IR 05000461/1986052
| ML20210D103 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 09/15/1986 |
| From: | Dupont S, Ring M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20210D020 | List: |
| References | |
| 50-461-86-52, NUDOCS 8609190054 | |
| Download: ML20210D103 (13) | |
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l U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Report No.~50-461/86052(DRS)
Docket No. 50-461 License No. CPPR-137 Licensee:
Illinois Power Company 500 South 27th Street Decatur, IL 62525 Facility Name:
Clinton Nuclear Power Station, Unit 1 Inspection At:
Clinton Site, Clinton IL Inspection Conducted: July 7 through August 29, 1986 fY%
Inspectors:
S. G.
uPont
_ f /S Ope
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3-Approved By:
M. A. R ng, Chief
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Test Programs Section Date
Inspection Summary Insoection on. July 7 through August 29, 1986 Report No. 50-461/86052 (DRS)
Kreas Inspected: Action on previous inspection findings (92701),
preoperational test result review (70322, 70541, 70560, 70577, 70544, 70326, 70325,70542,70400) and preoperational test result verification (70329).
Results:
Of the three areas inspected, no viclations or deviations were identified in two areas.
Within the remaining area, three violations were identified (failure to follow procedures - Paragraph 2.a.(3); failure to document an engineering evaluation - Paragraph 2.a.(2); failure to make corrective actions to preclude recurrence - Paragraph 2.a(5)).
8609190054 860716 PDR ADOCK 05000461
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DETAILS 1.
Persons Contacted D. P. Hall, Vice President
- J. W. Wilson, Plant Manager
- J. S. Perry, Manager, Nuclear Programs Coordinator
- W. Connell, Manager, NP and S
- D. L. Holesinger, Director, Startup Testing
- E. W. Kant, Assistant Manager, NSED
- R. W. Greer, Director, Outage Maintenance Program
- J. D. Weaver, Director, Licensing
- R. F. Schaller, Director, Nuclear Training
- K. A. Baker, Supervisor, Inspection and Enforcement Interface The inspector also interviewed other licensee employees, including members of start up and engineering.
- Denotes those attending the exit interview on August 29, 1986.
2.
Actions on Previous Inspection Findings a.
(Closed)UnresclvedItem(461L86055_-Oll: Clinton Power Station to conduct a fall _ure analysis of.two motor-operated valves during
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reoperational testing of the High Pressure Core Spray System p(HPCS). This item is being upgraded to three violations. During testing the licensee discovered that Valves 1E22-F010 and IE22-F011 (HPCS Testable Return Isolation Valves) failed such that 1E22-F010's shaft sheared and 1E22-F011's valve disk separated from the shaft.
General Electric (GE) conducted a failure analysis and concluded that the main contributors to the damaged valves were:
Limit switch problems resulting in overtravel of the stems into
the backseat.
Vibrations induced into the lines due to extensive use of both valves for throttling.
Original valve stems supplied by the manufacturer had high
hardness values with resultant high residual stress typical of 410 stainless steel.
The licensee applied the following corrective actions to the first two contributors: All safety-related valves were tested (M0 VATS) and limit switches were adjusted to prevent future overtravel into the backseat. Operational procedures were revised to not use isolation valves for throttling.
Pertaining to the last contributor, high hardness valves with 410 stainless steel, the licensee tested all 166 safety-related valve stems and check valve pins for hardness greater than Rockwell C 30 (RC 30).
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'h This effort determined that 15 motor-operated valve stems and check
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valve pins had excessive hardness. The licensee documented these findings in a Part 21 Report, No. 21-85-18, to Mr. J. G. Keppler, Administrator, Region III dated May 28, 1986. The licensee performed an engineering evaluation to determine effects of single failure and determined that the 15. stems and pins would not fail and affect the safety function of the effected systems.
