IR 05000461/1986077

Safety Insp Rept 50-461/86-77 on 861215-870302.No Violations or Deviations Noted.Major Areas Inspected:Previously Identified Insp Findings,Followup on 10CFR50.55(e) Items, Mod Activities & Corrective Action Program Adequacy

ML20205G005
Person / Time
Site:	Clinton
Issue date:	03/25/1987
From:	Hasse R, Phillips M, Wohld P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20205F959	List: IR 05000461/1986077 ML20205F952
References
50-461-86-77, NUDOCS 8703310352
Download: ML20205G005 (11)

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U.S. NUCLEAR REGULATORY C0fHISSION

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REGION III

Report No. 50-461/86077(DRS)

Docket No. 50-461 License No. NPF-55 Licensee:

Illinois Power Company

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500 South 27th Street Decatur, IL 62525 Facility Name: Clinton Nuclear Power Station, Unit 1 Inspection At: Clinton Site, Clinton, Illinois Inspection Conducted: December 15, 1986 through March 2, 1987

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372587 Inspectors:

P. R. Wohld Date b ~M 'Ta 7 R. A. H

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J/AffYf Approved By: Monte P.

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.Date Operational Programs Section

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Inspection Summary No. 50-461/86077(DifSl)_1_5_, 1986 thr_ough_ March _2_,

_198_7 (Rep _o_rt Inspection on December

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Areas Inspected: Routine, announced inspection of previously-identified inspection findings, followup on 10 CFR 50.55(e) items, additional inspection of modification activities, corrective action program adequacy, mixed grease in motor-operated valve limit switch gears, and motor-operated valve control logic.

Results: No violations or deviations were identified.

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DETAILS 1.

Persons Contacted

1. • D. P. Hall, Vice President, Illinois Power

• J. W. Wilson, Manager, Clinton Power Station

1. • K. A. Baker, Supervisor, I&E Interface

1. T. J. Camilleri, Acting Manager, SOM

1. • R. E. Campbell, Manager, QA

1. • W. Connell, Manager, NP&S

1. J. G. Cook, Assistant Plant Manager

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

• J. H. Greene, Manager, NSED

• H. R. Lane, Manager, Scheduling and Outage Maintenance

1. • J. S. Perry, Manager, Nuclear Program Coordinator

1. R. S. Richey, Director, Plant Maintenance

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

1. • E. A. Till, Director, Nuclear Training

• G. T. Warnick, Special Projects, I&E

1. • J. D. Weaver, Director, Licensing

• Denotes those attending the exit meeting held January 15, 1987.

1. Denotes those attending the exit meeting held March 2,1987.

Additional plant technical and administrative personnel were contacted by the inspectors during the course of the inspection.

2.

General Sumnia_ry This inspection report primarily addresses followup actions to maintenance and nodification program findings reported in NRC Inspection Reports No. 50-461/86045(DRS) and No. 50461/86-053(DRS).

Inspection of Illinois Power Company's response to the findings indicates that their actions have been effective in addressing the short-term items; longer-term, program-matic initiatives (presented by the licensee during a September 19 meeting and a December 18, 1986, enforcement conference with Region III) have largely been implemented and appear adequate at this time.

Inspection in the maintenance area indicated that:

Management changes have been made.

Maintenance Work Request documentation is considerably improved.

Corrective actions are more in depth and done with awareness for plant safety requirements.

The proper control of plant lubrication has been put into effect.

A three-man team of troubleshooters has been assigned the task of watchdogging quality in the maintenance department.

Maintenance planning has been reorganized and redirected to better support quality maintenance.

Bolt torquing controls have been put into effect.

Valve packing tightening controls have been put into effect.

All safety-related M0Vs (284) have been reinspected by a four-man team and reworked as necessary.

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Modification program improvements are discussed in the body of this

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report.

3.

