IR 05000461/1989016

Safety Insp Rept 50-461/89-16 on 890227-0303 & 890316-17.No Violations Noted.Major Areas Inspected:Followup on Allegation RIII-87-A-0027,involving Containment Integrity & Inservice Testing Program

ML20245D731
Person / Time
Site:	Clinton
Issue date:	06/14/1989
From:	Cooper R, Huber M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20245D727	List: IR 05000461/1989016 ML20245D722
References
50-461-89-16, NUDOCS 8906270215
Download: ML20245D731 (9)

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U.S. NUCLEAR REGULATORY C0fMISSION

REGION III

Report No. 50-461/89016(DRS)

Docket No. 50-461 License No. NPF-62 Licensee: Illinois Power Company 500 South 27th Street Decatur, IL 62525 Facility Name: Clinton Power Station, Unit i

Inspection At: Clinton Site, Clinton, IL 61727 Inspection Conducted: February 27 through March 3 and March 16-17, 1989 Inspectors:

kW M. P. Huber Fu- ( [/ N T Dat'e /

R W C pi Approved By: . f[/y/#

Engineering Branch Date /

Inspection Summary Inspection on February 27 through March 3 and March 16-17, 1989 (Report No. 50-461/89016(DRS))

Areas Inspected: Special safety inspection to follow up on Allegation Rill-87-A-0027 (99014). Areas involved containment integrity, the inservice testing (IST) program, and the extent to which licensee management understood the alleger's concerns to be programmatic safety issues prior to fuel loa Results: No violations or deviations were identified. The inspector noted the following:

The IST staff is currently knowledgeable and conscientious in their wor Actions taken to resolve NRC questions concerning earlier IST program revisions were weak and slow; however, improvements have been made and j are continuin l

Since the time the allegation was received by Illinois Power Company senior management, attention to resolving the issues was goo PDR ADOCK 05000461 O )

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DETAILS-

- 1. - Persons Contacted Illinois Power Company (IP)

• W. Gerstner, Executive Vice President W. Connell, Vice President F. Spangenberg, Manager,. Licensing and Safety

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

R.-Freeman, Manager, Nuclear Station Engineering Department-

• S.oBell, Supervisor,' Inservice Inspection

• J. Brownell, Project Specialist Licensing

, R. Morgenstern Director, Plant Technical Staff D. Antonelli, Director, 0perations Training;

*J. Cook, Manager, Nuclear P_lanning and Support B. DeLetter, Engineer --Inservice Testing

• F. Edler, Director,' Maintenance'and Technical Training J. Emmert, Supervisor, Electrical Engineering'.

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J. Funstom, Project-Engineer - Mechanical Design

• K. Graf, Jirector, Operations Monitoring

• D. Hall, Vice President-

• D. Holesinger, Assistant Manager, Clinton Power Station

• Hollon, Acting Director, Nuclear Program Assessment Group  !

• D. Holtzscher, Acting Manager, Licensing and Safety 4

• R. Kerestes, Director, Nuclear S E D D. Logan, Supervising Engineer - Mechanical Design

! *J. Miller, Manager, Scheduling and Outage Management 1 D. Parchem, Project Engineer - IST

• J. Perry, Assistant Vice President W. Sanders, Assistant Supervisor, Controls and Instrumentation-  ;

V. Harris, Former Technical Advisor to the Plant Manager (no longer employed at IP)

Soyland/WIPC0 1

• J. Greenwood, Manager, Power Supply U. S. Nuclear Regulatory Commission (U.S. NRC)

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• S. Ray, Resident Inspector-  !

