IR 05000461/1989017

Insp Rept 50-461/89-17 on 890403-27.No Violations Noted. Major Areas Inspected:Field Alterations & Plant Mods & Dedication of commercial-grade Equipment for safety-related Applications

ML20247H705
Person / Time
Site:	Clinton
Issue date:	05/19/1989
From:	Hasse R, Phillips M, Rescheske P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20247H702	List: IR 05000461/1989017 ML20247H695
References
50-461-89-17, NUDOCS 8905310295
Download: ML20247H705 (9)

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t U.S. NUCLEAR REGULATORY COMMISSION l

REGION III

Report No. 50-461/89017(DRS)

Docket No. 50-46 License No. NPF-62 Licensee: Illinois Power Company 500 South 27th Street Decatur, IL 62525 Facility Name: Clinton Power Station Inspection At: Clinton, IL 61727 Inspection Conducted: April 3 through April 27, 1989 di Inspectors: . eskhes MU(uudh 6'//'7 he[

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Dat4 0th ongiovanni, A. LL W k 19MW H W/7[8)

Dat6 Approved By: /N P. Phi lips, Chief Operational Programs 5//f/E[

Date Section Inspection Summary Inspection on April ? through April 27, 1989 (Report No. 50-461/89017(DRS))

Areas Inspected: Ro'utine, announced team inspection of field alterations and plant modifications, and the dedication of commercial grade equipment for safety related applications. The inspection included a review of design basis, installation, testing, resolution of identified discrepancies, QC/QA involvement, and commercial grade dedication. The inspection was conducted in accordance with Inspection modules 37700, 37828 and 3870 Results: Of the areas inspected, no violations were identified. One unresolved item was identified (Paragraph 3.b(3)) concerning the applicability of a 10 CFR 21 report. Four previously identified open items related to modifications were close :

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DETAILS Persons Contacted Illinois Power Company (IPCo)

D. P. Hall, Vice President K. A. Baker, Supervisor, I & E Interface

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R. E. Campbell, Manager, QA R. D. Freeman, Manager, NSED J. Greenwood, Manager, Power Supply M. C. Hollon, Acting Director, NPAG D. L. Holtzscher, Acting Manager, Licensing and Safety J. A. Miller, Manager, Scheduling and Outage Management J. S. Perry, Assistant Vice President J. W. Wilson, Plant Manager R. E. Wyatt, Manager, Nuclear Training U. S. Nuclear Regulatory Commission (U. S. NRC)

B. Drouin, Project Inspector, DRP S. P. Ray, Resident Inspector, Clinton Plant All the above listed persons attended the exit meeting held on April 27, ,

198 Other persons were contacted during the course of the inspection, including members of the licensee's system and design engineering staff, and procurement and purchasing personne . Action on Previously Identified Items (Closed) Open Item (50-461/85005-20): Verify installation of heavy duty turbo-charger drive gear assembly on all diesel generators. The installation of the heavy duty turbo-charger drive gear assembly was controlled by plant modification DG-38 which was completed during this refueling outage. This item was discussed in the resident inspector report 50-461/89014 and is considered closed, (Closed) Open Item (50-461/86017-07): Verify that separate class lE power supplies have been provided for both fuel zone level channel The installation and upgrade of fuel zone level instruments was controlled by plant modification NB-18 which was completed during this outage. This item is considered close , (Closed) Violation (461/86053-02d): Failure to document bases for .

concluding that no unreviewed safety questions were generated as a result of plant modifications. The inspector determined that the training provided by the licensee had proven effective in correcting I this proble (Reference Inspection Report 461/86077(DRS) for other supporting information for closure of this item). This item is considered close __ -__ -__ _ -___ ____ -_ __-_-_- ____ _

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. (Closed) Open Item (50-461/86054-12): Safety Evaluation Report i NUREG-0853,. Supplement No. 6, Paragraph 7.5.3.2 -' Verify.that the i

field wiring of the four primary containment isolation valves to l

SPDS has been completed prior to startup from the-first refueling outage. The modification-(VR-016) was completed during the 1989 refueling outage. This. item is considered close . Design Changes'and Plant Modifications l

The. inspectors reviewed three modifications, six field alterations,.and a sampling of temporary modifications to determine if they.had been conducted in accordance with regulatory and programmatic requirement The modifications were controlled by Nuclear Station Engineering Department (NSED) Procedure D.55, " Modification and Configuration Change Control."

