IR 05000461/1987014
| ML20215A079 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 06/09/1987 |
| From: | Huber M, Phillips M, Wohld P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20215A037 | List: |
| References | |
| 50-461-87-14, NUDOCS 8706160498 | |
| Download: ML20215A079 (16) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Report No. 50-461/87014(DRS)
Docket No.60-461 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 25 through June 1,1987 kk b @' T7 Inspectors:
P. R. Wohld Date 8$~L ggo M.
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Date Approved By:
onte hillips, Chief
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Operational Programs Section Date
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Inspection Summary Inspection on March 25 through June 1, 1987 (Report No. 50-461/87014(DRS))
Areas Inspected: Special safety inspection following up on allegations.
Results: Two violations were identified (Paragraph 2.a.(2) and 2.a.(4)).
8706160498 87 g h g PDR ADOCK 0 PDR G
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DETAILS 1.
Persons Contacted Illinois Power Company and Contract Personnel D. P. Hall, Vice President, Illinois Power D. Anontelli, Acting Director, NTD S. R. Bell, Technical Advisor, ISI T. J. Camilleri, Acting Manager, Scheduling and Outage Management R. E. Campbell, Manager, QA W. Connel, Manager, NSED J. G. Cook, Assistant Plant Manager R. T. Kerestes, Director, Field Engineering NSED J. S. Perry, Manager, Nuclear Program Coordination R. A. Schultz, Director, Planning and Programming F. A. Spangenberg, III, Manager, Licensing and Safety T. Warnick, Consultant, Licensing and Safety
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J. D. Weaver, Director, Licensing The above personnel attended the exit meeting on April 2,1987.
The inspector also contacted and interviewed other staff and contractor personnel during the course of the inspection.
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Followup on Allegations The inspectors performed followup inspection activities relative to three l
allegations pertaining to activities at the Clinton site. Results are as indicated below:
a.
(0 pen) Allegation RIII-87-A-0027 In March 1987, an individual alleged deficiencies with the inservice testing of safety-related valves under Section XI (Subsection IWV)
of the ASME Boiler and Pressure Vessel Code. Specific allegations were emphasized with respect to approximately 30 solenoid-activated containment isolation valves in the process sampling system and containment monitoring system. The identification number for the valves involved were as follows:
Process Sampling System (PS)
1PS004 1PS005 1PS009 IPS010 1PS016 1PS017 IPS022 IPS031 1PS032 1P5034 1PS035 1PS037 1PS038 1PSO43A IP50438 IPSO 44A 1PSO448 IPSO 47 1P5048 1PS056 1PS069 1PS070 Containment Monitoring System (CM)
ICM011 1CM012 1CM022 1CM023 1CM025 1CM026 1CM047 1CM048
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Specific allegations with respect to these valves were that:
(1) Valve stroke times for solenoid operated containment isolation valves did not match FSAR, Preoperational Testing, or Technical Specification values.
(2) Positions for above valves were not properly verified.
(3) Documentation did not exist for many tests for above valves.
(4) Many of the above valves were not tested at all.
(5)
Illinois Power was notified of these problems but did nothing.
NRC Review (1) With respect to Item 1, the stroke times in the FSAR, preoperational testing, and Plant Technical Specifications are not relevant to the licensee's Inservice Testing (IST) at this time because:
(1)Thevalvesactuall required by these documents, and (2) y operate much faster than The NRC and Illinois Power agreed that two seconds will be the maximum stroke time for these valves.
Originally, the licensee had submitted an IST program to the NRC, dated November 15, 1985, with relief requests numbered 32 and 43 (copies attached) which requested that the valves not be stroke timed.
Interim relief was granted to the licensee in July 1986 in Supplement 6 to the Safety Evaluation Report, Pages 3-6, pending detailed review of the program by NRC. That review is complete and the resolution of relief requests 32 and 43 was documented in an NRC letter to Illinois Power, dated February 6,1987. A copy of pertinent information from the attachment to that letter is attached to this report showing the agreement reached for two second maximum stroke times.
