IR 05000461/1990002
| ML20034A669 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 04/13/1990 |
| From: | Ring M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20034A663 | List: |
| References | |
| 50-461-90-02, 50-461-90-2, NUDOCS 9004240084 | |
| Download: ML20034A669 (19) | |
Text
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.' , . .t . n ' U.S. NUCLEAR REGULATORY COMM'SSION '
REGION III
i Report No.- 50-461/90002(DRP)_ , ;
Docket No. 50-461 License No. NPF-62 i I Licensee: Illinois Power Company 500 South 27th Street , Decatur, IL-62525 Facility Name:. Clinton Power Station-Inspection At: Clinton' Site, Clinton, Illinois l Inspection Conducted: February 26 through March 6,1990-l Inspectors: P. Brochman B. Drouin R. Mendez W. Olsen
H. Walker .2 l-Or- _ /3 19- . - l Approved By: Park A. RingI, Chief ! Reactor Projects Section 3B Date.
i Inspection Summary Inspection from February 26 through March 6.1990 (Report No. 50-461/90002(DRP))' Areas Inspected: Special team inspection by the resident and regional Inspectors-ofmaintenance,operationsinterface,(managementcontrols,andposttrip.
l review analysis for balance of-plant B0P) systems.. ' i-Results: Overall the programs for corrective, predictive, and preventative.
maintenance on BOP equipment appear to be acceptable. Operations ~ Department-activities in support of B0P equipment maintenance, the operation of BOP systems,-management controls and the utilization of prior industry events also appear to be acceptable...The post trip review program appears to be adequate. Areas for improvement were identified in the. preventative.
maintenance program, equipment tagout program, and post--trip review program.
One violation was identified which' involved the failure to recognize that the.
utilization of administrative methods for controlling radwaste tank levels, vice the installed instrumentation, required a 10 CFR 50.59 review.
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Persons Contacted- ' a! ' [, < Illinois Power'tompany (IP) 3 K* , ' , a] jrp.s
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- J. Perry, Vice President
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- J.-Cook, Manager, Clinton Power Station
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- R. Wyatt, Manager, Quality Assurance
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- R._ Freeman, Manager, Nuclear Station Engineering
- J. Miller, Manager,-Scheduling and Outage Management j
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- J.--Palmer, Manager, Nuclear Training-
- J. Palchak, Manager, Nuclear Planning'and' Support-
- D. Morris, Director, PlantL0perations
- S. Rasor,. Director, Plant' Maintenance
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- D. Holtzscher, Director, Nuclear Safety
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- R. Phares, Director; Licensing
- S. Hall, Director, Nuclear,Pregram Assessment
- P.y.Yocum, - Supervisor, Pbnt Operations
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- T.: Hill, Supervisor. Mechanir.a1 aaintenance
- A. Haumann,. Supervisor, Electrical Maintenance
- W. Clark, Supervisor, Control _& Instrumentation Maintenance
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- F. Armetta,' Supervisor, Radwaste
- K. Baker, Supervisor, I&E Interface
. . S. Richey,.P.M. Coordinator . R. Reichert, Shift Supervisor ~ " D. Andrew, Shift Supervisor.
J. Glowatch, SOM staff' .. R. Lebkeucher,: Licensing Staff S. Buck, Licensing-Staff: P. Breezeel, Licensing Staff , J. Schottel:,' Supervising Engineer, NSED J. Baer, QA Staff T. Donovan, Licensing ' Staff - Jeff Neuschwanger, Operations Staff Soyland
- J. Greenwood, Manager, Power Supply
[, NRC- _
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- M.'A.; Ring, Chief, Reactor Projects, Section 3B, Region III'
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- P.' Brochman, Senior Resident Inspector
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'*B; Drouin, Reactor Engineer, Region III ._ i ,
- R. Mendez, Reactor Inspector, Region III t
i j , , '*H.-Walker, Reactor Inspector, Region III ' - e.
, P The inspectors also contacted and interviewed other licensee and r contractor personnel during-the course of this inspection.
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- Denotestthose present during,the exit interview on March 6,1990.
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' Due to previous.NRC concerns with the:performanceiof; Clinton Statiori . ~in maintaining and~ operating Balance of Plant:(B0P) systems'(discussed-in the SALP;9 Report (50-461/89001(DRP)) and the.0STI Team:Repo~rt (50-461/89030(DRP)), a special~ team inspection was conducted,'duringa: ' , planned outage, to evaluate the condition'of B0P? systems and to observe-maintenance being performed on these systems.u.The focus of this ' '
, inspection was-in four areas: a.
A review'of the.effect'iveness of the licensee's: predictive,3 , ~ preventive, and corrective mai.ntenance on;B0P'sys_tems, ' ' ]a , - b.
A review'of t.he adequacy of operating proc'edures for B0P systems and-H operations! department interface activities.in support ofEmaintenance a on B0P systems, ,t .' A: review of the effectiveness;of management support in correcting ,p q c.
problems in B0P: systems and in. evaluatinglindustry, experience j , against B0P_ systems, x7
- . a , d.- A review of the adequacy of root.cause analysis for. plant' transients ] initiated by B0P systems.
" j m ' 3.
Action on Previous Inspection Findings 1 ' , .. . y (Closed) Violation (461/89003-01(DRS)):. Multiple examples.of; failure to s' ,- comply with maintenance' procedures. 'The. inspectors reviewed the 1licenseel - e A . - response and verified that the corrective: actions were'being implemented-as' stated.
The inspectors also reviewed -the; licensee's supplemental x response contained,in'a letter from D. L. Holtzscher to A. B. Davis; x.-
' - r . , dated' July 21, 1989, (U-601497).
The' inspectors' 2 observations of ' ~\\, a N" ' ', procedural compliance-are; discussed in Paragraph 4.b.. Based on these.
