IR 05000461/1985061

Insp Rept 50-461/85-61 on 851112-860207.Violation Noted: Jurisdictional Tagging Requirements of Administrative Procedure Changed Inappropriately & Maint Procedure Failed to Conform to IEEE 450-1975

ML20138A073
Person / Time
Site:	Clinton
Issue date:	03/08/1986
From:	Dupont S, Odwyer G, Ring M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20138A064	List: IR 05000461/1985061 ML20138A061 ML20138A066
References
50-461-85-61, NUDOCS 8603140024
Download: ML20138A073 (10)

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U.S. NUCLEAR REGULATORY COMMISSION REGION III ,

Report No. 50-461/85061(DRS)

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: November 12, 1985, through February 7,1986 Inspecto uP t .3 J 0 %/

G. F. O'Dwyer 3!7!8G Dhtd b

Approved By: M. A. Ring, Chief 7~ d Test Programs Section Date Inspection Summary Inspection on November 12, 1985 Through February 7,1986 (Report No. 50-461/85061(ORS))

Areas Inspected: Actions on previous inspection findings, preoperational test procedure review (70341), preoperational test witnessing (70315, 70441, and 70460), preoperational test results review (70322), and preoperational systems turnover and control by operations (71302). The inspection involved 117 inspector-hours onsite by two NRC inspectors including 40 inspector-hours onsite during offshift Results: Of the five areas inspected, no violations were identified in three area In the remaining two areas, two violations were identified (procedures not appropriate to the circumstances - Paragraph 6.d, and failure to revise procedures in accordance with established measures - Paragraph 6.e).

8603140024 ADOCK e60 $61 PDR PDR G

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DETAILS Persons Contacted

• W. C. Gerstner, Exective Vice President

• 0. P. Hall, Vice President

• F. A. Spangenberg, Manager, Licensing and Safety

• J. W. Wilson, Plant Manager

• J.- S. Perry, Manager, Nuclear Programs Coordinator

• J. Greenwood, Manager, Power Supply (Soyland/WIPCO)

• J. E. Loomis, Construction Manager

• J. L. Thompson, QE Manager

• E. W. Kant, Assistant Manager, NSED

• J. G. Cook, Assistant Plant Manager

• E.. J. Corrigan, Director, Quality Engineering and Verification

• J. A. Miller, Director, Nuclear Training

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• R. F. Schaffer, Director, Nuclear Training

• K. A. Barker, Supervisor, Inspectional Enforcement Interface l

D. Holesinger, Director, Startup Testing

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-The inspector also interviewed other licensee enployees, including members of the Quality Assurance, Startup, and Operating staffs.

l * Denotes those attending the exit interview on February 7, 1986.

l Actions on , Prev r _i_o_us_ Inspe_ction_

s Finding d (Closed)OpenItem(461/84-20-05): Review the upgraded preventative maintenance program for trending on an automated planning and scheduling

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program. The inspector reviewed the Maintenance Trending Procedure, 1 MS0-018, which was developed to utilize a computer program for automated l trending and the supporting documents, including printouts for system

failures, equipment history search results, and the search options display.

i The inspector has determined that the upgraded program is satisfactory and has no further concerns.

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(Closed) Unresolved Item (461/85036-01) and Violation (461/85036-02):

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Testing sequence was not controlled for preoperational test PTP-RI-01 and l

the actual testing sequence for all preoperational testing shall be

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documented within the test sumary of the test result package. The inspector reviewed several test result packages including PTP-VH-01 and verified the implementation of the requirements of the revised startup l

administrative procedure SAP-5, " Test Result Review " to document actual testing sequence and to verify that testing acceptance criteria were not violated by testing out of sequence. The inspector has no further i

concerns in this are (Closed) Open Item (461/85036-05): Verify control of jurisdictional transfer. The inspector has identified a violation in control of l

jurisdictional tagging as discussed in detail in Paragraph 6.e of this

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report. All concerns regarding jurisdictional control will be tracked l with the violation (461/85061-05) and therefore, this open item

(461/85036-05) is close _ . _ _ - _ _ _ _ _ _ _ L__m..____.-_______ . . . _ _ _ _ ----m __ m - -_.m.__ _ _ _ _ _ _ _.-_ m_-_--_.___._._______-_._m __ ______.____.____.____._____

