U-602670, Submits Revised Startup Readiness Action Plan to Include Specific Action to Ensure That CPS Personnel Clearly Understand That Safety Is Priority

Submits Revised Startup Readiness Action Plan to Include Specific Action to Ensure That CPS Personnel Clearly Understand That Safety Is Priority

ML20135F431
Person / Time
Site:	Clinton
Issue date:	12/09/1996
From:	Connell W ILLINOIS POWER CO.
To:	Beach A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
U-602670, WC-370-96, NUDOCS 9612130051
Download: ML20135F431 (19)

Text

nanvis Fonter t.,umpany Chnton Power Station

. P.O. Box 678

. Chnton,IL 61727 i e

Tel 217 935 5623 i Fax 217 935-4632 l Wilfred Connell i Vice President l ILLIN9BS Pt#WER I l

U-602670 1 A.120 WC-370-96 J December 9, 1996  !

Docket No. 50-461 Mr. A. Bill Beach  !

Regional Administrator Region III U.S. Nuclear Regulatory Commission i 801 Warrenville Road Lisle, Illinois 60532-4351 l

Subject:

Clinton Power Station Startup Readiness Action Plan

Dear Mr. Beach:

By letters dated September 17 and 24,1996, we submitted our corrective action plan in response to the September 5,1996, reactor recirculation pump seal failure event and the associated September 11,1996, Confirmatory Action Letter. Since then, we have completed a number of the actions described in our corrective action plan.

In addition, based upon further evaluations, including the results of the NRC's Special Inspection and Operational Safety Team Inspection, our plans have been revised ,

and additional actions incorporated into them. We clearly recognize the need to l accomplish a major shift in the safety culture at CPS to ensure that decisions and actions  !

in the plant are made with safety as the first and overriding concern. To this end, we have l included in our startup readiness plan several specific actions to ensure that CPS personnel clearly understand that safety must be our constant focus and takes priority over other considerations.

1)

A "l 120024 ,

9612130051 961209 PDR ADOCK 05000461 p PDR

U-602670

, Page 2 Attachment 1 is our Startup Readiness Action Plan which describes more fully the actions we plan to accomplish prior to startup of CPS, along with the current status of i

completion of these actions. As noted in the Startup Readiness Action Plan, we intend to

, perform formal assessments to verify completion ofpre-startup actions and to monitor the effectiveness of corrective actions to ensure readiness prior to startup. Attachment 2 includes additional technical actions involving plant equipment which will also be resolved l

prior to startup of CPS. Detailed records of the accomplishment of actions are being kept  !

at CPS and are available for NRC review. We are also developing a set oflonger-term actions to be taken after startup to further improve our performance in areas of weakness identified by the September 5,1996, event and related assessments and inspections, including methods to monitor the effectiveness of the corrective actions. The Long Term Action Plan is expected to be issued by December 13,1996. This plan will continue to be evaluated for additional action items, and revised, as necessary. We will keep the NRC Senior Resident informed of our progress in completing these activities.

Please call me if you would like to discuss these plans or require any further information.

Sincerely yours, Wil Vice President WEB /csm Attachments cc: NRC Clinton Licensing Project Manager ,

NRC Resident Office, V-690 i Document ControlDesk i Illinois Department ofNuclear Safety l l

l

, Attachment 1

. to U-602670 Page1of15 Startuo Readiness Action Plan Summary This at*=4mant describes the actions included in the Clinton Power Station (CPS) Startup Readiness Action Plan (SRAP). The SRAP encompasses actions to ensure that CPS can be returned to service safely and reliably.

The SRAP was developed based upon Illinois Power Company investigations and reviews of the September 5,1996 Reactor Recirculation pump seal failure event, results of other recent Illinois ,

Power Company assessments and reviews, and results of the NRC Special Inspection and l Operational Safety Team Inap~* ion conducted following the September 5 event. The SRAP incorporates all actions from Ilhnois Power Company's September 17 and 24,1996 Confirmatory l Action Letter responses.

The SRAP covers four areas determined to have caused the September 5,1996 event:

. Procedure Compliance / Adequacy -- includes actions to ensure that procedures are clear and consistent, and that arpa *=* ions for procedure compliance are understood and implemented.

• Conservative Decision Making / Human Performance - includes actions to ensure that personnel understand that safety focus is our top priority and implement this understanding l through conservative decisions. Also, this area includes actions to ensure that plant equipment operating limits reflect this conservative approach.

