IR 05000461/1987013

Insp Rept 50-461/87-13 on 870324-0410.Violations Noted: Failure to Adequately Implement Panel Insp Program

ML20209B657
Person / Time
Site:	Clinton
Issue date:	04/22/1987
From:	Falevits Z, Gardner R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20209B623	List: IR 05000461/1987013 ML20209B620 ML20209B640
References
50-461-87-13, NUDOCS 8704280491
Download: ML20209B657 (10)

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U.S. NUCLEAR REGULATORY C0bHISSION

REGION III

Report No. 50-461/87013(DRS)

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

Illinois Power Company 500 South 27th Street Decatur, IL 62525 Facility Name: Clinton Nuclear Power Station, Unit 1 Inspection At: Clinton Site, Clinton, Illinois

Inspection Conducted: March 24 through April 10, 1987 Z.A.I\\e h,

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Inspector:

Falevits i

Date k.hs W

/!2L 77 Approved By:

R. N. Gardner, Chief Plant Systems Section Date Inspection Summary Inspection on March 24 through April 10, 1987 (Report No. 50-461/87013(DRS))

Areas Inspection: Routine, announced safety inspection of licensee action on previous inspection findings; review and followup of Licensee Event Report (LER); licensee action on 10 CFR 50.55(e) report; licensee reinspection program for safety related panels; load driver card failures; and loss of l

annunciator event.

(92700,92701,92702,99020,41400)

Results: Of the six areas inspected, no violations were identified in five

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areas. One violation was identified during the review of the licensee

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reinspection program for safety related panels (Paragraph 5.b-failure to adequately implement the panel inspection program).

8704280491 070422 PDR ADOCK 05000461

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DETAILS 1.

Persons Contacted Illinois Power Company (IP)

W. C. Gerstner, Executive Vice President D. D. Hall, Vice President J. W. Wilson, Plant Manager N. Connell, Manager, NSED F. A. Spangenberg, Manager, Licensing and Safety R. E. Campbell, Manager, QA E. A. Till, Director, Nuclear Training K. L. Patterson, Director, Nuclear Purchasing J. G. Cook, Assistant Plant Manager J. A. Miller, Assistant Manager, NSED T. J. Comilleri, Acting Manager, SOM D. R. Falkenheim, Supervisor Reliability Engineering K. A. Baker, Supervisor I&E Interface 50YLAND/WIPC0 J. Greenwood, Manager, Power Supply Newman and Hotzinger S. P. Frantz, Attorney U.S. NRC P. Hilend, Senior Resident Inspector All of the above attended the exit meeting on March 26, 1987.

2.

Action on Previous Inspection Findings a.

(Closed) Unresolved Item (461/86071-02(DRS)):

This item concerned icensee inspection activities and corrective action to address problems involving improper installation of heat shrinkable tubing manufactured by Raychem. During a previous inspection, the inspector noted that the inspection checklist used by the QC inspector did not contain specific attributes and all applicable inspection requirements.

i Also, poor workmanship and minimal QC involvement in documenting anomalies on reworked Raychem splices was noted. During this inspection, the inspector selected several MOV's for inspection l

to determine the condition of the Motor leads containing Raychem splices.

(1E21-F011,1E12-F0248,andISX173A) No deficiencies were noted with the Raychem splices; however, several concerns were noted with the routing of the power cables inside the valve compartment. The licensee indicated that these will be reviewed and corrected. This item is considered closed.

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(Closed) Violation (461/86073-01(DRS)): This violation concerned l

instances in which electrical components had been added in the l

safety related panels while the pertinent drawings and design change i

documents did not identify these additions to the panels.

In addition, Superseded FECN's were being posted against drawings.

Licensee corrective action included investigation of the Design Status System (DSS) to identify and correct errors in posting change l

documents.

The licensee also noted that procedural controls now in I

existence for the operational Plant Modification Program minimize the possibility for conflicts between the DSS and actual plant configuration. This item is closed, c.