Action on Previous _Inspe_c_ tion Findings JClosed) Unresolved Itemj~461/86045-06): Poor mechanical condition a.

oTin~o~ tor-operated' vaTvis. A reinspection of all motor-operated

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valves had been performed per Maintenance Work Request No. C10294.

The licensee reported that all degradations noted that affect valve operability requirements had been corrected. The inspector reviewed the completed MWR package and found the licensee's actions adequate to close this item.

(Preventive maintenance that will address valve conditions in the long-term are addressed by Open Item 461/86045-04.)

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Maintenance procedure improperly

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Violation (461/86053-01a):

[ Closed)'Th'e in~olfif'ication of Limitorque valve operator torque switch b.

limiter plates. The licensee issued a 10 CFR 50.55(e) Deficiency Report 55-86-04 on this item which included the following corrective actions:

(1) the training of all Nuclear Station Engineering Depart-ment (NSED) personnel on controlling equipment modifications; and (2) the revision of CPS Procedure 8451.02 to delete Sections 8.7.3.12.1 through 8.7.3.12.4 and add Section 8.7.3.12.1 to prohibit raising the torque switch above the limiter plate without NSED evaluation and approval. The inspector considers these actions adequate to close this item.

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(Closed) Violation (461/86053-01b): Field Engineering Change Notice i

(FECN) caused the electricaaT~ drawings to incorrectly show the wiring

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assignment for three-phase power to the valve operator motors. Change

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Notices have now been issued against the drawings to correct this l

discrepancy and, when maintenance is performed on the motor control I

centers, phase tape will be used to label the connecting, three-phase wiring. The inspector reviewed these actions and determined that they were adequate to close this item.

(0 pen) Violation ~~1461/86053-01c:

Failure to provide post modification test acceptanc'e cr 'teFiT.~TFe~) inspector determined that the license d.

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had completed corrective actions related to the specific deficiencies identified.

This included a review of modifications completed subse-quent to completion of preoperational testing to assure that adequate testing had been performed and that the n:odification was functioning in accordance with design requirements.

In addition, training had been provided on the development of acceptance criteria. This item will remain open pending further NRC evaluation of the effectiveness of that training.

operated valve stems, fiiTuFeTo~) provide an adequate lubrication (Closed) Viol _ation (4_61/86053-02a : Failure to lubricate motor-e.

procedure, and failure to correct the lubrication procedure when it could not be used. Corrective action by the licensee included:

(1) the recheck of all 284 safety-related M0Vs for stem lubrication

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and the lubrication of all stems, if required (per MWR-10294); (2)

the revision of the motor-operated valve preventive maintenance procedure (CPS No. 8451.01) to include proper stem lubrication instructions for stem threads that do not extend above or below the

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operator housing. The inspector reviewed these actions and determined that they were adequate to close this item.

wire and missing can'duith'o'le W)g in valve motor-operators.

(Closed)Vi_olationJ461/86053-02b:

Failure to identify unqualified f.

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Because of this item and other concerns generated for the overall physical condition of the 284 safety-related valve motor-operators, the licensee performed a complete reinspection of each valve. The reinspection was done by four-man teams which included an electrician, a mechanic, an engineer, and a QC inspector. Valve conditions were identified that affected valve operability. These conditions were

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subsequently corrected, and included the replacement of the unqualified wire and conduit hole plug identified by the inspector.

The inspector reviewed these actions and determined that they were adequate to close this item.

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(Closed) Vio_lation (4_6_1/860_5_3_-0_2c):

Inadequate documentation of bolt

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torquing and material consumption during maintenance activities.

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Corrective action by the licensee included the following:

(1)the licensee had increased the emphasis on the appropriate procedures which involved planning, specification, and documentation of mainten-ance activities such as bolt torquing and material control; (2)

maintenance Procedure CPS 8170.03, " Tightening of Flanged Connections,"

was issued to improve control in this area; and (3) maintenance material control was changed to assure the proper documentation of material used on the job. The inspector reviewed the licensee's actions, including a verification of improvements in Maintenance Work Request package documentation, and considered them adequate to

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close this violation.