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(Closed) Violation (461/85048-01)'and Unresolved Item (461/85048-02):

Preoperational test PTP-SC-01, Standby. Liquid Control System, did not verify all design requirements. : Additionally, the unresolved item involved verification that the requirements of 10 CFR 50.62(c)(4) are met. The inspector verified that PTP-SC-01 was revised to contain the methodology to. verify adequate mixing of the boron solution under the conditions of the Technical Specification The inspector also verified

.that the requirements of.10 CFR 50.62 will be incorporated into the Technical Specifications and'as such a surveillance will verify the requirements. The inspector.has no further concern . .Preoperational Test Procedure Review The inspector reviewed the preoperational procedures for PTP-DG/DO-01,

" Division I Diesel Generator," and PTP-DG/DO-02, " Division II Diesel Generator," for compliance with the FSAR, the SER, Regulatory Guides 1.68 and 1.108, and.the Startup Manual. The inspector determined that the procedures.were: satisfactory and that the procedures' acceptance criteria were in compliance with the required design document No violations, deviations or unresolved items were identifie . Preoperational Test Witnessing The inspectors witnessed the following preoperational testing to ascertain through observation and record review, that testing was conducted in accordance with approved procedures and the requirements of the Startup Manual. The tests were found to be satisfactory except as noted below for PTP-SX-01: PTP-RC-01, " Rod Control and Information Systems." The inspector witnessed various logic testing that verified the rod selection, movement limits and annunciation function PTP-DG/00-02, " Division II Diesel Generator." The inspector witnessed two of the required starts and verified by review of data that an additional ten starts had met the requirements of the FSA PTP-SX-01, " Shutdown Service Water System." Revision While witnessing'the performance of various portions of step 7.12.2 the inspector noted that step 7.12.2.2 simulated an automatic containment isolation signal by jumpering a contac This signal caused, among other actions, the Service Air System Inboard Containment Isolation Valve, 1SA030, to clos The procedure then directs the actuation signal be reset and verification that the valve automatically repositions open. This is contrary to the applicant's commitment that ESF equipment will remain in its emergency state following a reset of the' actuation signal as documented in section 7.3.3 of Supplement 2 of the SER for Clinton. The SER further states that a manual operator action at the component level is required to return ,

the actuated equipment to its normal mod The applicant confirmed

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that this valve should not automatically reopen upon reset of the i

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, . actuation. signal and that the' test'is incorrec Further,.upon review of the design drawings the inspector determined that the logic for valve ISA030 is in compliance with the commitment and that.the valve

will not~ automatically reopen upon reset of the actuation signa The' inspector also' reviewed preoperational procedure PTP-N8-01,

'" Containment Isolation," and found the logic testing of the containment valves to be correct and in accordance with the commitment of the.SER. Additionally, the inspector found that valves 1SA030 and 1SA032 (Division I and II) were included in PTP-NB-04. Since the valves.are not part of the criteria.for acceptance of PTP-SX-01 and are included in the. acceptance of PTP-NB-04, the incorrect procedure (PTP-SX-01) is'not considered a' violation of the commitmen Additionally, the safety significance of having an inadequate testing method contained within PTP-SX-01 is mitigated by both the actual as-built logic being correct and the fact that the testing of these valves will be performed by PTP-N8-0 Prior to the completion of the inspection, the licensee submitted a Test Change Notice (TCN-1) to PTP-SX-01 to correct the testing method of valves 1SA030 and ISA032 to conform to the SER commitment. Because of the licensee's a cions, the actual safety significance, and the fact that the commiteent is met in PTP-N8-04, this is not considered a violation. However, because of the inadequate testing method contained in PTP-SX-01, this will be considered an unresolved item (461/85061-01) until the correction to the preoperational procedure is implemented by TCN- No violations or deviations were identified; however, one crea requires further review and is considered an unresolved ite . Preoperational Test Result Review The inspector reviewed the following preoperational test results for acceptance and completion of test objectives in accordance with the FSAR and SE In addition, the licensee's test result evaluations were reviewed for adequacy and found satisfactory:

