IR 05000461/1990007
| ML20034A640 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 04/12/1990 |
| From: | Gardner R, Kopp M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20034A637 | List: |
| References | |
| 50-461-90-07, 50-461-90-7, NUDOCS 9004240035 | |
| Download: ML20034A640 (8) | |
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U. S. NUCLEAR REGULATORY COMMISSION
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REGION III
Report No.:
50-461/90007(DRS)
Docket flo.:
50-461 License No.:
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Licensee:- Illinois Power Company 500 South 27th Street
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Decatur, IL 62525 Facility Name: Clinton Nuclear Power Station I
Inspection At: Clinton, IL 61727 Inspection Conducted: March 26 through 29, 1990
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Inspector:
/k40 M. J.' Kopp Date
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Approved By:
M*W (ft YM R. N. Gardner, Chief ~
Date Plant Systems Section Inspection Summary Inspection during March 26-29, 1990 (Report No. 50-461/90007(DRS))'
Areas Inspected: Special safety inspection concerning previously identified environmental qualification (EQ) inspection findings; licensee corrective actions regarding the Clinton EQ Program; licensee actions regarding the
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installed configuration of EQ Rosemount transmitters; licensee actions regarding the installed configuration of EQ Weed Resistance Temperature Detectors (RTDs);
and licensee actions concerning overpressurization of EQ ASCO solenoid valves (Modules 30703 and 62705).
Results: Ofthefiveareasinspected,oneviolationwasidentified(Paragraph
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2.c.); however, in accordance with 10 CFR Part 2, Appendix C, Section V.G, a Notice of Violation was not issued. One unresolved item was-also-identified in this report. The unresolved item concerned the need to review the safety significance and licensee's corrective actions regarding loose cover housings on Rosemount transmitters. Strengths observed in the licensee's EQ program included the following:
The licensee has taken adequate measures to ensure that the previously
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identified EQ equipment deficiencies have been corrected. Certain EQ
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equipment will be repaired or replaced during refueling outage #2, per previous licensee commitments.
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The licensee has taken steps to improve the overall EQ Program. This
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was evidenced by the addition of experienced EQ personnel to the licensee's
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staff, the implementation of EQ training throughout the organization, and the licensee's commitment to perform a walkdown of priority EQ equipment during refueling outage #2.
One weakness was observed regarding the licensee's support of the EQ plant walkdown during this inspection. The walkdown was not well coordinated and there appeared to be communication problems among the different plant organizations.
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DETAILS
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1.
Persons Contacted
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Illinois Power Company (IPCo)
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- J. S. Perry, Vice President
- J. G. Cook, Plant Manager
- R. E. Wyatt, Manager, Quality Assurance
- J. A. Miller, Manager, Scheduling and Outage Management
- R. D. Freeman, Manager, Nuclear Safety Engineering Department
- J. D. Palmer, Manager, Nuclear Training Department
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J. F. Palchak, Manager, Nuclear Planning and Support
l F. A. Spangenberg, Manager, Licensing and Safety
- R. B. Gill, Director, Nuclear Projects
- S. P. Hall, Director, Nuclear Program Assessment
- D. L. Holtzscher, Director, Nuclear. Safety
- T. R. Chitester, Director, Dasign Analysis
- R. W. Morgenstern, Director; Plant Technical Staff R. F. Phares, Director, Licensing
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- M. M. Kahn, Supervisor, Environmental Qualification
- K. A. Baker, Supervisor, Inspection & Enforcement Interf ace K. W. Dittman, Quality Assurance i
l V. P. Bacanskas, Quality Assurance
- S. 1. Meador, Planner
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Soyland Management-
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- J. Greenwood, Manager, Power Supply V. S. Nuclear Regulatory Connission (U. S. NRC)
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- P. G. Brochman, Senior Resident Inspector S. P. Ray, Resident inspector
- Denotes those present at the exit interview conducted on March 29, 1990.
2.
Licensee Action on Previously Identified Findings a.
(Closed) Violation (50-461/89006-01(DRS)):
This violation addressed the licensee's failure to take adequate
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corrective actions to resolve a previous violation concerning unqualified Amp Kynar butt splices installed in EQ circuits and EQ junction boxes located in containment that contained Okonite taped splices without the required weep holes. The' licensee's corrective actions failed to identify and repair all butt splices and junction boxes within the scope of the program.
As a result of the identification of the deficiencies noted above, the licensee formed an independent review board to review the methodology used to identify and repair the splices and junction boxes. The review board determined that the initial corrective action program to identify and repair splices and junction boxes
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allowed for the deletion of EQ equipment based upon factors such as the construction specification which prohibited the use of splices on certain equipment.
For example, the program did not account for construction errors that resulted in the use of splices contrary to the specification.
Therefore, the review board decided to review
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and inspect, as necessary, all EQ components required to operate in a 100% relative humidity environment in order to ensure that butt splices and junction boxes were identified and repaired.