. reviews and observations, the inspectors have no^further concerns; and! , , .. ' th_is item 1s' considered closed.
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' During the inspection, conditions =were observed to.assehsithe 2 h, WM(: % , ~ a. ' general and# specific material condition of the plant,,to' verify that 4i ! maintenance work requests (MWRs) hadlbeen initiated for identified.
1,' . ' g , equipment problems,'and to evaluate housekeeping.
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, The plant was in an outage during the inspection and systems were r not subject to normal operating conditions. and pressures.
Many y ,t >i equipment problems had been previ.ously identified by licensee j j"' personnel and maintenance requests (MRs) had been initiated as " , evidenced by the attached MR tags.
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- - ' j . . ,. g , , , . ~ ~ . . . ' , LThelmaterial' condition' of'the radwaste ' area; appeared t'o' be very! poor
and the ability'to maintain the operability of these'-systems,- atTal. ~ '
level commensurate with~the' system or componentifunctions under' 'I _.
, abnorma1' conditions, was questionable. JThe housekeeping and . , ' , material' condition of other plant areas appeared-to be acceptable ! ' considering the amount of outage related workt . / k ( . The insp'ectors. observed a'large ' number of MR tags and " Danger do" ' not Operate" tags in the radwaste control-room.
Discussions with-licensee personnel. indicated that manyc equipment problems existed- " in the~radwaste area'and equipment' availability'in this area.was; <. less than 80%. In the recent past',L equipment availability lin this: ' , -area had been less than 50%. The inspectors:were. told that' the ' > ' . availability of radwaste equipment;did:not,directly relate to plant capacity'nor.to the ability ofjthe pl. ant to" adequately. perform the s ! "radwaste function.. A maintenance supervisor hadirecently been
~ s , assigned to address radwaste problems'and the' area had~recentlym. -
' received: additional management. attention ( .A computer. report dated:
March 2,11990,-was? provided to the dnspectors,'which listed 256 open
,radwaste MWRs.L'A1though a number of MWRs were;of low significance, some documented equipment operability problems.; A lack-of! management - attention' and al_ location of resources in' the 'nonsafety-related ~ , y" radwaste area hadLresult'ed in-a significant deterioration'of - < radwiste equipment availability,3 efficiency and capability.
The , f" r . significance of this problemiwas lessened"because=the radwaste. ~!
, l facility was originally designed fo_r'a two unit plantxand therefore ' ' [ had excess, capacity for the present single unit' operation.
o - - The. inspectors noted that the.r$dwast'e' sludge tank level indicators '
l ~ , (m 'were inoperative.
The inspectors ~were told that maintenance for , l- 'these: level detectors was difficult-and these-controls had not been - effectively. utilizedLsince plant operations began April -17;-1987.
^ y' Licensee; personnel also statedithat another. level indication system
' existed for'the tanks; however, it was also considered unreliable, j'
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,4 s The tank administrative. controls were described in procedure - CPS'3909.03, " Operating Sludge System.'"- The radwaste control = room.
operator was required to monitor flows-in and.outiof the tanksito: , , determine when the? tank level-was-nearing capacity.~ Licensee 'i ' personnel; stated that, while:using this method in. July 1988, a; .. .% tank became'ov'erfilled and caused acspil1Joflradioactiv.e water and
~ sludge. into _th'e radwaste area.-. The _ affected room-was-contaminated ' to a level of 40,000 dpm/100 square' centimeters. The:spillLwas- , contained and the room subsequently decontaminated.
This.incidentt
L ,was docuraented ton. Condition Report No. 1-88-07-138.
. , "1 10 CFR 50.59 (a)(1) allowed changes to.the' plant, as describedmin' the Safety Analysis Report, without prior NRC approval provided.that.
, the change did not require a' change to the Technical Specifications.
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The radwaste.tankLlevel controlswere discussed'.in the-USAR, so.
the, inspectors l asked if:this change had been addressed'and the: si -
appropriate safety reviews-' completed.
A safety evaluation-was.
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- conducted for procedure CPS 3909.03 when< Revision 11 was>issuedi
- on. December. 19, 1988 to add ~the:use_of administrativefcontrols-
- t however, this:revisionJdid not addressidiscontinu'ance of'the . ' - existing.tankelevel controls:(level indicatorsiand annunciators)! , Consequently, the defacto" elimination-of.the use of.thel ultrasonic-
level system for controlling radwaste tank levels was made without? ' performing-a' safety evaluation ^ to determine:if"an unreviewed safe.ty.' 'a - - question existed. :The-failureito perform this; evaluation was'a: j violation of 10 CFR 50.59 (461/9000?-01(DRP)). The root cause of this violation was.tha' failure-of licensee.
. <j Lpersonnel to: understand that deciding not.to' utilize the installed j level. indicators required a 10 CFR 50.59 review, because credit is + ' taken for these level indicators and their~ annunciators'in'the USAR; . b.
Review of Ongoing Work- . t - . t The inspectors observed ongoing non-safety-related wor _k in'B0P ' electrical, mechanicul and-Control and Instrumentation (C&I) areas.
These' activities were selected from therplan of the day listings, y-work assignments in _ individual maintenanceLshops and through discussions with maintenance supervision.
Where possible,y , y significant nonsafety-related! activities were selected 1for review.
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- m Maintenance activities were observed to determine ~if those-
. 'i activities were performed in accordance with required administrative L! < , and technical requirements. ' Work activities were-assessed in'the
, l! following areas:
. . "' Work control and planning;_ management presence, involv'ement,.andL knowledge;. health physics : support and hazards; work instructions - - " (including procedures) available, adequate, a'nd used; personnel, , ? . trained and qualified; materials and parts ~ available, adequate.and/
used;1 required tools and measuring and. test equipment controlled,' , (calibrated and'used; post maintenance testing specified,~acceptanceL r ,~ ~ _ criteria' included, and performed as specified.
