IR 05000461/1986049
| ML20212A861 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 07/25/1986 |
| From: | Warnick R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Gerstner W ILLINOIS POWER CO. |
| Shared Package | |
| ML20204E535 | List: |
| References | |
| NUDOCS 8608010115 | |
| Download: ML20212A861 (2) | |
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JUL 251986 Docket No. 50-461 Illinois Power ompany ATTN: Mr. W.
. Gerstner Exec ive Vice President 500 South 7th Street Decator, L 62525 Gentlemen:
This refers to the routine safety inspection conducted by Mr. C. H. Scheibelhut of this office on June 30 - July 3 and July 7-11, 1986, of activities at Clinton Power Station authorized by NRC Construction Permit No. CPPR-137 and to the discussion of our findings with Mr. W. C. Gerstner at the conclusion of the inspection.
The enclosed copy of our inspection report identifies areas examined during the inspection. Within these areas, the inspection consisted of a selective examination of procedures and representative records, observations, and interviews with personnel.
No violations of NRC requirements were identified during the course of this inspection.
In accordance with 10 CFR 2.790 of the Commission's regulations, a copy of this letter and the enclosed inspection report will be placed in the NRC Public Document Room.
We will gladly discuss any questions you have concerning this inspection.
Sincerely, stristese 4W by Ao le W R. F. Warnick, Chief Reactor Projects Branch 1
Enclosure:
Inspection Report
No. 50-461/86049(DRP)
See Attached Distribution
Consumer Services
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JUL. 251986
Illinois Power Company
1
Distribution
REGION III==
Report No. 50-461/86049(DRP)
Docket No. 50-461
License No. CPPR-137
Licensee: Illinois Power Company
500 South 27th Street
Decatur, IL
62525
Facility Name: Clinton Power Station
Inspection At: Clinton Site, Clinton, IL
Inspection Conducted:
uneJ0- ' y 3 and July 7-11, 1986
7/M/Id
Inspector:
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Date
Approved By:
R. C. Knop, Chief
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Reactor Projects Section 1B
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Inspection Summary
Inspection on June 30-Ju1Y 3 and July 7-11, 1986 (Report No. 50-461/86049
(DRP))
Areas Inspected: Routine safety inspection
applicant actions on previous inspection findings, evaluation of applicant
action wich regard to Three Mile Island Action Plan requirements, and 10CFR21
items.
Results: Of the three areas inspected, no violations, deviations or safety
significant issues were identified.
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DETAILS
1.
Personnel Contacted
Illinois Power Company (IP)
"J.
A. Brownell, Licensing Specialist
- E. J. Corrigan, Director, Quality Engineering and Verification
"W.
C. Gerstner, Executive Vice President
"J. H. Greene, Manager, Nuclear Station Engineering Department
"R. W. Greer, Director, Outage Maintenance Programs
"J. E. Loomis, Construction Manager
"J. S. Perry, Manager, Nuclear Program Coordination
- R. F. Schaller, Director, Nuclear Training
- F. A. Spangenberg, Manager, Licensing and Safety
"J.
D. Weaver, Director, Licensing
"J. W. Wilson, Manager, Clinton Power Station
" Denotes those attending the exit meeting.
The inspector also contacted others of the applicant's staff.
2.
Applicant Actions on Previously Identified Items (92701)
a.
(Closed) Open Item (461/86016-02 (DRP)): " Low cell voltage alarm
setpoint may be set too low in battery test procedures." During a
review of surveillance test procedures, it was found that the
individual cell voltage low limit setpoint was 1.00 VDC. This
voltage is the cell polarity reversal point defined by the Institute
of Electrical and Electronic Engineers (IEEE) standard 450. The
setpoint should be set at a higher value to ensure that inaccuracies
in the test equipment will not cause a cell reversal that could
destroy the cell.
