IR 05000461/1987027

Insp Rept 50-461/87-27 on 870810-880429.No Violations or Deviations Noted.Major Areas Inspected:Followup on Allegation RIII-87-A-027 & Licensee Followup Actions to Violations & Unresolved Item Noted in Previous Insps

ML20154S504
Person / Time
Site:	Clinton
Issue date:	05/27/1988
From:	Danielson D, Huber M, James Smith NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20154S502	List: IR 05000461/1987027 ML20154S500
References
50-461-87-27, NUDOCS 8806090080
Download: ML20154S504 (8)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-461/87027(DRS)

Docket No. 50-461 License No. NPF-62 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 Conducte : August 10, 1987, through April 29, 1988 lb(Mc / T/ l2G/ l#

Inspectors: . Huber l Oate (3.h.' Smith dY 5/z6/ff

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i gYlv Approved By: D. H. Danielson, Chief 6!d7/80 Materials and Processes Date Section Inspection Summary Inspection on August 10, 1987, thrcugh April 29, 1988 (Report No. 50-461/87027(DRS))

Areas Inspected: Special safety inspection to follow-up on allegation RIII-87-A-0027 (99014) and of the licensee's follow-up actions to the violations (92702) and unresolved item (92701) identified in Inspection Report No. 50-461/87014(DRS).

Results: Of the areas inspected, no violations or deviations were identifie '

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l 8806090080 e80527 PDR ADOCK 05000461 I

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i DETAILS

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/W Persons Contacted IllinoidPowerCompaty(IP) ,,

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+0, P. HSil, Vice/ President x+R. E. Campbell, Manager, Quality Assurance .

xJ. W. Wilson, Pl o t Manager

+F. A. Spangenberg, III, Manager, Licensing and Safety

'+J. F. Palchak, Supervisor, Plant Support Services

+W. Connell, Manager, Nuclear Planning and Support x+J. Miller, Manager, Scheduling and Outage x+J. G. Cook, Assistant Plant Manager xJ. D. Weaver, Licensing Director xR. T. Kerester, Director Nuclear Station Engineering Department x+S. R. Bell, Technical Advisor, Inservice Inspection ,

, xR. E. Wyatt, Director, Nuclear Training ,

xR. D. Freeman, Manager Nuclear Stat 4en Engineering Department

1. W. E. DeMark, Station Quality Assurince Specialist

+J. Brownell, Licensing Specialist C. Mathews, Operations Engineer

- T. Donovan,-Compliance Specialist W.. cliff, Lead Operations and Technical Support

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

1. G. Baker, Supervisor, Quality Systems P

Soyland/WIPC0 ,

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xJ. Greenwood, Manager, Power Supply s The inspector also contacted and interviewed other licensee personnel i during the inspectio /

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+ Denotes those personnel attending the preliminary exit intervin

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on August 14, 1987.

1. Denotes those personnel attending the exit interview on October 5, 1987.

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xDenotes those personnel attending the exit interview on April 29, 1988.

l Action on Previot._s _ Inspection Findings i (Closed) Violation (461/87014-01): During the initial investigation i of allegation RIII-87-A-0027, it was identified that the remote system l

1 solation valves ICM011, 1CM012, 1CM022, ICM033, ICH025, ICM026, ICM047, I and ICM048 had not been properly verified prior to April 15, 198 During this inspection, the NRC inspector verified that Surve Olance '

Procedure 9061.03 had been revised on April 10,' 1987, to include a t position indication verification test at thd required two. year frequency and a quarterly valve stroke timing test. The NRC inspector

. Abo verified that that,e tests had been sbtisfactorily performed on '

the subject valves on Jude.26, 198 ,. t ,

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i (ClosedP 0nresolved Item (461/87014-02): During the initial inv',stigation of allegation RIII-87-A-0027, it was identified t.jtanoutdateddrawinghacbeenusedtoprepareSurveillance PrpcMure 9061.12, thus making the procedure unworkable. Condition Repc7t 1-86-12-104, Revision 1, dated August 12, 1987, was prepared