However, the inspector was unable to review the evaluation that verified that a comon mode of failure would not prevent one or more systems from performing their intended safe shutdown or design accident functions. Also, the inspector was unable to find supporting evidence of the licensee's conclusion for operating with a known defect until the first refueling outage in 1988. The inspector identified this to the licensee on August 21 and 25, 1986. On August 28 the licensee presented to the inspector a formal evaluation which demonstrated that even with a comon mode failure, the unit would still be able to achieve safe shutdown. This evaluation was based upon the contributors determined by GE. Only three of the valves were susceptible to all of the contributors and the evaluation adequately demonstrated that alternate suction paths and backup isolations were not susceptible to any of the contributors, thus assuring that the effected systems would be able to perform safe shutdown and accident response functions.
(1) The inspector determined from review and discussions that this evaluation had been previously made but had not been documented and retained as required by 10 CFR 21.51.
It is noted that 10 CFR 21.51(c) does allow records developed for the purpose of assuring compliance with 10 CFR 21 to be destroyed if they are not related to evaluations or notifications to the Comission.
However, the evaluation as described in 10 CFR 21.3(g) "means the process accomplished by or for a licensee to determine whether a particular deviation could create a substantial safety hazard" is considered related to Commission notification'and was not documented and retained. This is a violation (461/86052-01)
in that the determination that a common mode failure would not create a substantial safety hazard was not documented. Since the licensee did provide corrective actions promptly during the inspection by documenting the complete evaluation with common mode failure considerations, a written response to this violation is not required.
(2) 'In addition to reviewing the engineering evaluation above, the inspector sampled the following 13 maintenance work requests (MWRs) of the 166 MWRs that tested valve stems and check valve pins for excessive hardness:
835523 Check Valve IB21-F032A B26695 Isolation Valve 1E22-F023 B26691 Test Return Valve 1E22-F010 B35521 Check Valve 1B21-F010A
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B31216 Check Valve 1E21-F050B B31201 Check Valve 1E12-F031A B31202 Check Valve 1E12-F031B B31204 Check Valve 1E12-F041A B31205 Check Valve 1E12-F041B B31248 Check Valve 1G33-F052B B31247 Check Valve 1G33-F052A B31246 Check Valve 1G33-F051 831235 Check Valve 1E51-F066 The inspector found various problems with all of the MWRs.
Procedure No. 1029.01, " Preparation and Routing of Maintenance Work Requests," Section 8.2.19 states that the
" Repair / Technician... (shall) clearly describe all work performed on (the) original MWR in enough detail for machinery hi s to ry....
List all M&TE (measuring and test equipment)
used and attach all QC Accept Tags.
Attach all supporting documentation to the MWR...."
The objectives of these MWRs were to test and document the valve material hardness, to determine if cracking existed by doing dye penetrant testing (PT) or Ultrasonic Testing (UT) on any material with a hardness greater than Rockwell C of 30 (RC 30).
However, the inspector found that 13 of the 13 MWRs violated Procedure No. 1029.01, Sections 8.2.c3 and 8.2.19 as follows:
B26695, B26691, B31247 and B31246 did not contain on the MWR the acceptance criteria of RC 30 for hardness testing.
However, B31247 and B31246 did have the acceptance criteria on the unattached quality control inspection data sheets (QCIPs).
- B26695, B26691, B31216 and 831235 did not list the M&TE (hardness tester and UT devices) on the MWR.
B26695, B26691, B35521, B31201, B31202, B31204, B31205, B31248, B31247, B31246, and 831235 did not contain on the MWR the hardness data to support the conclusion that these valves tested acceptable.
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None of the MWRs contained the QCIPs which constituted the supporting documentation.
The QCIPs contained, in most cases, the actual test data and the M&TE used.
Failure to follow Procedure No. 1029.01 is considered a violation of 10 CFR 50, Appendix B criterion (461/86052-02) in that:
(1) Section 8.2.c3 requires that the MWR package include or reference the procedures and all of the MWRs reviewed did not
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reference the PT or UT procedures to use; (2) Section 8.2.19
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requires that MWRs contain all M&TE used and all supporting documentation.
None of the MWRs reviewed contained the supporting documentation and four MWRs did not list the M&TE used.
