IR 05000461/1986014

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Insp Rept 50-461/86-14 on 860224-0310.No Violation or Deviation Noted.Major Areas Inspected:Licensee Action on Previous Insp Findings,Part 21 Repts & 10CFR50.55(e) Repts
ML20210E466
Person / Time
Site: Clinton 
Issue date: 03/21/1986
From: Love R, Muffett J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20210E442 List:
References
50-461-86-14, NUDOCS 8603270354
Download: ML20210E466 (9)


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i-U.S. REGULATORY COMMISSION

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REGION III

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Report No. 50-416/86014(DRS)

Docket No. 50-461 License No. CPPR-137

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Licensee:. Illinois Power Company i

500 South 27th Street Decatur, IL 62525 I

Facility Name: Clinton Nuclear Power Station, Unit 1 Inspection At: Clinton Site, Clinton, IL Inspection Conducted:

February 25 through March 10, 1986

~ A o /a-b Inspector:

R. S. Love Date N Aw l~

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Approved By:

J. W. Muffett, Chief Plant Systems Section Date

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Inspection Summary i

Inspection on February 24 through March 10, 1986 (Report No. 50-461/86014(DRS))

Areas Inspected:

Routine, unannounced inspection of licensee's action on:

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previous inspection findings; Part 21 Reports;'and 50.55(e) Reports.

During i

this inspection, Inspection Procedures 92701, 92702, 92716, 99020, and 30703 were utilized.

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Results: Of the areas inspected, no violations.were identified.

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DETAILS 1.

Persons Contacted Illinois Power Company (IP)

  • W.

C. Gerstner, Executive Vice President

  • D.

P. Hall, Vice President

  • J. E. Loomis, Construction Manager
  • J. Greenwood, Manager, Power Supply (Soyland/WIPCo)
  • J. C. Wemlinger, Supervisor, Instruction
  • H.

E. Daniels, Jr., Project Manager

  • J. S. Perry, Manager, Nuclear Programs Coordinator
  • F. A. Spangenberg, Manager, Licensing and Staff
  • J. W. Wilson, Plant Manager
  • J. Greene, Manager, Startup
  • W. Connell, Manager, Quality Assurance
  • R. Campbell, Director, Quality Systems and Audits
  • R. Cowley, Assistant Director, Support Services
  • J. F. Palchak, Supervisor, Support Services
  • N. C. Williams, Director, Support Services
  • D. C. Shelton, Manager, NSED
  • K.

A. Baker, Supervisor, I&E Interface A. Sherwood, Lead Quality Assurance Engineer G. Bousquet, Quality Assurance Engineer J. A. Brownell, Licensing Specialist K. Davenport, Licensing Specialist F. Edler, Supervisor, Construction /Startup (NSED)

R. Lebkuecher, Licensing Specialist S. E. Rasor, Supervisor, Construction QA M. Maher, Supervisor, Electrical Maintenance.

J. S. Spencer, Director, Engineering Projects D. C. Onwualu, Staff Engineer, NSED H. Nodine, Supervisor, Controls and Instrumentation W. Clark, Assistant Supervisor, Controls and Instrumentation D. Blank, Assistant ~ Supervisor, Electrical Maintenance J. Nelson, Assistant Supervisor, Controls and Instrumentation Baldwin Associates (BA)

  • D. J. Schlatka, Project Manager
  • J. V. Hawkins, Manager, Quality Assurance
  • J. L. Thompson, Manager, Quality Engineering The inspector also contacted and interviewed other licensee and contractor personnel during this inspection.
  • Denotes those personnel attending the exit interview on February 27, 1986.

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2.

Licensee Action on Previous Inspection Findings a.

(Closed) Open Item (461/85041-11):

During a previous inspection, it was identified that:

safety-related and non-safety-related flexible conduits were ty-rapped together in instrument rack 1H22-P002; a non-safety-related flexible conduit for transmitter B33-N050A was damaged in instrument rack 1H22-P004; and a safety-related flexible conduit for transmitter 833-N014C was damaged in instrument rack 1H22-P022.

Based on NPR's acceptance of the CPS revised acceptance criteria, it is acceptable for non-safety-related and safety-related conduits to be in physical contact for a distance not to exceed two feet.

The separation of the conduits in rack 1H22-P002 are acceptable.

With respect to the damaged conduits in rack 1H22-P004 and 1H22-P022, these conduits were replaced.

The above actions resolve the inspector's concerns in this area.

b.

(Closed) Open Item (461/85022-02):

During a previous inspection, it was identified that the analysis for the "use-as-is" disposition on NCRs 27475, 27481, and 28664 was not available for review.