The applicant reviewed the concern and concluded that setting the
low cell voltage alarm setpoint at a value higher than 1.00 VDC was
desirable. A value of 1.10 VDC was recommended by the Nuclear
Station Engineering Department (NSED). NSED also determined that
CPS No. 9382.06, "125 VDC Battery Service Test", was correct in
requiring termination of the battery service test where an
individual cell reached 1 volt. The applicant revised CPS No.
9302.06 and CPS No. 9382.07, "125 VDC Battery Capacity Test", to
indicate a low cell voltage alarm setpoint of 1.10 VDC.
The inspector reviewed both of the revised procedures and found that
the individual cell low voltage alarm setpoint had been changed to
1.10 VDC. This item is closed.
b.
(Open) Unresolved Item (461/86017-04(DRP)): After a detailed review
of Administrative Procedure CPS No. 1029.01, " Preparation and
Routing of Maintenance Work Requests", Revision 8, the inspector had
a number of concerns about the adequacy of the procedure and the
review and approval process that led to revision 8.
A meeting was
held with the applicant to discuss the concerns that resulted from
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the review. At the conclusion of the meeting there were eight
questions that remained unresolved. These questions were as
follows:
(1) Comments developed during the applicant's review and approval
process leading to revision 8 could not be shown to be
documented and resolved in accordance with CPS No. 1005.01,.
Revision 16, paragraph 8.3.1.5.
This was considered an
unresolved item (46i/86017-04A).
(2) Definition of the term "a repair disposition that does not
affect fit, form or function" (461/86017-04B).
(3) The definition of job priorities for security systems and other
important equipment that do not directly affect plant
operations (461/86017-04C).
(4) Disposition of form CPS No. 1029.01F007 when a maintenance
request is converted to a maintenance work request (CPS No.
1005.01, Appencix A, paragraph Documents (g)) (461/86017-04D).
(5) Definition as to the location where permission to release
equipment or systems for maintenance is documented / recorded by
designated operating personnel (ANSI N18.7-1976, paragraph
5.2.6) (461/86017-04E).
(6) Paragraph 8.2.3 did not provide or reference instructions for
maintenance planners concernibd what was required to obtain a
minimally acceptable work package. In addition, no job
instru. r i cr.. were available to the maintenance planners
concernim; the preparation of a work package (461/86017-04F).
(7) The procedure did not provide or reference limitations on the
term " Tool Box Skills" (461/86017-04G).
(8) CPS No. 1029.01, Paragraph 3.2.17 required clarification of the
words "The work can continue if the results will be within
design requirements" (461/86017-04H).
The applicant took a number of steps to resolve the questions as
follows:
(1) The required comment control form, CPS No. 1005.01F002 was
filled out and initia11ed by the attendees of the
comment /resoletion meeting for revision 8 of CPS No. 1029.01.
Illinois Power (IP) QA indicated their concurrence with comment
resolutions by their final approval signature noted on the IP
QA Document Review Transmittal Form for CPS No. 1029.01, Rev.
8.
These forms were on record.
(2) To resolve this item, as well as several others noted below,
the applicant revised CPS No.-1029.01.
Revision 10 was the
revision pertinent to the current review.
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In CPS No. 1029.01 Revision 8,_the terms " repair" and " rework"
were used interchangeably. The two terms do not have the same
definitions and in the context of CPS No. 1029.01 the proper
term to use is " rework" which means to return a component to
fit, form or function per the design specifications. In order
to avoid any confusion on this point, the term " repair" was
eliminated in paragraph 8.0 of CPS 1029.01 Revision 10.
(3) The definition of job priorities for security systems and other
important equipment that do not directly affect plant
operations has been addressed in paragraphs 2.2.1 and 2.2.1.1
of CPS No. 1029.01 Revision 10.
Basically, the job priority
definition has been exoanded to include all plant equipment and
security systems. AJ o in this revision, the Shift Supervisor
has been given resrr sibility for assignment of all job
priorities (parar
,n 8.1.7).
(4) This was resolved by revising Section 8.2.2 of CPS No. 1029.01
in Revision 10 to have the original copy of the MR (form CPS
No.1029.01F007) attached to the MWR for inclusion in the work
package rather than just entering the MR/MWR into the Power
Plant Maintenance Planning System as was done in Revision 8.
