IR 05000461/1986059

Safety Insp Rept 50-461/86-59 on 860902-05 & 08-12.No Violations,Deviations or Safety Issues Noted.Major Areas Inspected:Tmi Action Plan Requirements & IE Info Notice Followup

ML20210L627
Person / Time
Site:	Clinton
Issue date:	09/25/1986
From:	Knop R, Scheibelhut C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20210L607	List: IR 05000461/1986059 ML20210L602
References
TASK-2.F.1, TASK-TM 50-461-86-59, IEIN-83-83, NUDOCS 8610020155
Download: ML20210L627 (11)

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U. S. NUCLEAR REGULATORY COMMISSION

REGION III

p i Report.No. 50-461/86059(DRP)

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

Licensee: Illinois Power Company 500 South 27th Street Decatur, IL 62525 l

Facility Name: Clinton Power Station

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Inspection At: Clinton Site, Clinton, IL

. Inspection Condo ed: S pterr er 2-5 and 8-12,1986 Inspector: C. H. Schei e hut

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'Date Approved By: R. C. Knop, Chief 25Y8d Reactor Projects Section 1B Date i

Inspection Summary Inspection on September 2-5 and 8 :2, 1986 (Report No. 50-461/86059 (DRP))

i Areas Inspected: Routine safety inspection by a Regional Inspector of l applicant actions on previous inspection findings, evaluation of applicant j action with regard to Three Mile Island Action Plan Requirements, IE

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Information Notice followup, and independent inspection of a Condition Report.

Results

Of the four areas inspected, no violations, deviations, or safety significant issues were identified.

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861002015S 860726 PDR ADOCK 00000461

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DETAILS Personnel Contacted

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4 Illinois Power Company (IP)

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, " G. Cook, Assistant Plant Manager

"E. J. Corrigan, Director, Quality Engineering and Verification

#J. A. Fertic, Director, Systems and Audits

1. R. D. Freeman, Assistant Plant Manager, Maintenance

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"J. H. Greene, Manager, Nuclear Station Engineering

"D. P. Hall, Vice President, Nuclear

"H. K. Lane, Manager, Scheduling and Outage

" S. Perry, Manager, Nuclear Program Coordination

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

. "J. D. Weaver, Director, Licensing

" C. Wemlinger, Supervisor, Operations Training

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1. Denotes those attending the exit meeting.

i The inspector also contacted others of the tpplicant's staf . Applicant Actions on Previously Identified Items (92701)

(Closed).0 pen Item (461/85004-03): " Complete installation, 1 development of procedures, and training on the use of the j postaccident noble gas effluent monitoring systems per NUREG-0737 j Item II.F.1, attachment 1 commitments." In Inspection Reports

, 461/86031 and 86050, the inspector considered the item closed except for calibration of the instruments. The applicant has now completed the calibration using solid radiation standards. Surveillance CPS No. 9910.73, " Calibration of Station HVAC Exhaust PRM," was ,

completed for the HVAC Exhaust Stack Monitors (ORIX-PR001 and

-PR002) and surveillance CPS No. 9910.74, " Calibration of SGTS l Exhaust PRM," was completed for the Standby Gas Treatment System

(SGTS) Exhaust Monitors (ORIX-PR003 and -PR004).

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The inspector reviewed the noble gas monitor calibration sections of

the two procedures and concluded that the monitors were successfully I calibrated using solid (Tc-99) sources. The validation of this

calibration using gaseous standards (Kr-85 and Xe-133) has been deferred 'to the 5% power milestone and is oeing tracked by open item 461/86024-01. Therefore this item is close i (Closed) Open Item (461/85005-26): " Verify inplace testing of air

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filter and adsorption units in gaseous 'radwaste systems as an

! initial acceptance test (SER11.3.1)." Section 11.3.1 of the Safety Evaluation Report (SER) for the Clinton Power Station (NUREG-0853)

j required verification of inplace testing of the HVAC filters and i activated carbon adsorption units. The testing of the SGTS filters

and adsorption units, the Laboratory Air System filters, and the i Respirator Air System filters was accomplished with partial test

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releases Nos. 1, 2, 3, and 7 for preoperational test XTP-00-12.