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The inspectors observed portions of work in ' progress on . _. - ten maintenance activities for the MWRs and' PM items listed below: 7' D08457 - Reactor Feed Pump "A" minimum flow isolation valve leak !
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. - D08562 - Install metersifor RE,f RFhTE, and TF systems-a i , ?m D10633 - Computer point for main ~ generator temperature! j , ,. . . a a D19156 - Repair feedwater instrument power supply ~~ yl ! [ D04966 - Check. component cooling pump motor relays for binding s.
D05297 - Check 7nonsaf'ety-related rel'aysiforIbinding-; J L x __ . .. , 005839 - Replace main' generator high side breaker
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008562 - Insta11Lelapsed time meters
, , D13053 - Investigat'e.high~ thrust be'aring' temperature , .
PCITSM025'-Loop calibration;of~ turbine vibration channels T5001A ' ' c
The insp'ectors ' concluded th'at the maintenance activities described in 'the above areas were satisfactorily, accomplished.by, skilled-V,l: mainten'ance personnel.
Maintenance personnel were competent andf knowledgeable of the work performed.
During the review of- , maintenance. work in progress the following specific observations -
and-concerns were identified" ^ ! ' , MWR 008562 - This MWR performed a modification to install elapsed ? timecmeters;for the reactor equipment orains,' reactor, building floorf
_^. drains;' turbine' equipment drains and' turbine building floor drains.
' The, installation was to. be completed-utilizing existin~gTspare~ wires N "- A . DForithe turbine building equipment drain. pumps the MWR. required that' ' ' , timer 1KR-TED64 be connected to the; terminal block designated
3 ,' - 1TE2PB.
However, the inspectorsLnoted'the timer was incorrectly.
' ' ~ ' connected to terminal block 1TE2PBl. 1 A review of the schematic _
L jindicated that' the' timer would not have worked as designed.. Thej o f
- inspectors noted that' information had be'enLincorrectly_ transferred'
,- ' on the-field engineering change notice into the job' step work sheet.. n - ' % a - The'licenseefissued a condition report-to correct.the wiring 7 - A" i -
- discrepancy and determine the root'cause of'the condition and'the
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] appropriate corrective action to prevent. recurrence.-- ,%
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~ MWR D10633= This-job involved lthe troubleshooting,andl repair of '
np~ l ~, a negative mainigenerator temperature monitoring point on,the plant '# 't; . computer.. The MWR contained.few specific instructions to assist' i ' ' -" ^" -the C&I technicians in.the work;'however,' the technicians appeared ' , to_ be knowledgeable and performed the work in an orderlyL manner.
! , , ' q.i MWR D13053 - On March 1,1990, the' inspectors verified as-built N4 ~ terminal connections in junction box IJB23K associated with the., , circulating water pumps located in the screen house. - The motor's-l ' thrust bearing temperatures had indicated'highiand the MWR was issued to investigate and correct the problem.' The inspectors.noted- , c ,
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. . , . . ' accumulated water and corrodediterminals inside the. junction box.1
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.In' addition ~,' water drops were(observed above the junction' box.. i , On-February li'1990,-the licensee's maintenance' department issuedf' '
- condition report:1-90-02-005,that, identified the accumulated water l
and corroded terminals'in two other' junction' boxes located outside ' ' the circulating -water screen house'.! Licensee personnel-did inspectO f the junction box'for the third circulating water pump;and did not find any problems; however, they,did not' document this fact on the C R.- Junction box IJB23K was located.inside the screen. house. The ! . ' j water which entered: box IJB23K was caused by: improper placement ' , of.a vent hose'above.the junction box.
A.new condition report
'l-90-03-017 was written to resolve the problem with IJB23K, to :~ ,. s ~ determine the' root cause. of the technical < problem andLto ensure - that prior corrective' actions.would have prevented, recurrence.
, 1, Duringtheinspectiona. corporate"$fficeelectricianSasobserved 'I - , Lunsuccessfully.attemptingto;calibratetheCV-8.maingeneratori-, ' ' - ,, overvoltage relays. 'The calibration sheet required a pickup voltage' i ' ' of 16 volts but;the-electri6ian noted that the relays picked up at _ 30 volts.1The electrician was: unaware;that the vendor manuallfor $ j f s. g + the relays' required that, a relay: resistor be shorted When making ' c @, e , measurements.., Subsequent'to. reviewing the manual, the electrician ~ & n , , calibrated the' relays; however, as-found valuesswere notirecorded(. ( -
, . and no reference was made in' the remarks section of the' problemsi ' % ' ' l
- encountered during. initial calibration.
g j>q " + > - c The inspectors concluded;that nonsafety-related maintenance h- 'p w, . . , l ' -4 ' ., manner as4 safety-related.maintenanc' performed in much the samet activities were acceptable andswere a1 _ < eactivities!'MWRs~andf
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, ., procedures were<used4 work' was" accomplished by skilled maintenance - n
' personnel, andsthe ' work.was generally documentedL in the same nianner l as safety-related work. Jhe previously,noted problems of' failure, ,='a ? , , . <
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to follow maintenance procedures ^, discussed?in Inspection Report ' No. 461/89003(DRS), were notLnoted by the inspectors during this inspection.
Maintenance, personnel appeared to be knowledgeable and F, " h,' h ' adequately trained in the work 1 performed.9 The inspectors noted that " . some nonsafety-related work, such asnradwaste, was givert such a low ' > ** - priority,lthat theiability of the, systems; to perform -their intended functions under abnormal conditions;was questionable.
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ReviewandEvaluationofCompjetedMdintenance( - ' c.
The inspectors selected 19Lcompleted MWRs, PMsp and calculations.on-had previously encountered problems. 'an; emphasis on systems:tbat' BOP systems important to safety, with,The purpose of.this review was,? - ' , to determine if specified electrical, mechanical, and C&I maintenanceL ' was accomplished'o'n thos'e selected systems /componeits: to assure. . l continued and. reliable-operation.
