IR 05000461/1981030

IE Insp Rept 50-461/81-30 on 811207-11.No Noncompliance Noted.Major Areas Inspected:Preoperational Test Program, Test Organization & Administration & Document Control

ML20040C479
Person / Time
Site:	Clinton
Issue date:	01/14/1982
From:	Jackiw I, Lanksbury R, Ring M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20040C477	List: IR 05000461/1981030 ML20040C476
References
50-461-81-30, NUDOCS 8201270715
Download: ML20040C479 (10)

Text

U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-461/81-30 Docket No. 50-461 License No. CPPR-137 Licensee:

Illinois Power Company 500 South 27th Street Decatur, IL 62525 Facility Name:

Clinton Nuclear Power Station, Unit 1 Inspection At:

Clinton Site, Clinton, IL Inspection Conducted: December 7-11, 1981 q?ifb-<,

Inspectors:

M. Ring /

/ a; FL 4Q{

'

g. Lariks >ury(December 9-11)

/[/f d

,

D l~c [ U~

I.N7$a:ctw, Chief

[k 6 Approved By:

Test Pfo' gram Section Inspection Summary Inspection on December 7-11, 1981 (Report No. 50/461-81-30)

Areas Inspected:

Routine announced inspection to review the preoperational test program; test organization; test program administration; preoperational document control; temporary modifications; and test and measuring equipment.

The inspection involved 53 inspector-hours onsite by two NRC inspectors including 0 inspector-hours during offshifts.

Results: No items of noncompliance or deviations were identified.

82012golI5 L

-

.

.

DETAILS 1.

Persons Contacted

• T. Plunkett, Plant Manager

• D. Cain, Assistant Plant Manager

• J. Greene, Startup Supervisor

• L. Tucker, Assistant Startup Supervisor

• D.

Vincent, Startup Administrative Assistant

• L. Koch, Vice President, Illinois Power

• M. Hollon, Supervisor, Construction QA

• M. D' Haem, Supervisor, Operations QA

• C. Calhoun, Operations QA

• E. Connor, Director, Compliance

• L. Dozier, Assistaat Director of Construction

• R. Morgenstern, Station QA Engineer

• W. Calhoun, Supervisor, Electrical Construction

• D. Tucker, Compliance Supervisor

• C. Motsegood, Supervisor, Construction Engineering

• Denotec those attending the exit interview.

In addition, several individuals from Baldwin Associates attended the exit interview. The inspectors also contacted other members of the licensee's technical and administrative staff.

2.

Preoperational Test Program A summary of some recent preoperational test problems encountered at other plants was discussed with the licensee (see Attachment A).

The licensee agreed to review those problems and ensure administrative controls are in place to minimize the occurrence of similar problems at Clinton. This review is scheduled to be completed by January 31, 1982. This is an open item (461/81-10-01) pending further review by the inspector.

The inspectors reviewed the licensee's description of the preopera-tional test program to determine that general areas of testing were identified and responsibilities have been assigned for the following:

a.

Flushing and cleaning systems b.

Hydrostatic testing c.

Instrument calibration d.

System turnover e.

Functional demonstration of equipment f.

Electrical, mechanical and instrument and control testing The inspecors determined that the Clinton FSAR, Startup Manual, Startup Procedures and Startup Instructions adequately identified and assigned responsibility for the above testing areas.

-2-

-

.

.

The inspectors reviewed the licensee's test program to ensure that it includes requirements for testing consistent with FSAR commitments-such that tests to be performed have been identified and sequenced.

The inspectors reviewed the program to ensure that for each of the identified tests the following was included:

a.

Test Objectives b.

Summary of the test c.

Necessary prerequisites d.

Acceptance criteria In order to evaluate the licensee's program, the inspectors utilized the Clinton FSAR, the Startup Manual, Procedures and Instructions and Regulatory Guide 1.68.

The inspectors noted that the Startup Manual describes preoperational tests that may not be completed or even started prior to fuel load. The FSAR and responses to Grand Gulf questions, however, indicate that all preoperational testing is scheduled to be completed prior to fuel load. The licensee agreed to resolve this discrepancy and provide a listing and description of those preoperational procedures to be completed or started af ter fuel load. This is an open item (461/81-30-02) pending development of the list and review by the inspectors.