(Closed) Violation (461/86073-03(DRS)): This violation pertained to numerous design discrepancies and as-built inconsistencies identified in safety related panels. Also, IP failure to establish appropriate measures to assure that design engineers use all design change documents posted against a drawing, and that the design change documents are used during activities relating to changes. Licensee

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corrective action included an extensive review of drawings and additional electrical panel walkdowns conducted to identify discrepancies between the design drawings and as-built field installation. Posting problems have been corrected, and drowings/ hardware inconsistencies have been resolved. Training sessions were given to involve personnel in the use of design drawings and the DSS system.

Procedures have been revised to include requirements for engineers to conduct a more complete technical review of each design change document included in plant modifications. The NRC inspector has conducted additional inspections to closely monitor the licensee's ongoing activities in

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this area.

This item is closed 3.

Licensee Event Report (LER) Review and Followup (Closed) LER No. 86-025-00 (461/86025-LL): Automatic actuation of Shutdown Service Water Pump "B" and other various Divi:.fon Il equipment due to licensee electrical technician error. The licensee determined that the cause of this event was attributed to a utility electrical maintenance l

personnel error while troubleshooting incorrect panel wiring associated with a plant modification.

i Licensee corrective action included the removal of the electrical lead that was found to be landed incorrectly on relay HG515B, and the satisfactory completion of the functional testing required by the Maintenance Work Request (MWR).

In addition, the utility electrical maintenance technicians associated with this event were counseled on the lessons learned from this event and a need to exercise a greater degree of alertness and attention to detail. The inspector recommended that the licensee counsel all electrical maintenance technicians on the lessons learned from this event to prevent recurrence.

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4.

Licensee Action on 10 CFR 50.55(e) Report l

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(Closed) 10 CFR 50.55(e) Item (461/86008-EE):

Improper installation of Raychem Heat Shrink splices in Class IE circuits. On September 2, 1986, IP notified the NRC of a potentially reportable deficiency concerning inproper installation of Raychem splices in Class 1E circuits.

Nonconformance Material Report (NCMR) No. 1-2508 was initiated to document deficient Raychem splices.

The licensee performed a review of safety-related electrical installation travelers to detemine and identi'y those installations located in harsh environments which utilized Raychen heat shrink splices. Of the 578 cables inspected, 252 cables were identified as having Raychem heat shrink tubing. Of the 252 cables, 46 had to be reworked / repaired due to deficiencies with the Raychem splica. The deficiencies identified consisted of improper adhesion and/or heating, incorrect size, and improper seal length. Subsequently, maintenance Work Requests C-15693, C-15698, C-31401 through C-31431, and C-11780 were initiated to inspect and repair / rework the deficient Raychem splices.

The inspector conducted several somple inspections of Raychem splices inside and outside harsh environments. During these inspections, the inspector questioned the acceptability of Raychem heat shrink tubing over the braided wire in the hydrogen ignitor junction boxes. The licensee determined that the contractor failed to provide specific directions to remove the conductor braiding as was required by Raychem.

Subsequently, the licensee concluded that, based on clarification from Raychem and a letter from S&L, the hydrogen ignitor splices were qualified.

During this inspection the inspector further examined the licensee's corrective action program, specifically, several Raychem heat shrink splices on M0V's and found them acceptable. Overall, licensee corrective actions to resolve this issue appear to be adequate.

5.

Review of Licensee Reinspection Program for Safely Related Panels a.

During a previous inspection conducted on November 17, 1986, through January 5,1987, the inspector identified discrepancies on Class 1E electrical panels between the drawings and the as-built electrical panel installation.

In addition, problems existed in the posting and field implementation of design change documents.

As a result of the NRC findings, the licensee performed a sample inspection of 46 Class IE electrical panels not previously reinspected under a 1985 50.55(e) program. Approximately 465 discrepancies were identified during the inspection of the 46 panels.

The licensee evaluated the findings and corrective action was implemented to correct the identified discrepancies, j

During the period of 1982 to 1985, as part of a general overinspection program to provide assurance that adequate QC inspections were

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conducted in the past, IP conducted an overinspection of approximately 50% of the Class 1E panels.