During this inspection, the inspector reviewed the analyses for the subject NCRs and found them acceptable.

c.

(Closed) Open Item (461/85041-10):

During a previous inspection, it was identified that the lighting in front of the remote shutdown panel had not been installed subsequent to the rotation of the panel to improve personnel access.

During this inspection, the inspector verified that new lights were installed in front of the remote shutdown panel, and are powered from a safety-related supply.

d.

(Closed) Open Item (461/85041-03):

During a previous inspection, it was identified that approximately 4,000 instruments had been turned over to IP.

These instruments had no Storage and Maintenance (S&M) work performed (by Baldwin Associates) since request of the instruments.

The evaluation of these instruments for acceptability was performed by IP under Condition Report (CR) No. 1-85-11-004,

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dated November 1, 1985.

IP's evaluation revealed that, although programmatic discrepancies were identified in the BA S&M program, no hardware deficiencies werel identified.

This conclusion is based on:

visual examination of the instruments for damaged or broken parts; instrument operability check, i.e., the device.is energized or pressurized and the input and output is checked for function; and the instrument is calibrated, i.e., the device is brought into specifications and checked for accuracy and repeatability.

The inspector reviewed a related sample of these items and finds the resolution of this matter acceptable.

e.

(Closed) Open Item (461/85002-05):

During a previous inspection, it was observed that the inspection of conductor butt splices were not required per the Termination Inspection Checklist although inspection was required per BA Procedure (BAP) 3.3.3.

Corrective Action Request (CAR) 223-1 was prepared to document the lack of objective evidence that butt splices were being inspected by quality control.'2 Corrective action included the following:

BAP 3.3.3 and form JV-447 (Termination

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Inspection Checklist) were revised to clarify the inspection requirements of drain-wires and butt splices; craft, QC, and engineering personnel were retrained in the installation and inspection requirement for drain-wires and butt splices; a 100%

reinspection program was initiated and discrepancies were identified and corrected through the NCR system; and the implementation of the corrective action was verified by IPQA.

The inspector reviewed.a selected sample of these items and finds the resolution of this matter acceptable.

f.

(Closed) Violation (461/85041-04):

During a previous inspection, it was observed that the Document Review Group (DRG) was improperly revising the Documentation Checklists (Form JV-146) due to a mis-interpretation of Generic Resolution 27.

Form JV-146 documents the receipt and acceptability of vendor documentation.

This NRC identified violation was documented on CAR 256 for followup. When DRG identified a discrepancy in a record package, a Docueent Exception List (DEL)' item was generated.

As-part of the corrective action for CAR 256, 7,182 DEL. items were identified with certain checklist codes.

Of the 7,182 DEL items reviewed, it was identified that 4,319 items dealt with JV-146 problems.

The applicable record packages were reviewed and 48 invalid JV-146 forms were identified.

Acceptable replacement JV-146 forms were provided and placed in.the applicable packages.

All QA DRG and QE DEL resolution personnel were retrained.

The inspector reviewed a selected sample of these items and finds the resolution of this matter acceptable.

g.

(Closed) Open Item (461/85054-03):

During a previous inspection, the licensee was unable to provide assurance to the NRR I&C Reviewer that the RPS power supplies would be treated as Class 1E equipment under the licensee's S&M program.

Region III was requested to followup on this item.

During this inspection, the Region III inspector observed that the RPS power supplies (IC71-S004A and B)

were classified as Class 1E equipment on the Mechanical Department Equipment List.

RPS power supplies are also listed as Class 1E equipment in FSAR Table 3.2-1, " Classification of Systems, Components, and Structures." During this inspection, the inspector reviewed the Preventive Maintenance computer printout dated September 9, 1985.

This printout indicated that the RPS power supplies will be in the routine preventive maintenance program when received from IP Startup.

In addition, the associated meters for this equipment is scheduled for routine calibration.

The review discussed above of the licensee's actions found the resolution of this matter acceptable.

h.

(Closed) Open Item (461/85013-01):

During a previous inspection, it was observed that BA Field Verification procedures did not address the inspection of conductor butt splices, installation of color coded identification tags on instrument sensing lines, and verification of separation of redundant instrument sensing lines.

Based on the 100%

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reinspection of conductor butt splices and Change No. 2 to the IP Overinspection Program, the above listed attributes were deleted from the Field Verification Program. _The inspector reviewed a selected sample of these items and finds the resolution of this matter acceptable.

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(Closed) Open Item (461/85013-02)':

During a previous inspection.

it was observed that the backup data for the use-as-is disposition

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on NCR 65745 was not part of the NCR package presented to the inspector for review. This NCR had been dispositioned by'IP NSED.