The inspection consisted of.a selective review of the following documents to determine the technical adequacy of the design changes:

10.CFR 50.59 safety evaluations QA/QC audits and surveillance Purchase orders and receipt i'ispection records Vendor. manuals Installation and testing results Design calculations for seismic qualification Condition reports documenting discrepancies identified during the design, installation and testing of the modification Maintenance work requests Updates to the USAR as required by 10 CFR 50.59(b)(2) Description of Design Changes Reviewed (1) Modification DG-038: This modification replaced the diesel generators turbo-charger gear drives with heavy-duty turbo-charger gear assemblies as recommended by NUREG/CR 066 The installation of the heavy duty assemblies was necessary to satisfy License Condition No. 7 as stated in Paragraph 9.6. of the Safety Evaluation Report NUREG-085 (2) Modification NB-18: This modification upgraded the Reactor Water Level Monitoring Fuel Zone Range Instrumentation from redundant non-class 1E to fully qualified class 1E, with the exception that one display channel utilized an unqualified but properly isolated recorder. While the recorder was unqualified, the instrument loop was fully qualified class 1E up to and including the' isolation device which is consistent with Regulatory Guide 1.97, Revision 3. The modification satisfied a commitment stated in the FSAR Table 7.1-1 (3) Modification VR-016: This modification satisfied a commitment in Paragraph 7.5.3.2 of the Safety Evaluation Report, NUREG-0853, Supplement No. 6 (SSER6). The modification added reed limit switches to four containment isolation valves and

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the logic to SPDS to provide valve position information to.the-

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main-control room. The SPDS had previously been modified to status 47 offthe 51 primary containment isolation valves

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discussed in SSER6; the four remaining valves were addressed by this modificatio (4) Field Alteration HPF006: This modification authorized the'

substitution of an unavailable Limitorque spring pack to one with a lower spring constant; The new spring 'nack had a lower spring censtant to allow additional torque switch adjustabilit .for achieving desired thrust values. This replacement._ spring pack was installed in the High Pressure Core Spray Suppression Pool suction valve lE22-F015 which had a history of-excessive closing thrus (5) Field Alteration M-F038: This field alteration installed a spray ring on the dryer / separator strongback. The addition of the spray ring mounted on the strongback was to reduce the amount of airbourne' radiation / contamination by allowing water to be sprayed on the dryer and separator while lifting from the reactor vessel. Prior to this modification, water hoses were available for preventing the equipment from drying. The proposed spray pattern was designed to allow the water to spray over the equipment; however, during actual use, the licensee discovered that the spray did not completely cover the equipment. According to the licensee, an improvement is planned to remedy this lack-of coverag (6) Field Alteration NRF002: This field alteration added ferromagnetic shielded conduit to the SRM D cables between the termination cabinet and the neutron. monitor system panel located in the main control room. The modification was a result of the excessive noise problems experienced with the SRMs. The problems with the SRM signals directly affected their reliability and operability during core alterations performed during the outage. Troubleshooting efforts by the licensee determined the need for further improvements which included a number of temporary modifications and proposed-

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changes to the system in future outage (7) Feedwater system modifications: The inspectors reviewed three modifications to the feedwater system. These modifications were precipitated in part by an event described in LER No. 88025, " Loss of Feedwater Heating System", and the difficulty in maintaining calibration of a function generator used to control the low NPSH trip setpoint for the feedwater pump i

