IR 05000461/1986031
| ML20199C613 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 06/12/1986 |
| From: | Gill C, Greger L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20199C605 | List: |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, TASK-2.B.3, TASK-2.F.1, TASK-TM 50-461-86-31, NUDOCS 8606180201 | |
| Download: ML20199C613 (15) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Report No. 50-461/86031(DRSS)
Docket No. 50-461 License No. CPPR-137 Licensee:
Illinois Power Company 500 South 27th Street Decatur, IL 62525 Facility Name: Clinton Power Station, Unit 1 Inspection At: Clinton Site, Clinton, IL
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Inspection Condu,ted: May 20-23, 1986 Inspector: C F. Gill f-/d,-86 Date
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Approved By:
. Greger, Chief 6-/d-86
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Facilities Radiation Protection Date Section
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Inspection Summary
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Inspection on May 20-23, 1986 (Report No. 50-461/86031(DRSS))
Areas Inspected: Routine, announced inspection of the preoperational radiation protection program regarding the status of certain TMI Action Plan and HVAC open and unresolved items.
Results: No violations or deviations were identified.
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B606180201 860612 PDR ADOCK 0D000461 G
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DETAILS 1.
Persons Contacted L. Anellis, Staff Specialist / Radiological Engineer
- G. Bell, Assistant to Manager, Scheduling and 0.M.
- R. Bhat, Supervisor, HVAC and Fire Protection
- J. Brownell, Licensing Specialist F. Cann, Startup Group Leader, BOP HVAC Testing and Balancing L. Combs, Procurement Specialist
- W. Connell, Manager, QA
- H. Daniels, Project Manager K. Davenport, Licensing, Engineer M. Dodds, Project Specialist / Radiological Engineer K. Evans, Emergency Planner R. Fields, Systems Engineer J. Gannon, HVAC Engineer
- W.
Gerstner, Executive Vice President
- J. Greene, Manager, Startup
- J. Greenwood, Manager, Power Supply
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- D.
Hall, Vice President L. Holtman, Staff Engineer D. Holtzscher, Director, Nuclear Safety J. Hunsicker, Supervising Engineer, C&I J. Jacox, Consultant
- E. Kant, Assistant Manager, NSED S. Khan, HVAC and Radwaste Group Leader
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J. Lockbridge, Supervisor, Radiological Engineering W. Mcdonald, Supervisor, HVAC Engineering, S&L
- G. Miller, Director, Fiscal Management (NP&S)
G. Mukesh, NSED HVAC Project Engineer W. Mullins, Supervisor, Chemistry S. Ornberg, HVAC Division Head, S&L
- J. Palchak, Supervisor, Plant Support Services J. Panici, Engineer K. Pruner, HVAC System Engineer
- P. Raysircar, Assistant Director, NSED Design Engineering
- R. Schaller, Director, Nuclear Training
- F. Spangenberg, Manager, Nuclear Licensing and Safety M. Stout, HVAC Project Engineer, S&L D. Waddell, Supervisor (Acting), Emergency Response B. Wahlheim, HVAC System Test Engineer
- J. Weaver, Director, Licensing
- Pat Gwynn, NRC Senior Resident Inspector The inspector also contacted other licensee employees and contractors including nuclear safety and licensing, radiation protection, startup and engineering personnel.
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- Denotes those present at the exit meeting on May 23, 1986.
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2.
General This inspection, which began at 12:30 p.m. on May 20, 1986, was conducted to review the status of certain TMI Action Plan and HVAC open and unresolved items. Tours of the licensee's facility were made during the inspection.
3.
Licensee Action on Previous Inspection Findings (Closed) Open Item (461/85004-01):
Complete compliance and action plan reports for NUREG-0737 Items II.B.3 and II.F.1 (Attachments 1, 2, and 3).
See Section 4.a.
(Closed) Open Item (461/85004-02):
Complete installation, development of procedures, and training on use of the post-accident sampling system per NUREG-0737 Item II.B.3 commitments.
See Section 4.b.
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(0 pen) Open Item (461/85004-03):
Complete installation, calibration, development of procedures, and training on the use of the post-accident noble gas effluent monitoring systems per NUREG-0737 Item II.F.1, Attachment I commitments. See Section 4.c.