During this inspection, the inspector reviewed FECN 7043 and revised Specifications K-2948, K-2949, and K-2999 that supports the use-as-is disposition on NCR 65745..In addition, this NCR has been forwarded to Sargent and Lundy (S&L), who pe'rformed an N45.2.11 (Quality Assurance Requirements for the Design of Nuclear Power Plants) review. The above actions satisfy the inspector's concern with NCR 65745.

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(Closed) Violation (461/85013-03):

During a previous inspection,

it was observed that IP NSED was providing inadequate dispositions on NCRs prepared by BA Field Verification.

Four examples.were provided.

After investigation by IP, it was determined that two new NCRs had to be issued due to improper disposition on the original NCRs.

A review i

of the responsible. engineer's work was performed.

The review encom-l passed 126 NCRs of which 27 had not received supervisory review prior to approval.

These 27 NCRs had been adequately dispositioned and were

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procedurally correct. The incorrect dispositions were discussed with the responsible engineer, and a letter was issued.to reinforce the counseling provided.

For the remaining NCRs, it was determined that supplemental travelers had been issued to rework the item before the NCR was prepared, and BA was performing their inspection to the original trav ler.

In the latter cases,,the IP investigation indicated

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documentation to justify the disposition were missing.

During this that the NCRs were properly dispositioned; however, the supporting inspection, the inspector was informed that General Electric provides the disposition on all NCRs associated with the Nuclear Steam Supply-System.(NSSS) and S&L provides the disposition on all NCRs associated

witn *.he Balance of the Plant (BOP).

IP NSED remains in the concur-

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rence cycle but provides no dispositions on NCRs. The above actions j

satisfy the inspector's concerns in this area.

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(Closed) Open Item (461/85041-05); (461/85041-06):

During a previous I

inspection, it was observed that instrument line valves for a given i

system were depicted on several S&L M10-1000 series drawings; however, these drawings were not. cross referenced (85041-05).

It was also

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observed that valves appearing on GE drawings.were not depicted on S&L M05 or M10 series drawings, nor were the GE drawings referenced on the S&L drawings (85041-06).

The inspector was concerned with the availability of these drawings to operations personnel and the ability

of the operations' personnel to locate'the applicable drawing (s) in that the drawings were not cross referenced.

IP operations and-engineering investigated the inspector's concern and determined that i

it was generic in nature.

As a result of the investigation, IP is in the process of combining the GE and S&L.0-1000 series drawings into IP M10-9000. series drawings. This as-built drawing has been or will be verified by walkdowns prior to issue. 'Oue to delays in obtaining i

procedure approval, none of the M10-9000 series. drawings have been i

issued as of February 27, 1986.

During this inspection, the inspector

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reviewed four of the new drawings and found that the licensee's

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proposed corrective action was adequate.

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1.

(Closed) Open Item (461/85041-09):

During the NRR Instrument and Control Systems Branch (ICSB) site visit, it was observed that the Control Room underfloor raceway covers were not installed.

Region III was requested to perform followup inspections to verify

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proper installation-of these raceway covers.

The installation of these raceway covers was observed by the Clinton NRC Resident Inspector and Region III based inspector during tours of the Control Room.

During the installation of the first five cover segments, a GE supplied sealant was used.

This GE sealant proved

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to be unsatisfactory for this application and had to be removed.

A qualified BISCO sealant was then used with satisfactory results.

Based on observations, personnel interviews, and -the review of IPQA surveillance reports, it was determined that the Control Room underfloor raceway covers were properly installed.

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(Closed) Violation (461/85030-05A):

During the CAT inspection it was observed that S&L was using the analysis method to justify lesser electrical separation than that required by IEEE-384 and the Clinton

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FSAR.

Analysis is an acceptable method to justify lesser separation in accordance with IEEE-384; however, Paragraph 8.1.6.1.14, Position C6 of the Clinton FSAR states that the analysis methods would not be used.

Amendment 34, dated July 1985, to the Clinton FSAR revised Position C6 to read; "The analyses performed in accordance with Section 4.5(3),

4.6.2 and 5.1.1.2 of IEEE-384-1974 shall be on permanent file avail-able for NRC review but will not be an integral part of the Safety.

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Analyse Report.

The inspector reviewed these changes and finds the resolution of this matter acceptable.

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(Closed) Unresolved Item (461/85042-04):

During a previous inspection, it was observed that electrical procedures had been revised based on an FSAR revision that had been submitted to NRR for approval.

The proposed FSAR revision changed the electrical separation requirements for CPS based on testing performed by W' le y

Test Labs.

