IR 05000461/1990027
| ML20217B203 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 02/28/1991 |
| From: | Lougheed V, Neisler J, Rescheske P, Vanderniet C, Yin I NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20217B185 | List: |
| References | |
| 50-461-90-27, NUDOCS 9103120029 | |
| Download: ML20217B203 (18) | |
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U.S. f10 CLEAR REGULATORY C0!VIISS10tl REG 10tl 111 Report ho. 50-461/90027(DRS)
Docket flo. 50-461 License flo. tiPF-62 Licensee: Illinois Power Company 500 South 27th Street Decatur, IL 62525 Facility flame: Clinton Power Station Inspection At: Clinton, IL 61727 Inspection Conducted: December 17, 1990, through January 30, 1991 Inspectors: &Gu I00/Q Peggy /RJ Re'scheske
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Operational Programs Section Inspection Summary Inspection on December 17, 1990 through January 30, 1991 W6 port ilo. 50-461/90027(DRS))
Areas Inspected: Routine, announced team inspection to assess control and EpTementation of temporary and permanent plant design changes (IP 37700).
Results: Two previously-identified open items were closed. One violation was identified in the are of design contro The licensee's temporary modification program adequately controlled simple plant alterations; however, an example was identified in which the design and engineering aspects of a temporary nodification were considered weak.
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The inspectors noted that a full 10 CFR 50.59 safety evaluation Was performed ,
for- all temporary modifications, which was considered to be a very conservative practice. All the 10 CFR 50.59 safety evaluations reviewed by the inspectors
.were generally of high quality. The evaluations were well documented, and demonstrated a technical understanding of the safety issues involve The inspectors reviewed twenty -(20) permanent plant design changes. Weaknesses were identified in the licensee's design control process, including design verification and testin Engineering evaluations in the form of calculations were generally adequate in regard to the-final results; however, they were not lete and did not documint design assumptions or verification. One always violationcomp (with two examples) was identified for failure to satisfy the design control requirements of 10 CFR Part 50, Appendix B, Criterion III (Paragraphs 4.a, 4.f). Other examples were identified which were representative of the design control weakness (Paragraphs 4 b, 4.e, and 5).
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REPORT DETAILS Persons Contacted-J. S. Perry,'Vice President G. L.- Baker,- Director,- Plant Support Services (PSS) !
K.-A. Baker,. Project flanager, Corrective Action Program J.11. Bednarz, Principal Assistant to Vice President A. K. Beecher, Operations Support J. W. Blattner, Project Site itanager, Sargent and Lundy (S&L)
J. G. -Cook, Plant 'itanager P. Frank, Graduate Trainee R. B. Gill,.itanager, fluclear Training and Projects and Assessments K. R. Graf, Director, QA J. Greenwood,itanager, Power Supply D.'t. Holtzscher, Director, Nuclear Safety :
R.-T. Kerestes, Director, Engineering Projects D. Korneman, Director, Systems and Reliability, NSED R. Langley, Director, Design and Analysis J. A. fiiller, lianager, NSED K. floore, Director, Plant Technical R. W. f4crgenstern, llanager, Scheduling and Outage fianagement
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J.-Neuschwanger, Supervisor, Plant Operations A.11. florris, Assistant Director, Systems and Reliability J. F. Palchak, flanager, flP & S J. L. Peterson, Supervisor, Technical Assessment R..Phares,. Director, Licensing J._W. Pruitt, Director, Programs and Administration-J. Puzauskas, Assistant Director, Design and Analysis J. V. Sipek, Supervisor, Regional Regulatory Interface F. A. Spangenberg, tlanager, Li~ censing and Safety R'. Stevens, Auditor G. C. ' Welsh, Assistant fianager, NSED R. E. Wyatt, !!anager, QA All.of thesabove individuals attended the exit meeting held onsite on
- January 11,1991. Additional material was submitted by the licensee, and discussions were held subsequent to the onsite portion of the inspection. The results of the inspector's review were discussed with J. Sipek of Licensing and Safety. on January 30, 1991.