I to document the fact that the required changes had not been incorporated into Procedure 9061.12. During this inspection, the NiC inspector reviewed the procedure changes and found them to be acceptable. The revised proceddre was in effect on September 14, 198 ' - (Closed) Violation (461/87014-03)

During the initial investigauon I of allegation RIII-87-A-0027, it was identified that procedures wert inappropriate due to not specifying quarterly valve stroking for the Process Sampling and Containment Monitoring solenoid containment 1'

isolation valve During this inspection, the NRC inspector reviewed ace %re changes and verified that Surveillance Procedure 9061.03

.ad aen revised on April 10, 1987, to include quarterly stroke time testin '

3. Follow-up on Allegations j Q pen) Allegation RIII-87-A-0027 B_ackground in March 1987, an individual identified potential deficiencies with the inservice testing (IST) of safety-related valves and the lack of containment integrity due to non-testing of certain valves to 10 CFR Part 50, Appendix J requirement In response to these allegations, an inspection (NRC Inspection Report No. 50-461/87014) was conducted on March 25 thru June 1, 1937, to determine to what extent the allegations could be substantiate Portions of the allegations were substantiated and some activities '

were found to be in violation of requirements. The resolution of these violations are addressed in paragraph 2 of this report .

The purpose of this inspection was to evaluate the licensee's ru iew and response to the alleger's concerns. During the course of this inspection a follow-up interview of the alleger was conducted and subsequently resulted in additional concerns being identified. Two '

of the four additional concerns are addressed in this inspection ,i l report. The two remaining concerns have been referred to NRR for evaluatio J

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During this ind yction, 'indings of the licensee's investiga;i \ and the corrective actions planned or taken were reviewed for acceptability l and completenes: 4

,' A major portion of the licensee's investigatd n *

l (April 2-23, 1987) was conducted by an investigator and a technical

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consultant. -During personnel interviews, the investigator recovered

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29 memoranda that were prepared by the allege The 29 memorandc were prepared between May 5 and August 27, 1986, and made recommendations,

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provided/ requested information, or identified perceived deficiencies with the IST progra During this inspection, the NRC inspectors reviewed the investigation

, reports prepared by the professional investigator and the consultan These reports contained summaries of personnel interviews, copies of

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, t the referenced memoranda, and actions taken to resolve the alleger's

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perceived deficiencies in the IST program. The NRC inspectors also reviewed the engineering response to the alleger's concerns contained a

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in the referenced memoranda. The NRC inspectors found the engineer's response to the alleger's concerns to be adequat '

Following the release of NRC Inspection Report No. 50-461/87014 the alleger was interviewed by the NRC to clarify the allegations and obtain additional and more detailed informatio ,-j During this interview, the following additional allegations

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were identified:

(1) When valve stroke times were changed, the review conducted to determine if the change was acceptable was not thorough enough l

, in that system requirements, radiological, environmental et considerations were not include #

(2)' Testable check valves in the ECCS were not successfully tested in that full stroke was not properly verified and the verification of their remote position indications was not adequat (3) Certain pressure isolation check valves inside the drywell are I

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not being considered containment isolation valves and appropriately

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tested as required by 10 CFR Part 50, Appendix J.

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(4) Certain valves were not included in the IST program that should have been.

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/ With respect to item (1) above these stroke times were changed prior to licensing of the plant and were not required to have a 50.59 review

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conducted to change the stroke times. However an analysis should have

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been conducted to determine the overall impact due to valve stroke time changes regarding system, radiological, and environmental considerations and determine the effect of the changes on system reliability and safet The NRC inspectors reviewed documentation provided to determine the

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thouroughness of the licensee's review of the stroke time changes with regard to system, radiological, and environmental considerations.