During this inspection, the inspector contacted the NRR

Licensing Project Manager and NRR Electrical Reviewer (for CPS) by telephone on February 18-19, 1986, with regards to the pending FSAR revision on electrical separation.

The inspector was informed that NRR had accepted the FSAR changes and that this acceptance would be

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documented in SER Supplement 6.

Based on the information provided by NRR, this issue is resolved.

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(Closed) Unresolved Item (461/85041-07):

During a previous inspection, it was observed that IP Startup was having a No. E22-5002.

IP had determined that the root cause of intermittent tripping of tne circuit breakers was caused:by incorrect sizing and/or incorrect trip

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settings ~by GE.

GE was using original design information rather than actual field conditions to perform their calculations.

In addition, IP identified two circuit breakers that failed to trip.

Using the actual field loads, GE recalculated the circuit breaker size, overload (OL) heater size, and trip settings.

This information is documented in the Field Deviation Disposition Request (FDDR) No. LH1-5038,

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Revision 11.

As a result of this FDDR, the two faultkicircuit breakers were replaced, OL heaters were replaced, OL heaters were

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reset, and with exception of two circuit breakers associated with the diesel generators, all circuit breakers were retested satisfactorily.

The two circuit breakers associated with the diesel generators will be tested in conjuction with the diesel generators.

During this inpsection, the inspector reviewed all the applicable records and

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except for the two circuit-breakers discussed above, all records were found acceptable.

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(Closed) Open Item (461/85054-02):

During a. review of allegation l

Region III 85-A-0144, the alleger stated that he had brought a concern to the attention of an IPQA engineer (by name), IPQA had not acted promptly on his concern (Reference:

Inspection Report 461/85054, Paragraph 3.b(3)).

During this inspection, the inspector reviewed the IP " Record of Coordination" that documented a meeting between the alleger and two IPQA engineers on November 7, 1985.

The purpose of the meeting was to inform the alleger of the status of IP's investigation of the alleger's concern.

As a result of the IP investigation, IPQA issued Surveillance Finding C-85-158 against S&L.

Corrective action was to issue FECN 12965, which revised the K-2999 specification and drawing E05-1200 and to revise the disposition on NCR 33408.

The alleger reviewed these documents and indicated that they resolved his concern.

On March 10, 1986, the alleger was telephonically contacted and he stated that he was satisfied with the actions taken by IP and the NRC on his concern.

3.

Review of Licensee Action on 10 CFR 21 Reports a.

(Closed) Part 21 Report (461/82004-PP): On December 21, 1981, Eberline Instrument Corporation notified U.S. NRC (Region IV) of a design defect on micro computer printed circuit boards manufactured by Eberline.

These circuit boards are used in radiation monitoring equipment which were sold to nuclear power facilities.

The defect in the circuit boards could potentially cause a loss of memory which resets all calibration parameters, including alarm trip levels.

The corrective action to resolve this defect was to install additional

' hardware in the form of a " piggyback" board containing a latch which prevents the interrupt data from. changing while it is being read.

This additional hardware and installation instructions were provided

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to CPS.

This modification does not change the operating character-istics of the instrument.

The modification to the central processing unit circuit boards were completed of the following Maintenance Work-Requests (MWR):

MWR No. B18665 (5 Units), Completed October 17, 1985.

MWR No. B19668 (1 Unit), Completed August 24, 1985.

  • MWR No. B19965 (1 Unit), Completed August 24, 1985.
  • s MWR No. B20417 (16 Units), Completed September 19, 1985.

MWR No. B19112 (1 Unit), Completed June 29, 1985.

  • Four units were supplied with the modification.

All spare circuit boards were inspected and they had the modification incorporated.

Based on NRC inspection of these actions, the above actions by IP-satisfy the corrective actions as recommended by Eberline.

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b.

(Closed) Part 21 Report (461/84007-PP):

On October 19, 1984, GE notified IP of a potential defect in a Class 1E dedicated inverter used in the Remove Shutdown Panel, C61-P001.

This defect was identified as an error in adjustment of the low voltage shutoff and turnon.

This could result in an inverter trip and failure to restart during a Design Basis Accident (DBA).

GE issued FDI-SKSZ and GE Work Request (GWR) 296 to correct this deficiency at CPS.

Two additional units are on order as spares.

GE will modify these spare inverter units prior to shipment.

As of February 27, 1986, the spare inverters have not been received at CPS.

During this inspection, the inspector reviewed FDI-SKS2, GWR 396, FDDR LH1-2998 that was issued to correct an error in FDI-SKSZ, and GE drawing 184C4723, Revision 3, that was revised to reflect the correct trip voltages. GWR 396 was closed (work completed) on September 9, 1985, and work was verified by IP.