. Management Oversight - includes actions to ensure that managers and supervisors understand their oversight roles and maintain a conservative " big picture" view of plant and a l focus on operational safety.

• Plant Material Conditions - includes actions to ensure that plant equipment is maintained to support safe and reliable operations.

In each of these areas, the SRAP defines specific actions to be taken, and designate the CPS l department responsible for accomplishment of the action. As stated earlier, these actions will be l completed prior to startup. l In addition to specific actions to be taken, the SRAP describes the assessments that will be performed to ensure startup readiness, including the Nuclear Assessment Department verifying completion of SRAP actions, and a formal assessment for determining readiness for startup.

l Startup will be accomplished utilizing a startup plan which includes hold points at which startup l progress and performance will be assessed prior to proceeding further. A startup readiness self-assessment will also be conducted at the direction of the Assistant Plant Manager-Operations.

Those actions in this attachment that were included in Illinois Power's earlier Confirmatory ,

l Action Letter response are indicated by (CAL] in parentheses after the action, along with a j reference to the portion of the response in which the action originally appeared.

1

, Attachment 1 to U-602670 Page 2 of15 Startup Readiness Action Plan L Procedure Compliance / Adequacy l NA Action Items Responsible Depaumfat i i

, 1. The adequacy ofpolicy statements and general Management Team procedures regarding conduct ofoperations and i procedure compliance will be reviewed, and changes I made as necessary to ensure that expectations and  !

, requirements regarding conservative decision-making i

and procedure compliance are clearly set forth. ,

)

(CAL II.1)

Status: Verificationin process.

j 2. A seminar on procedure compliance including Main Nuclear Training Control Room activities, turnover, log keeping, and Department l communications will be provided to the following

personnel

(CAL II.2)

• Site Managers e Plant StaffDirectors/ Assistant Director-Operations

• Work Control Team Leaders e Facility Review Group Members e Licensed and non-licensed Operations personnel

. Shift Technical Advisors

. System Engineers

e- Active operatorlicense holders

• Management monitors l Status: Verification complete.

.l J

_ _ .__ __ ._. . _ . _ - - _ . _ . _ _ _ . _ _ _ . . _ _ _ . . _ _ . _ _ _ _ _ _ . _ - ___-_m-.

I, Attachment 1 ts U-602670 Page 3 of15 1

ML Action Items Responsible Department

3. Procedures used in the following activities will be Plant StaffDepartments j reviewed to ensure clarity, consistency, and ease ofuse,

{ and changes will be made as warranted. (CAL II.3)

. plant startup

, e single loop operation

! e leak detection

. reactor coolant leakage e procedure adherence e long cycle lineup and operations

)

e conservative decision making

. management oversight

. RR seal problems Status: Verificationin process. 1 1

4. Operating crews will receive simulator practice on Plant Staff normal plant operation and startup activities to ensure Departments / Nuclear l familiarity with associated procedures, and identify any Training Department areas for procedure revision or enhancement. (CAL II.4)

)

Status: Verification complete.

5. The critique process will be revised to include: (CAL Plant Staff II.5)

. Appropriate, independent and objective inputs from other departments

. In-depth fact finding

. Expectations for timalia= of the evaluation and documentation are clear and enforced

. Specific detenninations on whether procedure noncompliances or nonconservative operations I occurred

. A timely review and concurrence of the facts by appropriate senior management Status: Verification complete.

. Attachment 1 to U-602670 Page 4 of15 h Action Items Responsible Department

6. Site personnel will participate in a seminar on procedure Nuclear Training compliance. (CALLTII.1) Department Status: Verification complete.

7. A review of procedures used for (a) movement of new Plant StaffDepartments fuel and (b) movement of fuel during refueling will be I conducted to ensure clarity, consistency, and ease ofuse and changes will be made as warranted. (CAL LT II.2)

Status: (a) verification complete, (b) verification '

complete.

8. Current methods to monitor and measure procedure Nuclear Assessment compliance program effectiveness will be assessed and Department revised. (CALLTII.3)

Status: Activities in progress;

9. Evaluate procedure process (use, revision, backlog). Independent Safety (CAL LTII.4) Engineering Group Status: Activities in progress. Procedure Assessment Plan issued.