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In one instance, General Electrie (GE) responded to the licensee's concern about valve closure times by a letter (L. S. Burns to K. K. Berry, dated April 29,1986) which listed the valves of concern and the technical specification closure times for the valves at that time. The letter recommended that the list be reviewed to see if any of these valves required more than the sp cified time to operate. The NCC inspector compared the stroke times for valves on this list with those on two other lists. The first was a listing of 150% or 200%

(depending on valves size) of actual valve stroke time for each valv The second list showed the limiting value of stroke time for each valve. The NRC inspector found 22 valves which required more time than that shown in the above G.E. Letter and which would necessitate changes to the Technical Specification in effect at that tim In each case, the Technical Specification was confirmed to be modified to accommodate.the maximum required time for closure. All valves on the list now operate within the stroke times established for them in the current Technical Specificatio ,

The specific valves identified by the alleger during the interview were those valves included in Document Transmittal Form (DTF)

No. JK-1183 dated August 4, 1986 (See Attachment 1). IP requested GE to perform the necessary analysis to evaluate the changing of stroke times. GE performed their review and responded to IP with the revised times, noting that considerations regarding radiological, environmental, etc. should be evaluated by others. GE approved the stroke time changes based on verification that safety and reliability were not adversely affecte The justification for disposition was also provided by GE in Field Deviation Disposition Requests (FDDR)

LW1-5746, 5747, 5748, 5749, 5750, 5751, and 576 Once IP received the revised stroke times from GE, it was necessary to review the revised times for radiological etc. considerations, as previously stated. IP initiated Action /Information Request (A/IR)

. No. 646 to Sargeant and Lundy (S&L) to request that the review be

! performe The analysis was completed by S&L September 26, 1986, l and it was concluded that "the increased stroki.19 times will not have an impact on the environmental . . . and radiological concerns."

Therefore, all necessary reviews of the effect of stroke time changes on safety and reliaoility of the system, and radiological and i

environmental considerations had been performed.

!' With respect to item (2) above the NRC inspectors reviewed surveillance procedures to determine the adequacy of the tests performed on ECCS check valves in accordance with the requirements of ASME Code '

Section XI, St5section IWV1, Paragraphs IWV-3300 and IWV-3520 and found them acceptabl !

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IWV-3300 requires that "valves with remote position indicators shall be observed once every 2 years to verify that valve operation is accurately indicated." The NRC inspectors reviewed Surveillance Test Procedure CPS No. 9053.05 "RHR Valve Operability Check (Shutdown),"

Revisiori 20 and associated surveillance reports for the valves on the dates shown below:

VALVE SYSTEM DATE OF TEST 1E12F041A RHR May 9, 1986 1E12F0418 RHR August 10, 1986 1E12F041C RHR August 24, 1986 Also reviewed were Maintenance Work Requests (MWR) No. C-2184 dated May 9, 1986, and No. C-22654 dated September 8, 1986. The MWR's were written to explore and correct problems encountered during the test Difficulty was experienced in achieving full lift of the disk with the actuator and consequently in achieving a confirming position signal for valve IE12F041A. The position indication test was subsequently successfully performed with the actuator spring removed. The licensee is currently planning to remove the actuators from the check valves and perform future stroke testing of these valves manually. The NRC inspectors also reviewed STP CPS No. 9051.02 "High Pressure Coolant System (HPCS) Valve Operability Test," Revision 20 dated August 18, 1986, for valve 1E22F005, SAP-5 "HPCS Preoperational test" dated June 25, 1986, for valve 1E22F005 and STP CPS No. 9052.02 "Low Pressure Core Spray valve Operability Test" for valve 1E21F006 and determined that adequate testing was done to meet the requirements of paragraph IWV-3300 of the ASME Code Section XI for the above mentioned valve Concern was also expressed that the testable check valve, 1E51F066, in the RCIC system was not tested as required. The licensee indicated that the light indication for the valve was not derived from the valve itself but the actuator, and therefore, the true position would not

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always be indicated by the lights. Subsequently, it was determined that position indication testing was not required for this valve, Paragraph IWV-3520 of ASME Code Sect!nn XI requires, in part, that l "check valves shall be exercised tc tne position required to fulfill

, their function . . by proving that the disk moves promptly away

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from the seat when . . flow through the valve is initiated." The I confirmation of the disk moving from the seat shall be accomplished by some positive means, such as control room valve position lights or indications of flow through the syste The NRC inspectors reviewed preoperational test results for the RHR, HPCS, RCIC and LPCS systems and determined that the check valve disk i movement was verified for the above mentioned valves and met the requirements of the ASME Code.