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(0 pen) Violation (461/86053-02d): Failure to document bases for concluding that no Tni~eviewed safety questions were generated as a result of plant modifications. The licensee conducted training for engineering and plant staff personnel responsible for preparing 10 CFR 50.59 safety evaluations. The inspector reviewed the lesson plan for this training and determined that the training content was appropriate. The licensee further corrected specific safety evalua-

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tions that were found to be deficient. This item will remain open pending review of the effectiveness of the training provided.

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.( C l os e_d)_ V i_ol a t i on_(_461/_86053-02e ) : Failure to include test documentation in the modification package as required by the plant

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nodification procedure. The inspector detemined that test documen-tation had been provided in the deficient modification packages.

Training had been provided on the requirenents for test documentation to be included in those packages. The inspector reviewed these actions and determined that they were adequate to close this item, testing resulting in ths"fairuFe~)t'o identify 17 valves with improperly (Closed) Violation (461/86053-03a :

Inadequate post maintenance j.

set motor-operator limit switches. The licensee has performed a comprehensive tw!uation of the valve problem history, using a multi discipline task f orce, that resulted in a corrective action program to address all aspects of assuring motor-operated valve quality. The i

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details of this work and corrective actions were reported in Attachment B of a letter to James G. Keppler, dated October 7,1986, " Reportable 10CFR50.55(e) Deficiency 55-86-04: Modification of Limiter Plates on Limitorque Valve Operators." In addition, the licensee had developed a detailed post maintenance test procedure to detect improperly set motor-operated valve limit switches and committed to perform this test

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prior to declaring any motor-operated valve operable under the Plant Technical Specifications. The inspector reviewed the licensee's corrective actions and considers them adequate to close this item.

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JClosed)_ Violation _,(4_6_1/8_6053-03b): Failure to properly control post modification testing activities. The inspector determined that

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training had been provided on test instruction and documentation requirements and that the specific documentation deficiencies identified in nodification packages for HP-06 and SX-15 had been corrected.

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(Closed) Violation (_461/_86_0_53_-04aj : Failure to evaluate the cause of the motor-operated valves not meeting their design thrust

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conditions. There were numerous examples of valve motor-operator

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repair, rework, or n.cdification to correct the failure of valve operators to meet their design thrust requirements, and for which the evaluation of cause appeared inadequate. The problem identified here was part of the overall valve problems identified in the licensee's Deficiency Report 55-86-04. The corrective actions identified in Appendix B of the final report, dated October 7,1986, addressed the problem and are considered adequate to close this item.

(Paragraph 4.a includes additional information on the review of the deficiency report.)

Further, M0 VATS testings was performed

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by the licensee on all safety-related, motor-operated valves to assure that each valve operator could provide the calculated, design thrust requirements.

identifiedlackofcraneoperati_b):

(Closed)_ Violation _(461/86053-0_4 Failure to correct the m.

ng hand signals. Hand signals are now posted, adequately addressing this specific item.

J' Closed)ViolationJ461/86053-04c): Failure to correct inadequate

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standby 1Tq~uTd i~ostriil pump lubrication instructions after they were

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found inadequate.

Proper instructions have been provided in

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maintenance procedures addressing the proper lubrication quantity and type. Further, inspection indicates that the licensee's attention to corrective action is improved.

[Close_d)han,olation J461/86053-04d):

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Failure to correct improper o.

design c ge after 1t resulted in valve motor burnouts and needed corrective action was recognized. Maintenance has been directed to

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add phase tape to the motor power leads at the motor control centers and engineering change notices have been posted against the drawings, correcting the problem.

(See paragraph 3.c above.) Also, the licensee has improved the timeliness requirements for handling deficiency reports and responding to corrective action requirements.