This portion of the allegation is substantiated; however, the two second maximum stroke time agreement settled this issue. Therefore, this portion of the allegation is closed.
(2) Allegation Item 2 relates to Paragraph IWV-3300 in Subsection IWV of Section XI of the ASME Code which requires a verification of valve remote position indication. The remote position indication verification for the PS valves had been done in November 1986 using Test Procedure CPS 9061.12, Revision 20, " Process Sampling Valve Position Verification Test." The inspectors reviewed the documentation for these tests and determined that it adequately assured proper remote position indication of the PS valves.
However, while Illinois Power maintained that test documentation was also available for the CM valves, the inspector reviewed the documents provided and concluded that the tests documented were not adequate to assure proper remote position indication.
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At the inspector's request, the licensee verified and documented evidence that the CM valves were actually in the position indicated by the Control Room lights. This documentation (in a memorandum to F. A. Spangenberg from_J. G. Cook; dated April - 15,1987) indicated, based on' temperature conditions for. these fail-closed" solenoid valves, that the " hot"
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condition of the valves properly corresponded to 'their open -.
indication in the Main Control Room and physical condition that the valves were expected to be in. _ The failure to otherwise substantiate the remote position indication of the valves.
- earlier, by appropriate means, is a violation of Technical Specification 4.0.5, which requires that the provisions of the ASME Code,Section XI, be met unless relief is requested'
and granted (461/87014-01). Based on the'above, this portion
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of the allegation is partially substantiated;-however as _of the date of this report, all of the alleged valves have.had their positions and associated indications properly verified, therefore, this portion of the allegation is closed.
During the review of CPS Procedure 9061.12, Revision 20,.the inspectors noted that.it was necessary to revise the surveil-lance in order to match the existing plant configuration. On November 17, 1986, operations had submitted a. Temporary Procedure Deviation (TPD) 9061.12, utilizing CPS No. 1005.08 F001, " CPS Temporary Change Form" Sequence No.1547, in order to complete'
the surveillance. However, the form was not used to make a permanent revision at that time. The TPD had received preliminary approval prior to the surveillance, but was subsequently disapproved by the Plant Manager following review by an Independent Tech Review and the Department Head. However an interview by the inspectors with the individual involved-in writing.the procedure determined that the procedure had been written to a P&ID that did not match the existing plant configuration. A comment control form CPS No. 1005.01 F002 has also been submitted on December 1, 1986, to be incorporated with Procedure Deviation for Revision (PDR) CPS 1005.07 F001 Sequence No. 1615 dated November 30, 1986, noting the changes necessary to match-up the surveillance procedure with the existing plant configuration. The coments were noted and will be incorporated into the next procedure pending further review and the revision of CPS No. 9061.12. The revision process for this procedure is an unresolved item pending a determination that the revision is properly completed in a timely manner (461/87014-02).
(3) Allegation Item 3, " documentation did not exist for many tests of the above valves," was partially substantiated as noted above.
The inspectors reviewed the documentation associated with Test Procedure CPS 9061.12 and found that it was adequate and
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complied with code requirements for the PS valves. However, documentation for the CM valve tests was not adequate in that
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-remote position indication verification could not b'e supported
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by the documentation. This is discussed in Item _2_above. Other test documentation required by Technical Specifications for-
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' stroke verif.ication had been. reviewed for the alleged valves and found to support' testing _within the required surveillance interval. Also, position verification documentation for the.
CM valves was forwarded.to the NRC.on April 15, 1987, and found to be acceptable. While the' lack of documentation substantiated this allegation, all. required documentation was made available (through.' additional testing) and was found to be adequate.
This portion.of-the allegation is closed.
(4)'- Allegation Item 4, that many of the. valves listed above were not tested at all, could not be substantiated. The inspectors noted,'however, that. Illinois Power had inappropriately interpreted relief requests 32 and 34 to imply that no valve
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stroking was required.