The MWRs and'PHg were reviewed.
for adequate work instructionsi proper prioritization, proper work authorization, use of qualified 1 personnel, documentation:of work-performed, understanding!of' problems, post maintenance testing and-appropriate' review and sign offs. The inspectors also' reviewed i I i l ' l~ l-
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Ui ~ ' This review. included an' evaluation of the extent that-vendor - recommendations, Informatio'n Notices, Service Information Letters,. QC involvement, and quality documentation were incorporated into the
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, BOP maintenance program,: The following MWRs', PMs, and calculations '
were reviewed: ' ' < , ' C44190 - M51V 1821F022A closed too fast q > - , ~ ,D01626 - FW turbidity, recorder indicating offascale low- <i , , ^ 002400 - Valve 1FWO12A.has massive pa'cking" leak'- D02636 - 1821-F311A check: valve leaking at both pins - ,, , D06545;. Remove l stuck poppet from_MSIE 1821F0220..
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2D07646 - Disassemble / add inspect' valve for damage- -
, D13754 - Valves did not fastLclose while performing surveillance: . 014035 - Relief valve 1821F408 is cycling excessively; . , , D14075-IFWOO4lockedupLresultinginireactbr, scram j ' j r, D14312.- TG oil pressure is low ~ -l i ' D14387 - Valve will not stroke full open ]
g ' ' L D01277 - Perform work and restore main. transformer;to ~ " operability _y , i 003351 - Perform thermography on)'igh side.' bushing-h ' y
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PEMCWA005 - Clean and inspect breaker, Megger circulating water l' , pump < motor - x s , , a ' u . ., , .c ,PENCWA007 - Clean and finspect breaker; Megger circulating water o, . 4 -.
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PEMMPM012-DoblejestFmainpowertransformerL . l y -!
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[ is M <I J g a*%+ a, h s Calculation No. 19-D-35 - Calculation for non-1ErDC sys u m V il
e - ,, - c n , , ' ~ L During the review of comp' Records of work performed were documented ' (, J leted MWRs the inspectors made the;
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5' following observations: j g ,, in the same manner as safety-related work; records of the more, icomplicated work were sometimes difficult to follow but were ' t j! 4 - ) n " , Aotherwise acceptable;, instructions for performing work; in some ~ g v4
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, . , , , / . . . , , . cases,didnotcontainlasmuchdetail-and'did'notbppeartobe'as: - thorough'as the instructions ~ in~ safety-related MWRs.
For the work 1 , covered by the MWR-packages. reviewed,: this;did 'not seem to impact 1 the. quality or adequacy:of._the work.
However, the inspectors;did " ~ identify some concerns _with:the following packages: PEMCWA005 and PEMCWA007
- The inspectors reviewed PMs associated with the circulating water pumps including monthly motor oil samples,x quarterly filter inspections or replacement, and motor ~
insulation resistance tests that were performed every five years._ _.
' ~ The PM program: allowed deferral of-PMsLup to'25% past the-due date.- The. inspectors-.noted that some circulating water pump PMs were-deferred beyond the 25% limit; for example, the quarterly filter: PM on pump 1CW01AA was-performed.in January 1989,-June'1989 andL _ y February 1990.
In addition, the oil sample PM on pump l1CWOPIC was not performed in October and November 1989.
> o > L ' sThe five year motor insulation 1 resistance tests-appeared to have met the acceptance criteria but the. quantitative values were not documented. =While the absolute values were unimportant, an;
'3 increasing:or decreasing value may indicate'a trend.
On July.17, f ~ 1988, the "A" circulating water pump' motor failed when all three _ phases' shorted to ground,; caused by.a phase-to phase fault;between * the motor windings. -An investigation report concluded that:the; l
cause of the failure was generic and a combination of design and: -l f - motorswere:manufacturedandpurchasedunderthesame>kthree' pump
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- manufacturing errors.
- The licensee recognized:that al specifications.
' + .The 1A motor was rewound but no action was taken by the licensee on~ l the other two circulating water pump motors. -The five year test _ j interval was not changed. The licensee stated that a high potential
test was considered, but due'to concerns that the test: voltage would damage the insulation _or' accelerate its degradation, a decision was: _ d , ' made-to not perform a high potential test.The; inspectors' reviewed the vendor manual and noted that the vendor didLnot recommend an d over potential test but did recommend a high potential. test and , i several other tests as part of'PM, none of which were performed by ( the licensee. :The licensee's Nuclear Station Engineering Department-- l (NSED) recommendation. letter of September 20, 1988, states,.inLpart, q "... the failure'strongly suggests a. manufacturing' defect-in all
three (circulating water) motors.'_ The inspectors' believe that_ the
licensee's actions to monitor the two additional circulating pump. ~ -! motors were not prompt nor adequate.
' ~ d.
Maintenance Procedure Review The inspectors reviewed the following procedures for adequacy of work instructions, acceptance criteria, post maintenance testing i requirements, and ease of use: CPS 1029.01, " Preparation and Routing of Maintenance' Work Requests," i Revision 25 CPS 1034.01, " Station Preventive Maintenance," Revision 15
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< . .. - . , .a4 CPS 3909.03,' " Operating -Waste' Sludge System," Revision 11 - ~ CPS 8451.08, "Correctica Maintenance'for Motor Operated Valves with SMB-ST Operators," Revision 0 , 'y.
, ~ u .y , , . CPS 8626.01,." Turbine ' Supervisory Vibration Circuitry Channel l ..
Calibration," Revision 31 ' . CPS 8801;16,:" Wire'or. Component Removed / Jumper Installation,"
< ' ' Revision 12 g ' . , The procedures reviewed were: acceptable.
