IR 05000461/1986041

Insp Rept 50-461/86-41 on 860602-0709.Violations Noted: Inadequate Housekeeping,Failure to Follow Procedure & Inadequate Test Control

ML20204E870
Person / Time
Site:	Clinton
Issue date:	07/28/1986
From:	Dupont S, Ring M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20204E853	List: IR 05000461/1986041 ML20204E846 ML20204E857
References
50-461-86-41, NUDOCS 8608010275
Download: ML20204E870 (11)

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.- U.S. NUCLEAR REGULATORY COMMISSION REGION III ,

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Report No. 50-461/86041(DRS)

Docket No. 50-461 License No. CPPR-137 Licensee: Illinois Power Company 500 South 27th Street Decatur, Illinois 62525 Facility Name: Clinton Nuclear Power Station, Unit 1 Inspection At: Clinton Site, Clinton, Illinois Inspection Conducted: June 2 through July 9, 1986 i

flS. G. DuPont 3R$

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Inspector: CL N '

tOate O Approved By:

Test Programs Section 4M8N Wate '

Inspection Summary Inspection on June 2 through July 9, 1986 (Report No. 50-461/86041(DRS))

Areas Inspected: Licensee's actions on previous inspection findings (92701, 92702), preoperational test witnessing (70315, 70441, 70442, 70444),

preoperational test result review (70325, 70544), preoperational test result verification (70329), startup test phase procedure review (72502, 72504), and startup test phase program review (72400).

Res'ults: Of the six areas inspected, no violations or deviations were identified in five of the areas. Three violations were identified in the remaining area (inadequate housekeeping - Paragraph 7.c(1); failure to follow procedure - Paragraph 7.c(2); and inadequate test control - Paragraph 7.c(3)).

8608010275 860728 PDR 0 ADOCK 05000461 PDR

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DETAILS

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i Persons Contacted f *J. W. Wilson, Plant Manager

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

• W. Connell, Manager, Quality Assurance

• J..A. Miller, Assistant Manager, Startup

• J. D. Weaver, Director, Licensing

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• K. A. Baker, Supervisor, Inspection Enforcement Interface The inspector also interviewed other licensee employees, including members of startup and plant staf * Denotes those attending the exit interview on June 20, 1986.

f ** Denotes those attending the final exit interview on July 9,198 ! Actions on Previous Inspection Findings (Closed) Violation (461/85061-03): Maintenance procedure CPS 8433.01

for generic battery maintenance did not meet the requirements of IEEE i Standard 450-1975. The inspector reviewed Revision 5 to procedure CPS 8433.01 and found that it meets the requirements of both the vendor manual and the IEEE Standard.

' (Closed) Open Item (461/85061-04): Maintenance Work Request (MWR)

B20401 was closed with deficiencies outstanding without resolutio The licensee corrected the deficiencies by issuing an additional MWR and committed to review 100 percent of all MWRs that were issued l on post-Phase II systems prior to declaring those systems operable to support fuel load. The inspector finds these actions adequate.

l (Closed) SER Open Item (461/85005-16): Verify initial battery capacity discharge test was performed on safety-related station i batteries as part of the preoperational test program. The inspector i verified that the initial capacity discharge test was performed by

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reviewing completed preoperational tests PTP-DC-01, PTP-DC-02, PTP-DC-03, PTP-DC-04, PTP-DC-05 and PTP-DC-06.

l (Closed) Unresolved Item (461/86013-01): Regulatory Guide 1.68 requirements are to be defined for fuel load procedures and program The inspector reviewed the revision to startup procedure STP-03-1

and verified that the requirements of Regulatory Guide 1.68,

[ Appendix C, were me (Closed) Unresolved Item (461/86013-04): The engineering evaluation l

for the damaged terminal on Battery OSS11EA was inadequate. The

licensee reevaluated the damaged cell post No. 9 and determined that j the connection is adequately sized to supply the connected load even j with the approximately 15 percent reduction in original surface

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contact are The licensee reviewed the performance of the damaged post and also concluded that cell post No. 9 performed similar to other undamaged posts. The licensee also established a preventive maintenance program to perform a quarterly visual and resistance

