 2, dated December 15, 1980, to supplement the Inspection and Enforcement Manual. The TI provides TMI-related

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inspection requirements for operating license applicants during the phase between prelicensing and licensing for full power operation. The II was

} used as the basis for inspection of the following TMI items found in NUREG-0737, " Clarification of TMI Action Plan Requirements".

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'. (Closed) TM1 Item I.C.1, "Short-term accident and procedures

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review". The requirements for this item have evolved since the publication of NUREG-0737. For Boiling Water Reactors (BWRs) a BWR Owner's Group was formed. Through the group, generic Procedure

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Generation Packages (PGPs) and generic Emergency Procedure Guidelines (EPGs) were developed. These were reviewed and approved by the NRC Office of Nuclear Reactor Regulation (NRR). Plant l

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specific EPGs for CPS were prepared by the licensee and subsequently

approved by NRR. Documentation of this is contained in Supplement 4 to the Clinton Safety Evaluation Report (SSER4 to NUREG-0853) in-section.13.6.3.1. The licensee prepared.the Emergency Operating

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~ Procedures (EOPs) and has subsequently implemented-them. This item is also being tracked as open item 461/85015-07. In Inspection Report 50-461/86059, the inspector reviewed the above open item and found that the requirements had been met except for the .EPG and E0P i concerning the control of combustible gas inside containmen The Owner's Group has formul'ated a generic EPG for the control of combustible gas inside of containment and forwarded it to NRR for review. NRR-has not, as yet, completed-its review. Therefore, the licensee has been unable to write a CPS specific EPG and EOP for the subjec /II 2514/01 indicates that NRR would -perform 'the reviews for this '

' item and TMI item I.C.8 with IE input. However, as documented in

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section 13.6.3.5 of SSER4, NRR would.not do the reviews for all facilities but. would perform audits of selected facilities. The Information Notice indicated below resulted from the audits that were performe ,/. IE Information Notice 86-64, " Deficiencies . in Upgrade Programs -for Plant Emergency Operating Procedures", was' issued by the NRC to alert all licensees to various problems found by the NRC staff ~in reviews and audits of E0Ps at other plant In response to the Information Notice, the. licensee performed a sample audit of one portion of an E0P and wrote a comprehensive audit plan to address the concerns of the notice. The sample audit found a few minor problems. The comprehensive audit plan was approved by licensee management for completion by December 15, 198 Because the one remaining EPG~and E0P is being tracked by open item 461/85015-07 and the' licensee has started a comprehensive audit of the. plant E0P upgrade program, this item is considered close However, an NRC review of the results of the audit is considered an open item (461/86064-01) and will be performed when the audit is completed.

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! (Closed) TMI Item II.K.1.5, " Verification of valve positions in safety related systems". This item is identical to open item 461/85005-36. Since the open item has been closed (see paragraph 2.b. above) this item is close No violations or deviations were identifie . Evaluation of Licensee Action With Regard to IE Bulletins (92703)

y (Closed) IE Bulletin 86-02 (461/86002-BB): " Static "O" Ring Differential Pressure Switches". As part of an environmental qualification upgrade

program, differential pressure transducers monitoring reactor water level

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were replaced by environmentally qualified differential pressure switches l manufactured by SOR, Inc. (formerly Static "0" Ring Pressure Switch-9-

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Company). At one reactor site ~, approximately 60 of these switches were installed in various systems including the reactor protection system and the emergency. core cooling systems. Events at this site have shown that the serles 102 or 103 switches provided by SOR, Inc..have serious

. reliability problems that indicate that their use in systems important to safety may not be acceptabl .+' Accordingly, the NRC issued IE Information Notice 86-47 and, as .mcre information became available, issued IE Bulletin 86-02. The Bulletin required all licensees to submit a report within seven days on the extent to which series 102.or 103 differential pressure switches are installed (or planned) as electrical equipment important to safety. If the switches were installed (or planned to be) certain other steps were require The licensee searched the CPS Master Equipment List, the CPS-Instrumentation Data Sheets, and their Standardized Nuclear Assistance Program (SNAPS) computer data base and found that the switches described in the Bulletin were not in use and were not planned to be used at CP General Electric, the reactor supplier, was also asked and confirmed that SOR differential pressure switches were .not supplied to CP The inspector reviewed the licensee's information collected for the item. The review showed that the licensee responded to the NRC within the seven day limit as to whether or not they installed or planned to install S03 switches (IP Letter U-600690 dated August 26, 1986, to NRC ,

Region-III with a copy to the NRC Document Control Desk). Nuclear Station Engineering Department (NSED) memo Y-81331. dated July 10, 1986 summarized the search of the Master Equipment List, SNAPS computer data base, and the Instrumentation Data Sheets for evidence of the existence at CPS of SOR series 102 or.103 differential pressure switches. None was found. Document Transmittal Form (DfF)-JK1122 dated July 1, 1986 from General Electric confirmed that SOR differential pressure switches had not been supplied to CPS. The inspector also determined that CPS uses

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Rosemount differential pressure transducers for the type of measurements described in the Bulletin. This item is close .No violations or deviations were identifie . Open Items Open items are matters which have been discussed with the licensee, which will be reviewed further by the inspector, and which involve some action on the part of the NRC or licensee or both. One open item disclosed during the inspection is discussed in paragraph . Exit Meeting *

The inspecter met with the resident inspector and licensee representatives-(denoted in paragraph 1) at the conclusion of the inspection on October 3, 1986. The resident inspector summarized the scope and' findings of the inspection. The licensee acknowledged the inspector's findings. The applicant did not indicate that any of the information disclosed during the inspection could be considered proprietary in nature.

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