In general,.the proc.edures-(as appropriate) contained; adequate: instructions,. numerous: sign off ~ , steps,: acceptance criteria,0 records of "asi found'! and "as.1ef t" , conditions,;and post maintenance' testing requirements.
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Preventative Maintenance ~
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The' inspectors revie'ed the' implementation of PMs:'on.nonsafety-related iL w
systems and. components.
In most cases, all PM activities were "
.i ' " , controlled.and conducted in the same manner as safety-related : system's 1
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' ' ' Il ' and components.
Vendor recommended PMs were' adequately addresseds .
- for both safety and nonsafety related equipment.
PM work"was - q
. performed by uti'lizing the same maintenance personnel, the same Ci'4l documentation, and the same. methods-as used for safety-related; i ' < i g work.f In the tracking and control of PMs, however, an engineering t . evaluation was required for. deferral' or rescheduling' of ,.H":' 'j ' safety-related PMs; engineering; evaluation was notarequired forJ
' systems did not provide an easy method for identifying PMsenots
. 7] deferral or rescheduling of:nonsafety-related PMs.
The PM control' F '- , ' . completed by the due or late 'date, since rescheduling or deferral y established a new date. The number'of PM deferrals past the late.
j , date was small and'in most cases PMs were performed as scheduled! .; There did not appear to be a significant problem'with preventative jl ' ' maintenance in either..the safety-related or.nonsafety-related area.
., y + -The inspectors did identify that General Electric safety-related;
and nonsafety-related HFA.and HGA relays were not-included in the.
established PM program. The. vendor manual-recommended that types' .j , HFA and HGA relay. contacts be' periodically cleaned.
With :the HGA ll relays, the vendor also recommendeditesting the voltage pi.ckup;and
dropout voltages, and pickup timescat an interval'of one to.;two 1l years.
These periodic tests were not accomplished.
Additionally, the licensee did not perform an evaluation.or' review to exempt these q ' relays from the PM' program.
The inspectors recognize.'that there were no regulatory requirements to review vendor recommended maintenance for 80P. systems / equipment i for inciorporation in the -PM program.
However, the.above instances mg demonstrated that consideration of this information'could increase 1 ! < plant / component reliability.
Thus, the inspectors: recommended that" r, j th'e licensee should consider such reviews to ensure that'B0P J equipment failures do not cause unwarranted plant transients.
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maintenance programifor BOP;systemsland components.. There'was; adequate managemen.t attentior,7for the' maintaining of BOP,systemss
- Mw ~ and : components. : Additione'Jy, BOP, equipment was; noted t,y;the. team. - M to be included;in the licensee's predictive maintenance program.
' L /, - ThelicenseelsperformanceofB0Pmaintenancewas,exceptwheref j e.
not'ed elsewhere'in this report;'the equivalent of.maintenancel ,N y" / l. ' performed on' safety,-related components.
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1 action by the, licensee.on some BOPtcomrionents; ' , . . s n!j ' , -
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' ~ . . N: Measur'ing and testTequipment-usd_d'to' conduct maintenance wasJ
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'i 'within-its-calibration cycle."
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wereiaccurate'and performed on. schedule 6
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- 1Many QC withess points weresest$blished. and; performed. in'
accordance with the, work; instructions.
' t , , Battery surveillances performed onithe'nori-1Efbattefies to
verify cell l voltage, specific gravity and electrolyt.e lever were the' equivalent of the Class 1E batteries.
Current'non-1E
," battery eload calculations were accurate and indicated sufficient battery capacity.
'
Scheduled thermography checks' verb performed'on a number of BOP- ' 1;
components such as the power-transformers and"non-1E medium to high~ voltage breakers; ' j , , Currentas-builtdrawingsreviewedlwere-acceptable.
, One violation was identified ' 5.
Operations The on-shift. observations involved accompanying the non-licensed , operators on their. tours, witnessingcroutine' licensed operator activities'.in the Control Room, interviewing numerous on-shift and o j station management personnel on their duties and interactions with support organizations.
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s y , . . m E, q , , > ~ vc Asamp1efreviewbytheinspectorsifnosmal.an"dLemergency.. operating: procedures indicated that they 'were consistent with the;as-built drawings - s for the' systems and reflected recent' modifications..,The procedure' thate - s were.locat'ed in the< Control Room and'other. applicable areas were controlled, _ current, and approved', fori use ' "
- ' .3
< The reacior operators: that weri interUiewed byihe' inspectors' wire ~
knowledgeable in their duties, includingfthe use of normal and emergency n . operating procedures.
The. morale;of' the' operationsi department personn'el. , - appeared to:be-excellent and severalcsxpres' sed an optimistic attitude ? '
toward the recent,changestto exi ting plant"policiesisnd procedures.
j , <. J,. , * , The inspectors reviewed'the tagout;ppocEdurelCPSlNo.11014. 01H' Safety J . Tagging," and observed two' auxiliary operato.rs' during the performance;of . s " a danger tagout (90-0012) on the CondensateiSystem in' preparation-for a' ' Main, Condenser. tube inspection._ The auxiliary l operators performed the tagout_in accordance with current Clinton Station: procedures.
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- However, during thel inspectors' review ofthe'statio' jagout procedure _ n , and discussions with severa1 Shift Supervisors.and operators, it was- !
-noted.that several past practi.cesthave recently been discontinued in-J accordance with-revisions to the station tagout procedure.- Theses i practice's' included:. locking,of ' electrical current' breakers 'when danger t tagging, signinglof-danger tags by the person'doing the hanging,'and signing of the danger tags by the person who: performed the verification' process, as re. quired.
' ,l < - l It was also noted that-when the danger tag program was computerized in; _ the fall of 1989 several functions were discontinued and the inspectorsy~ l believe that,the program has lost some of.its' previous conservatism.