During this inspection, the inspector reviewed Clinton Power Station
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(CPS)ConditionReports(CR) 1-89-04-035 and 1-89-04-072. These-CRs listed the equipment that was determined to be within the scope of the butt splice and junction box reinspection programs (initial
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and final) and the category of equipment that was-deleted.
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Justification for each category of equipment not reinspected was-
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also documented in the CRs. The inspector performed a selected-review of the licensee's justification for equipment that was not reinspected and determined that the licensee's justification appeared i
to be acceptable.
In addition the inspector performed a walkdown of.
t selected EQ equipment in the plant, including equipment excluded from the licensee's reinspections.
Based on the inspector's review and walkdown of selected EQ equipment, this violation is considered-
closed, b.
(Closed) Violation (50-461/89014-08(DRS)):
This violation concerned five examples of-the licensee's failure to ensure that EQ equipment was installed in the plant in accordance with the EQ tested configuration. The five examples cited in the Notice of Violation (NOV) were:
1) unqualified taped splices used-to terminate the field connections-on the hydrogen igniters; 2)'
instrument circuits landed on terminal blocks.on General Electric-(GE) supplied instrument racks not analyzed for leakage currents; 3)
ASCO solenoid valves terminated with unqualified connectors; 4)
limit switches not qualified for the postulated humidity. environment that they were located in; and 5) Conax electrical penetration enclosures installed in an unqualified configuration that would allow spray to impinge on instrument and control circuit terminal blocks'.
As a result of the above violations, the licensee took corrective action and replaced the unqualified splices on the-hydrogen igniters with qualified Raychem splices, replaced the terminal blocks on GE
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instrument racks with Raychem splices, installed Raychem heat shrink tubing over the connectors associated with the ASCO-solenoid valves, and installed an Electrical Conduit Seal Assembly (ECSA) on the limit'
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switches.
In addition, the licensee has replaced selected terminal blocks in Conax penetrations with Raychem splices and committed to the replacement of the remaining EQ instrument and control circuit terminal blocks in Conax penetrations during refueling outage #2.
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During this inspection, the inspector performed.a walkdown of selected-EQ equipment in order to determine the acceptability of the licensee's corrective actions. The walkdown samples included hydrogen igniters, GE instrument racks, and electrical penetrations. Based on the i
acceptable results of this walkdown, the inspector determined that
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the licensee has taken adequate corrective actions and this violation
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is considered closed.
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c.
(Closed) Unresolved Item (50-461/88009-06(DRS)):
i ThisitemconcernedWeedResistanceTemperatureDetectors(RTD)
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that did not have the terminal blocks or cover housing threads potted-
to prevent moisture intrusion as required by the EQ program. The licensee initiated Revision 01~to CR 1-88-04-095 on April 27, 1988, y
to document the identified discrepancies, provide-corrective action,
and to evaluate the root cause. The licensee performed a test and analysis of the unpotted configuration to demonstrate qualification
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of the RTDs for the duration that they were installed in the plant without the potting material.
In addition, the licensee sealed the terminal boards and cover housing threads on the RTDs.
During this inspection, the inspector _ reviewed Wyle Test. Report No.
40065-01 and Sargent and Lundy Calculation No. CQD-039466, dated.
April 25, 1988. These documents provided test results and an analysis-
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of unpotted Weed RTDs that were exposed to a Design Basis Accident (DBA)correspondingtotheClintonenvironmentalaccidentprofile. The test results and the analysis appeared to be acceptable.
The NRC inspector informed the-licensee that the previous failure.
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to have documented evidence of the qualification of the Weed RTDs in
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the applicable EQ file represented a violation of 10 CFR 50.49-
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requirements (50-461/90007-01(DRS)).
However, this violation meets the tests of 10 CFR Part 2, Appendix C, Section V.G.1; consequently,_
a Notice of Violation will not be issued, and this matter is I
considered closed.
3.
Corrective Actions Concerning the Overall EQ Program
l In addition to the corrective actions identified in Paragraphs 2.a. and
2.b., the licensee committed to upgrading the overall EQ program at the l
Clinton Power Station. The licensee's commitments were identified in-l IPCo's letter U-601477 dated June 30, 1989, and also in letter.U-601504
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dated August 8, 1989. Examples of the licensee's commitments included:
1) the hiring of additional personnel with EQ experience;'2) verification of the adequacy of the EQ baseline; 3) verification of the adequacy of the EQ zone boundaries; 4) verification of the adequacy of the EQ packages; 5) review of EQ procedures; and 6) additional training of personnel involved in the EQ program.
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During this inspection, the inspector interviewed licensee management and supervisory personnel concerning the commitments that have been implemented
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and the results achieved. The licensee stated that the addition of
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experienced EQ personnel to the engineering-staff has led to improved communications throughout the plant with respect to EQ requirements and-
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responsibilities.