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l (a) Field Alteration HDF014: This modification raised the feedwater heater level setpoint at which the feedwater heater is isolated from extracted steam. The intent of raising the setpoint was to provide more time for the normal feedwater drain valves and the emergency drain valves to control feedwater level. The modification was a direct result of the event described in the LER noted abov (b) Field Alteration FWF012: This modification expanded the range of feedwater temperature indication in the control room from 300 - 450 F to 250 - 450 F, and resized fuses in the feedwater heater level instrumentation power supplies. Expanding the feedwater temperature indication in the control room was a result of the event described in the LER noted above in which feedwater temperature dropped below the minimum indication previously available. The fuse resizing was done to ensure that a fault in the power supply would be cleared before impacting bus voltag (c) Field Alteration FWF0ll: This modification revised the low NPSH trip logic for the feedwater pumps, and eliminated the automatic start of additional condensate and condensate booster pumps on low NPSH in favor of manual contro (8) Temporary Modifications The inspectors reviewed the temporary modifications installed and/or removed during the refueling outage, using CPS Procedure No. 1014.03, " Temporary Modifications," as a guide. In general, the packages included sufficiently detailed safety evaluations which assessed the affects on other systems and the impact on safety. In addition, the required review and approval signatures appeared to be appropriate to ensure adequate implementation of the modification and completeness of supporting documentation. The licensee's Quality Assurance organization had recently identified a potential adverse trend regarding compliance with the temporary modification progra The inspectors considered the deficiencies to be administrative in nature (e.g., signatures, dates, extensions), having no adverse impact on safety or the implementation of the temporary modificatio b. Inspection Results In general, the design reviews and 10 CFR 50.59 safety evaluations were of good quality. Work Request packages contained installation procedures and details of the work performed. The modifications were processed in accordance with NSED Procedure D.55, " Modification and Configuration Change Control". The areas reviewed, including

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design documents and safety evaluations, installation, testing, station procedures requiring revision as a result of the modification, document control, drawing updating, etc., were found to be adequate with the following comments:

(1) Based on the licensee's screening process, a 10 CFR 50.59 evaluation was not performed for field alteration HPF014. The inspectors agreed with the licensee (per the guidance given in IE Manual Chapter 9800 "CFR Discussions"), that an evaluation would not be required because feedwater heater isolation on high heater level is not discussed in the FSAR. It was noted that this setpoint can impact feedwater heating as evidenced by the LER; however, there was no safety concern in this instance since the setpoint was moved in the conservative direction relative to maintaining ;eedwater heating. The inspectors recommended that the licensee carefully review their internal screening guidance against the NUMARC guidelines when the next draft is issued to ensure that they are using the most current guidance.,

The inspectors had no further concern (2) With regards to field alteration FWF0ll, the original logic for the low NPSH trip used a function generator used a function generator to compare available NPSH to required NPSH. The function generator used feed flow rate, fluid temperature NPSH available and NPSH requirement as variables and generated a

" floating" trip point for the pumps. Operating experience indicated that the function generator was unreliable and difficult to maintain in calibration. The modification replaced this logic with a fixed conservative setpoint using a 2/3 logic with a six second trip time dela The modification also added a control room alarm on low NPSH ,

(no time delay) and a trip bypass switch. When the automatic trip is bypassed, the NPSH requirements are monitored by the operator using the plant compute The licensee's Architect Engineer (A/E) concluded in its safety evaluation that, under a certain operating configuration, the probability of losing both feedwater pumps (FWPs) was increased as a result of this modification. This configuration was with the motor driven FWP in service and feed flow in the manual control mode. In this situation the FWPs would trip earlier than under the old configuration since the new fixed setpoint was based on the turbine driven FWP requirements at maximum flow which is greater than MDFWP requires. The licensee changed this conclusion in its safety evaluation. Their rationale was that the addition of the low NPSH alarm, the six second delay in trip initiation, and the addition of the trip bypass, allowed the operator to take manual control to avoid any unnecessary Feedwater pump trip. The inspectors agreed that any increase I

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in the probability of'FWP loss was not significant and no

.unreviewed safety question existed. The inspectors had no further concerns with this modificatio (3) Prior to the installation of the lighter spring pack in the actuator for lE22-F015 per field alteration HPF006, the licensee noticed that the stem nut appeared'to be badly wor On April 8, 1989, a condition report CR-1-89-04-052 was written to track this deficiency. Investigation showed that the stem nut was threaded for a 2 inch "0" diameter' stem although the stem was 1-3/4 inch."0" diameter . The identification stamp on the worn stem nut matched the actuator order number on the original actuator nameplate, thus the worn stem nut was installed in the valve by the valve manufacturer, Anchor Darling Valve Company. The licensee noted that the stem was replaced earlier this outage due to a 10 CFR 21 defect relating to stem material; however, the licensee concluded that'the current stem matched i the replaced stem. The stem to stem nut mismatch appeared to have occurred. prior to the original installation at Clinto Discussions with the licensee showed that the determination of