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The inspector reviewed the approved test results for the partial test releases and concluded that the filters and adsorption units were successfully tested. Supplement 6 to the SER defers testing of the Drywell Purge units and Off Gas units to beyond fuel load. This testing is being tracked as open item 461/86054-14. Therefore, this item is close c. (0 pen) Open Item (461/85015-07): " Confirm.necessary revisions to EPGs made, E0Ps upgraded, and operators trained before fuel load (SSER4-13.6.3.1)." Paragraph 13.6.3.1 of Supplement 4 to the SER required verification that revisions were made to the CPS emergency procedure guidelines (EPGs), that emergency off-normal procedures (EOPs) were upgraded, and that the operators were trained prior to fuel loa In Inspection Report 50-461/85053, the inspector determined that the requirements were fulfilled with the exception of the combustible gas control EPG and E0 The Hydrogen Control Owner's Group (HCOG) developed a generic Mark III EPG. Pending completion of the NRC staff's review and approval of the EPG, the CPS E0P cannot be written and implemente Consistent with the applicant's commitments to Confirmatory Licensing Issue #41, Licensing Condition #5, two interim operati instructions have been prepared as follows:

CPS No. 3316.01, " Containment Combustible Gas Control," provides instructions for the operation of the hydrogen ignitors (glow plugs)

and hydrogen recombiners. CPS No. 4111.01, " Combustible Gas Mitigation," provides interim guidance on when to initiate the Hydrogen Ignitor System (HIS) and hydrogen recombiner equipmen \

The inspector reviewed CPS Nos. 3316.01 and 4111.01 and found that they contained the pertinent material. Training records for the procedures were reviewed and the review showed that the operators had completed training on the latest revisions of the procedure A Record of Coordination, 1-202309 dated May 19, 1986, between the applicant and the NRC Licensing Project Manager on the subject of CPS Hydrogen Control Procedures was reviewed. The review showed that the implementation of the two procedures was consistent with the applicant's previous commitments and no other open commitments existe While this item remains open until an inspection confirms that the EPGs and E0Ps include procedures addressing hydrogen management, it is no longer considered a restraint to obtaining a fuel load licens d. (0 pen) Open Item (461/85039-23): The public address system which includes the site-wide warning system must be completely installed and operational prior to fuel loa in Inspection Report 50-461/86048, the inspector found that while the PA system (Gaitronics system) had been successfully preoperationally tested, a plant tour showed that a number of the telephone units were inoperable. Subsequently, operations personnel performed a system-3-i

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walkdown. Maintenance Work Request (MWR) C-21339 was generated to repair the inoperable equipment identified during the walkdown. A total of 241 Gaitronics telephone units-are installed. Under

!' MWR C-21339, 149 units were reworked. Subsequent to the closure of the MWR,.the plant technical department performed a walkdown of the

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entire system and found.24 units that could not page the main control room on channel one. Separate MWRs were written on each unit to correct the deficiency. In addition, the inspector indicated that the Gaitronics system alarms could not be heard in several normally manned areas (e.g. inside the NRC building and startup trailer). The technical department performed an evaluation

of alarm audibility. Two other areas were found where the alarm level was-not satisfactory. Minor modification CQ-15 was issued to

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install-additional speakers to correct the problem.

i To provide a regular verification of the Gaitronics paging function, 2 the applicant prepared procedure CPS No. 2107.01, "Gaitronics l Verification." This procedure requires testing of all accessible handset units within a six month perio !

j The inspector selected twenty Gaitronics handsets located throughout

the plant at random and tested them for their ability to. contact the-

main control room. All worked satisfactorily except for two. Both i of these units had deficiency tags indicating that the units Ucre inoperable and the MWR number under which they were being tracke During the regularly scheduled Friday morning test of the Gaitronics alarm function, three NRC inspectors joined' the operations staff in monitoring the effectiveness of the alarm system at points throughout the plant. While the alarms were heard, audibility and intelligibility of the accompanying voice announcements were unsatisfactory in almost all area It was also noted that these problems did not exist during normal paging use of the syste i- Therefore, this item remains open until a future inspection shows that audibility and intelligibility problems of voice announcemerts

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accompanying alarms have been solve (Closed) Open Item (461/86011-03): " Licensee to repair silica monitors on feedwater line." During a plant tour, the inspector

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found that the in-line silica analyzers in sample panel IPL88JA that monitor the feedwater were not functioning and had to be repaire Because of the operational problems with the in-line silica

analyzers, the applicant decided to use grab samples for silica

determination and not use the in-line analyzer Plant modification

{ PS-16 was implemented to disconnect the two analyzers (1AIT-PS024 j and 1AIT-PS025) and blank off their drain line connections at the L return drain header. The Final Safety Analysis Report (FSAR) Figure

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9.3-4 was changed to reflect the change. Section 9.3.2 of the FSAR j states that in-line analyzers or grab samples will be utilized to

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determine silica concentrations in water sample The inspector visited the sample panel and found that the drain line l connections at the analyzers were plugged. Facilities for taking i grab samples of the feedwater were also found. The inspector l