(Closed) Open Item (461/85004-04):
Complete installation, development of procedures, and training on use of the post-accident effluent sampling and analysis systems per NUREG-0737 Item II.F.1, Attachment 2 commitments.
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See Section 4.d.
(0 pen) Open Item (461/85004-05):
Complete installation, calibration, development of procedures, and training on the use of the containment high-range radiation monitors per NUREG-0737 Item II.F.1, Attachment 3 commitments. See Section 4.e.
(Closed) Open Item (461/85004-06):
Review of the ANSI /ASME N510 acceptance test program.
See Section 5.a.
(Closed) Open Item (461/85004-07):
Demonstrate, by laboratory testing, that the air cleaning systems' spinster carbon adsorber has not significantly degraded, and replace the carbon, if necessary.
See Section 5.b.
(Closed) Open Item (461/85004-08):
Complete ANSI /ASME N510 acceptance testing compliance analysis and action plan reports. See Section 5.c.
(Closed) Unresolved Item (461/85004-09):
Evaluate FSAR commitments on the use of silicone sealants on HVAC filtration systems and resolve the issue with NRR. See Section 5.d.
(Closed) Unresolved Item (461/85004-10): Correct the SGTS filter housing drain system installation and ascertain why the as-built condition did not agree with installation drawings.
See Section 5.e.
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(Closed) Open Item (461/85004-11):
Complete review of procedures to ensure proper administrative control of filter housing drain line isolation valves and revise procedures, as appropriate.
See Section 5.f.
(Closed) Open Item (461/85004-12): Demonstrate filter housing drain line isolation valve air leak tightness as part of the preop test program.
See Section 5.g.
(Closed) Unresolved Item (461/85004-13): Determine the design acceptabil-ity, clarify FSAR regulatory commitments, and develop procedures c.n the use of filter housing drain line loop seals.
See Section 5.h.
(Closed) Open Item (461/85004-14): Ascertain whether water check valves should be installed in filter housing drain lines and install valves, as appropriate. See Section 5.1.
(Closed) Open Item (461/85004-15):
Evaluate means for preventing fire
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protection system leakage from damaging air cleaning system filters.
See Section 5.j.
(Closed) Open Item (461/85004-16): Submit an amendment to clarify the
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commitment to Regulatory Guide 1.52, Revision 2, Regulatory Po.sition 2.e in FSAR Table 6.5.3.
NRR confirmed the acceptability of the control room HVAC recirculation filter train capacity in an internal NRC memorandum, which was sent to the licensee on the docket. The inspector reviewed the amendment to FSAR Table 6.5.3; no problems were found.
(Closed) Open Item (461/85005-27): Verify installation of noble gas effluent monitors (SER 11.5.1).
The inspector verified the installation of these monitors.
Refer to Open Items 461/85004-01 and 03 for discussion of other reviewed aspects of these monitors.
(Closed) Open Item (461/85005-29):
Verify installation of four high-range gamma monitors (TMI Item II.F.1.3).
The inspector verified the installation of these monitors.
Refer to Open Items 461/85004-01 and 05 for discussion of other reviewed aspects of these monitors.
4.
Status of Certain TMI Action Plan Items The inspector reviewed the status of the post-accident sampling system, high range noble gas effluent monitors, accident range iodine and particulate effluent sampling system, and containment high-range radiation monitors, NUREG-0737 Items II.B.3 and II.F.1 (Attachments 1, 2, and 3), respectively.
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a.
Compliance Documentation In a letter to the Regional Administrator, dated January 18, 1985, the licensee committed to prepare two documents to track commitment compliance for the above listed TMI Action Plan Items. These documents are internal-reports made available for NRC review. The
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first report is a NUREG-0737 commitment and compliance analysis which provides a detailed (line-by-line) identification of each commitment associated with the previously listed NUREG-0737 items, ascertains compliance, identifies any corrective measures needed or variance requests required, and identifies actions needed to document compliance. The second report is a detailed action plan providing a tracking system for actions needed to comply with NUREG-0737 commitments and to document compliance. This report is detailed enough to include specific tasks, persons assigned to each task, a schedule for completion, and a periodically-updated status.