It was their intent not to stroke the -
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solenoids quarterly, as required by ASME Section XI. The Inservice Inspection Program Manual, CPS No. 1887.00, dated May 31, 1986, directed that the CM and PS system solenoid valves only be stroked for post maintenance testing. Contrary to -this procedure, however, a procedure writer, who was apparently aware of the need to stroke the valves, included quarterly stroking of all the solenoids in an implementing procedure, CPS 9061.03. Document inspection indicated that-stroking of the_PS System valves had been done on September 24, 1986, and December 11, 1986; the CM System valves had been stroked on September 11, 1986, and December 12, 1986. Based on these tests,- this portion of the allegation was not substantiated.
On March 18, 1987, Temporary Change 87-0544 was issued against the test procedure to delete stroking the valves (in agreement with the program procedure, CPS 1887.00). The inspector
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informed the licensee that this was unacceptable. The licensee indicated _that the change would be deleted and stroking would continue on a quarterly schedule.
'Four problems were evident from this evolution:
(1) the program procedure, CPS 1887.00, violated Section XI requirements by not specifying quarterly valve stroking; (2) the implementing test procedure, CPS 9061.03, violated the requirements of the program procedure (which could have been written to prevent valve stroking e
for equipment protection reasons, etc.); (3) the discrepancy
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between the two procedures was apparently known, but not properly
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corrected; and (4) the quarterly stroking was recently removed from CPS 9061.03 instead of being added to CPS 1887.00 after at least some of the licensee's staff knew, through the NRC review
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process, that stroking and stroke timing would be required.
These four items constitute a failure to have procedures appropriate to the circumstances which is a violation of i:
Criterion V in Appendix B of 10 CFR Part 50(461/87014-03).
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problems identified and that they "did nothing." As a result of interviews with a number of licensee personnel, it is the
~ judgement of the inspector that the licensee's staff was. aware of the alleger's concerns and did address most of them, albeit indirectly, through.the-normal activities in this area onsite and through interactions with NRC and the NRC review and approval process of their Inservice Testing Program submittals.
In the case of the testing of the solenoid valves, poor technical judgements were made initially in developing and interpreting relief requests'32 and 43; and, the. test deficiencies'in this area should have been addressed in a more timely marner, i Therefore, this portion of the allegation (that
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the licensee "did nothing") could not be substantiated in that
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programmatic reviews of the IST program submittals were and are
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ongoing and the valve testing program was encompassed in this review process.
Conclusions As a result of reviewing the allegations made, interviews with members of the. licensee's staff, and a review of problems already identified by NRC.with the IST program, the initial program written
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in 1985 by the Illinois Power staff had a significant number of l-technical deficiencies. While the NRC review was-in progress and
.the resolution of these deficiencies were' being resolved, procedure
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writers were writing implementing. test procedures to the original program which was deficient. The Illinois Power staff should have i
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- responsive to problems identified by the procedure writers, but written a better quality program originally and could have been more chose instead to let the NRC review process continue and to change
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the procedures later, as necessary.
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.Because the results.of the NRC's review of _ the licensee's IST program indicated that there were several areas where the original submittal was deficient and needed to be modified (see letter dated February 6, 1987, from W. R. Butler, NRR Division of BWR Licensing-to
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Frank A. Spangenberg, Illinois Power Manager of Licensing and Safety),
.the general sense of the allegation made with respect to IST program
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deficiencies was substantiated. Violations are noted above for specific problems identified. To fully address the problem, the licensee has formalized task assignments to further review the o
history and evaluate and correct any remaining problems with the handling and implementation of IST program. This should be completed
by July 1, 1987. This allegation will remain open pending the F
completion of the licensee's review and completion of activities
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b.
(Closed) Allocation RIII-86-A-0111 r
This allegation was in five parts as follows:
(1) radiological work
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requirements were not observed during fuel receipt; (2) employees
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were not wearing dosimetry and security badges; (3) Illinois Power l
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I may have inaccurately told NRC Region III the' facts concerning t
labor / management situation at Clinton; (4) system cleanliness was not always adhered to; and (5) employment discrimination occurred
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when -the alleger was terminated. Allegation Items (1) and (2)
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_ were previously reviewed and documented in NRC Inspection Report
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No. 50-461/86050..