10. Review of System Operating Procedures Operations Operations Department personnel will perform a review /walkdown of system operating procedures. The l purpose of this walkdown is to identify and correct j procedure inadequacies that prohibit successful l completion of an operational evolution. l l

Status: Activity in progress. Project began 11/1/96. l i

I

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Attachment 1 to U-602670 Page 5 of15 Hg Action Items Responsible Denartment

11. Review of Station Surveillance Procedures Operations Maintenance The operating crew personnel will review scheduled surveillances prior to their performance to identify and correct inadequacies that prohibit successful completion of the surveillance activities. This review will be conducted in accordance with Operations Standing Order (OSO)-92.

Status: Activityin progress. Currently, surveillances are being reviewed 1-2 weeks in advance.

12. Maintenance Electrical Control and Instrumentation (EC&I) senior maintenance personnel who have experience with the performance of surveillances will review a random sample of the procedures, including at least 25% ofnli RF-6 surveillances to identify problems with methods or criteria.

Status: Activityin progress.

13. EC&I senior maintenance personnel who have Maintenance experience with performance of surveillances will review all outstanding comment control forms on surveillance procedures to assess if changes are timely and if significant problems exist which might call into question the effectiveness of the results.

1 Status: Activity in progress.

14. An assessment will be made of the EC&I maintenance Maintenanc' personnel who are qualified to perform surveillances to assure the combination of skills, procedures and training sufficiently prepares our technicians to properly perform surveillances. This will be accomplished by performing walk throughs of various surveillances by personnel with different levels ofexperience.

Status: Activity in progress.

1 J

Attachment 1

, to U-602670 Page 6 of15 l

& Action Items Responsible Denartment

15. EC&I supervision will review the last 35-50 TPDs or Maintenance PACS to determine the significance of the changes and affect on training, previous acceptability and effectiveness of the change.

Status: Activity in progress.

16. Field observations of RF-6 EC&I surveillances will be Maintenance performed to assess the actual quality of performance of the package. 4

~

l Status: Activityin progress. l

17. Provide training to appropriate personnel on Licensing 10CFR50.59 purpose, process and applicability.  !

Status: Under development.

i 1

9

1 Attachment 1 j ,

to U-602670 Page 7 of15 l

IL Conservative Decision-Making / Human Performance  !

& Action Items Responsible Denartment i

1. Expectations of conseivative decision making CPS Management Team l emphasizing safety of operation will be clearly defined and provided in writing to the following personnel:

(CAL I.1)

. Site Managers

. Plant StaffDirectors/ Assistant Director-Operations

. Work Control Team Leaders

. Facility Review Group Members

. Licensed and non-licensed Operations personnel

. Shift Technical Advisors

. System Engineers

. Active operatorlicense holders

. Management monitors Status: Verification complete.

2. A seminar on conservative decision making emphasizing Nuclear Training safety of operation will be provided to: (CAL I.2) Department / CPS Management Team /

. Site Managers Nuclear Station

. Plant StaffDirectors/ Assistant Director-Operations Engineering Department

. Work Control Team Leaders

. Facility Review Group Members

. Licensed and non-licensed Operations personnel

. Shift Technical Advisors

. System Engineers

. Active operatorlicense holders

. Management monitors Status: Verification complete. I

3. Plant or equipment condition limits will be provided to Plant Staff Dcpartments ensure conservatism: (CAL I.3)

. Operation of the plant at power, with Reactor Recirculation pump seal degradation exceeding conservatively established limits will not be permitted.

Status: Verification complete.

, . Attachment 1 l

. to U-602670 l Page 8 of15 l 1

& Action Items Resoonsible Department

4. Personnelinvolved have recognized and acknowledged Plant Staff their roles and errors made in this event. The Plant

', Manager will personally discuss elements of this event l

with each shift crew. (CAL VI.1) l I

~

Status: Activityin progress.

S. Plant Manager will meet with each crew member to Plant Staff ensure the following: (CAL VI.2)

. understanding of safe and conservative operation ,

e impact of operator actions and possibility for negative plant response e responsibility for placing plant in safe configuration

. planning for the n=rpacted

. procedural compliance is required even when no one is watching

. understanding of plant material conditions which impact plant operations Status: Activityin progress.

6. Additional plant or equipment condition limits will be Plant StaffDepartments developed as appropriate based on CPS and industry operating experience, to ensure conservatism. (CAL LT I.4)

. Turbine Vibration Status: Activityinprogress.

~ 7. Review April 1996 incident corrective actions for Licensing adequacy, timeliness and effectiveness. (CAL LT IV.1)  ;

i Status: Verification in process.