Based cn the review of the above documents, the inspector is satisfied that the trip voltages now meet the design requirements.

c.

(Closed) Part 21 Report (461/85003-PP):

On June 18, 1985, GE notified IP of a potential defect in that GE CR2940 switches are not qualified for use in harsh environment.

The CR2940 switches are qualified for use only in a mild environment.

The GE letter states, in part, "The resulting condition which could lead to a substantial safety hazard is the failure of a device (Switch CR2940) on a non-safety system (Standby Liquid Control System) which may cause failure of required Class 1E equipment (Emergency Core Cooling Systems) during a LOCA on some BWR/6's.

The utility should evaluate this information as it relates to existing or future plant equipment, conditions, procedures, or plans." The CR2940 switches of concern are the test switches for the SLCS storage tank outlet valves and SLCS pump motors.

IP's evaluation concluded that the GE CR2940 control / test switches used in the SLCS are qualified to meet their intended use and that the common mode failure scenario postulated by GE will not degrade the CPS ESF MCC buses.

During this inspection, the inspector reviewed the backup data and found it to be adequate to support the licensee's conclusions.

4.

Review of Licensee Action On 10 CFR 50.55(e) Reports a.

(Closed) 50.55(e) Report (461/84014-EE):

On June 21, 1984, IP informed Region III of a potentially reportable condition involving the BAQA Vendor Surveillance Program.

This condition involved contracts assigned to a specific BAQA vendor surveillance engineer.

During routine surveillance activities, a significant number of discrepancies were identified with the contracts assigned to the subject engineer.

For followup and corrective action, this condition was documented on CAR No. 173, dated May 9, 1984. The corrective action consisted of a 100% review of all procurement documentation for each contract assigned to the specific engineer.

This review addressed 14 purchase orders involving 311 Receiving Inspection Report packages.

This review resulted in four nonconformance reports and ten open item reports.

Types of discrepancies identified were:

missing certificates of compliance; missing material test reports; wrong purchase order number on the certificate; missing material test

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reports; wrong purchase order number on_the certificate of compliance; and vendor shipped material without a release-to-ship from BA.

It should be noted that no hardware problems were identified.

The conditions identified in the nonconformance and open item reports have been resolved and the reports closed.

IP has. reviewed and evaluated the findings associated with this investigation and determined that the conditions described in CAR 173 and the resulting nonconformances represented a significant condition adverse to the safety of operations at CPS.

The corrective action to prevent recurrence was to terminate the subject engineer.

During this inspection, the inspector reviewed the data reference above and found it to be adequate to support the licensee's conclusior.s.

b.

(Closed) 50.55(e) Report (461/85013-EE):

On November 20, 1985, IP informed Region III of a potentially reportable condition involving the use of unapproved Daniels Type HX4 crimping tools on an indeter-minate number of lugs for various Class 1E safety-related applications.

The root cause was the failure to incorporate the K2999 specification requirements for acceptable tools into the IP Electrical Haintenance Procedure, CPS 8492.01.

This condition was documented on*CR 1-85-09-043 for followup and corrective action.

The IP investigation determined that the Daniels crimpers-(Type HX4-M22520/5-01 with die Y501) were only used on AMP lugs for No. 10-22 AWG wire sizes.

These terminations were docurented on Nonconforming Material Reports (NCMR) 2-052 and 2-0449.

To prove or disprove the acceptability of the lugs for the terminations identified on the NCMRs, ten sample crimps were performed for each crimp size.

These sample crimps were visually inspected, and pull tests were performed with no failures.

Based on these tests, GE found the lugs acceptable for use in the GE supplied equipment.

This acceptance is documented'in GE letters GSI-453-85 and GSI-489-85.

As documented in S&L letter SLEI-19098, the lugs installed in BOP equip-ment were found acceptable as installed.

To prevent recurrence, IP

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Procedure CPS 8492.01 was revised to show the list of connectors (lugs) and crimpers that are acceptable for use at CPS.

During this inspection, the inspector reviewed the above referenced data and found it acceptable.

In addition, the inspector verified proper closure of the CR and two NCMRs discussed above.

5.

Exit Interview The Region III inspector met with the licensee representatives (denoted under Paragraph 1) at the conclusion of the onsite portion of the inspection on February 27, 1986.

The in-office portion of the inspection was discussed telephonically with Mr. J. Brownell, IP Licensing Specialist, on March 10, 1986.

The inspector summarized the scope and findings of the inspection. The inspector also discussed the likely informational content of the inspection report with regard to documents or processes reviewed during the inspection.

The licensee acknowledged this information and did not identify any such documents or processes as proprietary, gn

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