~ The inspectors recommended that operations department management' evaluate i current philosophy'in order to provide more positive' control of;the i station tagging program.
The inspectors reviewed CPS' procedure No. 1014.03,;" Temporary _.. Modifications," and also reviewed the temporary. modifications which ~ j > were presently installed.
The inspectors noted that_several temporary i modifications had been in existence for greater than.two years.
Subsequent discussions with operations department management indicated that management attention ~was being directed toward_ resolving some of the , long standing oroblems.
The inspectors'also interviewed several members -
of the Nuclear Support Engineering' Department including-several system i engineers. -The'= Nuclear Station Engineering Department had provided in depth engineering reviews'and created design change packages for:several
long standing temporary modifications.
The fo'llowing temporary modifications were reviewed- '
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88-044
- 88-058
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99-099 . , s .. ' ~ The-Operations Department. Director had recently instituted 'a Temporary
, = Modifications Tracking Program and had established a goal to-. reduce the number of' Temporary, Modifications to approximately fifteen by the:end of.
" , 1990.
The' inspectors reviewed _ CPS procedureLNo.' 1014.05L"PreparationofPost- ~ ' iMaintenance' Testing,'? and interviewedJseveral Shift Supervisors and - Assistant Shift Supervisors concerning the Post Maintenance: Testing- . program (PMT) at Clinton Station.
The: procedure for<PMT was-reviewed for applicability,-clarityrand completeness and no discre'ancies weres p noted.
The Shift Supervisors and Assistant! Shift Supervisors that _were ^ interviewed.concerning PMT were very' knowledgeable about the program and - ' aware of:its necessity. The overall Operations: support to others departments appeared:to be. aggressive and well planned with appropriate. numbers of Operations : personnel available1on-shift-..to support required-' commitments. -Overall, the Operations Department appeared to be well managed by' aggressive leadership which was also responsive-to changing j requirements.
i i No violations or deviations were identified. ' .1 e :i 6.
Management Support j Management support to B0P equipment issues:was evaluated'by reviewing the mechanisms available to the licensee-for the identification of B0P j problems and by assessing the effectiveness-of< licensee actions to j resolve identified problems, a.
The licensee employed the folloking~mechanismssto identify B0P
problems: The review of Condition ReportE(CR) corrective _ action i on significant events involving B0P. equipment:"the trending.of ' maintenance work requests (MWR) - Maintenance Trend _ Analysis;
Maintenance Improvemerit; Analysis; Program <(reliability 1 centered -
maintenance); and QualityrAssurance-(QA) auditstof significant B0P j issues.
li ' + , _ , ,g x > ~ o c TheCorrectiveAction'B'oard1(CAB)reviewedsdlec$e'dsignificant d condition report problems.to ' ensure accurateiproblem' identification, root cause analysis and corrective action'determinatiori.
Any B0P equipment implications. in a significant' problem.wo~uld receive appropriate managementLattention throughsthe CAB.
l, ' , Theinspectorsobserved_theCABmeetingcon'ductedonFebruary28, t 1990.
The inspectors noted that proposed corrective actions were
closely scrutinized for appropriateness and anyTapplicable' generic i implications.
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, , . 'l , , The Maintenance Trend Analysis (MTA) was conducted b) the Nuclear' Station Engineering Department (NSED) Reliability Engineering Staf f-. ' ~ ~ , .The inspectors reviewed NSED Procedure R.0, Revision 3, " Equipment Failure Maintenance Work Request Trending and Evaluation," dated E " June 15, 1988,- and_ discussed MTA'with the_ supervising engineer./ The program analyzed equipment failures over!a specified time and population through the review of MWRs.
Equipment problems s identified through the review would be.- further' analyzed for any; " *, failure trends.
Corrective actions completed ontthe Bailey Chart .
~ Recorders and> initiated on the.Camroll Bearings of the containment. c personnel hatch demonstrated the value.of MTA i.n identifying and , resolving BOR; issues.
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9 t- . . s Eight scrams experienced by the licensee 1were cause'd.by the failure- .
of-B0P equipment and controls, resulting inithe Maintenancei d'
' Improvement. Analysis Program (MIAP)..The,MIAP.-was developeditol ' upgrade the BOP maintenance by; optimizing' program.; effectiveness and.
' efficiency.
The upgrade-will be accomplished through a three phase < study which began with the Feedwater Delivery. System, Phase I.. Th'e- ' "' q study will involve ~ a systematic review and analysisiof the 80PF j ,_ system,'sub-system, component functions, failure modes (including trip logic / functions) and maintenance history;in. order to establish' , maintenance priorities consistent with s'afety, operability and'
< economic considerations.
Phase I was~being performed by the licensee at the time of the inspection.
The licensee anticipated that the Phase I: study would be completed by.. April. 30, 1990._ The licensee will then; modify the B0P maintenance program to ensure that the critical Feedwater Delivery System equipment isLappropriately; maintained to increase the reliability _of critical BOP equipment.
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Although no determination of MIAP effectiveness ~ could be reached.
-i at the time-of the inspection,- the program should result in the-
" identification of significant-B0P1 issues.
j
QA interest in B0P problems in the past resulted from QA. review of j condition reports, previous QA audit findings, NRC-open items, and .1 licensee event reports which may have involved B0P. issues. :The QA 't Department did perform a limited scope audit on,B0P Turbine-Trips (Q-38-89-18, dated September ~ 27,1989).
The QA audit determined-a-I need.to identify all B0P equipment failures which could result inEa R Turbine / Generator trip with subsequent. reactor: scram and to developu .an appropriate maintenance program to enhance BOP reliability; (Note: The MIAP will: resolve the QA findings).
] The inspectors concluded that the licensee has appropriate = -l mechanisms available to self-identify B0P -problems.
' .] b.