8. Review SOER 92-01, " Reducing the Occurrence ofPlant Licensing Events Through Improved Human Performance,"

response for adequacy. (CAL LT IV.2)

Status: Verification complete.

,y

Attachment 1 ts U-602670 Page 9 of15 ML Action Items Responsible Departmut

9. Simulator Restan Training Operations / Nuclear Training Department Active licensed operators and Shift Technical Advisors / Shift Engineers will participate in startup training on the simulator. This training session will reinforce expectations on management oversight and roles, procedure compliance, conservative decision making and reactivity management. The simulator session will be conducted with the intended crew composition as we rotate into normal shift compliments and will include management monitors.

Status: Activity has not started.

i

- . . . ~ - - . - . _---.._-- --.-.--. ..-.. . . - - - -

I I

' Attachment 1 j -

to U-602670 Page 10 of15 i

i 1 l III. Management Oversight  !

j No Action Items Responsible Department i

] 1. Roles, duties and expectations of personnel involved in Plant StaffDepartments operational oversight activities will be reviewed and revised. (CALIII.1)

Status: Veri 6 cation complete.

l 2. Provide a briefing on operational oversight roles and Plant StaffDepartments/

j responsibilities to the following personnel: (CAL III.2) Nuclear Training Department i e Operating crews

! . Active Operator License Holders j 1 . Shift Technical Advisor {

e System Ragia-s j e Assistant Plant Manager-Operations and Assistant i

! Director-Operations

. Plant Manager t e Management monitors j Status: Verification complete.

i

3. During restart activities and until stable power operation Plant StaffDepartments i is achieved, myerier.ced plant personnel will be assigned l to monitor main control room activities. They will be j specifically be charged with assessing the proper oversight functions by line management. (CAL III.3)'

i

)

Status: Activity in progress, and will continue through

startup to stable power. Also awaiting revised

work schedule for Management monitors. Draft Management monitors objectives is presently i j being reviewed.

l l 4. A startup plan will be developed which provides " hold Plant StaffDepartments  !

l points" at which progress in the startup, equipment i

conditions and appropriate next steps are evaluated by Operations management and the shift crews. (CAL III.4)

Status: Verification in process.

i 1

1 1

l ,

~

Attachment 1

. to U-602670 Page 11 of15 l

h Action Items Responsible Department i

5. Methods will be developed to monitor operational Nuclear Assessment decision making to ensure that expectations continue to Department be met and are reinforced. (CAL LT I.3) l Status: Verification in process.

6. A process will be established to ensura that personnel Plant StaffDepartment ,

who may be assigned to operational positions which have oversight responsibilities will be briefed on those {

4 responsibilities prior to assuming the position. (CAL LT III.1)

Status: Verification complete.

7. The Senior Management Team will conduct a self- Vice President and Senior critique of personal performance related to this event and Management Team identify areas for improvement. (CAL LT VI.1)

Status: Activities in progress.

8. Establish a lower threshold for initiating assessments Nuclear Assessment based on events, conditions or trends. (CAL LT VI.2) Department Status: Activityinprogress.

1 Attachment 1 to U-602670 Page 12 of15 l l

IV. Plant Material Conditions

& ActionItems Responsible Deoartment

1. The "B" Reactor Recirculation (RR) pump seal was Nuclear Station  !

replaced and will be tested. (CAL V.1) Engineering Department 1

Status: Verification process, a) Assembly and l preliminary testing activities have been verified.

l b) This item cannot be verified as complete until PMT is performed at plant startup.

l 2. The Drywell Floor Drain (RF) leak detection and flow Nuclear Station measurement instrumentation was made operable and Engineering Department l testei (CAL V.2) 1 j Status: Verification complete.

3. The Drywell Equipment Drain (RE) leak detection and Nuclear Station 4

flow measurement instrumentation was made operable Engineering Department j and tested. (CAL V.3)  !

! Status: Verification complete.

I

4. Outstanding corrective MWRs will be reviewed to Facility Review Group

} evaluate material conditions that impact plant operations.

(CAL V.4)

Status: Verification complete.

5. Develop and implement the following actions for RF leak Nuclear Station detection systems

(CAL LT V.3) Engineering Department e Incorporate the leak detection calculation method (based on RF sump fill times) into the process

computer.