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check of the battery. The inspector finds these actions adequat (Closed) Violation (461/86013-05): Corrections to' inspector identified deficiencies were not timely and the deficiencies were repeated during subsequent inspections. The licensee assigned an engineer full Lime responsibility to track dnd expedile 'resolutiori of NRC issues. The inspector finds this action adequate to provide the necessary attention for timely corrective action (Closed) Open Item (461/86013-06): The licensee was tasked with reviewing the battery maintenance program for adequacy. The licensee reviewed and revised their battery maintenance procedure The inspector reviewed these revisions and found that they are now in agreement with the vendor manual and IEEE Standard (Closed) Unresolved Item (461/86013-07): Nuclear Station Engineering Department was tasked with reviewing the station batteries preoperational data to determine if the data was still valid with the conditions of the batteries as found by the inspector and noted in Inspection Report No. 461/86013. The inspector reviewed the licensee's detailed evaluation and is in agreement with the licensee's conclusion that the preoperational data is still valid and that the batteries' conditions had been correcte (Closed) Deviation (461/86013-03): Battery OSS11EA was not tested as required by IEEE Standard 450-1975. The inspector reviewed the test data of acceptance test ATP-DC-07 and verified that the IEEE Standard required capacity discharge test was performed. The test results verified that the battery capacity (113.25%) exceeded the 90% of design requiremen (Closed) Unresolved Item (461/86025-01): Maintenance Work Requests (MWRs) B20401 and B05915 were inadequately closed. The licensee revised procedure CPS 1029.01, " Preparation and Routing of Maintenance Work Requests," to require justification of any job steps not performed as required by the MWR. The inspector finds this action adequat (Closed) Unresolved Item (461/85061-01): Verify that preoperational test PTP-SX-01, " Shutdown Service Water System," test method is adequate and that the containment valves will not automatically open after the isolation signal is removed. The inspector reviewed Test Change Notice (TCS) 1 to the preoperational procedure and verified that the testing method adequately demonstrated that the isolation valves will not automatically reposition open after the isolation signal is remove No violations or deviations were identifie i

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3. P_reoperational Test Witnessing The inspector 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 (SUM). The tests were found to be satisfactory:

PTP-LE-01, " Loss of Power Test" PTP-DG/D0-02, " Division 2 Diesel Generator and Fuel Oil" The inspector witnessed the following sections of PTP-LE-01:

7.1, " Test 1 Loss of Offsite Power (LOOP) Division 1," 7.7,

" Test 7 Loss of Coolant Accident (LOCA)," and 7.8, " Test 8 LOOP and LOCA." The objectives of the tests were to verify (1) that on a LOOP the emergency bus has been de-energized and that the loads have been shed from the bus; (2) that the diesel generators automatically start and load unto their bus; (3) the diesel generators operate as required during a LOOP and LOC The inspector found the performance of these tests to be adequate and the performance of operations personnel was also adequate for this stage of training and testin The inspector reviewed the data of Section 7.11, " Test 11 Hot Start of Division 1 Diesel Generator." The objective of the test was to verify that the Division 1 diesel generator would start while hot or in a coastdown from operating with a simultaneous LOOP and LOC The diesel generator took a longer time to start and load (greater than 15 seconds) than the requirements contained in the FSAR (less than 13 seconds). Further reviews revealed that this condition resulted because the two lube oil pressure switches, S24 and S24A are designed to close on 16 pounds per square inch (psig) pressure decreasing. These switches are in the starting or cranking permissive circuit and prevent the engine from starting by locking out the air start motors until lube oil pressure has decreased below the setpoint of 16 psig. The function of these switches is to protect the air start motors from damage if a start signal is received and the air start motors are still engaged while coasting down. However, the inspector is concerned that these switches could delay the response of the emergency core cooling systems during a simultaneous LOOP and LOC The inspector discussed this concern with Mr. Marvin W. Hodges, Chief, Reactor Systems Branch, Division of BWR Licensing, Office of Nuclear Reactor Regulation (NRR) and the following is Mr. Hodges' conclusion:

• The issue is not a concern with the Design Break Accident (DBA) because the analysis demonstrates that one division of emergency core cooling systems is adequate to prevent core damage in the worst cas * In support of the above, only one diesel generator would be in coastdown at any specified time. In addition, for one diesel generator to be in coastdown while another is out of service with a simultaneous LOCA and LOOP, the probability is extremely low and as such is within the DBA analysi .