• Denotes.those present at the exit interview on March 3, 198 I . Follow up on Allegations-(99014)

(Closed) Allegation RIII-87-A-0027:

I Backgrou )

In March 1987, an individual identified potential deficiencies with the.IST of safety-related valves and the lack of containment integrit l

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I Considerable inspection effort has been expended to completely address the alleger's concerns. This effort included technical l assistance from NRC's Headquarters' staf Technical aspects of the allegation were addressed in previous NRC Inspection Reports No. 50-461/87014, 50-461/87027 and 50-461/8802 A Notice of Violation was issued addressing the technical aspects of the alleger's concerns.that were substantiate b. NRC Review The alleger also contended he alerted licensee management to several technical issues prior to fuel load and management did not take l proper action due to a concern that fuel load may be delaye The NRC inspectors were able to substantiate certain aspects of the technical concerns provided by the alleger (see previous inspection reports). Except for some questions concsrning the IST pro scope, the NRC staff concluded in a letter to the alleger (gram V. Stello to alleger dated December 13, 1988) that, either there was no technical merit to specific allegations or, where specific allegations were substantiated, they were not material to licensing decisions. During

! this inspectiot, the inspectors interviewed a number of supervisors and managers who might have been involved in activities related to IP action in response to the allegation. The alleger contended that forty-four memos were forwarded to IPC management identifying the problems. Twenty-nine memos were recovered and provide the basis of this inspection. The remaining memos were not available onsite and the alleger would not provide them to the NRC. Documentation was reviewed including the IST program submittals and responses, memoranda, j and procedure histories to determine to what extent the allegation of 1 management misconduct was valid regarding the IST program scop (1) Procedure Histories The following procedures were reviewed by the NRC inspector: )

CPS 9051.01, "High Pressure Core Spra) System Pump Operability."

Revisions 20, 21, 22, and 23 dated January 20, 1986, '

May 6, 1986, August 18, 1986, and October 9, 1987'

respectivel CPS 9051.02 "High Pressure Core Spray Valve Operability Test." i Revision 21 dated January 1, 198 i CPS 9052.02 " Low Pressure Core Spray Valve Operability

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Checks."

Revisions 20, 21, and 22 dated December 23, 1985, July 31, 1986, and February 18, 1987 respectivel ,

CPS 9053.05 " Residual Heat Removal Valve Operability Check (Shutdown)."

Revision 2 :

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CPS 9054.02 " Reactor Core Isolation Cooling Valve i j Operability Check."

l Revision 20 dated February 27, 198 CPS 9069.02 " Shutdown Service Water Valve Ope 'ility l

Test."

Revisions 20, 21, and-22 dated May 21, 1986, September 8,

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1986, and April 3, 1987 respectively, a '

The procedures were identified in the alleger's memos written while he was employed at Clinton. The review was conducted t determine to what extent any comments made by the alleger were documented through any formal process beyond his memos, and to evaluate actions taken by the licensee on comments that may have been made by the alleger. Since the alleger's concerns

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arose from his work done as a procedure writer, Comment Control Form / Originator Comments, which can be used by procedure writers to resolve concerns that they might have with the' procedure, were reviewed. No concerns similar to those in the alleger's memos were found in the Comment Control Forms appended to the procedures and no problems were noted in the procedure i Additionally, no records could be found that indicated that the

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alleger forwarded any comments through' formal channels that would have required action to be taken by IP managemen Responsible licensee personnel stated that no Safeteam files ;

existed on the issues generated by the alleger, nor were there i any records of concerns expressed to the licensee's Quality )

Concern Hotline, a mechanism established for persons to voice l their concerns to an independent quality group.

l (2) IST Program Scope At the time of the allegation, some of the safety-related valves identified by the alleger were omitted from the Clinton i IST program. IP was in the process of revising the program for !

submittal to the NRC for final acceptanc l The NRC inspector conducted a review of the action taken by the licensee to correct the IST program in response to findings in NRC Inspection Report No. 50-461/88020 which identified valves i

that perform a safety function that were required to be in the IST program, and were omitted previously from the program.

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The seven IST program submittals to the NRC were reviewed to I determine the status of the valves (whether or not they were in !

l the program). Table 1 lists the status of those valves during '

l the developmental stages of the IST program. These valves were l those identified by the alleger as being required to be in the IST program and were not.