During a November 1985 site visit, the inspector found the completed reports did not adequately substantiate the licensee's compliance with their commitments to NUREG-0737. Since then, the licensee has been adequately responsive to concerns raised by the inspector.
The commitment and compliance analysis report divided the commit-ments to NUREG-0737 Items II.B.3 and II.F.1 (Attachments 1, 2,
' and 3) into more than 160 subparts. Although the licensee had previously developed documentation which adequately demonstrated-compliance with most of these individual commitments, the initial action plan consisted of over 140 individually assigned and scheduled actions. The inspector noted that several actions were assigned by the licensee for many of the individual commitments for which the licensee could not initially demonstrate compliance.
Significant accomplishments of action plan implementation include approximately 50 special evaluations / calculations, 20 new or revised procedures, ten major system modifications, and eight concurrence /
variance request letters submitted to NRR. With the exceptions noted below in the next four subsections, the licensee presently appears able to adequately demonstrate compliance with NUREG-0737 Items II.B.3 and II.F.1 (Attachments 1, 2, and 3). Although the licensee still has some remaining action items to complete, the proposed actions seem appropriate and the scheduled completion is timely; this matter is considered closed.
b.
NUREG-0737 Item II.b.3, Post-Accident Sampling System (PASS)
The installation of the PASS is complete; the scheduled turnover of the system to the plant operating staff is May 31, 1986.
Relevant procedures have been developed and approved with the exception of Procedure CPS No. 1890.30. The inspector selectively reviewed portions of these procedures; no significant problems were noted.
Procedure CPS No. 1890.30, Post Accident Sampling Frogram, is scheduled for completion by June 30, 1986. The purpose of this procedure is to describe, in one location, those training, qualification, periodic testing, mainteaance, sampling and analysis methods used to ensure compliance with Technical Specification 6.8.4.c.
Completion of this procedure and the PASS testing and training program is being tracked by Open Item 461/85005-43. The qualification and training of RCT's (including operation cf the PASS) is being tracked by Open Item 461/85017-02. The requirement to adequately demonstrate
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the capability to collect and analyze a PASS sample is being tracked by Open Item 461/85040-02. Because the inspector's remaining concerns are being resolved in a timely fashion by the licensee and adequately tracked by the licensee and other NRC open items, this matter is considered closed.
c.
NUREG-0737 Item II.F.1, Attachment 1,-Noble Gas Effluent Monitors The installation of the post-accident noble gas effluent monitors (Eberline AXM-1 systems) is complete; the monitoring systems were turned over to the plant operating staff on May 8, 1986.
Verification of system operability, accessibility, and procedural adequacy are being tracked by Open Items 461/85039-10, 11, and 12, respectively. The qualification and training of RCT's (including operation of AXM-1 systems) is being tracked as Open Item 461/85017-02.
In letter U-600451, dated March 10, 1986, the licensee presented the proposed AXM-1 noble gas channel calibration program to NRR.
Conference telephone calls were conducted with the. licensee by the NRC (NRR and Region III) on April 14-16, 1986, to discuss the resolution of certain compliance issues. As a result of these discussions, the NRC has concluded that the licensee has adequately demonstrated the acceptability of the AXM-1 noble gas post-accident effluent monitoring system's range, range overlap, and accuracy; the scope of the system's calibration program also appears adequate.
In the March 10, 1986 letter, the licensee committed to perform the first phrase of the calibration program prior to fuel load and to perform a validation test prior to exceeding five percent rated reactor power using Xe-133 calibration gas. The schedule for the calibration program is uncertain because the necessary byproduct license amendment for the calibration sources has not been approved.
With the exception of calibration program completion, the inspector's remaining concerns are being resolved in a timely fashion by the licensee and adequately tracked by the licensee and by other NRC open items. This matter remains open pending completion of the calibration program.
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NUREG-0737 Item II.F.1, Attachment 2, Sampling and Analysis of Plant l
Effluents
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The installation of the post-accident sampling systems, (Eberline AXM-1 systems) is complete; the sampling systems were turned over the the plant operating staff on May 8,1986.
Verification of system operability, accessibility, and procedural adequacy are being tracked by Open Items 461/85033-10, 11, and 12, respectively. The l
qualification and training of RCT's (including operation of AXM-1 i
systems) and the calibration of the modified Ge detector system are I
being tracked as Open Items 461/85017-02 and 03, respectively.