The inspector is satisfied that the issue is adequately addressed by the DBA analysis; however, the inspector is requesting the Office of NRR to provide resolution of the issue and as such the issue is an unresolved item (461/86041-01) pending NRR's respons No violations or deviations were identified; however, one issue requires further examination and is documented as an unresolved ite . Preoperational Test Result Review The inspector reviewed the preoperational test results for PTP-RP-01 (Partial Results No. 1), " Reactor Protection System," and PTP-NB-01,

" Nuclear Steam Supply Shutoff System," for acceptance and completion of test objectives in accordance with the FSAR, SER and SUM. The licensee's test result evaluations were also reviewed and found satisfactor No violations or deviations were identifie . Preoperational Test Results Verification The inspector verified that the following acceptance (ATP) and preoperational (PTP) test results were reviewed and accepted by the licensee in accordance with the SUM and were found to be satisfactory:

PTP-IA/SA-02, " Loss of Instrument Air Test" PTP-VR-01, " Containment Building HVAC" PTP-VX-01, " Essential Switchgear Heat Removal" PTP-VF-01, " Fuel Building HVAC" No violations or deviations were identifie . Startup Test Phase Procedure Review The inspector reviewed the following startup test phase procedures for compliance with the FSAR, Regulatory Guide 1.68, Draft Technical Specifications, and the Startup Manual. The inspector found the procedures to be satisfactory:

STP-13A-3, " Process Computer" STP-11-3, "LPRM Calibration" STP-11-6, "LPRM Calibration"

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STP-13A-2, " Process Computer" l STP-12-1, "APRM Calibration" l STP-12-3, "APRM Calibration"

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STP-12-6, "APRM Calibration" STP-19-1, " Core Performance" l STP-19-2, " Core Performance" STP-19-3, " Core Performance" STP-19-4, " Core Performance"

! STP-19-5, " Core Performance"

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STP-19-6, " Core Performance" l

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No violations or deviations were identifie .

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d 7. Startup Test Phase Program Review Inspection Scope The inspector toured the Division I and II diesel generator rooms to verify that the diesel generators and support systems were in a condition to support fuel loa The inspection included housekeeping, system status, and control of testing and operational

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activitie . Summary of Inspection Results Because of the inspector findings in the diesel generator rooms pertaining to the above objectives, the inspector expanded the inspection to include various zones in the Fuel Building. This inspection resulted in three violations with numerous example Listed below are general summaries of the violations with further descriptions in Paragraph 7.c of this report:

• The inspector found debris, test equipment and portable equipment in both diesel generator rooms and the Fuel Building. Some of these findings included oil soaked rags on or around the emergency diesel generators, a test hose hanging over a inch pressure sensing line and test equipment stored within an energized local control panel for the diesel generator. All of these findings are examples of poor housekeeping and resulted in a violation (461/86041-02).

• The inspector found two Deficiency Identification tags on the Division II diesel generator associated with MWRs C25153 and C04208. Both MWRs were previously cleared without removing the tags. This is an exam le of failure to follow procedure CPS 1029.01, Revision 10, p' Preparation and Routing of Maintenance Work Request (MWR)," and is a violation l (461/86041-03). An additional violation was documented in

, Inspection Report No. 461/86023 where four examples were l documented in which the licensee failed to follow procedure CPS 1029.01, Revision 8; therefore, this is considered a repeat violatio In addition to the previous violation, the inspector t also documented violations and concerns with the activities l controlled by procedure CPS 1029.01 in Inspection Reports

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Nos. 461/86025, 461/86013 and 461/8506 * In the Fuel Building, the inspector found that two separate tests were in conflict in that the controls established by the High Pressure Core Spray (HPCS) doors for the air balance test were violated by a test hose for Local Leak Rate Testing (LLRT). This is a violation of test control (461/86041-04).