, Others. contacted during the course of the inspection included members of~the
- licensee's system / design engineering, operations, and technical staffs, and Sargent &'Lundy (S&L) representatives, i
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, Action on Previously Identified Items (Closed) Osen Item'(461/86066-01(DRS)): Incorrect position for valves F040 and F068 during Type A test. The inspectors reviewed !
the licensee's Updated Safety Analysis Report (USAR) and Clinton 1 Procedure CPS 9861.01, Revision 21, " Integrated Leak Rate Test (ILRT)," and determined that these valves were correctly configured for the Type A test. This item is considered close _(0 pen) Open Item (461/86066-02(DRS)): Tne inspectors reviewed Field Alteration C-F057, which would add a temperature sensor inside containment during the ILRT. Additional ilRC review was needed, including review of the results of the temperature survey. The review and closure of this item will be discussed in flRC Inspection Report flo. 461/9100 (Closed) Open Item (461/87033-02(DRS)): Acceptability of increased temperatures inside containment. The inspectors reviewed the information'in TI 2515/98 and Information flotice 87-65, and the licensee's findings in condition report CR-1-88-10-108, and concluded that the increased-containment temperatures were acceptable. This item is considered close . Inspection Scope The objective of the inspection was to assess the licensee's control and implementation of plant design changes, and to verify _ the technical adequacy of the design and engimering, installation, and testing. The inspection included a sampling of permanent plant design changes and a selected review of associated documentation, such as 10 CFR 50.59 safety reviews, design and calculations, installation, testing criteria and results. .The depth of the review varied with each design change; for several design changes, the inspectors observed portions of the installation and/or testing in progress, or walked down the' completed modification. The licensee's temporary modification program and
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implementation was also evaluated during the inspection. -The 10 crR 50.59 safety evaluation was reviewed for each permanent and tenprary-design change selected, and the licensee's safety review program was assessed. Quality Assurance (QA) involvement in the nodification process was also assessed as a matter of' routine. An inspection summary, which includes a discussion of licensee strengths and weaknesses in the areas evaluated, is in Paragraph 7 of this repor . Permanent Plant Design Changes The licensee's design change program was controlled by fluclear Station Engineering Department (ilSED) Procedure D.55, " Modification and Configuration Change Control," and Clinton Power Station Administrative
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Procedure CPS lio. 1003.01, " Design Control and !!odification." A design
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,.hange was considered a modification if it had significant impact on '
plant operation and was complex from both a technical and installation standpoint. Therefore, the majority of the design changes implemented by the licensee were defined as field alterations. The majority of the design work (including calculations) was contracted to the architect engineer (A-E) and others. The inspection team reviewed twenty (20) design-changes, three (3) of which were completed prior to the current refuel '
outage. The following is a brief description of each, and a discussion
- of the deficiencies identified when applicabl , Field Alteration C-F057 This field alteration added a temperature element in the liain Steam Tunnel area, as. discussed in NRC Open Item 461/87066-0 The -
alteration was comprised of two parts: recalculating the volume fractions for the ILRT accounting for the new sensor, and installation of wiring for the senso (The actual sensor would be installed only during the ILRT.) The inspectors reviewed the safety evaluation for the alteration and found it to be acceptable. The '
inspectors also reviewed the calculation of the temperature volume weighting fractions. The results of this review are discussed below. The inspectors reviewed the post-modification . testing for the alteration. The_only testing done at the time of-the review was a continuity check on the wiring. Review of the results of the temperature survey, and closure of the Open item, will be discussed in ilRC Inspection Report No. 461/91002.
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NSED prepared Calculation tio. 323, Revisir,n 0, on flarch 27, 1990, in support of the above alteration. Calcukcion No. 323 relied upon
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information presented in NSED calculation No. 21, Revision 1, which was the latest in a series of calculations dating back to ,
April 4, 1983. Problems which were noted in the calculation chain were:
1) The licensee was unable to produce a copy of NSED calet:lation
>- 11 0 . 21, Revision 0, during the inspection. Without Revision 0, there was no calculated basis for some of the numbers used in succeeding calculations.