.a 10 CFR 21 applicability was on-going between the licensee and Anchor Darling. . This issue was not resolved by the end of the inspection period and is considered to be an unresolved item (50-461/89017-01(DRS)), pending the completion of the licensee's evaluatio No violations were identified; however, an unresolved item is

' discussed above in Paragraph b(3). Dedication of Commercial Grade Equipment For Safety Related Applications i

The inspectors reviewed the licensee's program for the procurement and dedication of commercial grade equipment used in safety related e applications. The procurement and dedication process was controlled by Nuclear Station Engineering Department (NSED) Procedure FE-5, " Purchase Requisition Classification". The current revision'of this procedure did not require the explicit identification of critical characteristics and-the means for verifying they were met; however, in many cases this was implicit in the specifications and documentation requirements (e.g.,

material certifications). The inspectors also reviewed a major revision to this procedure currently _in the approval cycle. It appeared that this revision would put the program in full conformance with EPRI NP-5652,"

Guideline for The Utilization of Commercial Grade Items in Nuclear Safety Related Applications." This included the identification of critical characteristics and identification of explicit means for verifying they are-satisfied. The inspectors were satisfied that existing program weaknesses were aggressively addressed by the pending revision to the progra _ - -___-______-_ _ _ _ _-_ - -_ -______ . _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ - _

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The ir;pectors also reviewed a sample of commercial grade equipment currently used in safety related applications, to determine if there was reasonable assurance that they would perform their safety-related functio In general, the equipment consisted of small store items, such as fuses, small fittings and valves, some consumables, circuit boards, connectors, et Typically, dedication is accomplished at receiving inspection. The licensee relies heavily on the use of qualified suppliers and manufacturers for assuring the quality of commercial grade equipment. The licensee audits manufacturers to determine if they have a QA program adequee to assure that a specific part conforms to the specifications publi> ad in the manufacturers literature prior to placing them on the qualified manufacturers list. The same concept is used for qualified suppliers,  !

except in this case the supplier must have a program that provides reasonable assurance that parts supplied meet the published description of that part. At a minimum, the receiving inspectior.-(and dedication)

consisted of verification of part number'for items purchased from qualified manufacturers or suppliers. In most cases other documentation was also required (e.g., material data sheets and statement of conformance to original specifications). The inspectors found only one case in which on-site *,esting was to be used for the dedication process. This involved the dedication of pressure gauges for the hydraulic control units. These 4 gauges were purchased "at risk" with dedication to occur by post-installation testing. The inspectors found no case in which there was not some assurance that the item would perform its safety-related functio The inspectors concluded that the licensee's current program was weak in the explicit identification and verification of critical characteristics; however, no cases where a potential problem might exist in the field were identified. The pending revision to this program should resolve the noted weaknes It is the licensee's intent to backfit this program to existing stores items prior to any reorder . Quality Verification The inspectors reviewed a number of Quality Assurance Surveillance Reports and Audit findings related to modifications performed during the outag The identified concerns and potential adverse trends were discussed with the licensee. Based on the review and discussions, it was apparent that Quality Assurance activities were effective in identifying problem Since the concerns being addressed were recent findings, the effectiveness in obtaining resolution of issues was not assessed by the inspectors.

' Unresolved Items i

Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, violations, or l deviations. An unresolved item disclosed during the inspection is l discussed in Paragraph 3.b(3).

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. Exit ~ Interview i The inspectors met with the licensee representatives (denoted in Paragraph 1) on April 27, 1989, and summarized the scope and findings '

of the inspection. The inspectors also discussed the likely informational content of_the inspection report with regard to documents or processes reviewed by the inspectors during the inspection. The licensee did not identify any such documents / processes as proprietar i

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