(5) Designated individuals release equipment up to three times on
any given MWR. All MRs on equipment released to Plant Staff
are reviewed and signed by the Shift Supervisor prior to the MR
being forwarded to Maintenance. MWRs which remove equipment
from service must do so via a tagout request which must be
approved by the Shift Supervisor prior to Maintenance beginning
work. All MWRs require that Maintenance group supervision
notify the Shift Supervisor prior to starting work and document
this notification by signing and dating Block 51 of the MWR,
Additionally, the following actions were taken:
(a) The Operations Department implemented a log book to
annotate the MWR and Shift Supervisor / Asst. Shift
Supervisor signature. This log is used to document that
permission has been given to perform work activities.
(b) Plant Staff revised procedures CPS No. 1029.01 paragraph
8.2.13 and CPS No. 1401.01 paragraph 8.5.8 to
proceduralize the use of the log book.
(6) Instructions have been provided in the form of a Maintenance
Standing Order (MS0), MSO-023, "In-House Guidelines for
Maintenance Work Requests". The purpose of this MSO is to
provide guidelines to be used during the preparation,
scheduling and closeout of work packages. This MSO is
referenced in Section 11.31 of CPS No. 1029.01 Revision 10.
(7) Tool box skills have been defined in a position paper by the
CPS Plant Manager and Manager of QA. This position paper,
" Quality Assurance and Plant Staff Interfaces," dated January
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7,1986, lists examples of skills which are common knowledge
for the various disciplines by virtue of their being standard
industry practices. Work practices utilizing tool box skills
are routinely evaluated by supervisory personnel as required in
paragraph 2.2 of CPS No. 1502.03 Revision 2.
Currently, each
maintenance discipline conducts inhouse tool box skills
training; however, beginning July 1, 1986, the Nuclear Training
Department will conduct formalized tool box skills training
which is required for all maintenance disciplines. Work
involving tool box skills is not considered to be a change of
work scope prcviding it is confined to the component covered by
the MWR as noted in CPS No. 1029.01 paragraph 8.2.15.
(8) The last sentence of paragraph 8.2.16 (8.2.17 in Revision 8) of
CPS No. 1029.01 was revised for clarification. Actual or
expected design deviations will require a review by the
Technical Department as defined in 8.2.5 and 8.2.6.
The inspector reviewed Revision 10 of CPS No. 1029.01 and found that
the changes indicated in items (2), (3), (4), (5) and (8) were
satisfactorily incorporated.
For item (1), the inspector reviewed the completed Comment Control
Form, CPS No. 1005.01F002, and the IP QA Document Review Transmittal
Form for Rev. 8 of CPS No. 1029.01 and determined that the originals
were on record. The review showed compliance with the pertinent
requirements of paragraph 8.3.1.5 of CPS No. 1005.01.
For item (5), the inspector also reviewed paragraph 8.5.8 of
Revision 7 of CPS No. 1401.01 and found it also procedurelized the
use of the Maintenance Work Request log book.
For item (6), the inspector reviewed Revision 6 of MS0-23
The
review showed that it provided adequate guidance to the maintenance
planners for the preparation of work packages. Paragraph 4.1.21
refers the planner to paragraph 8.12.5.1 of CPS No. 1501.02 if
approved procedures are not available to perform the work. However,
paragraph 8.12.5.1 uses the terms " guidance," "should," and "may"
for the preparation of approved procedures. This appeared to be
inconsistent with the requirements of ANSI Standard N18.7-1976,
paragraph 5.3.5(4) which indicates that such procedures "shall" be
approved. The inspector requested that the applicant demonstrate
compliance with applicable requirements of ANSI N18.7-1976. This
matter remained unresolved at the conclusion of the inspection.
This is considered another example of unresolved item 461/85012-02
which questioned the use of the terms "should" and "may" in
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administrative procedures used to fulfill regulatory requirements
and applicant commitments.