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(Closed) Violation (461/86053-04e):

Inadequate cause and corrective action on a valve motor-operator maintenance activity. This, as for item 3.1, was part of the overall problems identified in the licensee's Deficiency Report 55-86-04. The corrective actions, determined adequate by inspector review, are the same as those for item 3.1 as

further discussed on paragraphs 3.1 and 4.a.

a wobbly valve stem. 7 hi wobb W ) valve stem has been observed, whi (Closed)Violatio_nJ~461/86053-04f:

Inadequate corrective action for

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stroking, by the maintenance supervisor, Nuclear Station Engineering Department personnel, and a valve vendor representative. Their

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collective conclusion is that even though the valve appears to have an eccentricity in the motor-operator stem nut that causes the wobble,

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the valve is fully operable as is.

Further, the valve, 2SX076B, was

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determined to have an infrequent need for use. The licensee's deter-minations of operability were documented in: (1) a September 16, 1986, memorandum to J. W. Wilson from R. D. Freeman, and (2) a November 13,

1986,. memorandum to F. C. Edler from L. K. Hasten. The inspector reviewed the licensee's corrective action and considers it adequate to close this item.

4.

Followup on 10 CFR 50.55(e) Items

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(Closed)10CFR50.5_5]elI_t_emj461/8600_-EEJ:

Inappropriate

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modification of valve motor-operator torque switch limiter plates and other problems with motor-operated valves. The modification of the limiter plates was addressed in Violation 461/86053-01a.

Corrective action was completed and the violation closed in this report.

(See Item 3.b.) The cumulative problems experienced with motor-operated valves, addressed in the same 50.55(e) report, are being addressed by a 20 point program submitted in Attachment B to the licensee's final, October 7, 1986, submittal under 10 CFR 50.55(e)

Deficiency 55-86-04 Items 1, 3, 4, 5, 7, 8, 9, 10, 14, 16, 17, 18, and 20 have been completed and the inspector determined that the licensee's corrective actions were satisfactory.

Item 12, on post maintenance testing, was dccumented as complete but the inspector noted that recon.nendations made, as documented in the licensee's file,

had not been processed for implementation. Other items in the i

attachment that were not yet complete included the following:

Item 2 - Prepare standard valve / operator specifications which reflect

" lessons learned" from MOV deficiencies; Item 6 - Issue specific instructions / standards for M0 VATS adjustments (thrusts, overload, i

backseat, etc.); Item 11 - Provide plan and schedule for creation of MOV maintenance / testing group, under a dedicated supervisor, establishment of M0V " Baseline" Data, and issuance of program procedures; Item 12 - Review criteria; Item 13, Combine appropriate steps from GTP-55 with applicable CPS procedures; Item 15 - Develop

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an MOV qualification / maintenance training program (classroom training and " hands on" lab session), and Item 19 - Revise machinery history program to allow identification of multiple causes of failure. While

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the inspector considered the licensee's program adequate to close this 50.55(e) deficiency, the final completion of Items 2, 6, 11, 12, 13, 15 and 19 will be considered an open item pending completion by Illinois Power and subsequent inspector review (461/86077-01).

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specifications,acceptancecri,ter,1/86010EEJ:

(Closed) 10 CFR 50.55(e)lte,m (4_6 Inadequate testing b.

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~_ ia, and test documentation for modifications. Violations (461/86053-01c), (461/86053-02e), and (461/86053-03b) identified testing deficiencies related to modifica-tions (see paragraph 3). Licensee review of these violations indicated that extensive engineering evaluations would be required to determine the effect of these deficiencies on the assurance of the associated system's ability to perform their required safety functions and that the issue was reportable under the provisions of 10 CFR 50.55(e).

The inspector reviewed licensee actions to correct the identified deficiencies and preclude recurrence. Licensee actions included:

Joint Test Group (JTG) review of all modifications completed since preoperational testing to determine the adequacy of acceptance criteria, test results, and test documentation.

Correction of deficiencies identified by the JTG including retesting when required.