Because the inspector's remaining concerns are being resolved in a timely fashion by the licensee and adequatel/ tracked by the licensee and other NRC open items, this matter is considered closed.
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e.
NUREG-0737 Item II.F.1, Attachment 3, Containment High-Range Radiation Monitor The installation of the Containment High-Range Radiation Monitors (CHRRMs) is complete; the scheduled turnover of the monitors to the plant operating staff is June 11, 1986.
Relevant procedures have been developed cod approved. The inspector selectively reviewed portions of these procedures; no significant problems were noted.
Initial training has been completed.
Licensee letter (U-600469), dated March 12, 1986, from Hall to Denton (NRC/NRR) requested that the completion of preoperational testing (including calibration) of these monitors be deferred until prior to initial criticality. The electronic calibration of the CHRRMs was part of test XTP-CM-02, which was successfully completed and approved May 8, 1986. The in-situ source term calibrations have not begun. With the exception of the calibration program completion, the inspector's remaining concerns are being properly resolved and tracked by the detailed action plan associated with the commitment and compliance analysis of this TMI Action Plan Item (See Subsection 4.a above). This matter remains open pending completion of the calibration program.
5.
Status of Certain HVAC Filtration System Items In January 1985, the inspector selectively reviewed the licensee's HVAC filtration systems regarding compliance with certain commitments and regulations (Inspection Report No. 50-461/85004).
In addition, the inspector' met with licensee representatives to:
(1) determine the status of the ANSI /ASME N510 acceptance test program; (2) inform them of the types of documents which should be available onsite for NRC inspector review; (3) discuss programmatic deficiencies discovered recently at other Near Term Operating License (NTOL) plants; and (4) request that spinster carbon be laboratory retested, an ANSI /ASME N510 acceptance test compliance analysis be prepared, and the use of silicone sealant on HVAC ductwork and filter housings be evaluated. As a result of this inspection, 11 open/ unresolved items were generated (Items No. 461/85004-06 through 16).
During onsite inspections in November 1985 and February 1986 (Inspection Report No. 50-461/86001), the inspector noted that the licensee made little apparent progress towards resolution of the above listed HVAC l
filtration system open/ unresolved items. At the licensee's request, i
members of the NRC/ Region III staff met with licensee representatives l
on March 6, 1986, to discuss, in part, inspector perceived problems with licensee management controls and responsiveness to certain NRC concerns regarding the licensee's installed HVAC filtration systems and the ANSI /ASME N510 acceptance test program.
These concerns included resolution of licensee commitments, open and unresolved items, and field problem and condition reports.
The licensee representatives at the meeting were, in general, able to explain that most of the apparent lack of responsiveness to NRC concerns arid apparent management control weaknesses were due to the normal priority mechanism of an NT0L nuclear
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power plant. They also reaffirmed that the deficiency tracking systems (FPR, CR, etc.) were functioning properly, and all workers would continue to be encouraged to make appropriate use of these systems (Inspection Report No. 50-461/86001, Section 19).
Partially in response to NRC concerns that apparently an unusually large number of field problem reports (FPRs) and condition reports (CRs) were needed to address HVAC startup problems and an inordinate number of these problems did not appear to be resolved to the satisfaction of the startup group, the licensee now holds two or three scheduled meetings between HVAC startup and system engineering representatives each week. The inspector reviewed selected examples of HVAC related FPRs/CRs; satisfactory resolutions appear timely.
In addition, the inspector selectively interviewed individuals who have issued HVAC related FPRs/CRs; in general, they are satisfied with the final disposition of the apparent deficiencies.
Partially in response to NRC concerns that numerous HVAC filtration system open/ unresolved items (461/85004-06 through 16) have remained open for a seemingly inordinate length of time and that the qualify of the documentation to demonstrate compliance was seriously lacking, the licensee appointed a special task force to assure that the concerns were properly addressed and that compliance documentation was adequate. The task force was under the guidance of the Assistant Director, NSED Design Engineering and the Supervisor, HVAC and Fire Protection Engineering.