For item (7), the inspector reviewed the position paper, CPS No.
1502.03 Revision 2, and paragraph 8.2.15 of CPS No. 1029.01. The
review showed that tool box skills were adequately defined and their
use controlled by the procedures.
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In summary, the inspector considers subitems 461/86017-04A, B, C, D,
E, G, and H to be closed. Subitem 461/86017-04F remains open until
a future inspection shows that paragraph 8.12.5 of CPS No. 1501.02
complies with the requirements of paragraph 5.3.5 of ANSI Standard
N18.7-1976.
c.
(Closed) Open Item (461/86017-06): "For the containment purge and
vent valves determine that (1) mechanical stops were installed to
limit 24 inch and 36 inch valves to 50* open, (2) body to bracket
bolting material for the 36 inch valves were changed to higher
stress allowable material ( A-354 GR BD), and (3) preferred
orientation of all valves were verified."
The work accomplished by the applicant to satisfy the three items
above was completed and documented on the following travellers: VQ-
4-E, VQ-7-D, VQ-8A supp. 8, VQ-8-F and VR-2 supp. 7.
The inspector reviewed the travellers and found documented evidence
that mechanical stops were installed in the.24 inch and 36 inch
valves that limited their travel to 50* open; that body to bracket
bolting for the 36 inch valves was changed to A-354 GR BD; and that
the orientation of all of the pertinent valves was checked. Two
were found incorrectly installed. They were removed and installed
correctly. The inspector also selected two 36 inch and one 24 inch
valves at random and inspected them in the plant. The orientation
of all three was found to be correct. High strength (A-354 GR BD)
body to bracket bolting material was found on the 36 inch valves.
Physical evidence (scratched paint, paint removed from bolt threads,
paint removed from gasket edges, etc.) was found that the pneumatic
operators had been removed from all three valves. This was
necessary to install the mechanical stops. Based on the review and
inspection, this item is closed.
d.
(Closed) Deviation (461/86018-02): "Fai'ure to provide for periodic
testing of instrument air for particulate contamination, failure to
provide for acceptance criteria concerning the size of particulates
present in the instrument air, and failure to provide for testing of
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instrument air quality following repair or modification of the
instrument air system."
The applicant took the following steps to correct the deviation:
(1) Vendors of safety-related equipment were contacted and the
maximum contaminant particle size that the components can
accept in the air stream and maintain operational reliability
was determined.
(2) The smallest of the above particle sizes was set as the new
acceptance criterion fcr the Instrument Air (IA) system.
Amendment 38 to the Final Safety Analysis Report incorporated
the criterion in section 9.3.1.
(3) Startup procedure No. XTP-IA-01, "IA Cleanliness Verification
Procedure," was written, accomplished, reviewed, and accepted
by IP QA.
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(4) Procedure CPS No. 2603.01, " Instrument Air Quality" was
revised. It was upgraded to safety-related status (designated
as class code SNQN). Revision 1 addressed:
(a) periodicity -
(yearly) of dewpoint measurements, (b) periodic changes of all
IA system filters, (c) periodic blowdowns to monitor IA system
cleanliness, (d) procedural examinations for cleanliness during
preventive maintenance, and (e) corrective action required when
acceptance criteria are not met.
(5) Procedure CPS No. 6804.01, " Collection and Determination of
Instrument air particulates", was revised. -Revision 1
addressed periodicity of testing and corrective action requirec
when 3 micron criterion at the filter discharge is not met.
(6) Procedure CPS No. 1019.02, " System cleanliness", was revised.
Revision 1 contained specific instructions related to IA
testing after repairs / maintenance / modifications.
(7) Sargent and Lundy (S&L) Specification K-2882, " Cleaning
Specifications," Appendix A, was revised. Revision 4 of
Appendix A sho' led the additional cleanliness requirements of
the I A system that supplics air to safety-related components.
(8) Personnel training for CPS No. 6804.01 Revision 1 was
completed. Personnel training for the revisions to CPS Nos.