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(1)~ Allegation Items (3) and'(5) dealing with the labor / management
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situation and employment discrimination at Clinton were reviewed
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to determine if any NRC requirements had been violated. The alleger had stated that when,IP management had-told NRC.
management that IP was taking disciplinary action against
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maintenance workers and supervisors who were not complying with program requirements, IP failed to tell NRC that'all letters of reprimand issued to union technicians had subsequently been rescinded due to grievances. The NRC does not regulate how a
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utility enforces personnel practice requirements.. The only applicable regulation,10 CFR 50.7, deals with employee
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discrimination when the employee is engaged in certain protected activi ties. The inspector called the alleger for additional information; however, he did not want to discuss the matter further. The inspector also called the U.S. Department of Labor in Springfield, ' Illinois, as the U.S Department of.
Labor is charged with investigation or employment discrimination issues raised under 10 CFR 50.7 (Employee Protection) the
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inspector determined that no employment discrimination complaint had been filed by the alleger. Hence, these parts of
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the allegation could not be substantiated.
It should be noted that there were management problems in the area of-maintenance which were identified by the NRC.in Inspection Report-
No. 50-461/86053.
In the absence of any new information l
from this part of the allegation, it.is considered closed..
i (2) Allegation Item (4) dealt with system cleanliness. The allegation indicated that there were instances where workers had failed to maintain cleanliness control. The inspectors
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interviewed several' individuals on the licensee's staff and i
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determined that there had been instances of fluid system cleanliness problems in the past; however, they further stated that these problems had already been documented and fully
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addressed. There was no indication of any other problems
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in this area.
In a phone call to the alleger on March 8,
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1987, he refused to provide any further information. Subsequent
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to the time the allegation was-made, the licensee completed hot
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operational testing. One of the objectives of this testing is to assure the adequate overall cleanliness of the systems prior
to fuel loading. Although there had been problems with system
cleanliness in the past, the hot functional testing assured that all systems were adequately clean prior to fuel loading.
Hence, there is no further safety concern with this part of the allegation and it is considered closed.
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The closure of allegation Parts 3, 4, and 5 above completes the closure of this allegation. -
c.
(Closed) Allegation RIII-80-A-0156'
This allegation was in three parts as follows:
(1)procedureon cranes was prepared by unqualified persons; (2) maintenance department supervision directed maintenance personnel to ~perfom work without a-procedure; and (3) inadequate instructions'were. given for' replacement of the polar crane cable.- This allegation was forwarded to Illinois Power 3r resolution by letter dated.0ctober 27, 1986, from Mr. C. E. Norclius, Director, Division of Reactor Projects, NRC-Region III.
Illinois Power submitted the results of their investigation of this allegation to NRC Region III in a letter from Mr. D. P. Hall dated December II,1986. The inspectors reviewed.the licensee's evaluation as follows:
(1) Allegation Item (1) indicated that the procedure on cranes was prepared by. unqualified persons. The allegation indicated that the procedure in question was CP3 No. 8106.03, Revision 2, " Crane Inspection, Maintenance, and Testing '(Including Special Lifts)."
This procedure had been prepared by personnel within the Maintenance Department responsible for assuring that the procedure contained all necessary direction, was technically correct, and conformed with QA requirements. The procedure was subsequently reviewed by the. Mechanical Maintenance Supervisor, Maintenance Director, NSED, QA, and the Facility Review Group before being approved by the Station Manager. The procedure was also reviewed by the licensee's QA organization which determined that the procedure was adequately prepared to fulfill its intended use. The inspector also reviewed this procedure in conjunction with the -licensee's program for handling heavy loads. The inspector determined that the licensee's procedures were in confomance with NUREG-0612, Control of
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Heavy Loads at Nuclear Power Plants." The inspector determined that there were no specific regulatory requirements regarding-the qualifications of personnel assigned as procedure preparers; and that the procedure writer did not appear to be unqualified based on the adequacy of the procedure. Therefore, this portion of the allegation could not be substantiated.