The inspectors reviewed licensee actions on NRC'identifisd B0'P issues contained in open items, inspection: reports and SALP-. 'Open .g - items-in NRC inspection reports received appropriate actio'n as i-demonstrated by the licensee's BOP preventive' maintenance program.
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The licensee's corrective action for BOP issues' identified ~1n the-Operational Safety Team Inspection'(OSTI) and the Clinton'SALP 9 " reports (NRC Inspection Reports No. 50-461/89030(DRP) and No. 50-461/89001(DRP),"respectively) was comprehensive.' Most- ; actions however, have only been implemented;recently or.have yet i' h to be fully implemented.
The effectiveness of the licensee's action !' will be determined after fu111 implementation has been achieved.
The l inspectors determined through interviews with~the Licensing staff I that open items, commitments'to the NRC, and othen NRC identified BOP issues.are directed to the appropriate licensee staff, where ' l _- generic BOP implications can be investigated and corrective action initiated.
The Licensing staff tracked actions through closure.
The inspectors concluded that.NRC identified BOP issues were usually- " appropriately addressed by the licensee. - 1 c.
The licensee had.a comprehensive' industry feedback program which was managed by the Licensing staff. ' Procedure L.1, Revision 4,. " Feedback Program," dated September 15, 1989, governed, licensee efforts.
Any BOP issues identified by the NRC, industryi-vendor and Architect / Engineer documents are reviewed-for' applicability, referred to appropriate staff.for the' development of an' action plan, . and then tracked to action plan completion.
The inspectors reviewed l ' several NRC.and. industry originated notifications.
NRC' notifications generally received good management attention and-were promptly 'd . L' addressed.
The inspectors noted, however, that the licensee di not devote appropriate resources to certain industry originated ' recommendations prior to May 1989.
By Fall 1989'the licensee had dedicated the resources necessary to' properly address all applicable.
industry recommendations and to. review completed actions for effectiveness.
The inspectors interviewed-an Independent Safety Engineering Group (ISEG)' representative and determined that no'B0P failure occurred prior to Fall 1989, as a result of the insufficient.
action on some industry recommendations.
. . The inspectors concluded that the licensee's feedback program was effective in identifying and addressing ~ Clinton B0P issues, Thelicensee'cpeticipationinind'ustryinitiativesthroughtheBWR i d.
Owners Group (BWROG). appeared extensive.
The BWROG participation i evidenced licensee support to the identification and resolution of y' j t BOP issues.
Other indications of management support are described'belowIy' ' The-inspectors observed contractors installing Raychem splices on L control cables.in safety-related electrical penetrations 1EE32E, " under HWR D04862.
The group-appeared to be well supervised.
The ' work was stopped by the workers in'the field,when they could not workers obtained additional' guidance from'Lspecifications & The-' managem perform the work in accordance with MWR's > resumed. This is an' improvement over previo~us performance 'of' - contractors at Clinton, s, , , . . G
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The inspectors also attended the' daily outage meetings.
These meetings appeared to be an excellent forum for. dissemination of accurate and concise information on outage progress, problems and anticipated problems.. Good consideration was given to ALARA for all planned and emerging work.
Personnel safety was emphasized.
Problems / events were promptly critiqued and information disseminated to work crews.
Good staff coordination mitigated many problems that arose during outage. briefings.
Good planning skills were demonstrated.
The outage appeared to be effectively controlled, (i.e., work efforts, planning and scheduling, contractor oversight' _ , procedural. compliance, minimizing personnel errors, emphasis on . personnel safety, and good communications). -In preparation,for the outage the licensee conducted " Outage Management Seminars." The inspectors attended sever'a1 of;these seminars and they seemed very effective with good planning, an' excellent exchange of,id,eas,'and good discussion of potentia 1' problem areas.
Theinspectors.determinedthattbelicenseehasallocathd, significant resources to the resolution of previously identified BOP ' ' problems and to the identification / study of new BOP issues.
The BOP ., maintenance program will be further evaluated when OSTI/SALP report H corrective actions have been;fullys implemented and have been ' functioning for a period 'suf ficient to' assess' effectiveness.. :The licensee initiatives in the'Maintenanc'e Improvement Analysis' Program will be evaluated to determine if BOP equipment' reliability was' enhanced.
, , No violations or deviations were identified.# ' . 7.
Root Cause Analysis .
The inspec{ ors reviewed the plant operating histury fof the past two. i years and selected five post trip review packages for' evaluation.
The packages covered trip numbers 15, 16, 19, 20.. and 21 from July 16, 1988 through July 31, 1989.
These reactor trips were all initiated by B0P equipment, The inspectors reviewed each package'to verify that the root cause of the trip had been ascertained and abnormal ' component responses identified. :The inspectors reviewed the corrective actions to ensure that they were adequate and timely and were effective in preventing recurrence.
' The inspectors reviewed the licensee's root cause analysis procedure CPS procedure No. 1041.01, " Post Trip Review," to verify that it contained adequate provisions for evaluation of the transient and review of abnormal equipment responses.
Post trip review packages 16 through 21 & were acceptable; however, the inspectors did' identify several concerns , with review package 15.
' This event was initiated by a failed limit switch on the turbine building condenser pit sump high water level circuit.
When this switch failed, in conjunction with an already failed sump level switch, all three circulating water pumps tripped.
This led to a loss of condenser vacuum: , 16?
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i i . . and a turbine trip, reactor trip, and: subsequent' main steam =line isolation.. The corrective action stated forithis trip was, W R C53329 written to investigate / troubleshoot / repair condenser pit. level ~ - switches." The first concern was that>this statement was not a , . description of corrective actions taken to prevent recurrence, but was only ansaction plan.
Nor could the' inspectors find any records which u indicated'that management had evaluated this event from a broad , perspective.
