IR 05000461/1986016

Insp Rept 50-461/86-16 on 850303-06.No Violation Noted. Major Areas Inspected:Consistency & Compatibility Between Draft Tech Specs,FSAR,as-built Configurations & Associated Surveillance Requirements

ML20210D854
Person / Time
Site:	Clinton
Issue date:	03/19/1986
From:	Knop R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20210D836	List: IR 05000461/1986016 ML20210D833
References
50-461-86-16, NUDOCS 8603270071
Download: ML20210D854 (8)

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U. S. NUCLEAR REGULATORY COMMISSION

REGION III

! Report No. 50-461/86016(DRP)

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

. Licensee: Il 'inois Power Company 500 South 27th Street

! Dccatur, IL 62525

Facility Name: Clinton Power Station, Unit 1 j Inspection At: Clinton Site, Clinton, IL Inspection Conducted: March 3-6, 1986 Inspectors: S. Stasek R. Evans

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R. Larson K. Ward D. Baxter

Approved By: R. p, e / ['

Projects Section 1C Date

Inspection Summary

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Inspection during the period of March 3-6, 1986 (Report No. 50-461/86016(DRP))

Areas Inspected: Special announced team inspection to determine the level of consistency andl compatibility between the plant Technical Specifications (Draft), Final Safety Analysis Report (FSAR), as-built configurations, and associated surveillance requirements. The inspection involved a total of 190 I inspector-hours onsite by one NRC inspector and four consultants including 27 inspector-hours _onsite during off-shift '

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Results: No violations of NRC requirements were identified during the inspectio There was high degree of consistency between the Technical Specifications, FSAR,

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and as-built configurations. There were two minor discrepar.cies identifie l However, a number of inadequacies were identified with associated procedures that implement Technical Specifications surveillance requirement !

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8603270071 860319 PDR ADOCK 05000461

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a 9ETAILS Persons Present at Exit Meeting i

Illinois Power (IP)

• D. Hall, Vice President, Nuclear

• J. Perry, Manager, Nuclear Program Coordination J. Cook, Assistant Plant Manager, Operations

• J. Miller, Director, Startup Programs ,

R. Morgenstern, Director, Plant' Technical

• H. Lane, Manager, Scheduling and Outage Management D. Holtzscher, Director, Nuclear Safety E'. Corrigan, Director, Quality Engineering and Verification E. Kant, Assistant Manager, Nuclear Station Engineering Department J. Wemlinger, Supervisor, Instruction l **F. Chevalier, Supervisor, Operations Support

• • K. Baker, Supervisor, I&E Interface

)! **R. Phares, Technical Specification Coordinator i

i U.S. Nuclear Regulatory Commission'

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f S. Stasek, Resident Inspector, Dresden (Team Leader)

l R. Evans, EG&G (NRC Consultant)

R. Larson, EG&G (NRC Consultant)

K. Ward, EG&G (NRC Consultant)

D. Baxter, EG&G (NRC Consultant)

• T. Gwynn, Senior Resident Inspector, Clinton

• Hiland, Resident Inspector, Clinton

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• Denotes those persons atterding the exit meetin ** Denotes those who were specifically contacted during the inspectio . Comparison of Final Safety Analysis Report, Draft Technical Specifications, and As-Built Configurations The inspection ~was conducted to compare selected systems, components, and structures, as described in the Final Safety Analysis Report (FSAR), for uniformity and compatibility with the plant Technical Specifications (Draft)

and as-built configuration Additionally, surveillance requirements as outlined in the Technical Specifications were reviewed for proper inclusion into appropriate operating surveillance procedure The following systems were reviewed during the inspectio l

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a. Low Pressure Core Spray System (LPCS)