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reviewed chemistry procedure CPS No. 6001.01, " Sampling and Analysis Requirements," and found that a weekly grab sample for silica was required. The inspector reviewed Figure 9.3-4 of the ESAR and found that the in-line analyzers were no longer shown. The inspector reviewed section 9.3.2 of the FSAR and found that in-line analyzers or grab samples will be utilized to determine silica concentrations in water samples. This item is close f. (Closed) Open Item (461/86016-01): " Review surveillance procedure discrepancies between technical specification requirements." During a review, an inspector compared surveillance procedures with the applicable Technical Specifications sections and found the following discrepancies: No procedure was found for the Channel Check called out in Table 4.3.3.1-1 and Section 4.3.3.1. The procedure had not been written at the time of the inspection, but a procedure number (CPS 9000.01) had been assigne . The trip setpoint and allowable value given in Table 3.3.3-2, Items A.1.d and B.1.d, could conflict. The allowable value was given as 5 2 0.5 sec and the trip setpoint was given as >5 se . The LPCS pump flow, called out in Section 4.5.1.b.1 of the Technical Specifications is required to be at least 5010 gpm with a pump differential pressure greater than or equal to 276 psid. The values stated in released Surveillance Procedure 9052.01, Revision 20, and the Data Sheet 9052.01D001, Revision 20, did not agree with the Technical Specifications. The inspector reviewed Revision 21, not released at the time of the inspection, to both the procedure and the data sheet, which corrected this proble . The inspector was unable to find any reference to disposition of the procedure data in 12 out of 13 procedures reviewe It was determined that disposition is covered by administrative procedure CPS 1011.02, " Implementation and Control of Surveillance Testing". The data sheets for Surveillance Procedures CPS 9052.02 and 9433.37 (9052.02D001 and 9433.37D001) did not include tolerances or inequalities on the allowable or acceptance value . Two surveillance procedures in the electrical system (CPS 9000.02, Revision 20, and 9031.01) included in the Technical Specification Track 1rg document, were not available for review. The inspector was informed that CPS 9031.01 had not been written, and would not show up on the Operating Manual Status Report (OMSR) until it was in the review cycle. CPS 9000.02, Revision 20, was in revision and not available for review, although Revision 1 was reviewed.

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The applicant revised the various procedures to remove the discrepancies with the Technical Specification The inspector reviewed the various procedures with the following results: CPS No. 9000.01, " control Room Surveillance Log", revision 20, was issued 7/7/86. The Channel Checks required in Table 4.3.3.1-1 and Section 4.3.3.1 were included in the procedur . This item was closed in Inspection Report 50-461/8601 CPS No. 9052.01, " Low Pressure Core Spray Operability Checks",.

revision 21, was issued 3/18/86. It includes CPS No. 9052.01,

"LPCS System Pump Operability Data Sheet". The flow rate and pump differential pressure values agreed with the Technical Specification . CPS No.1011.02, " Implementation and Control of Surveillance Testing", revision 6 effective 8/8/86. Disposition of surveillance data was covered by.the procedur . CPS No. 9052.02, " Low Pressur e Core Spray (LPCS) Valve Operability Checks", revision 21 issued 7/3/86 including CPS No. 9052.02D001, "LPCS Valve Operability Data Sheet". The stroke time acceptance criteria was indicated as a maximum time. CPS No. 9433.37, "ECCS LPCS Minimum Flow E21-N051 Channel Calibration", revision 22 issued 4/28/86 including CPS No. 9433.37D001, "ECCS LPCS Minimum Flow E21-N051 Channel Calibration Data Sheet". Tolerances were added to the allowable trip limit . CPS No. 9000.02, " Unit Attendant Surveillance Log", revision 20 issued 7/7/86 including CPS No. 9000.020001, " Unit Attendant Surveillance Log Data Sheet". This procedure required performance of Technical Specifications surveillances required by the following sections: 4.6.3.4, 4. 9. 9, 4.1.5.a .1, 4.1.5.a.2, 4.1.5.a.3, Figure 3.1.5-1, 4.1.3.3.a, 4.7.2.a, and 4.8.3.1. CPS No. 9031.01, "RPS Solenoid Dus Power Monitor Channel Functional", revision 20 issued 4/19/86. The procedure satisfied the surveillance requirements of Sections 4.8.4. and 4.8.3.1.3 of the Technical Specifications.