Various as-built I

discrepancies were identified and corrected.

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As a result of the recent findings on the 46 panels, IP determined j

that out of a total population of 230 Class 1E electrical panels f

at Clinton, there were approximately 92 electrical panels which had not been reinspected under any of the previous reinspection r

programs. During a February 11, 1987 meeting between the licensee and Region III staff at Region III, the NRC recommended that the

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licensee reinspect the remaining 92 panels before exceeding 5% power.

On February 23, 1987, the licensee completed the reinspection of

the 92 panels. Evaluations for the identified discrepancies were l

completed March 13, 1987. During these reinspections, 2170 discrepancies were identified. All discrepancies were documented and categorized as follows:

Ca tegory Number of Exception A

B1

B2

C 1669 N/A 464 The following corrective action documents were initiated to resolve the identified discrepancies:

Corrective Action Number Category Document Initiated B1 MWR's

B1 NCMR's

C MWR's 144 C

NCMR's

All B1 MWRs and NCMRs had been completed and closed; while the C MWRs and NCMRs were being scheduled for implementation.

b.

The inspector reviewed the licensee's ongoing re-inspection activities and reviewed the resolution and disposition of selected electrical / instrumentation and control deficiencies identified during the walkdown inspections.

During this inspection period, the inspector reviewed selected verifications and engineering evaluations performed by the licensee and architect / engineer of deficiencies noted during the inspections.

Evaluations associated with panels H13-P601,1R102J,1E22-S301 and 1E22-5004) were reviewed. The review

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l indicated that overall the panel inspection program appeared to be adequate in identifying, evaluating, and Correcting asabuilt discrepanCiesi however, the licensee and architect / engineer had not conducted a comprehensive verification and evaluation review on some of the discrepancies. The inspector informed the licensee that a number of comaleted evaluations had been prematurely dispositioned as "use as is" laccing a thorough and comprehensive engineering review. The licensee indicated that an additional review would be conducted to address the inspector's concerns.

In addition, the inspector made the following

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observations during the review of the panel vcrification and evaluation

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program:

(1) FDDR LH1-3762, Revision 0, Sheet 4, erroneously depicted Reactor Core Isolation System (RCIC) instrument loop schematic termination points TB8 as TB6, TB10 as TB9, and TB10 as TB9.

The architect / engineer. (Sargent and Lundy) incorporated these errors into IP schematic diagram E02-1RI99, Sheet 5, Revision H.

dated October 26, 1986. The termination errors were transferred to the drawings due to an inadequate drawing review process.

During the ongoing verification program, the licensee had identified field installed vendor conductors (associated with loop schematic E02-1RI99, Sheet 5), which were not depicted on the drawing.

Subsequent licensee's engineering review of the impact of the vendor conductors on the system logic failed to identify the noted erroneous termination numbers on the drawing.

At the conclusion of the inspection, the licensee indicated that the schematic drawing would be revised to show the correct

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termination points.

The inspector interviewed the Sargent I

and Lundy senior project engineer and questioned him as to the methodology used to incorporate G.E. FDDR's into IP design drawings, specifically the existing recuirements for an engineering review to assure that all cesign documents conform and depict the intended design. The senior engineer stated that no requirement existed for a design review of drawings which were revised to incorporate G.E. FDDR's; and that G.E. is responsible for the adequacy and correctness of the design depicted on the FDDR's, in addition, the inspector noted that no requirement existed for IP engineers to conduct a design review of the drawings subsequent to the incorporation of G.E.

design change documents such as a FDDR. This item is considered unresolvedpendingfurtherreview(461/87013-01(DRS)).