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The licensee's February 1982 IST program submittal to the NRC j included 6 valves identified by the allege Subsequently, IP j i

contracted Sargent and Lundy (S&L) to establish procedures for l preparation of Pump and Valve Operability Packages (PV0P's) 1 which addressed procurement, installation, maintenance and i testing requirements for all safety-related valves with an

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active function. This was done by the licensee in response.to

! an NRC audit of the PV0P's which concluded.that substantial l problems existed with the PV0P's and needed to be corrected.

l The new PV0P's were to include.all safety-related active, seismic category 1 pumps and valves. Based on interviews with licensee personnel, the decision was made by the IP staff to make the PV0P master list and the IST master list agree. This would then identify all valves that should have been in the IST progra As part of the continuing review process of the IST program, the licensee resubmitted in December 1985 (updated in March 1986) to the NRC their IST program which included a revised list of i valves. Six valves were added and twelve from the program based i on the review conducted by S&L.

l In January 1987, the licensee commenced a review of the alleger's ]

l concerns in response to letters addressed to IP managemen l.

l Based on the internal review of the alleger's concerns by the l l IP staff and NRC questions, the licensee submitted to the NRC a !

I revision of the IST program in June 1987. This submittal included a revised valve listing which included all of the valves identified by the alleger except six. The licensee claimed that these six valves performed no active safety function and were exclude Of the twelve valves removed in response to the S&L review, i valves in the steam condensing mode of the Residual Heat i Removal System, lE12 F051 A, B and F065 A, B, were removed from ,

the program because the system that they are in was permanently l tagged out of service, and therefore, the valves would serve no function. These valves are required to be carried administrative 1y but they do not need to be tested as allowed by Subarticle-

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IWV-3416 of the ASME Code,Section X The valves were reinserted into the program for administrative purposes in May 1988.

1 . i i The status of the control room HVAC valves OVC 10 and 20 A and B,

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and RHR valves lE12 F037 A and B, was being questioned by the NRC prior to fuel load. These valves were added to the program in the

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The remaining Table 1 valves identified by the alleger were  ;

incorporated into the program in response to NRC requests stemming from the review of the alleger's concerns in May 1988 (see Table 1). .

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The NRC inspector reviewed actions taken to update'all respective. programs and documents.and ensured the licensee was in compliance.with the ASME Code with respect to these valve Condition reports were issued by~the' licensee in response to 1 the violation in NRC Inspection Report No. 50 461/88020. ~These )

were_ written to correct all problems associated with the valves, j All valves that were in the IST program at the time of this ]

-inspection were'being tested as. required, and the.PV0P maste '

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list in the FSAR was being updated to also include these valves (3) Extent of Licensee' Involvement The NRC inspectors conducted interviews to determine,1for the-period of April to December, 1986 (fuel load was in September 1986):

To uhat extent'certain individuals knew of the' alleger's concerns and their understanding of programmatic significanc Why the alleger's concerns were not recorded nor acted i upon through the deficiency reporting syste What action was taken to resolve the alleger's concerns and was it appropriat Whether IP management discussed the concerns with the alleger, and the results of any discussion I l

The IST program responsibilities of the Technical Advisor l to the Plant Manager and the manner in which this individual ]

interacted with the Technical Department,.0perations Support Group, and the Plant Manage ;

Some individuals interviewed were aware'of the alleger's concern Those responsible for procedure. comment resolution were getting comments from groups other than the Operations Support Group to .!

whom the alleger was assigned.. These comments were considered j by the licensee to be not unlike the alleger's comments both in l type and significance in that the program was in a developmental i stag d Interviews with licensee personnel disclosed that informal .

discussions were held between the alleger and others responsibl R for the program development before fuel load. Meetings of this !

nature were not uncommon and were viewed in the context of- i

" program development," These meetings involved. Technical l Department and Operations Support Group' staff representative The Technical Department staff and supervision felt the alleger's technical comments were adequately and timely cJdressed as they l were made known through the alleger's memoranda.- Interviews '!

with licensee personnel further disclosed that, had a perception i existed on the part of IP supervision and staff that the concerns l were not being handled adequately and in a timely manner, escalation of the concerns to management would have occurred.- .