The inspector also determined through review of the station procedure approval forms (CPS No. 1005.01F006, attached to all

revisions) that training was not required for any of the procedures

prior to implementation. This item is close g. (Closed) Violacion (461/86017-03)

A temporary procedure change (procedure deviation for revision or PDR) No.86-094 was issued

against CPS No. 1029.01, revision 7, " Preparation and Routing of Maintenance Work Requests, in siolation of CPS No. 1005.07, i " Temporary Changes to Station Procedures". The violation resulted l

in CPS No. 1029.01 being inadequate to control the documentation of

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nonconforming conditions on a MWR within the requirements of 'the

IPQA progra In Inspection Report 50-461/86048, the inspector determined that all

, of the corrective actions required to close the item were completed

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except for one. The remaining item required all CPS personnel authorized to sign a PDR to read the notice of violation (NOV).

l The applicant obtained a listing of all personnel authorized to sign a PDR, required them to read the NOV, and required them to sign and date a required reading route sheet indicating that they had read

the NO The inspector reviewed the listing of personnel authorized to sign 4 PDRs and the signed required reading route sheets. The review indicated that all personnel authorized to sign a PDR had read the NOV. This item is closed, l

f (Closed) Unresolved Item (461/86017-04F): After a detailed review of Administrative Procedure CPS No. 1029.01, " Preparation and

Routing of Maintenance Work Requests", revision 8, the inspector had eight concerns about the adequacy of the procedure and the review

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and approval process that led to revision In Inspection Report

! 50-461/86049,'the inspector concluded that concerns A, B, C, D, E,

! G, and H were satisfactorily resolved. The remaining concern, F,

! concerned paragraph 8.12.5.1 of CPS No. 1501.02, " Conduct of 1 Maintenance", revision 4. This paragraph used the terms " guidance",

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"should", and "may" for the preparation of approved procedure This appeared 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

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demonstrate compliance with the applicable requirements of ANSI N18.7-1976.

The applicant revised CPS No. 1501.02 to be consistent with

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paragraph 5.3.5(4) of ANSI N18.7-1976. Paragraph 8.t2.5.1 was revised to state that corrective maintenance procedures "shall" be i written if certain listed criteria are met. Also, a note was added to the paragraph that stated when appropriate sections of supporting i documents such as vendor manuals are referenced in MWRs to j accomplish safety related' work in accordance with the referenced l document, then the referenced document shall have the same level of review and approval as a safety related procedure. To assure

, conformance to this requirement, the applicant reviewed all safety l related maintenance procedures to determine if any contained

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such procedures were identified. The use of these procedures was

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suspended until the referenced supporting documents received the l same reviews and approval as safety related procedures. When this

! was accomplished, the use of the procedures was reinstated.

i The inspector reviewed CPS No. 1501.02 revision 5 and found that it i

met the pertinent requirements of ANSI N18.7-1976. The inspector j also reviewed training records and found that the appropriate

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personnel had received training on revision 5. The inspector visited the cocument control center and found that the following vendor manuals have received the same level of reviews and approval as safety related procedures:

• 645E4 "Turbocharged Engine Maintenance Manual - 3rd Edition",

May 1976. (Maintenance portion only.)

• Section VI, Maintenance and Repair Instructions of E-Systems, Montek Division, Snubbers and Accessories Manual. (Section VI only.)

• Dikkers Instruction Manual G471-6/12 (Maintenance portions only.)

• GEK-63100 Hydraulic Control Unit part No. 767E 800G1-G3 (Sections IV and V only.)

• Harnischfeger (P&H) Instruction Manua (Sections V, VI, VII, and VIII only.)

This item is close . (0 pen) Open Item (461/86024-01): Validate calibration of noble gas effluent monitors using gaseous (Kr-85 and Xe-133) sources. The applicant has taken no action on this item. However, the noble gas effluent monitors have been calibrated using solid sources (see paragraph 2.a. above). In accordance with Record of Coordination Y-202432 dated 6/5/86 between the applicant and NRC RIII personnel this item was to be reclassified as a 5% power item when the monitors were successfully calibrated with solid sources. This item will be the subject of a future inspectio (Closed)'Open Item (461/86040-01): " Licensee to resolve water spillage problem around feedwater sample panel". During a plant tour, the inspector noticed standing water around the Feedwater Sample Panel (1PL88JA). During operation, this water could be radioactively contaminate The applicant issued MWR C21918 and Field Problem Report (FER)

200614 to investigate and solve the problem. The water ponding was caused by unevenness in the finished floor slab. A cnannel was cut in the floor to create a path from the panel to the nearest floor drain. The source of leakage was the in-line silica analyzer When the condenser was not under vacuum, a head differential caused water in the drain lines from the analyzers to back-flow and spill on the floor. The on-line silica analyzers were disconnected and the drain lines plugged (see paragraph 2.e above).