(2) Allegation Item (2) dealt with maintenance supervision directing personnel to perform work without a procedure. The licensee's evaluation determined that this allegation was partially substantiated. Recent examples were found with personnel performing maintenance activities in the area of work controls, some of which dealt with Maintenance Work Request (MWR) job stepping. The inspectors' review of the licensee's investigation of this allegation indicated that deficiencies identified with MWR job stepping and the use of Maintenance Standing Orders had been appropriately entered in the licensee's corrective action program.
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This portion of this allegation is' identical'to those areas-Lexamined in a previous NRC inspection _(NRC Inspection Report No. 50-461/86053) during the time frame addressed in this allegation. The findings of that inspection cover the same areas addressed by this allegation,' and the resultant violations identified in that inspection also. corroborate and substantiate this allegation.
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Corrective actions had been initiated by the licensee:and'
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subsequently' inspected by the NRC (see NRC-Inspection Report:
No. 50-461/86077). The findings-of that inspection indicated
'that the licensee's corrective actions were adequate.
(3) fA11egation Item (3) dealt with inadequate instructions given for replacement of_the polar crane cable.
This item was addressed and' substantiated by a discussion of this issue in>
NPC Inspection Report No. 50-461/86054.
Corrective action is also addressed in the report and noted as satisfactory; hence,.
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this' item is closed.
3.
Unresolved Items Unresolved items are matters about which information is required to ascertain.whether they are acceptable items, violations,-or deviations.
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-On-unresolved item identified during the inspection is discussed in Paragraph 2.a.(2).
4.
Exit Meetinas-The inspectors met with the licensee representatives (denoted in Paragraph 1) on April 2, 1987, to discuss the scope and. findings of the inspection. The inspector also discussed the results of the review of-valve test documentation and the findings regarding the crane allegation in a telephone discussion on June 1, 1987.
The licensee acknowledged the-statements made by the inspectors with respect to items discussed in the i
report.
The inspectors also discussed the likely informational content of the
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i inspection report with regard to documents or processes reviewed by the
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inspectors during the inspection. The applicant did not identify any -
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such documents /prosesses as proprietary.
Attachments:
As stated
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RELIEF REQUEST d32
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Component Identification:
Containment Monitoring Containment Isolation Valves A.
Name:
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B.
Number:
See Table 32-1 Isolate the containment monitoring system from the C.
Function:
containment
ASME Section III Code Class:
D.
B ASME Section XI Valve Category:
E.
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Relief from:
IWV-3410 Valve Exercising and str6ke A.-
ASME Code Requirement:
time' test
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These valves perform only a containment B.
Reason for Relief:
isolation function and do not serve as a reactor coolant The speed at'which these air operated valves close boundary.
does not influence the mitigation of an accident.
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NONE (Valve 64 position will C.
Alternate In-Service Test:
be verified during the normal performance of conta'inment isolation surveillance requirements.)
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e-91-LJE51
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TABLE 32-1
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Size Valve ICMDb1 3/4 1CM012 3/4.
'1CM014 1/2 1CM015 1/2 1CM016 1/2 1CM017 1/2 1CM018 1/2 1CM022.
3/4 1CM023 3/4 1CM025 3/4 1CM026 3/4 1CM028 1/2
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ICM031 1/2
1CM032 1/2 1CM033 1/2.
1CM034-1/2
1CM047 3/4 i
1CM048 3/4
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o RELIEF REQUEST 043 I.-
Component Identification:
A..
Name:
Process Sampling Containment Isolation Valves
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Number:
See Table 43-1 C.
Function: Isolate the process sampling system from the containment.
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ASME Section III Code Class:
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ASME Section'XI Valve Category:
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Relief from:
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ASME Code Requirement: IWV-3410 Valve Exercising'and Stroke
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Time Test j
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Reason for Relief: These valves perform only a containment isolation function and do not serve as a reactor coolant boundary.