2603.01 and 1019.02 were not considered necessary because of
the nature of the changes. Training for startup procedure XTP-
IA-01 was not necessary because the author supervised the
testing.
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The inspector reviewed the list of air-operated safety-related
components that require IA and the vendor correspondence concerning
acceptable air cleanliness requirements. The inspector also
reviewed section 9.3.1.4 of amendment 38 to the Final Safety
Analysis Report (FSAR) and found that the amendment reflected the
requirements of ANSI Standard MC 11.1-1976 and the vendor
requirements for air quality. The inspector reviewed startup
procedure XTP-IA-01 and the test results. The review showed that
all safety-related components requiring air for operation were
receiving air of the required quality. The inspector reviewed
Revision 1 of CPS No. 2603.01 and found that it was classified SNQN
and properly addressed a yearly determination of dewpoint, periodic
changes of all I A system filters, periodic blowdowns of the IA
system to monitor IA system cleanliness, procedural requirements to
inspect pertinent components for cleanliness during preventive
maintenance, and corrective actions required when cleanliness
criteria are not met. Tne inspector reviewed CPS No. 6804.01
Revision 1 and found it addressed required periodic (yearly) testing
of IA for particulate contaminction and the corrective actions
required when the criteria are not met. The inspector reviewed
Revision 1 of CPS No. 1019.02 and found it contained instructions to
test for air quality following repair / maintenance / modifications to
the IA system. The inspector reviewed Revision 4 of Appendix A to
S&L specification K-2882 and found that it contained the additional
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IA system cleanliness requirements. The inspector determined that
training for proceduce CPS No. 6804.01 was completed and agreed with
the applicant's reasons for not requiring additional training for
the other procedures. The inspector concluded that the corrective
actions taken and the actions taken to prevent recurrence were
adequate. This item is closed.
e.
(0 pen) Open Item (461/86026-01):
"A.
Inadequate preventive
maintenance procedure, B.
No list of approved solvents for the
plant, C.
Inconsistent lubrication requirements for threaded
fasteners, D.
Clarification of the role of PMT requirements in
maintenance procedures." During a review of maintenance procedures,
four specific concerns were identified. These were as follows:
(1). The technical adequacy of CPS No. 8019.01, " Personnel Airlock
Maintenance," was in question because it did not contain
preventive maintenance lubrication instructions _even though it
was classified as a preventive maintenance procedure
(461/86026-01A).
(2) The inspector determined that a list of approved solvents did
not exist for the plant. The solvent specified in most of the
procedures reviewed, acetone, may be inappropriate in some
mechanisms that contain organic seals or diaphragms that may be
degraded by the acetone. This appeared to be a generic problem
(461/86026-01B).
(3) There was inconsistency between procedures in steps requiring
the torquing of threaded fasteners. Some procedures required
lubrication of the threais with a specified lubricant. Other
procedures did not require thread lubrication before
torquing. This appeared to be a generic problem (461/86026-
01C).
(4) Section 8 of each maintenance procedure contained a subsection
sometimes called Post Maintenance Testing (PMT) and sometimes
called Operational Test. The inspector learned that specifying
PMT is now the responsibility of the plant technical staff and
is a function of the MWR process. Since these procedures were
written before this requirement was effective, the procedures
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may not be adequate to address the PMT requirements.
It was
noted that the current revision of CPS No. 1029.01 contained
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provisions for specifying PMT. The applicant was requested to
clarify the use of PMT information contained in the maintenance
procedures in light of current MWR practices (461/86026-01D).
To resolve these concerns, the applicant took the following actions:
(1) Routine preventive maintenance lubrication is scheduled by the
applicant's "Survtrac" computerized maintenance scheduling
system. Therefore, routine lubrication instructions were not
included in preventive maintenance procedures. Routine
lubrication of the airlocks was identified in the "Survtrac"
system as preve~.cive maintenance items MMMCSA004S, and
MMMCSA005S.