The inspector reviewed FSAR Sections 6.3.1.1, 6.3.2.2- 6.3.2.2.3,

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7.3.1.1.1.1, 7.3.1.1.1.2, 7.3.1.1.1.5, 8.3.1.1.2, 8.3.1.1.5, 8.3.1.3.1.1 including associated figures and tables, and compared them with the Technical Specifications, Sections 3/4.3.3, 3/4.5.1, 3/4.5.2, 3/4.8.3, Tables 3.3.3-1, -2, -3, and Table 4.3.3.1-1, for the Low-Pressure Core Spray (LPCS) System and associated electrical system Although correlation was at times difficult, information contained in the Technical Specifications agreed with that in the FSAR with the following exception. Table 6.3-8 of the FSAR was not consistent with Section 4.5.1.b.1 of the Technical Specifications, dealing with pump flow. The FSAR specified a different pressure across the LPCS pump at >5010 gpm than the Technical Specification ft.r the same conditions. The inspector was subsequently informed by plant personnel that the discrepancy was being investigated and a change was in proces The associated system trip setpoints are not given in the FSAR directly, but the FSAR references the Technical Specifications and the Elementary Diagram Device List (EDDL), with Note 5, and the Design Specification. The inspector reviewed the EDDL and the Design Specification for trip setpoints and found no discrepancie Surveillance procedures were compared with the applicable Technical Specification Sections 3/4.3.3, 3/4.5.1, 3/4.5.2, and Tables 3.3.3-1, 3.3.3-2, 3.3.3-3, and 4.3.3.1- The following discrepancies were identified:

(1) No procedure was found for the Channel Check called out in Table 4.3.3.1-1 and Section 4.3.3.1. The procedure had not been written at the time of the inspection, but a procedure

. number (CPS 9000.01) had been assigne (2) The trip setpoint and allowable value given in Table 3.3.3-2, Items A.1.d and B.1.d. could conflict. The allowable value was given as 5 10.5 sec and the trip s tpoint was given as >5 se (3) The LPCS pump flow, called out in Section 4.5.1.b.1 of the Technical Specifications is required to be at least 5010 gpm with a pump differential pressure greater than or equal to 276 psid. The values stated in released Surveillance Procedure 9052.01,~ Revision 20, and the Data Sheet 9052.010001, Revision 20, did not agree with the Technical Specification The inspector reviewed Revision 21, not released at the time of the inspection, to both the procedure and the data sheet, which corrected this proble (4) The inspector was unable to find any reference to disposition of the procedure data in 12 out of 13 procedures reviewed. It was determined that disposition is covered by administrative procedure CPS 1011.02 " Implementation and Control of Surveillance i Testing".

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(5) The data sheets for Surveillance Procedures CPS 9052.02 and 9433.37 (9052.020001 and 9433.370001) did not include tolerances or inequalities on the allowable or acceptance value (6) Two surveillance procedures in the electrical system, (CPS 9000.02, Revision 20, and 9031.01) included in the Technical Specification Tracking document, were not available for revie The inspector was informed that CPS 9031.01 had not been written, and would not show up on the Operating Manual Status Report (OMSR)

until it was in the review cycl CPS 9000.02, Revision 20, was in revision and not available for review, although Revision 1 was reviewe The above discrepancies and those surveillance procedure discrepancies described in subsequent sections of this report will be reviewed during subsequent inspection This is considered an open ite (461/86016-01(DRP))

The inspector performed a walkdown of the LPCS system and the associated electrical system along with Illinois Power personne The location and identification of the main flow piping, valves, and pumps along with certain minor loops were verified to be in accordance with the P&ID drawing (M05-1073). Electrical buses (1AP07E (4.16kV) and 1AP11E (480V)) and breakers (1AP72E ar.d 1AP73E) for the LPCS motor-operated valves and pumps were viewed and compared to the Electrical Loading Diagram (E02-1AP03). No discrepancies were note The inspector witnessed a dry run of Surveillance Procedure CPS 9433.37, Part 8.2, along with the associated prerequisites, performed by Control and Instrumentation (C&I) personnel. The required procedures and test instrumentation, with calibration information, were examined for conformance to the surveillance procedure requirements. A walkthrough of the procedure was performed to identify all affected hardware and to assure that the procedure.could be performed as writte Precautions and general information on the procedure were discussed with the technician, who appeared to know how to handle the procedure. No discrepancies were note b. 125 VDC Power System The inspector reviewed Section 8.3.2 of the FSAR in comparison with Sections 3/4.8.2.1 and 3/4.8.2.2 of the Technical Specifications for Divisions 1, 2, 3, and 4 of the 125 V DC power distribution syste These documents were also compared with the electrical one-line diagram for the 125V DC system (E02-1DC06). The documents agreed with each other and with the one-line diagram as to the components of each of the division The surveillance requirements specified in Technical Specification Section 4.8.2.1 and 4.8.2.2 were compared with the surveillance inspection procedures and found to cover the Technical Specifications as require .