. Perform complete and thorough cicW g of the RF

weir V-notch system.

e Determine and implement float setpoints change for

i improved time response for the alternate (LD-027)

leak detection system which is based on RF sump pump discharge flow measurements.

l Status: Activityin progress.

l l

. l l

Attachment 1 to U-602670 l Page 13 of15 j f

j Ng Action Items Responsible Denartment

6. Incorponte the leak detection calculation method (based Nuclear Station

on RE sump fill times) into the process computer. (CAL Engineering Department i i

LT V.5) i i

Status

Activityin progress.

+

l t

a 7. The Vice President, Manager-CPS and Manager-NSED Senior Management Team i i will assess long term material deficiencies on a quarterly i i basis to ensure that corrective actions are being pursued

! aggressively and operational needs are clearly being met.

l (CAL LT V.6) (This will satisfy the initial assessment.

The quarterly assessment will be a long term action.)

At a minimum this assessment will address

f 1

. Main Control Room Deficiencies j . Operator Work Arounds j e Maintenance Rule Category A.I. Systems

. . Top 10 Long Standing Material Problem List i i

j Status: Activities in progren 1

j 8. Review 1995 and 1996 NRC Inspection Report material Licensing i condition items for adequate response. (CAL LT V.7)

Status: Verification complete.

l 4

l

l l

' Attachment 1

, ts U-602670 .

i Page 14 of15 i

& Action Items Responsible Department j

9. Operabilitv/ Generic Letter 91-18 Review adequacy of past operability evaluations and Eng*meering and determinations. Identify and resolve any open issues Operations  ;

which would result in equipment operability being questionable.

Status: Activities in progress.  !

Develop Operability Determination Program for Clinton Power Station. Engineering and Operations Status: Activities in progress.

Develop guideline for Reportability.

Licensing l Status: Activities in progress. j Train appropriate engineering personnel on Operability Engineering  !

Determination Program.

Status: Under development.

Train appropriate operations personnel on Operability Operations Determination Program.

Status: Under development.

l t

l f

Attachment 1 )

to U-602670 i Page 15 of15 l

Na Action Items Responsible Department

, 10. Action Plans Review adequacy ofpast action plans and determine if Engineering any actions are required.

Revise CPS 1010.0' accedure on action plans.

Determine if any changes are needed to action plan process / program.

Status: Activities in progress.

Provide guidance to appropriate site personnel on action Operations plan use as it pertains to manipulation of plant equipment.  !

Status: Under development.

11. Butterfly Valves Perform bounding analyses for pipe stress and supports, Engineering and update seismic analyses to validate initial operability evaluation and to determine if any further RF6 actions .

are required to assure operability is maintained.

Status: Engineering evaluation completed. Awaiting '

completion ofECN 29942 and 29943 for FC pipe i supports.

I

12. Conduct a review of open MWRs (except CM-MWRs) Maintenance / Operations /

older than 6 months old to verify no material deficiencies Engineering exist that significantly affect plant operations.

Status: Activities in progress.

Attachment 2 l

. to U-602670 l Page1of2 i Technical Actions Reautred for Startun This attachment describes the technical actions required to be resolved for startup of Clinton

?

Power Station. Although these actions are not described in the Startup Readiness Action Plan, i they will be complete prior to startup. These actions include those required by Technical Specifications or equipment operability concerns.

No. Action Items Responsible Department

1. Resolve immediate operability issues with feedwater NSED check valves 10 A/B and 32 A/B.

t J

Status: In progress. ,

1 i 2. Provide assurance that feedwater check valves will NSED i remain operable for one operating cycle. This will be i required within 60 days of plant startup.

4 Status: Not started.

1 1

3. Determine and resolve operability issues within the scope NSED {

i of GL 96-06. Written response will be provided in  !

4 accordance with the generic letter reportmg l

requirements.

i I. Status:In progress.

4. Ensure that AR/PR system is an effective tool for Operations l j identifying radiological conditions within CPS. Provide  !

l training and expectations to Radiation Protection and i Operations personnel on monitoring and use of the l system.

Status: In progress.

5. Review the current population ofidentified operator Operations workarounds for proper priority and scheduling of resolution. Ensure adequatejustification for those that will not be corrected in RF-6.

Status: In progress.

Attachment 2 to U-602670 Page 2 of 2

& Action Items Responsible Department

6. Review the current population ofidentified Main Control Operations Room deficiencies for proper priority and scheduling of resolution. Ensure adequatejustification for those that  !

are not scheduled in RF-6.

Status:In progress.

l l