(2) Review of Verification Walkdown Exception sheets generated by the licensee to document verification findings and evaluation determination indicated that the licensee failed to identify and properly evaluate a number of as-built discrepancies between field installations and design drawing requirements in High Pressure Core Spray 4.16KV switchgear 1C1 (IE22-5004),

cubicles 11, 12, and 13. On March 25, 1987, during the review of licensee completed evaluations associated with HPCS switchgear 101, in conjunction with a visual inspection of the i

switchgear, the inspector identified several errors and omissions. These errors included a jumper installed in 4.16KV

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switchgear bus 101, cubicle 102, electrically connecting terminal points A400 and A410 to A401 and A402 (contrary to design require-monts). Review of HPCS schematic diagram E02-1HP99, Sheet 107, indicated that the jumper was installed between point 4 of fuse FU-12, and point 4 of fuse FU-11.

Further review indicated that FU-12 fed tie HPCS undervoltage detection circuitry associated with " Normal Source, Bus System 1;" while FU-11 fed the HPCS undervoltage detection circuitry associated with " Reserve Source, Bus System 2."

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System design required that an alarm be actuated in the control l

room if either of the above fuses was blown. With the jumper installed as found the alarm would come on only when both fuses were blown, at which time both system 1 and System 2 circuits would not function. Assuming a short in the circuit downstream of FU-11 and FU-12 both fuses, during an undervoltage condition,

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would blow. The Normal and Reserve undervoltage detection circuits would then be incapable of starting the HPCS diesel l

generator within 3 seconds as designed; instead, the second level undervoltage circuitry (relay 6255) would actuate after a 15 second time delay to start the diesel. Subsequent to this

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finding, the licensee stated that FDDR LH1-3016-0 had added

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the noted jumper. The jumper should have been removed per

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FDI-SKRL-0 which was not properly implemented in the field.

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Based on the findings outlined above, the inspector informed

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the licensee that adequate inspection and evaluation requirements apparently were not established and executed to inspect, properly document, evaluate and disposition as-built discreaancies in safety-related panels and switchgears; and l

that t11s was a violation of the requirements of 10 CFR 50, i

Appendir.B,CriterionX(461/87013-02(DRS)).

At the exit interview, the inspector informed the licensee that i

a reinspection of the HPCS panels and switchgears which were depicted on multiple system drawings would be needed; also, a comprehensive review of the work areviously performed by the verifters and evaluators who had seen assigned to perform the inspection and verification on the HPCS switchgear would be needed to resolve the concerns raised by Region III.

In addition, the inspector informed the licensee that all identified A or B1 items would need to be resolved and corrected prior to exceeding (

5% power. The licensee indicated that the reinspection and review would be conducted, c.

During the inspectors review of the licensees verification and evaluation of documents associated with the HPCS system, the inspector noted that the licensee had included in the "C" category

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items regarding hardware deficiencies such as extraneous hard wired grounds and jumpers which were not depicted in the design drawings.

By licensee's definition, category "C" items could have been lef t uncorrected until December 1987. The inspector informed the licensee that a review of all "C" items was required to determine and correct identified field hardware problems such as extra jumpers, grounds, and miswirings. During the licensee's review of the "C" items, 22 additional hardware discrepancies were noted.

The licensee stated that the 22 items would be field corrected prior to exceeding 5% power.

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Load Driver Card failures During the past several months, the Clinton station has experienced several failures in load driver cards which caused the inadvertent dCluation of an SRV and which were identified as the potential root cause of other events.

Load driver cards are logically similar to solid stated relays and their application in the solid state Nuclear System Protection System (NSPS)

circuits is unique to Clinton.

The NSPS is made up of the following systems:

Reactor Protection System, Nuclear Steam Supply Shut of f System, Automatic Depressurization System, High Pressure Core-Spray System, Low Pressure Core Spray system.

Residual Heat Removal System, and Reactor Core Isolation Cooling System. The Clinton Self-Test Systen (STS) is designed to automatically and continuously test and n.onitor the NSPS functional circuitry at Clinton which includes the load driver cards.

On March 24, 1987, dur ing a routine surveillance test of the trip setpoints on SRV No. 41c, the SRV opened inadvertently and cycled 15 times.

Following this event and as a result of the recent load driver related events the licensee requested that G.E. perform an evaluation to determine the root cause of the SRV event and the potential effect of load driver failures on plant safety.

Preliminary results indicated that the locd driver surge transient suppression Zener diodes had shorted out.