Questions such as the following were not addressed: (1) Was the design of the circulating water pump-trip circuit appropriate , with an automatic trip or would an alarm in the control room and-subsequent operator manual action be adequate, (2) Was the design of.
a this level switch appropriate for its use in this location, (3) Had-maintenance on the switch, or. lack thereof, caused this problem, . . ' (4) How did the unmonitored failure of the first level switch contribute-
to this~ event, and (5) Was'the lack of any external indication of the > status of the level switches (on or off) a contributor to this event.
The second concern deals with the classification of the type of trip (types I through V, (relating to understanding the cause of the trip, did ' all the plant equipment respond properly, and were there any abnormal chemistry or radiation readings)).. This trip was classified as' type I (the cause of the trip is known and all safety-related and important to safety.. equipment functioned properly during the transient).
However, the , trip package > stated that the A reactor recirculation flow control valve '(FCV) did not run back to the required position when reactor vessel water ' level dropped to level 4'setpoint but locked up.
Subsequently, it was
, reset and did run back to its required position.
These facts were. stated on the post tripfreview and should have resulted in classifying this trip l ' " as a type II' (equipment did not function properly).
Based on a review of ' ~ > < the existing records the inspectors were unable to determine if_this + apparent malfunction of the FCV was ever resoli/ed.
The' third' concern deals with onsite review of.the post trip review I ' , package by'the. Facility Review Group (FRG).
Minutes for FRG meeting , v 88-068 indicated that the FRG did identify a concern with the operation . of the FCV and that one of the members of the FRG agreed to initiate a
condition report'to investigate this problem; however, the condition
report'was.never initiated.
Additionally, the FRG meeting minutes , contained no indication that questions on the. acceptability of-the + ' ' circulating water pump trip circuit or maintenance of.the level switches-were ever discussed.
Discussions with members of the FRG indicated-that, . these questions were probably discussed but not documented.
Nor did the FRG identify that the trip package was improperly classified (based on " the response of the FCV).
ticensee Event Report 88-019 stated in various portions that all equipment responses to the transient that followed the scram occurred.
> as designed and that the FCVs ran back to minimum position when reactor vessel water level dropped past level 4.
When the inspectors. questioned the discrepancy between the post trip review package and the LER, concerning the response of the FCV, the licensee was unable to provide ,
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In subsequent reactor-trips the FCVs have responded properly; consequently, the inspectors did ' not have any concerns with their operability, but the inspectors were . concerned with the licensee's evaluation and documentation of abnormal-equipment responses.
Overall, the inspectors viewed the post trip review' process as a technique to be used by plant management to evaluate the response of the plant; and that the evaluation and any conclusions need to be documented / and completed prior to restart.
Additionally, the post trip review process was not just within the purview of the Operations Department, but was the responsibility of all departments at Clinton station.' The licensee was encouraged to improve its efforts in documenting evaluations and decisions.
The inspectors did note improvements in the documentation of the post trip review packages which occurred after trip 15.
In subsequent' discussions with licensee management they indicated that.the FRG would evaluate its method of reviewing and documenting evaluations of post trip packages.
No violations or deviations were identified.
8.
Conclusions The inspectors concluded that nonsafety-related maintenance activities were acceptable and were performed'in much the~same manner-as safety-related maintenance activities.. MWRs and procedures were used, work was accomplished by skilled maintenance personnel, and the work was generally documented in the same manner as safety-related work. The previously noted problem of failure to follow maintenance procedures was not noted by the inspectors during this inspection.
Maintenance personnel appeared to be knowledgeable and adequately trained in the work performed.
The inspectors noted that some nonsafety-related work, such as radwaste, was given such a low priority for maintenance work that the ability of
the systems to perform their intended functions under abnormal conditions was questionable.
The implementation of PMs on nonsafety-related systems and components I was acceptable.
In most cases, all PM activities were controlled and conducted in the same manner as safety-related systems and components.
Vendor recommended PMs were adequately addressed for nonsafety-related equipment, in most cases.
PM work was performed by utilizing the _ same maintenance personnel, the same documentation, and the same methods as '
used for safety-related work.
In the tracking and control of PMs, however, an engineering evaluation was required for deferral or.
' rescheduling of safety-related PMs; an engineering evaluation was not , ' required for deferral or rescheduling of nonsafety-related PMs.
The'PM control systems did not provide an easy method for identifying PMs not completed by the due or late date.
The number of PM deferrals past'the - late date was small and in most cases PMs.were performed as scheduled.
There did not appear to be a significant problem with preventative , maintenance of BOP systems.
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.' ,'+ j' [ } . . " . ,/ ~ The material: condition of the plant was adequate;!however,lthe radwaste .. area needed significant attention,q During-discussions,kplant mana'gement ij h . m , ~' '4v < stated that programs to.: improve the radwaste' system and reducelthe.
- U overall number of ~MWRs.had been developed and would be implementedcafter,, ,e this maintenance outage'was completed.
. , , . . .. +. .
^ - The inspectors believe a" weakness existed in' the' utilization of procedures" by personnel from the Illinois Power corporate officerin DecaturL(relay
calibration and maintenance) which do not appear to meet the standard. set "Y for Clinton. station personnel or the standard which would be' imposed on ~ any contractor who performed work at Clinton Station.
During the. exit ' ' interview, licensee management' expressed disagreement with this'issuec ' .. . ... . . One violation was identified involving the failure to perform an appropriate 10 CFR 50.59 evaluation'(see Paragraph'4.a).
> , 9.
<ExitInterview(30703) ,, The: inspectors met with the licensee' representatives denoted in Paragraph 1-at the conclusion of the inspection on March 6, 1990.
The. inspectors . summarized the purpose and ' scope.of the inspection and the findings.
-The inspectors also discussed the likely informational content of the 1,5 _, inspection report, with regard.to documents or processes reviewed by~the' , ' .." inspectors during the inspection.
The licensee did not identify any such-documents or processes as proprietary.
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