In addition, the licensee stated that general EQ training has been given by the EQ supervisor to personnel throughout the organization and that specific training is scheduled within the next few
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months. The general training, according to the licensee, has served to increase EQ awareness at Clinton.
In addition, the licensee committed to l
performing walkdowns of priority EQ equipment during refueling outage #2.
to provide further verification that the EQ equipment at Clinton meets the s
configuration requirements identified ~in the EQ packages'.
No NRC concerns were identified.
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EQ Rosemount Transmitters CPS CR 1-89-11-036 was initiated on November 15, 1989, to document a loose cover housing found on EQ transmitter IC71-N050A. The licensee's corrective action resulted in a walkdown to verify that the cover housings
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on EQ Rosemount transmitters were hand tight.
As a result, six transmitters were identified with loose covers and four were found with loose conduit fittings. Maintenance Work Requests (MWRs) were written to tighten,the~'
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cover housings and conduit fittings.
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CPS CR 1-90-02-026 was initiated on February 12, 1990,.and documented l
another loose cover housing found on EQ transmitter ILT-CH260D.
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management decided to verify that the cover housings and conduit fittings-on all EQ transmitters were properly torqued.
EQ requirements specified a'
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torque value of 200 inch pounds for cover housings and 150 inch pounds or.
four to seven turns hand tight for conduit fittings. MWR D15049 was -
written to verify the cover housing and conduit plug torque, and neck seal integrity on all EQ Rosemount transmitters located in a 100% relative humidity environment.
As a result, thirteen transmitters were declared to have been previously inoperable and are documented in Licensee Event
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Report (LER) 90-003-00.
The licensee's root cause analysis stated that the corrective action taken
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to resolve the initial problem identified in CR 1-89-11-036 was poorly planned and coordinated, that there was no independent verification of the completed corrective actions, and that the decisions and approvals regarding resolution of this issue were made late at night and were the last restreint prior to restart.
Pending further NRC review of LER 90-003-00 concerning safety-significance
l and the licensee's corrective actions, this is considered an Unresolved Item (50-461/90007-02(DRS)).
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5.
Potential Failures of EQ ASCO Solenoid Valves NRCInformationNotice(IN)88-24,"FailuresofAirOperated. Valves (A0Vs)
Affecting Safety-Related Systems", alerted licensees to potential problems I-with A0Vs in safety-related systems.
Specifically, the IN addressed the j
affect of nonsafety-related air system failures-on safety-related' air
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operated solenoid valves (S0Vs).
As a result of IPCo's review of IN 88-24, 73 solenoid valves were identified s
with a maximum operating pressure differential (M0PD) of less than the 110
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psig maximum instrument air (IA) pressure.
Failure of the air regulator sets supplying air to the SOVs could result in full system pressure being supplied to the valves and subsequent failure of the valves in a nonsafe-
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position. Further review by the licensee concerning the reliability of the nonsafety Fisher Air Regulator Sets, the affects of the accident environment on the BUHA-N elastomer contained in the regulators, seismic suitability, and redundancy concluded that the S0Vs are operable until the.
<i next refueling outage. The licensee has committed to replace the affected S0Vs with higher rated MOPD valves.
During this inspection, the. inspector reviewed the licensee's analysis-concerning the ability of the BUNA-N material contained in the. air
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regulator sets to withstand the accident enviror. ment conditions, and.the licersee's review concerning redundancy.
Based upon the licensee's analysis, the inspector identified no additional concerns.
No further NRC concerns were identified.
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6.
Violations for Which a " Notice of Violation" Will Not be Issued The NRC uses the Notice of Violation (NOV) as a standard method for formalizing the existence of a violation of a legally binding-requirement.
However, because the NRC wants to encourage.and support licensees initiative for self-identification and correction.of problems,'the NRC.
will not generally issue a NOV-for a violation that meets the tests of 10.
CFR 2, Appendix C,Section V.G.I.
These tests are:
(1).theviolationwas identified by the licensee; (2) the violation would be. categorized as Severity Level IV or V; (3) the violation was reported to'the NRC, if required; (4) the violation will be corrected, including measures to prevent recurrence, within a reasonable time period; and (5) it was not a violation that could reasonably be expected to have been prevented by the licensee's corrective action for a previous violation. -In addition,Section V.A states that for isolated Severity Level V violations, an NOV normally will not be issued regardless of who identifies the violation provided the licensee has initiated appropriate corrective action before the report ends. Violations of a regulatory requirement identified during the inspection for which a NOV will not be issued are discussed in Paragraph 2.c.
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Unresolved item An unresolved item is a matter about which more information is required in order to ascertain whether it is an acceptable item, an open item,
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a deviation, or a violation. An unresolved item is discussed in Paragraph 4 of this report.
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Exit Interview The Region III inspecter tet with licensee representatives (denoted in Paragraph 1) at the conciusion of the inspection on March 29, 1990. The inspector discussed the likely content of the inspection report with regard to documents or processes reviewed by the inspector..The licensee did not identify any such documents or processes as proprietary.
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