(3) The inspector also reviewed Condition Report No. (CR) 1-86-03-086 initiated on April 14, 1986, and completed on May 22, 1986, including corrective actions.
The CR was initiated because of the licensee's review and discovery that MWRs did not record.
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M&TE used as required by' Procedure No. 1029.01. The condition report also noted that the results of the stem hardness testing was not recorded on some of these MWRs.
The licensee's investigation into the condition revealed that two problems contributed to the condition as follows:
(a) Procedure No. 1029.01, Section 8.2.19 requires the repairman / technician to record the M&TE used on the MWR.
Since the M&TE used for stem hardness testing was operated by quality control (QC) personnel and QC personnel are normally inspectors verifying compliance by the repairman / technician, they (QC) did not recognize that Section 8.2.19 applied.
(b) The Procedure QC used to perform the MWR, QAI No. 510.04 required the data to be recorded on the data sheets and not on the MWR which was in violation of the higher tier (overriding) Procedure No. 1029.01.
In addition to this problem with QAI 510.04, the QAI Procedure was cancelled during the task and replaced with QAP 510.04.
The licensee's conclusion was that "considering this information the question of M&TE information being recorded for stem hardness test per the requirement of CPS 1029.01 is indeterminate" and that the QAP now instructs the inspector to ensure the M&TE information is recorded on the work document.
It also provides further instructions that state "the M&TE should be listed on the MWR."
Additionally, the licensee identified 59 MWP.s that did not list M&TE which were corrected on May 2, 1986, and that QC inspectors had been instructed to the requirements of CPS 1029.01.
(4) The inspector disagrees with the licensee's closure of this condition report and finds that the corrective actions and investigation were inadequate and ineffectual as follows:
(a) "The question of M&TE information being recorded for stem hardness test per the requirement of CPS 1029.01 is indeterminate."
L The inspector reviewed 13 out of 166 MWRs and found that four (B26695, B26691, B31216 and B31235) did not record the M&TE used.
These MWRs were completed on March 16, March 27, April 24 and May 8, 1986.
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It should be noted that three of the four were completed after the 'first Condition Report No. (1-86-03-074) was initiated on March 18, 1986, and the first revision of 1-86-03-086 was initiated on March 21,1986.. Condition Report No. 1-86-03-086,=
Revision 0 was addressed in association with i
1-86-03-074 and closed on March 21, 1986 per J. W.
Wilson, Manager-CPS. However, CR-1-86-03-086, Revision 1 (April 14,1986) was issued because of the
" premature closing of Revision 0.
Revision 0 was closed with the intent that the condition would be resolved through the response of CR-1-86-03-074."'
2.
Of the 59 MWRs found to be deficient of M&TE and corrected, five pertained to the stem hardness testing.
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With the four found by the inspector (not corrected by the corrective actions taken by CR-1-86-03-86, Revision 1) and the five found by the licensee (approximately 9% of their sample) the. inspector concluded that the M&TE information required by CPS 1029.01 was not being recorded.
(b) "QAP 510.04 now instructs the (QC) inspector to ensure the M&TE information is recorded on the work document by stating the M&TE should be listed on the MWR."
h It is possibly correct that QAP 510.04 does ensure that M&TE infomation is recorded on the work document. But QAP 510.04 does not require that the
" work document" is the MWR. QAP 510.04, Section B.2 states, in its entirety, "M&TE should be listed on the MWR g Data Sheet by Maintenance Discipline performing the work or the QC inspector." This is not a requirement but merely guidance or advice that does not enforce compliance or is enforceable itself.
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By allowing M&TE to be documented on data sheets the problem of M&TE not being documented on the MWR was not corrected and the supporting data (QCIPs) was not attached as noted by the inspector in Violation No. 461/86052-02 above, "all of the MWRs (13 out of 13) did not contain the QCIPs which constituted the supporting documentation."
(c) "QC inspectors had been instructed to the requirements of CPS 1029.01."