Since none of the work involved safety related equipment, the records were not reviewed. The inspector determined by direct observation that the area around the sample panel was clean and dry and that the panel was in operation. This item is close *

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No violations or deviations were identifie . 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 NUREG-0737, " Clarification of TMI Action Plan Requirements".

(0 pen) Item II .F.1, " Accident Monitoring Instrumentation".

Subitem Install noble gas monitors. As indicated in paragraph above, the work on this has been completed. Therefore this subitem is close Subitem Install containment high range monitors. While these monitors have been installed, they have not been calibrated. The calibration is considered a constraint on initial criticality, not on fuel loa No violations or deviations were identifie . IE Information Notice Followup (92701)

IE Information Notice No. 83-83, "Use of Portable Radio Transmitters Inside Nuclear Power Plants". The information notice delineated several reported instances in which portable radio transmitters caused system malfunctions and spurious actuations in nuclear power plant It also noted that solid state devices installed in the plants have been responsible for all the known cases of radio frequency interference (RFI)

generated by portable radio transmitters. Since the Clinton Plant is considered an all " solid state" plant, it may be vulnerable to RFI problem The applicant wrote Condition Report (CR) 1-84-01-011 to investigate the problem and recommend corrective actions. The following corrective actions were taken:

• Preoperational Test Procedure (PIP)-CO-01 (Site Communications)

required the testing of hand held radios from all areas normally accessible to personnel. Radio " dead spots" were determine Observance of RFI effects on equipment was required to be reported. No effects were observed. However this testing was inconclusive because the status of possibly affected equipment was not known at the time of the individual test * RFI considerations were included in the Post Trip Review procedur * Cautionary notes warning of possible RFI effects from hand held radios have been included in maintenance procedure '.,

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Subsequent to the CR, the Nuclear Station Engineering Department (NSED)

reinvestigated the problem and transmitted the results to the Plant Manager (Memo Y-79870 dated March 11, 1986, D. C. Shelton to J. Wilson). The memo offered the following recommendations:

• Administrative controls should be the primary means of- controlling RF * Signs should be posted in RFI sensitive areas of the plant to alert personnel that radio usage is prohibite . Operation, Security, and Emergency Planning procedures should be revised to identify RFI concerns and list areas where radio usage is prohibite * Training should be given to employees on RFI and areas where radio usage is prohibite While the Information Notice ir.dicated that certain switchgear relays were susceptible to RFI, the inspector observed that the applicant had not addressed that aspect in the CR or NSED memo. It was suggested that this be don The inspector's review of the applicant's response to the Notice showed that timely and adequate actions were take No violations or deviations were identifie . Independent Inspection of a Conditicn Report (92701)

During an NRC review of Facility Review Group (FRG) meeting minutes, documented in Inspection Report 50-461/86054, a question was raised concerning the disposition of Condition Report (CR)-1-86-07-009. Further inspection of the question revealed the following informatio .An MWR was written that included the requirement to core drill through a reinforced concrete wall. While performing the core drilling operation in accordance with job steps in the MWR, the worker cut through a piece of reinforcing steel (rebar). As a result, CR-1-86-07-009 was written to disposition the occurrence. The CR was closed and approved by the FRG based on the following:

• A nonconforming material report (MCMR) analysis showed that the structural integrity of the wall was unaffecte * The worker was chastised for not drilling in the spot designate * The applicant is develcping concrete expansion anchor work and core drilling procedure * Pending procedure approval, the subcontractor (Stone and Webster)

will use MWR Job steps consistent with the draft procedure .

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'o The basis for closure of the CR raised a number of concerns about the validity of the closur * The use of job steps in an MWR is not considered an adequate

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substitute for approved procedures since the level of review is differen * Since a procedure for setting concrete expansion anchors and core drilling was indicated as being in preparation, what was used for this type of work prior to the occurrence?

• If MWR Job steps were used, can the work be considered adequate for safety related structures?

The inspector discussed these concerns with the applicant and requested an FRG review of the closure of the CR. The review was pending at the close of the inspectio These concerns are considered to be an unresolved item (461/86059-01) and will be the subject of a future inspectio No violations or deviations were identified. One unresolved item was identified abov . Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, items of noncompliance, or deviations. One unresolved item disclosed during this inspection is discussed in paragraph . Exit Meeting The inspector met with the resident inspector and applicant representatives (denoted in paragraph 1) at the conclusion of the inspection on September 12, 1986. The resident inspector sunnarized 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 natur