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The insp0ctor reviewed items MMMCSA004S and MMMCSA005S in the
"Survtrac" system and found that the items listed the frequency
(6 month), approved lubricants, and reference to a controlled
document (vendor manual). Review of the listed document in the
vault showed it contained identification of the lubrication
points. The inspector considers this approach to routine
lubrication satisfactory since approved lubricants for the
individual. components were given, and reference was made to a
controlled document for specific lubrication details. This
subitem is closed.
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(2) The applicant has prepared a list, "NSED Approved Products
List," that included solvents approved for use at CPS. For
each solvent, the list included typical applications and
limitations on its use. The applicant reviewed all (128)
mechanical maintenance procedures to identify usage of
acetone. Of the procedures reviewed, 43 were found to contain
a reference to the use of acetone as a solvent. These 43
procedures were revised to remove the reference to the use of
acetone and referenced the NSED Approved Products List instead.
The inspector reviewed the approved product list and found it
adequate.
In particular, one of the limitations on the use of
acetone is that it is not to.be used on non-metallic items.
The inspector chose three of the revised procedures at random
and found that reference to the use of acetone as a solvent was
removed. This subitem is closed.
(3) The applicant reviewed all (128) mechanical maintenance
procedures to determine conformance with the threaded fastener
lubrication requirements given in the vendor manuals.
A total
of 15 procedures deviated from vendor requirements and were
revised to reflect the methods given by the vendor.
The inspector selected three of the revised procedures and
compared them with their pertinent vendor manuals.
In all
cases the revised procedures reflected the methods given in the
vendor manuals. This subitem is closed.
(4) The applicant's actions on this subitem were not complete at
the time of the inspection. Therefore this item remains open.
No violations or deviations were identified.
3.
Evaluation of Applicant Action with Regard to Three Mile Island (TMI)
Action Plan Requirements (25401)
The NRC Office of Inspection and Enforcement issued Temporary Instruction
(TI) 2514/01, Revision 2, dated December 15, 1980, to supplement the
Inspection and Enforcement Manual. The TI provides TMI-related
inspection requirements for operating license applicants during the phase
between prelicensing and licensing for full power operation. The TI was
used as the basis for inspection of the following TMI items found in
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a.
(Closed) Item II.E.4.1*
" Dedicated hydrogen penetrations."
Hydrogen recombiners for postaccident use located external to the
containment shall have dedicated containment penetration systems
that meet the single failure requirements of General Design Criteria 54 and 56 of Appendix A to 10CFR50. The procedures for the use of
the combustible gas control system following an accident that
results in a degraded core and release of radioactivity to the
containment must be reviewed and revised, if necessary.
In Inspection Report 50-461/86010, the inspector determined that the
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hardware aspects of the item were satisfactory. However, one
procedure had not been written and another was incorrectly
classified as non-safety related.
The applicant has rewritten and reclassified CPS No. 3316.01,
" Containment Combustible Gas Control," which covers the operation of
the hydrogen recombiners. The applicant wrote Off-Normal Procedure
CPS No. 4111.01, " Combustible Gas Mitigation," which integrated the
operation of the combustible gas control system with other
techniques f: * combustible gas control.
The inspector reviewed the two procedures and found that they were
both classified as safety-related and covered the operation and
timing of use of the systems. This item is closed,
b.
(Closed) Item II.E.4.2: " Containment Isolation Dependability." In
NUREG-0737, the following requirements for improved dependability of
containment isolation were listed:
(1) Tne containment isolation system design shall comply with the
requirements of Standard Review Plan Section 6.2.4.
(2) All systems that penetrate containment shall be classified as
essential or non-essential and the results of the evaluation
reported to the NRC.
(3) All non-essential systems shall be isolated by the containment
isolation signal.
(4) The design of the control systems for automatic containment
isolation valves shall be such that resetting the isolation
signal will not result in the automatic reopening of
containment isolation valves.
(5) The containment setpoint pressure that initiates the isolation
signal must be reduced to the minimum compatible with normal
operating conditions.