The task force representatives were from QA, plant staff, startup, NSED, licensing and the Sargent and Lundy HVAC Engineering Division; each representative had a designated backup. The inspector found that, contrary to early site visits, the HVAC related open/ unresolved items have been properly addressed and documentation was adequate for closure determination. The review of this documentation and plant tour findings are presented in the ten subsections which follow.
a.
The ANSI /ASME N510 Acceptance Test Program The inspector reviewed the status of the ANSI /ASME N510 acceptance test program, the acceptance test criteria matrix, and selected completed test reports. All procedures for this test program have been approved and issued for use.
The inspector reviewed selected portions of relevant procedures; no problems were noted.
The following systems are scheduled for testing before fuel load:
Laboratory HVAC (VL), Standby Gas Treatment HVAC (VG), and Breathing Air System (RA). The following systems have been scheduled after fuel load, pending acceptance of deferral requests per licensee letter U-600469, dated March 12, 1986:
Radwaste Building HVAC (VW),
Drywell Purge (VQ), Control Room HVAC (VC), and the Offgas System (VO). The Machine Shop HVAC (VJ) will also be tested after fuel load.
Only the ANSI /ASME acceptance tests for the Breathing Air System i
(RA) have been completed. Some of the tests on this system will be repeated, in part, because of an apparent design flaw in the mounting arrangement for the charcoal canisters and the use of charcoal without
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qualification documentation..The inspector reviewed the Lest reports for the RA system; no problems were noted. The test reports indicate the procedures are apparently followed properly, comments are complete and ~ relevant, and any deficiencies noted are properly entered on the appropriate deficiency tracking system and resolved in a timely manner.
The inspector reviewed the acceptance test matrix and selected calcu-lational bases; with the exception of the maximum allowable control room unfiltered inleakage, no problems were noted. The value stated in the acceptance criteria for this pararreter is adequately documented, pending completion of the licensee's commitments to make two FSAR corrections in Amendment 39 and to obtain NRR concurrence that the present control room air-lock configuration is acceptable. The inspector also reviewed licensee documentation that the scope of the ANSI /ASME N510 acceptance test program has been acequately submitted on the docket for NRR review; no problems were noted. The completion of the HVAC acceptance test program is being tracked by Open Item 461/85005-26.
b.
Charcoal Adsorber and HEPA Filter Qualification-
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In a letter to the Regional Administrator, (U-0785) dated January 18, 1985, the licensee stated that:
(1) iodine retention testing of spinster charcoal for HVAC filters, for the initial filter loading, will be performed if the charcoal is over 18-months old or has been stored under questionable conditions and (2) this testing, if required, will be performed on the affected adsorber prior to fuel load. During the review of adsorber qualification records for charcoal designated for use in the ESF HVAC filtration systems (VC, VG, and VQ), the licensee discovered that portions of the vendor qualification test were done improperly. With the concurrence of NRR, the licensee successfully requalified this charcoal adsorber (four batches, 40,000 pounds) according to the criteria of ANSI N509-1980.. Test Procedure GTP-411, " Sampling Impregnated Absorbant from Standard Drums for Vendor Testing," was developed and approved for use in ensuring that representative batch samples were collected. Nonconforming material reports (NCMR 01-2058 and 02-0768)
and a condition report (CR 1-85-11-053) were issued and resolved by the licensee concerning this matter. The inspector selectively reviewed ~ portions of the original qualification report, the closure packets for the NCMRs and CR, Test Procedure GTP-411, and~the requalification test report; no problems were noted.
The licensee.also reviewed the vendor qualification documentation for non-ESF charcoal adsorber and for ESF and non-ESF HEPA filters.
All of the non-ESF, N510 charcoal adsorber was found to be unqualified in that:
(1) the RA system charcoal did not have batch traceability (three trays), (2) the VQ system charcoal was not requested by the purchase order to have the required documentation (6000 pounds), and (3) the VW system (Radwaste Tank Filters) charcoal was unqualified because of improper vendor tests (330 pounds).
Condition reports (CR 1-86-05-046 and 1-86-05-049) were issued and resolved by the licensee concerning this matter. During a plant-
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tour, the inspector confirmed that the unqualified adsorber was properly segregated with attached hold tags. The licensee intends to dispose of the unqualified charcoal and purchase qualified replacement charcoal before final filter tests are completed.