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. Allegation items 3 and 4 are under review by NRC Headquarters to determine the necessary course of action required to address and correct the possible deficiencies, Conclusion The allegations identified in NRC Inspection Report No. 50-461/87014 were substantiated. Items (1) and (2) identified during the interview with the alleger could not be substantiated in that proper evaluations had been performed with regard to stroke time changes and the ECCS check valves had been verified for proper stroke and remote position indicatio The licensee has been responsive and has addressed the previously identified items promptly, and no new concerns were found during this inspection; however, this allegation will remain open pending the completion of the NRC Headquarters review and of the licensee's action in response to the activities in this are . Exit Interview The Region III inspectors met with the licensee representatives (denoted in Paragraph 1) on August 14, 1987, October 5, 1987, and at the conclusion of the inspection on April 29, 1988. The inspectors summarized the scope and findings of the inspection and that closure of this allegation would be pending NRC Headquarters review and action and a phone exit would be conducte The inspector also discussed the likely informational content of the inspection repor The licersee acknowledged this information and identified the investigator's report as proprietary. The inspector stated that he wculd reference but not quote from this report while preparing the inspection repor This was found satisfactory by the license .. ..

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• ATTACHMENT 1 ACTUAL ISI

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PRESENT

- DESIGN SPE T1HE T1HE TIME (SEC.)_ (SEC) (SEC)

VALVE N *

100 74.94 112 IB21-F065A 72.72 109 IB21-F0655 100 120 93.00 340 1E21-F096A 92.00 338 IB23-F0955 120 120 93.00 - 140 IE21-F095C 95.36 143 1521-F095D 120 30 21.09 32 1C-F0E3 94.55 142 1E12-F004A 100 100 95.70 344 1E12-F0045 75.70 124 . IE22-F006A 60 SO 76.64 135 3E22-F0065 34.51 51-1E12-F00E 39' 30 35.79 53 1E12-F009 78.00 117 1E32-F014A 90 90 77.00 126 IE32-F024E 75.73 333 1E12-F024A 90 77.50 137 IE12-F0243 90 77.60 116 IE12-F026A 90 75.20 313 IE12-F02SB 90 23.34 30 3E12-F042A

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25 29.E3 30 - 1E12 -F04 2 5 29.E2 30

l(' . 1E12-F042C IE12 -F04 7 A -

90 76.41 77.75

         })5 317
  .~1E12-F0475     7E.00 317 1E12-F06SA   90      -

75.00 117 IE32-F06SE 90 91.30 137 1E12-F105 100 wv eme.. . ~ 91.00 137 c-100 29 39.26 9.hthij. ?.. lE21-F001 lE21-F005 25 60 '73.02 310

' 2r e." 1E22-F001
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11.27 17 l;?" 1E51 -F013 15 16.6L 25

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20 . 27.07 41

 ...... '. '1E51-F063      27.09  41
'- de ,  -1E51-F064   33    74 60  49.00
i'b]. .I[ lE51-F065
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38 13.41 20 '

.. 1G33-F001     13.06  20 3G33-F004   18 35.52  2*

IG33-F02E 16 24.89 22

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1G33-F034 IE 23

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IS 13.64 l 1G33-F039 33.43 20 l 1G33-F040 1E 13.76 21 1G33-F053 18 13.30 20 IG33-F054 18 7.44 13 1E51-C002E 10 ,

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