No items of noncompliance were identified.

3.

Test Organization The inspectors reviewed the licensee's organization in order to determine that responsibilities, methods of appointing, and lines of authority for key test personnel were formally specified in writing.

Additionally, interfaces between organizations were examined to verify that organizational responsibilities were clearly established. The Startup Manual, Clinton FSAR and Clinton organizational charts were used for this review.

4.

Test Program Administr.-ti_on The inspectors reviewed the licensee's program to verify that methods have been established for the test group to receive jurisdiction over systems from other organizations. The program was also reviewed to verify that administrative procedures provide for:

a.

Control of system status prior to testir?

b.

Return of systems or components to a st y ctaan for modification or repair.

c.

Control of system status subsequest to test;ng.

The inspectors reviewed the licensee's program to verify that adminis-trative measures have been established to govern the conduct of testing including the following:

-3-

,

.

.

a.

Method to verify-a test procedure is current prior to its use.

b.

Method'to. assure personnel involved in the conduct of a test'

are knowledgeable of the~ test procedure, c.

Methods to change a test procedure during the conduct of testing.

d.

Criteria for interruption of a test.

e.

Methods to coordinate the conduct of testing.

'f.

Methods to document significant events.

g.

Methods for identifying and documenting deficiencies and their.

resolutions.

The inspectors reviewed the licensee's program for the evaluation of test results to verify that it contained provisions for the following:

a.

Reduction of test data to meaningful' and understandable form.

b.

Checking of test results and comparing to previously determined performance standards.

c.

Identification of deficiencies and their corrective action.

d.

Testing, following corrective action or modifications, to ensure system is adequately tested.

2.

Appropriate review of results.

The inspectors primarily utilized the Startup Manual and Regulatory Guide 1.68 for their review of the above areas. During the course of the review, several comments on the wording and content of the Startup Manual were discussed. The licensee agreed to review these come.ats and make changes as appropriate. This is an open item (461/81-30-03) pending review and incorporation of comments and subsequent. inspector review.

No items of noncompliance or deviations were identified.

5.

Document Control The licensee's program for test procedure control was reviewed to verify that administrative measures had been' established to control review, approval and issuance of test procedures and revisions.

'The inspectors also reviewed the licensee's program to verify that master indexes were available for drawings and manuals which indicate their current revision number and that a mechanism exists to ensure test procedures will be updated when manual or drawing revisions occur.

These programs were reviewed to verify that the responsibilities for implementation of these controls had been assigned in writing. The licensee's Startup Manual, Procedures and Instructions were used for this review.

-4-

_

.

.

..

-

.-

._

.-

.

.

,

.No-items of noncompliance or deviations were identified.

-

6.

Temporary Modifications, Jumpers and Bypasses

,

The inspectors reviewed the licensee's program to verify that written administrative controls had been established for controlling temporary modifications, jumpers and bypasses..The inspectors noted that the licensee's procedures did not contain provisions for independent verification of installation or removal of jumpers as described in ANSI 18.7, Section 5.2.6.

The licensee agreed _to review their pro-

cedure from the aspect of implementing controls similar to ANSI 18.7 during their test program. This is an open item (461/81-30-04)

'

pending further review by the inspector.

j No items of noncompliance or deviations were identified.

7.

Test and Measurement Equipment The inspectors reviewed and discussed with the licensee.his program and administrative procedures for control of test and measurement equipment during the preop and startup programs to determine if the program addressed the following:

a.

A listing of controlled test equipment, the calibration require-ments, and the calibration history.

b.

Controls for storage and issuance to preclude use of equipment which has not been calibrated within the specified interval.

i c.

Requirements for recording test equipment identity and calibra-

!

tion date in test procedures to permit retest if equipment is i

subsequently found out of calibration.

'

The following problem areas were noted:

1.

CPS No. 0AP1512.01N, Calibration and Control of Measuring and'

Test Equipment a.

The procedure does not currently require that if a piece of test and measuring equipment (M&TE) is lost or damaged that a recheck of the equipment that was calibrated with the M&TE is to be' performed. The licensee has stated that they are aircady doing this and have agreed to add the required instructions to the procedure. This is an open item (461/81-30-05) pending review of the procedure change by the inspector.

b.