The licensee also found a number of HEPA filters designated for use in non-ESF, N510 filter systems which did not have adequate qualification documentation.
CR 1-86-05-045 and NCMR 02-0767 were issued and resolved by the licensee concerning this matter. These HEPA filters were reportedly tagged for use only in non-N510 systems.
The inspector selectively reviewed portions of the purchase orders, vendor qualification test records, and NCMR and CR closure packets; no problems were noted.
c.
ANSI /ASME N510 Compliance Documentation The licensee, in a letter to the Regional Administrator (U-0785),
dated January 18, 1985, committed to prepare two documents to track compliance for the ANSI N510 acceptance test program.
These documents are internal reports made available for NRC review.
The first report is a commitment and compliance analysis which s
provides a detailed (line-by-line) identification of each commitment associated with ANSI N510, addresses the review of other documents listed in Section 14.b of Inspection Report No. 50-461/85004, assures that potential programmatic deficiency areas such as those discussed in Section 14.c of Inspection Report No. 50-461/85004 do not exist at Clinton, assures that specific deficiencies at Clinton identified in Section 14 and 15 of Inspection Report No. 50-461/85004 were properly resolved and that similar deficiencies do not exist elsewhere in the plant, ascertains compliance, identifies any corrective measures needed or variance request required, and identifies actions needed to document compliance. The second report is a detailed action plan providing a tracking system for actions needed to comply with
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commitments and regulations, for design deficiencies and other discrepancies and their resolution, and to document compliance.
This report is detailed enough to include specific tasks, individuals assigned to each task, a schedule for completion, and a periodically updated status. The inspector selectively reviewed portions of these reports; the conclusions of this review follow.
The ANSI /ASME N510-1980 line-by-line commi_tment and compliance analy-sis report is divided into 55 ESF commitments (Regulatory Guide 1.52)
and 55 non-ESF commitments (Regulatory Guide 1.140). Approximately 30 action plan items were assigned; 35 variances from commitments were noted.
In general, the report was well organized, cross-references were extensive, and engineering justification statements appeared technically sound.
The significant variances to the specifi-cations of ANSI /ASME N510-1980 appear to be adequately addressed in amendments to the FSAR. Minor variances appear to have adequate engineering justification. The inspector selectively reviewed
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portions of the commitment and compliance report, variances, action plan closure pockets, and supporting documentation (CRs, NCMRs, FCNs, FECNs, FPRs, FSAR amendments, procedural revisions, etc.); no significant problems were noted.
In addition to the ANSI N510 commitment and compliance analysis, the task force addressed previously expressed inspector HVAC filtration system concerns (0 pen Items No. 461/85004-06 through 16) by establish-ing a "HVAC Inspection Punchlist." This punchlist designated action items by Inspection Report Open Item No. to ensure that inspector's concerns were properly addressed; approximately 150 action items were assigned by organization group and responsible individual with scheduled completion dates and periodic updates. Because of the comprehensive efforts of the task force, the closure documentation for the punchlist action items represented, in general, adequate licensing closure packets for the previously listed inspection report open items.
Some of the corrective actions initiated by the task force are discussed in other subparts of this section; this matter
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is considered closed.
d.
Use of Silicone Sealant on HVAC Ductwork and Filter Housings
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During a plant tour in January 1985, the inspector noted that silicone sealant was used on longitudinal duct seams for ESF (Control Room) and non-ESF (Radwaste Exhaust and Drywell Purge) air
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cleaning systems.
The apparent use of silicone sealants on non-ESF filter housings war. also noted.
The inspector informed the licensee that NRR was currently ascertaining the acceptability of silicone sealants on HVAC ductwork and filter housings at another NTOL, and concurrence for the use of silicone sealants on Clinton HVAC systems should be obtained by the licensee from NRR.
The licensee's initial position concerning the use of silicone sealant on HVAC ductwork was provided to the NRC in Letter U-0878 dated June 11, 1985.
In addition, the licensee performed a special review of the use of silicone sealant on Control Room HVAC ductwork.
This review, reported to the NRC in Letter U-600248 dated October 8, 1985, concluded that the use of silicone sealant is satisfactory and provides adequate radiological dose protection per 10 CFR 50, Appendix A, GDC-19.