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L The inspector found that 44 QC inspectors had been
trained on " Preparation and performance of inspections QAP 510.04 (Section) B.2" and not CPS 1029.01.
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2.
As identified in 2.a and b above, QAP 510.04 does
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not meet the requirements of CPS 1029.01 and training on QAP 510.04 does not prevent recurrence but assures that the same problem will recur in the future.
3i Since the training was conducted by " required reading" between March 31, 1986, and May 5, 1986, and the inspector identified two deficient MWRs that were completed during this period and one that was
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completed after May 5,1986 (MWR B31216 dated May 8, 1986), this corrective action was ineffectual in
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preventing recurrence.
In general, the inspector found the licensee's actions to identify and resolve this problem to be ineffective because of inability to fully determine the root cause and inattention to the importance or impact of the problem.
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The licensee had determined that a contributing cause was that QC was not aware of their responsibility as repairman / technician to CPS 1029.01 but failed to correct that condition.
In addition, the licensee failed to recognize that QAP 510.04 does not meet the requirements of a higher tier document, CPS 1029.01.
Failure to correct identified conditions and prevent recurrence is a violation (461/86052-03) of 10 CFR 50, Appendix B, Criterion XVI in that measures shall be established to assure that conditions adverse to quality, such as deficiencies and nonconformances are promptly identified and corrected.
In the case of significant conditions adverse to quality, such as traceability of M&TE used to determine the quality of material reported by a 10 CFR 21 Report, the measures shall assure that the cause of the condition is determined and corrective action is taken to preclude repetition.
In addition, since a major contributor was the failure of lower tier procedures to meet the requirements of upper tier procedures, the licensee needs to address the generic question of what other departments, such as engineering, operations and technical staff perform activities by using a lower tier procedure that does not meet the requirements of a higher tier administrative procedure.
b.
(Closed) Open Item (461/85015-01): Verify satisfactory conclusion of test demonstrating adequate Control Rod Drive
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Water (CRD) return flow to the reactor vessel (SER, Paragraph 4.6).
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The licensee had committed t'o demonstrate the CRD return flow in FSAR Question and Response (Q&R) 410.5 (Amendment 7, September 1981).
However, this issue was addressed by the Office
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of Nuclear Reactor Regulation (NRR) based upon the Licensing Review Group (LRG) - II Position Paper for issue 5-ASB, " Control Rod Drive System Vessel Inventory Make-up Rate Test." The LRG-II position stated that for Clinton, the testing per.NUREG-0619 is no longer required. The' licensee has amended the FSAR to
document the LRG-II position and has approval from NRR to not perform the test prior to fuel load.
The inspector reviewed two
letters to NRR, U-600633 dated July 16, 1986, to
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Dr. W. R. Butler, Director BWR Project No. 4, Division of BWR
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Licensing and U-0529 dated September 3, 1982, to Mr. J. M. Novack, Assistant Director for Licensing, Division of Licensing.
Resolution of this issue is being documented in Amendment 39 to the FSAR.
c.
(Closed) Open Item (461/85005-16): Verify initial battery capacity discharge test performed as part of preoperational testing program.
The inspector reviewed the test results from the preoperational tests for all station batteries and verified by independent calculations that all battery capacities were greater than the IEEE requirement of 90 percent. The following
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preoperational tests were reviewed and found satisfactory:
PTP-DC-01, "DC. Power Distribution and Battery Charger 1A"
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PTP-DC-02, "DC Power Distribution-and Battery Charger 1B"
PTP-DC-03, "DC Power Distribution and_ Battery Charger IC"
PTP-DC-04, "DC Power Distribution and Battery Charger 1D"
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PTP-DC-05, "DC Power Distribution and Battery Charger 1E"
PTP-DC-06, "DC Power Distribution and Battery Charger 1F"
d.
(Clo' sed) Unresolved Item (461/86013-04):
Engineering evaluation on Battery (OSS11EA) was inadequate.
The inspector reviewed
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the revised engineering evaluation and fcund it satisfactory in determining the impact of the damaged cell terminal on the battery design functions and the operation of the system.
e.