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c. Details (1) The inspector toured the Fuel Building, Division I and II diesel generator rooms and found that the housekeeping of these areas was in violation of housekeeping requirements. The following conditions were found by the inspector:

Division I Diesel Generator Room

• Numerous oil soaked raos were found on the enaine's ski It should be noted that during this inspectioil the licensee had a temporary pre-lube system connected to the engine. The inspector also found that this temporary system leaked excessive lube oil onto the engine's ski The inspector addressed this concern to the licensee; however, the Manager - CPS stated that the cleanup of free standing oil was not scheduled until after the permanent modification is installe * Various material used for scaffolding was stored around the engine skid and under and around the safety-related diesel generator air start supply piping. This is an example of not controlling construction materials around a completed, preoperational tested, safety-related system when adequate storage was available in other areas away from safety-related systems and component Division II Diesel Generator Room

• The inspector found that the upper covers on both of the skid mounted instrumentation panels were not made up and that only one appeared to be addressed with a Deficiency Identification tag (MWR C19655). The inspector questioned the plant staff on the applicability of MWR C19655 to determine whether it applied to one or both panels. The inspector did not receive an answer during the inspection; i however, while the inspector was present in the diesel

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generator room, a maintenance crew corrected the deficiency on one of the panels and removed the ta The inspector noted that the other panel remained in the deficient condition. When questioned, the maintenance

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crew stated that they were authorized to correct the deficiencies associated with MWR C19655, which affected only one of the two panels. Therefore, the deficiencies on the other panel remained unidentified and uncorrected.

! * The inspector found oil soaked rags on the engine's skid and under one of the skid mounted panel * The inspector found a test box (portable equipment) and an operator's communication headset stored within the energized local engine and generator control panel (1PL12JB).

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Fuel Building

• The inspector found that a test hose used for LLRT was hanging from a % inch pressure sensing line for the B Drywell Chiller Unit inlet pressure gaug * The inspector also found a portable air blower rigged on the valve handwheels for valves 1WS065B and 1WS0678, B Drywell Chiller Supply valve All of the above findings are examples of poor housekeeping, poor area tours by plant staff, inadequate area controls and ineffective management in that many of these conditions existed for several days without being detected by required plant staff tours, and management controls were ineffective in preventing construction material from being stored around safety-related equipment. In addition, the licensee did not demonstrate that activities conducted within controlled areas were being monitored by supervision or management. As such, poor housekeeping is a violation (461/86041-02).

The following corrective actions were taken by the licensee during the inspection:

• During the Stone & Webster (contractor) site safety meeting No. 18, the licensee reinforced that each individual is responsible for housekeeping or material deficiencies in the plan All deficiencies should be reported for initiation of an MWR or Condition Repor ,

These actions should prevent recurrence where a deficiency on one component is cleared while a similar deficiency is not identified on another component as discussed in the above violatio * Memorandum J. O. No. 15485 was 'tsued to reinforce the responsibility of all personnel to report and identify deficiencies and to maintain good housekeeping in the

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* Operations Night Orders and memorandums to all station employees reinforced the requirements and responsibilities of identifying, reporting, correcting housekeeping deficiencies and maintaining good housekeeping.

! * A memorandum was issued to correct problems with test hose l

routing and storage of test equipmen The inspector reviewed and found the above actions to be adequate, and they should prevent recurrence of housekeeping problems. Therefore, a written response is not require .

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(2) During the tour of the Division II diesel generator room, the inspector found two Deficiency Identification tags associated with MWRs C25153 and C04208 were still hanging on the diesel generator after the MWRs had been completed and reviewed by supervision for closure. In the case of C04208, the MWR had been closed four months pior to the inspection. The licensee stated that these two t g were controlled under Baldwin Associates'(contractors)proceduresandassuchwerenot required to be removed by tl'e BA procedure after the MWR was complet This is riot in agrament with the CPS procedure 1029.01, " Preparation and Rotting of Maintenance Work Requests (MWR)," Section 8.2.c.19 which has as an action statement,

" Remove deficiency identif? cation tags, notify Maintenance Group Supervisor of completion 01 wct k . . . ." The inspector finds this to be an example of a failure to follow the instructions of procedure CPS 1029.01 and as s nh is a violation (461/86041-03).