Paragraph 8.1.14 of the procedure currently allows an M&TE file to be destroyed and its Equipment Identification Number

!

(EIN) reissued after-one year for any lost or damaged units of M&TE or Reference Standards.

If this procedural allowance

-5-

-

_. _ _

-

_

_

__

_.,

_ ____________ ______

O

is utilized then M&TE or Reference Standards would not have a unique identification number and the potential exists for more than one piece of M&TE or more than one Reference Standard-to eno up in use with the same EIN. The potential exists for plant equipment being calibrated with a piece of M&TE for which no calibrated records exist. The licensee has agreed to change the procedure to not allow reissue of an EIN. This is an open item (461/81-30-06) pending review of the procedure change by the inspector.

c.

Paragraph 8.1.12 of the procedure allows the licensee to reestablish the acceptability of equipment calibrated with M&TE or Reference Standards, that are later found to be out-of-calibration, by retesting or recalibrating, commencing with the most recently calibrated or tested equipment, until two items in succession are found to be within normal speci-

.fications.

ANSI Standard N18.7, paragraph 5.2.16, and CPS Operational QA Manual, Chapter 12, requirement 6, require that when M&TE are found to be out of calibration, an evalua-tion shall be made and documented concerning the validity of previous tests and the acceptability of devices previously tested from the time of the previous calibration.

The inspector believes that the licensee has not met the intent of the ANSI Standard and QA Manual with their current procedure for the following reasons:

1.

The existing procedural requirement does not require a " documented evaluation" of the validity of previous work.

2.

The potential exists for two items in succession to be calibrated within normal specifications with M&TE that is not within its required calibration band.

3.

The licensee was unable to give a technical justifica-tion as to how "two items in succession" was developed as an acceptable method of meeting the intent of the ANSI Standard and QA Manual.

The inspector discussed the above with the licensee and provided them with an acceptable method of verifing the validity of previous work. The license agreed to consider this in their review of this matter. This is an open item (461/81-30-07) pending further review by the inspector.

2.

CPS No. 0AP1912.01N, Calibration and Control of Rad Chem Measuring and Test Equipment The inspector reviewed the licensee's calibration program for the Rad Chem department and noted that at this time it has not-6-

.

_

.

.

..

..

_ _ _ _ _ - _ _ _ _ _ _ _ _.

.

been fully implemented and all of the procedures have not been issued.

It was also noted that for the procedures that have been issued that problems similiar to those noted above in Item j

1 also exist. This was discussed with the Rad Chem Supervisor j

and he has agreed to make whatever changes are made in the l

Maintenance Department procedures as a result of these open items.

l This is an open item (461/81-30-08) pending review of the fully implemented Rad Chem calibration program by the inspector.

3.

The inspector reviewed the licensee's Startup Manual and noted that in the section covering procedure format that no requirement existed to include a form for the test engir.eer to record infor-mation on the piece of M&TE being util.tzed (i.e., calibration date, instrument number, etc.).

This was discussed with the Startup Supervisor who stated that a form is already being used and he agreed to include a requirement to use this form in the next revision to the Startup Manual.

No items of noncompliance or deviations were identified.

8.

Exit Interview The inspectors met with licensee representatives (denoted in paragraph 1) on December 11, 1981. The inspectors summarized the scope and findings of the inspection. The licensee acknowledged the statements

~

by the inspectors with respect to the open items.

Attachment: Recent Preoperational Test Problems Encountered at Other Plants-7-

- _ _ _ _ _ _ _ - _ _ _ _ _

-

.

ATTACHMENT A RECENT PRE 0PERATIONAL TEST PROBLEMS ENCOUNTERED AT OTHER PLANTS 1.

Turnover a.

No documentation included in turnover package for an air blow used to clean components in diesel generating air start system.

No specific acceptance criteria for cleanliness were used.

Subsequently, one set of air start motors failed due to dirt in an air valve.

b.

Several components turned over for pre-op testing were lacking blue tags indicating release for pre-op testing.

Components temporarily turned back to construction were not tagged to indicate the status.

• c.

Turnover package for diesel generator system did not identify jumpers which master jumper log and another jumper log identified as being installed.

(Jumpers were not installed.)

d.