PTP-VH-01, " Shutdown Service Water Vent" PTP-HP-01, "High Pressure Core Spray" No violations or deviations were identifie . Preoperational Systems Turnover and Control by Operations Scope of Inspection The inspector reviewed the administrative and management controls to determine if the systems configuration, testing, maintenance, and design changes are controlled, tracked and evaluated after a system is transferred from Startup's control to the Illinois Power (IP)

plant staf _ _ _ - _ _ _ _ _ _ _ _ - - _ _ _ - - _ _ _ _ _ _ _ _ _ - _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ - _ -

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'+ r KThe inspector. determined that the. turnover l process was accomplished

.in two separate stages, the Phase II Final Release and the Declaration of Readiness. In general, the Phase II Final Release is described in the Startup Manual and accomplished by Startup and Clinton Power Station (CPS), administrative procedures while the Declaration of Readiness does not have any administrative procedures accomplishing control other than management verbal' directives, Phase II Final Release-The' inspector reviewed startup procedure SAP-6, " System Release to Plant Staff," and CPS procedure 1040.01, " System Release Review and Acceptance." The Phase II is initiated by the Manager - Startup by submitting the release package to the CPS Plant Staff for revie The review is accomplished in two parts, the review of documents provided and a system walkdown by the applicable departments with Startu The inspector reviewed the following Phase II Release packages:

DC-1, " Division I 125VDC Battery System" DG-1, " Division I Diesel Generator System" LP-1, " Low Pressure Core Spray System" HP-1, "High Pressure Core Spray System" AD-1, " Automatic Depressurization System" The inspector also verified that the following documentation was included in the packages:

• Marked up drawings defining the boundaries of the releas * Lists of equipment, panels, breakers, cables, and instruments within the release boundarie * A punchlist defining open item * A copy of the temporary alterations log for any open ite *. A description of any incomplete testing that should be normally accomplished prior to Phase II Release,-including test exception * A description of any special precautions and instructions for operations or maintenance that are not normally in the CPS Operating Manua * Copies of open CWRs, MWRs, FPRs, GWRs, CRs, NCMRs and design change * A description of any unsatisfactory test results which have not ,

been corrected prior to the releas !

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.P The inspection did not determine ~ the adequacy of tt.e above

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-documents, only that the documents were provided in the Phase II

Final Release.. The adequacy of the documents will be examined in 1 1 ~ detail-during subsequent inspections .

L CPS 1040.01 recommends, "that the final release package is reviewed

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' to identify any conditions which may preclude release acceptance." .

2 Examples may include unsatisfactory or incomplete test results, outstanding construction work, equipment inoperability, and the  :

system final ASME N-5 Data Report not being certified by the Authorized Nuclear Inspector (ANI).- The' inspector finds this to be  ;

' inadequate for acceptance since.this is'only a recommendation that

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may or may not be considered by the reviewing CPS Plant Staff Director for' accepting the system.' In addition, the inspector found that the

. ' preoperational test is not required by CPS 1040.01 to be completed or

the test results to be reviewed and evaluated prior to the Phase II Final Release. CPS 1040.01, Step 8.4.2 states, "Normally, startup 4 does not initiate a Phase II release until the preoperational test i results have been reviewed and accepted by the Joint Test Group." The

inspector has determined that on several occasions the test results

have not been reviewed, and on at least one occasion the system was

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Phase II released initiated without completing the preoperational

tes The inspector found that preoperational testing was still being i performed on the High Pressure Core Spray system while the Phase II s review was being conducted by CPS Plant Staff. Another Phase II

release was initiated on the Division III 125 VDC Battery System with i one complete test section and acceptance criteria still open for

- retesting. Discussions with CPS Plant Staff revealed that the i licensee finds these activities to be acceptable because the open

testing on the battery. system will be punchlisted and a Startup Test Authorization Form (STAF) tust will resolve the open item as defined 1 by Section 6.2, " Completing Open Phase II Items," of CPS 1040.01.

l Section 6.2 defines open items in three broad categories: (1) open testing which only requires a STAF to complete; (2) open work where maintenance activities require a Maintenance Work Request (MWR) and l

possibly a STAF to complete testing and; (3) open modifications which  !