It should also be noted that Section 1.0, " Purpose," of procedure CPS 1029.01 states, "This procedure establishes a system for identifying, controlling, documenting and determining requirements for work terformed by the Maintenance Department or contractors within the station." Since this procedure established the sy' stem of controlling MWRs for both plant staff and " contractors, the contractor's procedures should not deviate from the statiof s established controls. However, the licensee demonstrated to the inspector that only 291 tags were hung by BA and committen tc the inspector to remove all applicable tags (those asso:iated with closed MWRs) because there is a small numbar of BA tags in the plant and BA no longer hangs or removes tags. Illinois Power Company provided an assurance that CPS management will provide adequate control of futurecontractors'proceduresbyrequiringthatcontractors follow site procedures or that contractors procedures will meet the requirements of established systems of control and procedure During the inspection and prior to issuance of this report, the licensee made adequate corrective actions by identifying those tags remaining that will require removal and as such, the licensee is not required to respond to the violatio (3) Also during the tour of the Fuel Building, the inspector noted that a hose used for Local Leak Rate Testing (LLRT) had blocked open the barrier door to the High Pressure Core Spray (HPCS)

room. The door was posted with a sign that instructed all personnel that an air balancing preoperational test was in progress and the door should not be left open. The inspector discussed this condition with the test coordinator who was not aware that an LLRT was in progress in the HPCS roo The inspector did find that plant staff personnel, who were performing the LLRT, were coordinating with the control room. This coordination was being performed on available systems on a first come basis without coordinating with the applicable startup test

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eng'ineer or the test coordinator. Additionally, the LLRT was l not scheduled on the Daily Activities Schedule which is used to prevent testing and other activities from interfering with each other. This is considered a violation of testing control (461/86041-04).

i The inspector also found that none of the parties associated with the LLRT had followed the instructions of the posted sign

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in notifying the air balancing test engineer, even though the t applicable communication number was provided. In addition to the plant staff engineers associated with LLRT, the inspector witnessed other plant staff (security, maintenance and operations) violating the posted signs without notifying the

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applicable engineer. In conclusion, the inspector found that

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plant staff did not follow posted instructions, did not coordinate interfering activities and that plant staff ,

, supervision was not aware of LLRT testing in the HPCS room

! when questioned by the inspector. This is also an example of

inadequate management and supervision of activities within the

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statio !' During the inspection and prior to issuance of this report, the j licensee made the following corrections:

• Training was conducted for plant staff and startup to

! reinforce requirements to follow instructions of posted

signs and to improve the information contained on the i posted signs. The training also included the importance

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of timely posting and removal of signs.

* The Daily Activities Schedule instructions were revised to include requirements that work requiring plant l coordination is scheduled. Also, requirements were

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! STAFs and surveillance testing are to be approved by the

! plant manager or the shift supervisor to improve i

coordination and management involvemen * Training and instructions have reinforced the importance of providing details of the activity boundary to the shift supervisor to improve coordination of activitie The inspector found these corrective actions adequate and therefore no response is required for this violation.

[ d. Summary i

The inspector found that all three violations were related in that activities within the station were being performed without adequate

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rooms even though plant staff toured and inspected the rooms for

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these conditions on a shiftly basis. The inspector found that

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supervision was ineffective in verifying the adequacies of these tours and that management did not control access to or the activities within these rooms. Violation 461/86041-03 identified a condition where management controls allowed a contractor to deviate from the established system of controlling MWRs. Violation 461/86041-04 identified where supervision was not aware of the details of testing being performed within the station and that management had not established an adequate system to control these activities. The inspector found these to be examples of weak programs which needed improvement. The licensee made improvements during this inspection period which included training of plant staff and management personnel to emphasize the program needed to control activities after fuel load such as startup phase testing, deferred preoperational testing, surveillance testing, operational modes, and maintenance activities. In addition, the licensee defined the program in response to a previous inspection (461/86013). The adequacy of these improvements will be assessed by resident and regional inspectors in subsequent inspections of the licensee's ability to control and perform technical specification surveillances prior to fuel loa . Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, violations, or deviations. An unresolved item disclosed during this inspection is discussed in Paragraph . Exit Meeting The inspector met with licensee representatives (denoted in Paragraph 1)

on June 20 and July 9, 1986. The inspector sunnarized 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 by the inspector. The licensee did not identify any such documents or processes as proprietary. The licensee acknowledged the statements made by the inspector with respect to the finding