(Closed) Deviation (461/86013-03): Battery OSS11EA was not tested as required by IEEE standard 450.
The inspector' reviewed the results of
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Acceptance Test No. ATP-DC-07, "DC Power Distribution (OSS11EA),"
i and determined that the requirements of the IEEE standard were met, including the battery capacity discharge test which verified that the
battery capacity was greater than 90 percent.
f.
(Closed) Open Item (461/85005-35):. Verify that Illinois Power performed leakage testing of the secondary containment as part
of the preoperational testing program.
The inspector reviewed the completed test results and data collected by preoperational test PTP-VG-02, " Secondary Containment Leak Test" and verified that the requirements of the FSAR and SER, Section 6.2.2 were met.
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No violations or deviations other than those in Paragraph 2.a were l
identified.
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.o 3.
Preoperational Test Review
The. inspector reviewed and performed independent calculations to determine that the following preoperational test results met the required acceptance and test objectives in accordance with the FSAR and SER.
The licensee's test result evaluations were also reviewed for adequacy and found satisfactory.
PTP-FC/SM-01,~ " Fuel Pool Cooling and Cleanup / Suppression Pool Makeup,"
Partial Tests 1 and 2 PTP-AP-01, " Voltage Study - Data Collection"
PTP-DC-03, "125VDC Subsystem IC (Division 3)," Partial Tests, 1, 2,
3 and 4 PTP-DC-04, "125 VDC Subsystem 1D"
PTP-DC-05, "125 VDC Subsystem 1E"
PTP-DC-06, "125VDC Subsystem 1F
PTP-DG/00-01, " Diesel Generator" Partial Test 2 and STAF 86-53
PTP-HP-01, "High Pressure Core Spray," Partial Test 2 and STAFs 86-08
and 86-26 PTP-LL-01, " Emergency Lighting"
PTP-NB-04, " Containment Isolation," Partial test and STAFS 86-31,
86-32, 86-33, 86-67, 86-68, 86-72, 86-75, 86-76 and 86-98 PTP-VP-01, "Drywell Cooling"
PTP-MS-01, Main Steam System," Partial Tests 1, 2 and 3
PTP-RP-01, " Reactor Protection," Partials 1 through 6
PTP-HG-01, " Containment Combustible Gas Control," Partial
PTP-RC-01, " Rod Control and Information System"
PTP-VG-02, " Secondary Containment Leak Test"
PTP-SX-01, " Shutdown Service Water"
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PTP-NB-02, " Automatic Depressurization System"
PTP-NB-05, " Automatic Depressurization System"
PTP-IP-01, " Instrument Power"
PTP-LE-01, " Plant Loss of Power Test"
No violations or deviations were identified.
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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 Startup Manual and were found to be satisfactory:
PTP-IA/SA-02, " Loss of Instrument Air"
PTP-FP/CO-01, " Fire Suppression System"
PTP-FH-02, " Fuel Handling and Vessel Servicing Equipment"
PTP-VF-01, " Fuel Building HVAC"
PTP-FW-02, "Feedwater Control"~
PTP-AR/PR-01, " Digital Area and Process Radiation Monitoring"
PTP-AP-01, " Voltage Study - Data Collection"
PTP-SV-01, " Safety Relief Valve Monitoring"
PTP-SP-01, " Nuclear System Protection System Self Test and Analog
Test" ATP-DC-07, "125VDC UPS Subsystem"
PTP-FH-01, " Inclined Fuel System"
PTP-VR-01, " Containment Building HVAC/ Purge"
PTP-NR-01, "Startup Range Neutron Monitoring"
PTP-RS-01, " Remote Shutdown System"
PTP-RR-02, " Reactor Recirculation Flow Control"
PTP-RD-02, "ATWs Alternate Rod Insertion"
PTP-VX-01, "Estential Switchgear Heat Removal" f
PTP-RT-01, " Reactor Water Cleanup"
PTP-IP-03, "RPS Solemoid Inverter 8"
ATP-AC/DH-01, " Acid and Caustic Handling"
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ATP-AN-01, " Annunciators"