Conduct of training in the areas of acceptance criteria specification, conduct of testing, and documentation of test results.

The inspector was satisfied that the modifications had been adequately tested and no impact on the ability of systems to perform their safety function had resulted from the modifications. On this basis, this 50.55(e)itemisconsideredclosed. The effectiveness of the training provided to preclude recurrence will be tracked via violation i

(461/86053-01c).

(see paragraph 3.d.)

5.

Additional Insp_ection of Modification Activit,ies

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In addition to the followup on previous inspection findings, the inspector also reviewed the Nuclear Station Engineering Division (NSED) procedures relating to modifications and an internal audit of modification activities conducted by the IP QA organization.

The NSED procedures were reviewed against the requirements of ANSI N45.2.11,

" Quality Assurance Requirements for the Design of Nuclear Power Plants,"

1974. The procedures appeared to address the requirements of that standard.

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The inspector reviewed internal Audit Report Q38-86-67, " Quality Assurance Audit of Plant Modifications." Findings resulting from this audit included the following:

l The plant modification program does not fully satisfy the Corporate

Nuclear Procedures.

Tracking and statusing of modifications is ineffective.

No mechanism has been established to readily identify the

modification work in progress on a given system.

Lack of procedural compliance.

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l Lack of design control.

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Poor record quality and completeness.

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The temporary modification program is being used for activities unrelated to the program.

Scme of the findings parallel those of flRC inspections (i.e., lack of procedural compliance and poor record quality and completeness) for which corrective action was in progress. Others were of an administrative nature.

Several new items of potential regulatory concern were identified:

(1)no mechanism for the shift supervisor to track the status of a modification; (2) failure to cancel derivative design documents (purchase orders, drawing change notices, etc.) when a modification is cancelled; and (3) failure to complete impact assessments prior to the initiation of final design.

The inspector reviewed the response to these findings and found them to be generally adequate. Completion of corrective action in response to these findings in considered an unresolved item (461/86077-02).

6.

Cor_rective Action Program Adequacy

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The inspector reviewed the licensee's activities with respect to corrective action under 10 CFR 50, Appendix B, Criterion XVI.

It was apparent from the review of recent plant activities that the licensee had improved in addressing corrective actions. Also, the licensee had been reviewing and improving the program in this area during the inspection period. Deficiency reviews and trending had been improved with an increase in frequency and quality of trend reviews.

Improvements adopted by the licensee included the following:

Policies have been established to require one hour verbal respcnse and five day written response to audit findings.

CPS No. 1016.01 (Condition Reports) has been revised to require one hour notification to a department head level of any condition requiring a Condition Report, and the ingnediate notification of the Shift Super.isor if the condition involves in-plant equipment.

Organizational changes have been made and goals established for the Maintenance Department.

Condition Reports were to be processed by a single group which determines the cause and appropriate corrective action.

Programs have been established to monitor maintenance activities and identify problem areas or potential concerns.

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Condition Reports,flCMR's, and Monitoring Reports are trended to l

detect program and personnel deficiencies.

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l Frequent meetings were to be held with management to discuss problem areas and establish corrective actions.

f The inspector has no further questions on the licensee's correctiv e action program.

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7.

Mixed Grease in the Motor _-Op_e_ rated _ Valve _ _ Limit Switch Gears

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During the inspection, the licensee discovered that Mobile 28 lubricant had been added to the limit switch gears in approximately 40 valve motor-operators which had previously been lubricated with Beacon 325.

The mixing of these two lubricants is considered unacceptable; hence, the gears were flushed and relubricated with Mobile 28 prior to declaring the identified valves operable. The licensee's corrective action in response to this problem was adequate. No violation was issued on the original problem because:

(1) it was detected prior to any apparent problem with valve operability; (2) it was licensee identified, and (3)

corrective action was timely and appeared adequate.

8.

Motor-0pe_ra_ted Valve Control Logic The inspector provided the licensee with some details on concerns for the existing motor-operated valve control logic.