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A walkdown of one of the surveillance procedures was performed to verify that the actual hardware locations and identification agreed with the test procedure. All major components of the DC system, Division 1, were verifie No discrepancies were note During the review of the surveillance test procedures (6 out of 8),

several apparent inconsistencies and concerns were noted. The apparent inconsistencies were discussed with plant personnel and satisfactorily resolve The following concerns were noted:

(1) The safety precautions listed in the various test procedures appeared to be incomplete. The appropriate Institute of Electrical and Electronics Engineers, (IEEE) Standard 450

" Recommended Practice for Large Lead Storage Batteries for Generating Stations and Substations," or vendor-stated precautions, such as the use of protective clothing when working in the battery rooms, were not included. Also, pertinent precautions were not included in the body of the procedur The applicant committed to review the subject test procedures and revise them accordingl (2) Test Procedure CPS 9382.02 required that test personnel set the individual cell voltage low limit setpoint at 1.00 VD This value is the cell polarity reversal point defined by IEEE 45 The setpoint should be set at a higher value to ensure that inaccuracies in the test equipment will not cause a cell reversa The applicant was requested to re-evaluate this setpoint and consider revision of the test procedure accordingly. This is considered an open ite (461/86016-02(DRP))

(3) Each division battery has only one cell assigned as the pilot cel As cells start to deteriorate, the weaker cell could be assigned as the pilot cells so that they can be closely watched for possible corrective action or replacemen (4) Technical Specification Section 4.8.2.1,c,4 requires that a battery charger capacity test be conducted every 18 month This test was not listed under section 4.8.2.1.d, even though testing can only be accomplished under shutdown condition c. High Pressure Core Spray System (HPCS)

The inspector reviewed FSAR Sections 6.3.2.2.1, 7.1.2.1.3, and 7.3.1.1.1.3, including Tables 6.3-8 and 6.3-10, in comparison to Technical Specification Sections 3/4.3.3, 3/4.5.1, and portions of Tables 3.3.3-1, 3.3.3-2, 3.3.3-3, and 4.3.3.1- In addition, the specific sections listed above were compared with applicable plant surveillance procedures. A walkdown of the HPCS system was conducted to assure that the valve and component identification and orientation ;

of the as-installed system agreed with the current as-built drawing l The following concerns were noted:

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(1) The FSAR referenced the Condensate Storage Tank as one of the supply systems for the HPCS system. This was inconsistent with the rest of the FSAR and Technical Specifications which referenced the Reactor Core Isolation Cooling (RCIC) supply tank as a source of suppl FSAR change request 3729 previously identified the discrepancy and proposed a change to the FSAR that would correctly identify the RCIC supply tank as a source of HPCS suppl '