(6) Containment purge valves that do not satisfy the operability
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criteria of the Staff Interim Position of October 23, 1979,
must be sealed c]) sed or modified to meet the operability
criteria.
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(7) Containment purge and vent isolation valves must close on a
high radiation signal.
In response to these requirements, the system designs and their control
systems were reevaluated and the results included in the FSAR and
amendments to the FSAR.
In section 6.2 of the CPS Safety Evaluation
Report (SER) (NUREG-0853), and Supplements 2 and 5 to the SER, the NRC
accepted the design and definitions of essential and non-essential
systems. For item 6, above, modifications were required to satisfy
operability requirements for the containment purge valves and made an SER
confirmatory item (461/86017-06) to assure that the modifications were
made.
The applicant completed the modifications indicated in item 461/86017-06
(see paragraph 2.C above). The appilcat.c performed the following
Preoperational Tests (PTPs) to demonstrate, among other things, that the
requirements of tnis TMI Action Plan Item were met:
PTP-NB-04 demons' rated that requirements 3 and 4, above, were met.
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PTP-RH-01,-HP-01, and -LP-01 demonstrated that isolation of
essential systems performed as designed.
PT?-VP-01, and -VQ-01 demonstrated that the requirement 7, above,
was met.
A Region III inspector witnessed performance of parts of the PTPs listed
and reviewed the results of all the PTPs following applicant review and
approval. The inspector found that the PTPs satisfactorily demonstrated
operation of the systems in accordance with the requirements. This
inspection and review was documented in Inspection Report 50-461/86052.
This item is closed.
No violations or deviations were identified.
4.
Applicant Actions on 10CFR21 Item (92700)
(Closed) 10CFR21 Item (461/86007-PP): " Failure to Incorporate Rockwell
Bulletins in S&L Design Documents".
Rockwell International, supplier of
the hydrogen recombiner units.for CPS, identified the failure of an
electrical component (timer KS-2) during environmental qualification
testing. Rockwell reported this matter to the NRC under the requirements
of 10CFR21. Rockwell then initiated and issued Bulletin #0020 describing
required modifications to correct the condition and transmitted it to S&L
(the applicant's Architect Engineer) for insertion into the
operations / maintenance manual. During the resolution of an unrelated
matter, the applicant discovered that the hardware u.adifications required
by Bulletin #0020 had not been performed. Further review determined that
the bulletin had been inserted in the manual as an "Information Only"
document and no design change had been initiated.
The applicant requested a listing and copies of all Rockwell bulletins
that applied to CPS. Review of the information supplied by Rockwell'
identified another bulletin (#0034) applicable to CPS. That bulletin had
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also been sent only to S'<.
However, S&L had no reco'rd of receipt of the
bulletin. The applicant and S&L reviewed the bulletins and determined
that hardware changes were required by both. Accordingly, Field
Engineering Change Notices (FECNs) 13011 and 13590 were issued to
implement the contents of Rockwell Bulletins #0020 and #0034. Bulletin
- 0020 required removal of a timer and wiring modifications in the control
panel. Bulletin #0034 required replacement of some capacitors and
cleaning of the annunciator control circuits. To preclude recurrence,
Rockwell was requested to address future correspondence regarding the
Clinton hydrogen recombiner units directly to the Illinois Power Company
for technical evaluation and processing.
t
The inspector reviewed the FECNs and their accompanying work requests and
QA records. The review indicated that the work had been accomplished in
accordance with the applicant's QA program. The inspector reviewed the
applicant's letter, F-1452, dated March 14, 1986 to Rockwell
International and concluded that the problem should not recur. This item
is closed.
No violations or deviations were identified.
5.
Exit Meeting
The inspector met with the resident inspector and applicant
representatives (denoted in paragraph 1) at the conclusion of the
inspection on July 11, 1986. The resident inspector summarized the scope
and findings of the inspection. The applicant acknowledged the
inspector's findings. The applicant did not indicate that any of the
information disclosed during the inspection could be considered
proprietary in nature.
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