(A copy is attached to this report.) Pending further review by NRC, the subject will be considered an open item (461/86077-03).

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Open Items Open itens are matters which have been discussed with the licensee, which will be reviewed further by the inspector, and which will involve some action on the part of the NRC or licensee or both. Open items are discussed in Paragraphs 4.a and 8.

10. Unresolved Item _s_

Unresolved items are matters about which information is required to ascertain whether they are acceptable items, violations, or deviations.

One unresolved item identified during the inspection is discussed in Paragraph 5.

11. Exit Meetings

The inspector met with the licensee representatives (denoted in Paragraph 1)

on January 15 and March 2,1987, to discuss the scope and findings of the inspection. The licensee acknowledged the statements raade by the inspector with respect to items discussed in the report.

The inspector also discussed the likely informational content of the

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inspection report with regard to docurrents or processes reviewed by the inspector during the inspection. The applicant did not identify

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any such documents / processes as proprietary.

J Attachment: Motor-Operated Valve Control Logic

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Attachement Mo_ tor-0perate_d Valve Control Logic The motor-operated valve control logic adopted by Illinois Power appears unnecessarily complex and has contributed to serious problems in the area of valve setup, maintenance, testing, operation, and surveillance. The design has evolved over time, combining coninon practice in the use of small motor, motor overload relays, and licensee's philosophy for application of Limitorque geared limit switches and torque switches, and NRC concerns suggesting bypassing motor overload relays per Regulatory Guide 1.106. The resulting design failed to consider potential problems in the areas noted above.

The circuit design (also discussed in Inspection Report No. 50-461/86045(DRS),

Paragraph 3.a) incorporates motor overload relays and bypass switches in the main control room which not only bypass the overloads but also change the torque switch bypass logic.

Per Surveillance Procedure CPS No. 9381.01, Revision 20, M0V Thermal Overload Bypass Device Verification, there are 111 bypass switctes for 312 valves involving 380 sets of bypass contacts.

Problems with the existing circuits, either already experienced or perceived, are as follows:

a.

The decision "to bypass" or "not to bypass" involved a con' plex safety evaluation of 624 valve strokes with an attendant possibility for error in this first step.

b.

With bypasses invoked for safety-related strokes only, a maintenance electrician is faced with four possible combinations of overall valve logic instead of one (just for rising stem valves).

c.

The bypass feature requires extra coordination between the control room and maintenance mechanics whenever maintenance, testing, or surveillance is performed.

d.

Post maintenance testing is required in both the TEST and NORMAL positions of the TEST / NORMAL bypass switch.

e.

Normal plant evolutions require stroking valves with the bypass switch in the NORMAL position. Both this and Item d. result in valve stroking with the motor overload relay contacts bypassed, considerably defeating the original purpose of the overload relays, f.

Technical Specifications No. 4.8.4.2.la and b and 4.8.4.2.2 require an 18 month verification of the overload bypasses. As currently written, in Revision 20 of Surveillance Procedure No. 9381.01, this will involve lifting and relanding 380 wires to check continuity through the bypass switch contacts. This activity will cause more problems than it will identify and is still an inconplete verification of valve operability for operation with the TEST / NORMAL switch in the NORMAL position.

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Administrative controls will be necessary throughout plant life to assure that the 111 bypass switches are controlled per Technical Specification operability requirements.

For the above reasons, and because of problems already experienced at Clinton Power Station, the overall programs with respect to assuring the quality and reliability of safety-related valve operation are questionable with respect

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to the basic quality requirements of 10 CFR 50, Appendix B.

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In the opinion of the inspector, the goals of safe and reliable valve operation

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would be best served by hardwiring the valve circuit represented by the NORMAL position of the bypass switch. Conducting all valve programmatic evolutions

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in this configuration could greatly simplify valve setup, maintenance, testing, operating, and surveillance requirements.

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