(2) An apparent discrepancy was identified in Surveillance Procedure 9051.0 The In-Service Inspection (ISI) acceptance criteria specified an opening time of 100 seconds for Valve 1E22-F015, while the Technical Specification required the HPCS to be operational in 27 second Review of preoperational test PTP-HP-01 listed a required opening time of 20 seconds with an actual opening time of 18 seconds. This apparent inconsistency was brought to the attention of plant personnel during the inspection. A change in the surveillance procedure was initiated to reflect the required opening time listed in PTP-HP-0 (3) The inspector noted an apparent variance in the HPCS pump differential pressure between the Te'chnical S)ecification Section 4.5.1.3 and Surveillance Procedure 9051.01. )lant personnel initiated a change to the surveillance procedure to more accurately reflect the requirements of the Technical Specificatio The apparent discrepancies identified above were made known to the applicant and, changes are in progress; the inspector has no further concern in this are d. Containment Isolation System The inspectors respectors reviewed Saction 6.2.4 " Containment Isolation System" including Table 6.2-47 of the FSAR, in comparison with Technical Specifications Section 3/4.6.4 including Table 3.6.4- There were no inconsistencies noted between the FSAR and Technical Specification Table Approximately 55% of the containment isolation valves (162 of 294 valves) listed in Technical Specification Table 3.6.4-1 parts 1 and 4 were sampled by the inspectors. The valves were observed to be in place and, in conformance with the FSAR, Techn'ical~ Specifications, and P&ID drawing It was noted by the inspectors that a significant number of the vaives were physically difficult to locate because they were not identified with proper tacs. This was brought to the attention of the utility. This is considerec gan open item. (461/86016-03(DRP))

Approximately 50% of.the valves listed in Table 3.6.4-1 were sampled and reviewed for ) roper inclusion into surveillance test procedures as addressed by tietsurveillance requirements in Technical Specification No discrepancies were identified as a result of the review in this are . _ _ . _ _ _ _ _ _ _ _

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. Standby Liquid Control System (SBLC)

The inspectors reviewed Technical Specifications Section 3/4. with Section 9.3.5 of the FSAR and the P&ID drawings for the standby liquid control system. The SBLC surveillance procedures were reviewed to determine if the Technical Specifications were properly included into the surveillance procedure The inspectors also performed a physical walkdown of the system to verify that in place configurations were in conformance with the FSAR, Technical Specifications, and P&ID drawings. No discrepancies were n'tedo in this are The inspectors attempted to monitor performance of a surveillance procedure to verify SBLC operability. -This was the first time this surveillance was to be run and would have included individual valve stroke timing, pump flow verifications, and vibration check' requirement The test was terminated shortly after onset due to a determination by the operators performing the procedure that demineralized water was inadvertently passing through the SBLC pumps and-filling the test tank without the pumps being in operation. A preliminary evaluation indicated that a system modification may be required to establish a better means of verifying pump flowrate. Further review of the modification and subsequent performance of the SBLC operability surveillance will be performed at a later dat This is considered an open ite (461/86016-04(DRP)) Standby Gas Treatment System (SBGT)

'The inspector reviewed Sections 7.3.1.1.9 and 6.2.3.3.1 of the FSAR with Technical Specifications Section 3/4.6. No inconsistencies were noted between the FSAR and Technical Specifications in this are The inspector reviewed appropriate surveillance procedures to insure proper inclusion of the Technical Specifications surveillance requirements. The inspector performed a walkdown of the system to verify that in place configurations were in conformance with the FSAR, Technical Specifications and P&ID drawings. No discrepancies were noted in this are The inspector noted during his review of the monthly system 10 hour1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> operation surveillance procedure and the system walkdown that several operational steps were required by the Surveillance Procedure (SP)

9067.01 Revision 20 that were not readily obvious to the operators as how to perform them, that is, prerequisite 5.4 to the SP requires verification that the system Constant Air Monitor was operable, but did not specify where to go or how to verify this status. Also, step 8.2.L required verification that the train heaters energiz There were no-indicating lights or ammeter associated with this heater to make this determination. The operator specified that he would check the air temperature leaving the heater to determine its statu However, he did not know what constituted an acceptable temperature change to verify proper operation. These apparent procedure inadequacies were brought to the attention of the utilit . . - - .

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No violations or deviations were identified during the inspectio . Open Items Open items are matters that have been discussed with the licensee ~, which

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will-be reviewed further by the inspectors and which involve some action on the part of the NRC or licensee or bot Open items disclosed during the inspection are discussed in Sections 2.a, 2b, 2.d, and 2.e.

Exit Interview j The inspectors met with licensee representatives (denoted in Section 1)

j at the conclusion of the inspection on March 6, 1986, and summarized the scope and findings of the inspection activitie After discussion with the licensee, the inspectors have determined there is no proprietary data contained in this inspection report.

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