The NRC position concerning the use of silicone sealant and other temporary patching materials on HVAC systems at Clinton is contained in an internal NRC memorandum from R. Bernero to J. Hind, Subject:
Response to request for Technical Assistance Related to Air Cleaning Systems at Clinton (TIA 85-70); a copy of this memorandum was sent to the licensee on the docket. Based on the position stated in the above memorandum and several discussions with NRR, the licensee committed in Letter U-600336 dated December 11, 1985, to perform a leakage rate test every 18 months on the portion of the negative pressure ductwork outside the Control Room habitability zone. This
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testing requirement has been incorporate into the draft CPS Technical Specifications, Section 4.7.2.h, and Surveillance Procedure CPS 9866.04 has been issued to provide the test instructions. This matter is considered closed.
e.
SGTS Filter Housing Drain System Configuration In Table 6.5-3 of the CPS FSAR, the licensee's commitment to Regulatory Guide 1.52, Revision 2 (March 1978), Regulatory Position 3.h states that water drains are designed in accordance with the recommendations of Section 5.6 of ANSI N509-1976 which states, in part, that drain lines shall be individually valved, sealed, or otherwise protected to prevent bypassing of contaminated air around filters or adsorbers through the drain system.
Contrary to the above, during a plant tour in January 1985, the inspector noted that the installed SGTS filter housing drain system configura-tion consisted of nine drain lines of which only two are valved.
The nine drain lines were all welded construction and hardpiped to a common header. The as-built configuration was not acceptable because it would allow filter bypass via the drain lines. Both SGTS trains had the same installation detail.
Based on a review of the turnover exception list and punchlist tracking system data, it appears that the uninstalled valves have been adequately tracked by the licensee.
During a plant tour on May 22, 1986, the inspector verified that the valves have been installed on both SGTS filter housing drainage systems.
The inspector also noted that the visual inspection checklist for each system's ANSI /ASME N510 acceptance test includes a verification of proper filter housing drain line configuration. This matter is considered closed.
f.
Filter Housing Drain Line Isolation Valve Administrative Controls The position (open or closed) of HVAC filter housing drain line isolation valves must be procedurally controlled to ensure that these valves are closed during filter operation to preclude filter bypass.
In a letter to the Regional Administrator, dated January 18, 1985, the licensee stated that:
(1) a review will be performed to identify procedures needed to ensure that specific instructions are provided on controlling filter housing drain line isolation valves and (2) these procedures will be revised to incorporate this requirement prior to the associated systems being released to Plant Staff for operation.
The licensee identified 12 procedures which upon revision should ensure, by requiring proper valve lineups, that the systems respective filters are not bypassed during HVAC operation. Valve lineups are required to be performed by CPS prestart Procedure No. 1401.01 and surveillance Procedure No. 1011.05.
The inspector
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selectively reviewed portions of the relevant approved and draft procedures and confirmed that approval of the draft procedures was being properly tracked by the licensee; no problems were noted.
g.
Filter Housing Drain Line Isolation Valve Leakage Determination Even if proper administrative control is established to ensure that filter housing drain line isolation valves are closed during filtration train operation, filter bypass via the drain lines is not precluded unless the isolation valves are leak tight. The licensee should verify air leak tightness for all filter housing drain line isolation valves as part of the preoperational test program.
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Preoperational Test Procedure No. XTP-00-012, "HVAC In Place Filter Testing," requires that the filter housing drain line isolation valves be verified closed before testing each unit. Temporary Change Notice (TCN) No. I to XTP-00-12, Appendix D, "NUCON Precedure for Visual Inspection of Nuclear Air Cleaning Systems," requires two inspections to be performed as follows:
(1) visual inspection checklist per ANSI N510, Section 5 requires observations for conditions that could result in the bypassing of the system and (2) visual inspections of filter housing drains for visible interconnecting drains and to determine if drains are sealed or valved within the unit or visually adjacent area.
In addition,
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Appendix E, " Specification for Housing Leak Test," to XTP-00-12 in Section 7.10, " Location of Leaks," identifies in 7.10.1.8 that housing drain lines which are not valved or capped are frequent contributors to leaks sufficient to cause housing test failure.