includes changes to the system after the preoperational test was i performe CPS recommends that the Maintenance Department should review and determine if the open item should be closed with an MWR

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alone,'or if a STAF should also be performed. In addition, the t

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Nuclear Station Engineering Department (NSED) should generate Plant i Modification Requests (PWR) to track remaining modifications or may  :

! request the Technical Department generate the.PWR, d

.These recommendations of CPS 1040.01 do not require any department to i take actions or specify that any organization is responsible to track the system as a whol This subject is part of an unresolved inspection item (461/85061-02) in that the administrative procedure,  ;

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CPS 1040.01, does not define the minimum criteria for accepting a system or that management controls the Phase II release activity.

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.p Declaration of Readiness'or Operability The' inspector discussed the process described as " Declaration of

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Readiness" with various directors and the Manager - CPS. During the discussion the inspector determined that the process was accomplished

without, an administrative procedure to direct the activities. - The

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activity was. accomplished, however, by verbal management directives during scheduled meetings where the various department directors discussed closure.of punchlist items,.such as MWRs, open testing, and modifications. Once the system punchlist is reduced to a condition to

support fuel load, the Manager - CPS declares the system operabl However, as discussed above with CPS, Procedure 1040.01, there is no minimum acceptance criteria established except by verbal directive This is also considered part of the unresolved item (461/85061-02) in that minimum acceptance criteria for a system are not established and that management control is by verbal directives onl The licensee has committed to develop and define a management program with administrative procedures containing minimum acceptance criteria for. determining system operability in response to the above unresolved item (461/85061-02). In addition, the licensee will ensure that the previously accepted systems will comply with the developed acceptance criteri Maintenance Work Request (MWRs)

The inspector reviewed several MWRs on the Division III 125VDC Battery System to ensure that tracking and closure were adequat However, the inspector identified the following violation (461/85061-03) and an open inspection item (461/85061-04):

The inspector reviewed the closed MWR 818449 which required performing an equalizing charge on the Division III 125VDC Battery as a prerequisite of a preoperational test. The MWR's requirements were accomplished by maintenance procedure CPS 8433.01, " Generic Procedure for Battery Maintenance," Section 8.2, " Battery Equalizing." The inspector reviewed CPS 8433.01 for compliance with the Institute of Electrical and Electronics Engineers standard (IEEE) 450-1975, "IEEE Recommended Practice for Maintenance, Testing, and Replacement of Large Lead Storage Batteries for Generating Stations and Substations" and determined that the procedure was not appropriate for the activities affecting quality, such as, a battery equalizing charg The procedure does not conform with IEEE 450-1975 (461/85061-03)

because the acceptance criteria of Section 9.0 of CPS 8433.01 does not meet the requirements of Sections 3.4.(1) and 3.4.(2) of the standard as follows:

IEEE Standard 450-1975, Section 3.4(1) requires that an equalizing charge should be given if the specific gravity of an individual cell drops more than 0.010 from the average of all cell , .-.

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IEEE Standard 450-1975, Section 3.4(2) requires that an equalizing charge shall be given:if the average specific gravity of all cells drops more than 0.010 from the acceptance test value when corrected for temperature and electrolyte level .These requirements are the criteria to perform and satisfy an equalizing charge. CPS 8433.01 did contain these requirements; however, specifically for only the Diecel Driven Fire Pump Battery and not for all safety-related batteries, such as the

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Division III 125 VDC Batter Additionally, the procedure does not specify that the recorded specific gravities are compensated for temperature as required by the IEEE standard.' The specific gravities for the individual cells are recorded as on the data sheet, CPS 8406.00.0001, but there is only one column for gravities and it is not apparent that they are compensated for temperatur In addition to the requirements of the IEEE Standard, the draft Technical Specifications (TS) Table 4.8.2.1-1 requirements for operability of.the battery are not specified or met by procedure CPS 8433.01. The requirements of TS Table 4.8.2.1-1 for pilot cell corrected specific gravities (for electrolyte temperature'and level) to be greater than 1.200 and for individual connected cells to be greater than 1.195 are limits which require actions to be taken to restore the parameters to within their limits within a set time or the battery will be declared inoperabl Procedure CPS 8433.01 does not verify the requirements of the Technical Specifications after an equalizing charge nor does the procedure require that an additional charge be performed if these specifications are not me The inspector has determined that procedure CPS 8433.01 is inadequate to perform prerequisites for preoperational testing in accordance with IEEE' Standard 450-1975 or to perform corrective maintenance on safety-related batteries for compliance with the Technical Specifications after fuel load. This is considered a violation (461/85061-03) of 10 CFR 50, Appendix 8, Criterion ,