ATP-AN-02, " Control Room Annunciators"
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ATP-AS-01, " Auxiliary Steam"
ATP-CL-01, " Chlorination"
ATP-CZ-01, " Display Control System"
ATP-DA-01, " Digital Data Acquisition"
ATP-DL-01, " Laundry Equipment and Floor Drains"
ATP-GC-01, " Generator Stator Cooling"
ATP-HC-01, " Turbine Building Crane"
ATP-HC-02, " Turbine Building Crane"
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ATP-HY-01, " Hydrogen"
ATP-MS-01, " Main. Steam (Non-safety)"
ATP-RA-01, " Breathing Air"
ATP-SR-01, " Spectral Analysis, ALARA, and Dosimetry"
ATP-T0/0T-01, " Turbine Oil and Transfer"
ATP-TS-01, " Turbine Supervisory"
ATP-TW-01, " Filtered Water"
ATP-WM-02, " Waste Water Treatment"
ATP-WT-01, " Turbine Building Closed Cooling Water"
PTP-FP/CO-02, "PGCC F 1re Protection"
PTP-FP-CO-03, " Fire Alarms"
PTP-NR-02, " Power Range Neutron Monitoring"
PTP-RD-01, " Control Rod Drives"
PTP-RV-01, " Reactor Intervals Vibration Test"
PTP-SIT-01, " Structural Integrity Test"
PTP-VW-01, "Radwaste Building HVAC"
PTP-FW-01, "Feedwater"
PTP-HC-02, " Fuel Handling Building Crane"
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' PTP-IA/SA-01,." Service and Instrument Air" ATP-CA-01, " Condenser Vacuum Mechanical"
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LATP-CA-02, " Condenser Vacuum Electronic"
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ATP-CP-01, " Condenser Polishing"
ATP-CY/MC-01, " Cycled Condensate"
ATP-DM-01, "Screenhouse and Makeup Pumphouse"
ATP-EH-02, " Steam Bypass"
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ATP-ES-01, " Extraction Steam" ATP-GS-01, " Turbine Gland Seal Steam"
ATP-HD/DV-01,_"Feedwater Heater Drains"
ATP-PS-01, " Process Sampling"
ATP-PS-02, " Process Sampling"
ATP-SF-01, " Suppression Pool Cleanup"
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ATP-VJ-01, " Machine Shop"
.ATP-WM-01, " Makeup Demineralizer"
ATP-WS-01, " Plant Service Water"-
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ATP-WT-02, " Turbine Building Closed Cooling Water"
PTP-AR/PR-01, " Area & Process Radiation Monitoring"
I PTP-AR/PR-02, " Analog Radiation Monitoring"
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PTP-CD/CB-01, " Condensate / Condensate Booster"
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PTP-CW-01, " Circulating Water"
PTP-EM-01, " Environmental Monitoring"
PTP-LM-01, " Loose Parts Monitoring" i
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- PTP-0G-01, "Off Gas Glycol"
P PTP-RD-02, "ATWS Alternate Rod Insertion"
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PTP-RE-01, " Fuel Building Equipment"
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PTP-RR-01, " Reactor Recirculation Flow Control"
.PTP-RR-03, " Flow Control Hydraulic' Power Unit"
PTP-VR-01,'" Containment Building HVAC"
PTP-VT-01, " Turbine Building HVAC"
PTP-VT-02, " Turbine Building HVAC"
No violations or deviations were identified.
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5.
Exit Interview
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The inspector met with licensee representatives (denoted in Paragraph 1) on August 29, 1986.
The inspectors summarized the scope and findings of the
inspection. The. licensee acknowledged the statements made by the i
inspector with respect to the violations denoted in Paragraph 2.a.
The.
inspectors also discussed the likely informational content of the-inspection report with regard to documents or processes reviewed by the inspector during the inspection.
The licensee did not identify any such
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documents or processes as proprietary.
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