This matter is considered closed.
h.
Filter Housing Drain Line Loop Seals In January 1985, the inspector informed the licensee (Inspection Report No. 461/85004) that:
(1) concurrence on the acceptability of using loop seals on Clinton HVAC filter housing drain lines should be obtained from NRR; (2) if NRR finds the use of loop seals unacceptable, the licensee should propose design corrections for NRR review; and (3) if NRR finds the use of loop seals acceptable, the licensee should clarify the commitments to the appropriate regulatory positions in the CPS FSAR by amendment and develop procedures to ensure that the loop seals remain properly filled.
In a letter to the Regional Administrator, dated January 18, 1985, the licensee, in response to this concern, stated that:
(1) a review will be performed to identify all procedures for filling and surveillance of the loop seals on filter housings and (2) these procedures will be reviewed to incorporate this requirement prior to the associated systems being released to the Plant Staff for operation. As documented in an internal NRC memorandum from R. Bernero to J. Hind, Subject:
Response to Request for Technical Assistance Related to Air Cle aing Systems at Clinton (TIA 85-70),
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NRR found the use of loop seals acceptable pending NRC/ Region III review of installation and procedures; a copy of the memorandum was sent to the licensee on the docket.
The licensee determined that the drywell purge system loop seal was not required and the SGTS loop seal fill line was not in the correct location. A condition report and two FECNs were issued to correct the situation.
In order to establish the refill periodicity to be required by procedures, the licensee generated calculations to establish loop seal evaporation rates for the SGTS and Control Room HVAC systems. The loop seal fill procedures are currently under revision to incorporate the design changes and correct procedural inadequacies; the inspector verified that these procedures are being properly tracked ar.d scheduled for approval before the associated systems are released to plant staff. The inspector selectively reviewed portions of the calculations, the CR and FECNs, relevant parts of FSAR amendments, and the draft procedures; no problems were noted.
1.
Filter Housing Drain Line Water Check Valves During a plant tour of the station filter housings in January 1985, the inspector noted there were no water check valves installed in any of the drain lines to prevent water backup into the housings.
The inspector requested the licensee to review the situation and ascertain whether water check valves should be installed in filter housing drain lines to protect the filters from possible water damage (Inspection Report No. 461/85004). The inspector's review of the draft procedures for administrative control of filter housing drain line loop seals and isolation valves (Subsections 5.f, g, and h) indicates that the licensee review is correct in that water check valves are apparently not needed.
J.
Fire Protection System Potential Leakage Problems In January 1985, the inspector briefed licensee representatives on problems another NTOL plant had with filter damage due to fire protection system leakage and system modifications a second NT0L plant is considering to preciude the problem occurring at that plant. The inspector requested the licensee to evaluate means for preventing fire protection system leakage from damaging air cleaning system filters (Inspection Report No. 461/85004).
In a letter to the Regional Administrator, dated January 18, 1985, the licensee, in response to this request, stated that IPC would perform a review of the charcoal filter fire protection isolation provisions to ensure that there are adequate provisions to prevent leakage through the Fire Protection System from wetting filter charcoal.
The licensee has established a preventative maintenance program to periodically remove water leakage from the fire protection system low point drain legs when the charcoal filters are in service; for four of the ten systems, modifications have been necessary to create
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adequate low point drain legs.
Recent leakage monitoring indicates that the periodicity of this preventive maintenance program is conservative. The licensee also plans to install open-ended loop seals into the fire protection system low point drain lines before the charcoal is loaded into the filter housings. The inspector reviewed the licensee's internal response to IE Information Notices 83-41, " Actuation of Fire Suppression System Causing Inoperability of Safety-Related Equipment," and 85-85, " Systems Interaction Event Resulting in Reactor System Safety Relief Valve Opening Following a Fire Protection Deluge System Malfunction"; no problems were noted.
6.
Exit Meeting The inspector met with the licensee representatives (denoted in Section 1)
at the conclusion of the inspection on May 23, 1986. The scope and findings of the inspection were summarized.
The inspector also discussed the likely information content of the inspection report with regard to documents or processes reviewed by the inspector during the inspection.
The licensee identified no such documents / processes as proprietary.
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