During the inspection, the inspector reviewed the licensee's i submitted draft revision to CPS 8433.01 to meet the requirements of IEEE Standard 450-197 These corrections appear to be  ;

adequate and as such, a written response to this violation is not required. Additionally, the inspector will review the final '

revision and other procedures pertaining to maintenance and surveillance.of safety-related batteries during subsequent inspection The inspector also reviewed WR 820401 which replaced cell number 1 on the safety-related Division III batter The WR was closed with l the following deficiencies: j

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The Maintenance Work Request continuation sheet identified that the bolts for cell connections were stretched and stripped while being torqued during reassembly. The inspector was unable to determine the cause because the torque wrench serial number was not provided except for the replacement activities for the

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damaged bolts. Also, the inspector was unable to determine if the bolts that were damaged had been inspected by Quality Control prior to installation and being damage This is an open item (461/85061-04) until the inspector reviews the condition report and determines the cause of failure and the involvement of quality, e. Jurisdictional Control and Taagina The inspector reviewed the administrative procedure CPS 1040.01 and operations department procedure CPS 1440.01, " System Turnover and Release" for jurisdictional control and determined that Section of CPS 1440.01," Post Phase II Release," provided ir.-tructions for jurisdictional tagging. The procedure step 8.5.1 requires that

"within five days after the Release, all of startup's jurisdictional tags should be replaced with plant staff's jurisdictional tags."

Additional requirements are contained in step 8.4.10 of CPS 1040.01 to have plant staff jurisdictional tags hung within five working days of the releas The inspector reviewed the documentation of several system turnover status sheets, CPS 1440.01F001, and determined that the above requirements were not implemented, in that, several systems, such as the Component Cooling and Division I 125VDC Battery Systems did not have their jurisdictional tags hung within the time Ifmits established by the above procedure Additionally, the inspector visually verified that some systems, such as the Division II Diesel Generator and HPCS, were not tagged while others had been tagged. The inspector discovered during discussions with plant staff members that the Manager - CPS had removed the requirements of hanging plant staff jurisdictional tags by a verbal directive without revising the procedures. This is considered a violation (461/85061-05) of the 10 CFR 50, Appendix B, Criterion VI, in that activities affecting quality, such as jurisdictional control to determine the availability of systems for operations control, shall be performed by approved procedures, f. Summary The inspection of the turnover process resulted in two violations:

(461/85061-03) for an inadequate procedure to perform an equalizing charge on safety-related batteries as a prerequisite for preoperational testing or to satisfy Technical Specifications; and

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(461/85061-05) revising the jurisdictional control process by management directive without revising the administrative and

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departmental procedures. Additionally, an unresolved item (461/85061-02) to develop a turnover process with management and

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l administrative procedures that require minimum acceptance criteria

and documented evidence of the turnover quality, and one open item (461/85061-04) to resolve the deficiencies identified in a closed maintenance work request were identifie No other 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 involva some action on the part of the NRC or licensee or both. An open item disclosed during the inspection is discussed in Paragraph 6.d(2).

8. Unresolved Items l Unresolved items are matters about which more information is required in l order to ascertain whether they are acceptable items, items of violation l

or deviations. An unresolved item disclosed during the inspection is i discussed in Paragraphs 4.c, 6.b, and . Exit Interview l The inspector met with licensee representatives (denoted in Paragraph 1)

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on February 7, 1986. The inspection summarized the scope and findings of l the inspection. The inspector also discussed the likely informational I content of the inspection report with regard to documents or processes l reviewed by the inspector during the inspection. The licensee did not i

identify any such documents or processes as proprietary. The licensee i

acknowledged the statements made by the inspector with respect to the l findings.

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