The speed at which these air operated solenoid valves close does not influence the mitigation of an accident.
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Alternate In-Service Test:
NONE (Valve position will be verified during the norcal performance of containment isolation surveillance requirements.)
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Valve Number Size
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1PS004 3/4-1PS005 3/4
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1PS009 3/4 IPS010 3/4 IPS016 1/2 1PS017 1/2 1PS022 1/2 IPS023
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1PS032 3/4 1PS034 3/4 1PS035 3/4 1PS037 3/4 1PS038 3/4 IPSO 43A 3/4
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IPSO 43B 3/4 IPSO 44A 3/4 IPSO 44B 3/4 1PSO47 3/4
1PSO48 3/4 IPS055 1/2 IPS056 1/2
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1PS069 1/2 1PS070 1/2 t,
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Containment Monitortne System 1.
How are excess flow check valves ICM002A, 0028, 003A, and 0038 tested and at what frequency are they tested?
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Excess flow check valves ICM002A, 003A, and 0038 are exercised Response:
quarterly using an air flow test to verify that they will close to restrict excessive flow. Valve 1CM0028 will be ' tested during refueling outages because this valve is 8 feet below normal suppression pool level and testing would require a diver to enter the suppression pool or lowering the pool level 8 feet, either of which cannot be performed quarterly during power operations and is not practical to accomplish during cold shutdowns (Refer to relief request 637).
Are the' valves listed in relief request 032 passive valves as defined 2.
in IWV-21007 If so, they should be identified as such in the IST Program.s.,If, not ',they.should be exercised and have their. stroke times
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measured in accordance with the Code.
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The purpose of measuring valve stroke times in the IST program is to detect valve degradation to allow for repairs of degraded valves prior to their failure, and not for any functional or accident mitigation
reasons as indicated in relief request 032.
Solenoid operated valves are not exempted from the stroke time
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measurement requirements of Section XI; their stroke times must be measured and corrective action taken if these times exceed the
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. 11miting value of full-stroke time. The NRC staf f will grant relief
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fron the trending requlremenis of Se,ct10n.NI M *#'
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[ Paragraph IWV-3410 (c)(3)) for these rapid acting valves, fio, wever t c.. e..,
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order to obtain this relief the licensee must assign a maximum
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limiting stroke time of 2 seconds to these valves.
A request f or reitef f rom the stroke time trending requirements Response:
for rapid acting solenoid valves which have a ilmiting value of full-stroke time of 2 seconds or less will be submitted (Relief request 058). The stroke times of these rapid acting valves will be measured, but need not be trended.
If the 2 second limiting stroke time is exceeded, the degraded valve must be Relief declared inoperable and corrective action taken.
request 032 will be deleted from the IST program.
Provide a more detailed technical justification for not exercising 3.
valves ICM066 and 067 quarterly or du, ring cold shutdowns. Also, provide the P&ID that shows valve 1CM067 for the staff's review.
Valves The reitef request for ICM066 and 067 will be deleted.
Response:
1CM066 and 067 will be exercised quarterly, or a cold shutdown justification will be provided and the valves tested during
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cold shutdowns. The P&I0 was provided.
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Process Samplina System
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Provide a more detailed technical justification for not measuring stroke times for the solenoid operated valves in this system (refer to relief request 034 and coment f.2).
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Response:
These solenoid operated valves will be identified as rapid
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acting valves with a limiting value of full-stroke time of j
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-- "2 seconds. These' valves w111 b51M1oded la rel,1ef requ,est 958j$h.
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and will be tested in accordance with the NRC staff's position for rapid acting valves.
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15 any credit taken for the operation of this system?
If so, review the saf ety function of the f ollowing valves to determine if they should be included in the IST program.
IPSO 4)
IPS013 1PS029 IPSOSO 1PS019 IPSO 46A
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1PS006 1PS0?$
IPSO 468 Response:
The process sampling system is not required to perform a safety related function other than containment isolation.
These valves are not containment isolation valves and, therefore, they need not be included in the IST program.