G.E.

is currently testing and analyzing the root cause of the diode tallures, in addition, each load driver application (total 364) had been reviewed by G.E. to evaluate the etfect of load driver short circuit and open circuit failures on system operation and plant safety.

G.E. and the licensee concluded that the evaluation results indicated that all potential

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failures were bound by previous Clinton Safety Analysis; that while certain single load driver failures could disable a system, in all cases.

redundant or diverse means of protection were still available and plant safety would not be impacted.

The potential worst case eff ects of load driver failures were identified, analyzed, and sunmarized in letters IP-3070, dated April 9, 1987, and IP-3072, dated April 10, 1987. The

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above G.E. analyses were transmitted to NRR on April 16, 1987, for review and evaluation of licensee compensatory actions to be taken as denoted in the subject analyses.

The licensee is considering possible future design modifications to the load driver circuitry to prevent recurrence.

The inspector will review licensee action in this area during future inspections.

7.

Rev_iew of Loss of Annunciators,Even_t The Clinton annunciator systeu is an audio visual alarm indicator whose purpose is to focus an operators attention on a plant condition which is off normal.

The system consists of enclosed logic cabinets H13-P630, which monitors the h5SS parameters and inputs and H13-P850, which monitors the BOP parameters and logic inputs.

In addition, each cabinet contains a ground ftult detection card which monitors any system ground fault in the 125VOC ungrounded annunciator pcwer supply.

The ground fault detected by the ground fault card would light a monitoring light located on the card.

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On April 5,1987, numerous annunciator windows on ESF panels H13-P601 H13-P680 and the Off-Gas panel failed. Licensee initiated priority Maintenance Work Request (fMR) No. C49710 to investigate the problem and also contacted the annunciator Vendor for assistance.

The licensee detennined that:

(1) Three 125VDC annunciator power supplies in panel H13-P630 had blown fuses; while the forth one was out of service at the time.

(2) The H13-P630 NSSS annunciator panel ground f ault detector card had failed.

(3) The "SRV Trouble" annunciator circuitry contained a ground fault which caused a tie to exist between the power

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supplies and logic of the H13-P850 (B0P) annunciator panel l

and the H13-P630 (N5SS) annunciator panel.

(4) The ground fault detector card in panel H13-P850 had failed.

(5) The reflash card in panel H13-P850 associated with " Turbine Trip, EHC" annunciator had f ailed.

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The one ampere fuses in the 125VDC power supplies had been i

replaced with two ampere fuses in the past to atternpt to l

resolve a probim of inadvertent fuse blowing in thi; panel.

l The inspector reviewed the associated logic and schenatic diagrams, the l

control room operators log, the annunciator vendor manual, and f4WR ho. C49710.

The inspector also interviewed several control room operators and observed the control room annunciators on panels H13-P630 and H13-P850.

In addition, the inspector observed licensee personnel perfonning trouble shooting on the f ailed ground fault detector card to detenaine the root cause.

Licensee corrective action included replacement of the failed ground f ault detector cards in both panels, removal of the electrical tie between panels H13-P630 and H13-PH50, replacement of failed annunciator panel reflash card in panel H13-P650, removal of the two identified system grounds, and increased surveillance and nonitoring of the ground fault detection cards.

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l}nresol ved _ I tem An unresolved item is a matter about which more information is required in order to ascertain whether it is an acceptable item, a deviation, or a l

violation. An unresolved item disclosed during this inspection is discussed

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in Paragraph b.b.

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Exit Interview

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The Region !!! inspector met with licensee representatives (denoted under Paragraph 1) at the conclusion of the inspection on March 26, 1987.

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l addition, a conference call was initiated on April 10, 1987, between the l

NRC and IP to discuss the issues documented in this raport. During the

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exit meeting, the inspector summarized the purpose and findings of the inspection. The licensee acknowledged this information. The inspector

also discussed the likely informational content of the inspection report i

with regard to documents or processes reviewed by the inspector during the

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inspection. The licensee did not identify any such documents / processes as proprieta ry.

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