Since IP supervision and staff were acting on the alleger's i 6  :

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comments and considered they were resolving them, they felt no need to escalate them to managemen Thus, IP management did not get involved in the resolution of the alleger's technical comments prior to fuel loa Members of IP management who were interviewed stated that daily or weekly project status meetings were held prior to fuel load in which ISI/IST program status was periodically discussed;

" management", as defined in the IP organization, did not include department heads or supervision. Detailed issues regarding program development were not routinely discussed at these meetings. Furthermore, those interviewed who routinely attended these meetings did not recall discussing the alleger's concerns in the context of allegations or programmatic safety issue Since two of the alleger's memos were addressed to two individuals, one of whom was the. Technical Assistant to the Plant Manager, the inspector asked questions of the licensee to clarify the role that this individual had with regard to IST program development and/or oversight, as well as his interaction / relationship with the Plant Manage The Technical Assistant to the Plant Manager was hired based on his purported extensive knowledge of and experience with ASME Code requirements. His relationship with the Plant Manager was

"results oriented" - that is, he was given broad latitude to troubleshoot problems to affect resolution without much feedback to the Plant Manager other than informing him of the results he had achieved. In this regard, he was assigned oversight responsibility for the PV0P program and the translation of Code testing requirements into programs and procedures such that the surveillance procedures generated would be able to be accomplished in the field. The Technical Assistant to the Plant Manager was aware of the alleger's concerns and believed they were being addressed. This matter was not raised to the Plant Manager's attention because it was considered by the Technical Assistant and responsible supervisors to be resolve c. Conclusions Based on the findings of this and previous inspections, the NRC inspectors concluded that some of the alleger's technical concerns ;

were valid. These are specifically discussed in previous inspectio l reports. Notices of Violation have been issue ;

l Regarding the allegation that IP management did not properly pursue i the alleger's concerns because they may have impacted negatively on the fuel load schedule, the NRC has concluded that this allegation is not substantiated. During the alleger's tenure cnsite IP Technical Department and Operations Support supervision, as well as the Technical Assistant to the Plant Manager, were aware that concerns had ariser, and believed the issues were being properly q resolved. IP staff conducted meetings with the alleger as necessary to clarify and address his concerns. Specifically, regarding the

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alleger's concerns on the. scope of the IST program, IP staff determined that they would depend on the S&L PV0P effort to establish the final IST scope. Further detailed analysis of the alleger's concerns in this area was not undertaken by IP staff. While conceptually, the PV0P effort should have paralleled the IST. program, the decision to depend on S&L resulted in some errors going undetecte Notwithstanding, based on this inspection effort, the staff concludes IP management was unaware of the alleger's concerns prior to fuel load and, thus, could r.ot have suppressed or concealed the . Exit Interview The Region III inspectors met with the licensee representatives (denoted in Paragraph 1) at the conclusion of the inspection on March 17, 198 The inspectors summarized the purpose and findings of the inspectio The licensee representatives acknowledged this information. The inspectors also discussed the likely informational content of the inspection report with regard to documents or processes reviewed during the inspection. The licensee representatives did not identify any such documents / processes as proprietary.

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IST PROGRAM SUBMITTAL i

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VALVE FEB DEC MAR JUNE AUG MAR MAY 82 85 86 87 87 88 88 l OVC 10 A, B X X X X Reinserted in Response to NRC i

17 A, B X 1 X X X X i

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i 20 A, B X 1 X X X X Reinserted in Response to NRC i

l 25 A, B X X X X 1B21F001, 2 X X X X X X 1E12F037A, B X 1 X X X X Reinserted in Response to NRC F040,49 X 1 X F051A, B X X 2 X F065A, B X X 2 X l l

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lE51F004, 5 X 1 X X X X Reinserted in Response to NRC l i 1FC085A, B X 1 X X X X l

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TOTAL = 23 I

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X = In IST Program 1 = Removed to Correspond With PVORT Lis = Removed Due to System Tag-Out i I

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TABLE 1: Valves identified by alleger and IST Program inclusion date i l