Approximately 10% of tags on RHR and Reactor Protection System indicating release for pre-op testing were missing or mutilated.

c.

System release for pre-op testing did not. include several components.

Tag identifying release for pre-op testing for a component was hung on piping vice the component and tag remained when component was removed for calibration.

f.

Tvn) dif ferent revisions, each designated 01, to the RHR System pre-op test release were found to be in use.

g.

" Temporary" brackets were welded to, and removed from, the primary containment liner by subcontractors without instructions, procedures or drawings governing their Installation.

No records of welding, removal and NDE verification of the liner following removal existed, ll.

Test Procedure a.

Licensee review of the Integrated leak rate test was not adequate

-

to uncover significant deficiencies.

b.

Test procedure measuring response time for turbine control valve fast closure did not include acceptance criteria listed in design documents.

c.

The 250VDC Battery Test was terminated without making an approved change to the procedure and without completing the actions required by the procedure.

.

...

._.

.- -

..

-

_.

-

-

-

.

-2-

d.

Procedure on reactor recirculation and flow control did not contain precautions or limitations necessary to protect the reactor vessel against thermal transients.

i

{

" Minor Change Request" was approved when the intent of the proce-e.

dure was changed.

'

i f.

A change to the Startup Manual was generated, reviewed, proofread, and approved even though it listed the same criteria for major

<

and minor procedure changes.

g.

A test procedure acceptance criteria' was written,f approved,

'

performed and results reviewed and approved for the low level alarm on the diesel generator fuel storage tanks which would

i allow the amount' of stored fuel to fall below the minimum require-ments of the FSAR.

h.

A test procedure involving reactor vessel level was performed,

'

reviewed, and the results approved without noting a potential safety degradation through a malfunction of the system's trip i

switches.

i.

Vibration instrument was used which was not listed in the

'

required test equipment section of the procedure.

Ill. Calibration

a.

Calibrations of entire instrument loops were not always being-performed prior to pre-op testing.

No program existed for

'

conducting periodic calibrations during the construction phase of the plant ' prior to acceptance of a system for operation.

b.

A procedural requirement to have all instruments "within current calibration intervals" was signed off even though the intervals

,

had not been determined.

c.

A wattmeter for the diesel generator was not properly calibrated; its calibration was not assured by the test' engineer; and records of its calibration and the required correction factor.

were not kept.

As a' result the diesel generator was inadvertently overloaded up to 126% of rated power during,

subsequent testing.

I

(

i

!

.

y

.- -

-,,,

y,

,

,

e m.

-

~,,..

.

_.

-.,.. _. -.,

, _..

, - -..., -. -,...

,. -

,,,,

-.

e' ?

.*

_3_

IV.

Jumper and Temporary Power Control a.

Removal of _the electrical jumpers in a dicsci generator-panel was not verified and documented in master jumper log.

Situation existed for four months.

b.

No procedure established for shift engineer to control status _of electrical power leads during station construction.

Originated with a personal injury accident.

V.

Cleanliness Lack of a program to maintain adequate cleanliness as evidenced by a foreign substance high in chlorides found adhering to the inside of the reactor vessel wall, head core support plate and feed sparger inlet box; dust, grit and debris such as cups, cigarette packs and beer cans found in diesel generator, TIP machine and reactor control panels.

VI.

Document Control Motor operated valve torque switch setting lists issued by station nuclear engineering department were not controlled in that several incomplete, inconsistent or obsolete lists were being used at site.

Vll. Deficiency Documentation Two weeks elapsed between the identification of a damaged thermocouple on reactor vessel bottom drain _ and the generation of a deficiency report. One month clapsed between the t ime that recirculation loop suction temperature instruments were known to be giving inaccurate readings and the issuance of a deficiency report.

Vill. Valve Lineups

,

Several valves which should have been shut (one should have been tagged shut) were lef t open and as a result high pressure core spray

'

and condensate and low pressure core spray were cross-connected causing a rupture of the steam jet air ejector condenser.

IX.

Design

The design of the diesel generators did not guarantee capability to

'

supply reliabic emergency power in required time would not be impaired during periodic testing of dicscis.

Therefore, the preop test _did not include a demonstration of this capability.

,

.

f

.