F 2) The licensee did not provide a written justification for increasing the calculated containment volumes and decreasing the drywell volumes in order to arrive at the USAR stated volumes for the containment and drywel ) The licensee did not justify changing the methodology in the latest calculation used for calculating the weighting fractions for
. two subvolumes from that used in previous revision ,
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4) A 1985 Bechtel calculation specifically did.not. follow the requirement that the design be verified or checke Subsequent discussions-concluded that the final weighting fractions for the ILRT were acceptable. The licensee agreed to document the design basis in a traceable manner prior.to the end of the outage, and to (in the long term) revise the calculatio CFR Part 50, Append _ir B, Lriterion Ill, Design Control, as implementet by. CPS Quality Assurance-flanual and several flSED procedures, requires that certain design control measures be established to control and verify the adequacy of design. The deficiencies identified above in the calculations supporting Field Alteration C-F057, constitute an example of a violation (50-461/90027-01a(DRS)).
Further discussion of the weakness identified in the licensee's-design control process is in Paragrapn 7 of this report, Field Alteration HP-F004 This field alteration added an c. ice in the high pressure core spray (llPCS) test line return to the reactor core isolation cooling (RCIC) tank, and installed a boot seal for secondary containment boundary. This alteration was performed to reduce the vibration in the llPCS test return line in order to ensure that secondary containment integrity was maintained. Additionally, the use of a boot seal on the secondary containment boundary provided more flexibility in the penetration seal, such that secondary conton""ent inteority would be maintained if vibration did occu The inspectors reviewed the safety evaluation, supporting calculation, and post-modification testing. 11tnor problems were found with the calculation, as discussed below. The safety evaluation was thorough, as was post-modification testin Calculation flo. OltlP2, Revision 4, was prepared by Sargent and Lundy on September 20, 198 During the inspectors' review of this calculation, numerous mathematical and transcription errors were note The deficiencies identified in the calculation did not affect the results; however, the design control weaknesses were representative of other examples identified in this report. During the exit meeting the licensee stated that this calculation had been verified by use of an alternate calculational method, rather than by a straight revlew of the calculation.
4 Field Alteration MS-F012 This field alteration provided a more reliable seating method for the main steam isolation valves (MSIVs). This alteration was being worked as eight separate field packages - one per MSIV. Installation
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of the modification was dependent upon the local leak rate test (LLRT)
results, in that the modification was only performed this outage on the one tISIV that failed the LLRT. The modification, which has been proposed for all General Electric Boiling Water Reactors with Atwood and florrill IISIVs, involved installation of a'n anti-rotation poppet / pilot assembly. The safety evaluation, the proposed changes to the USAR, and the post-modification testing were found acceptable, Field Alteration CC-F006 This field alteration replaced the relief valve on the component cooling water ~(CCW) storage tank. The modification was performed to minimize leakage of nitrogen from the tank by using a valve with a tighter seat, thus improving CCW pump net positive suction hea The design documentation, including the 10 CFR 50.59_ safety evaluation screening, was acentabl Field Alteration ES-F006 This field alteration was intended to accomplish two task First, the four safety-related main condenser vacuum pressure transmitters (pts) for initiation of ilSIV Group I isolation were to be relocated
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to higher elevations to provide-continuous instrument line sloping back to the condenser. -Second, two non-safety related basket tips were to be installed on the vacuum sensing line inlets inside the main condenser to eliminate any possible flow velocity impact on instrument accuracy. The inspectors reviewed the design documentations and observed the PT installation in progress,-and identified the following deficiencies:
(1) The license'e's 10 CFR 50.59 safety evaluation screening for this modification was considered to be weak in that half of the justification for not requiring a safety evaluation described the purpose of the alteration, and the other half of the justification was so general that no specific references to any USAR, TS, or procedures were documente (2) The inspectors observed that two of the four pts were installed on solid block walls by means of wedge type expansion anchor bolts, but the calculation only considered these bolts installed in concrete. As a general rule of expansion bolt design, a masonry block has less'than half the tensile strength of concrete, and has predictable shear characteristics. The
, licensee agreed with the inspectors and requested the A-E'to-evaluate the installation on solid block walls. The new calculation showed the installation to be adequat ,
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(3) The design of the basket tip-was without any documented calculation. However, there had been detailed seismic analysis performed for the basket tip installation, even though the line/ system was considered non-seismic. An acceptable evaluation of the basket tip design was prepared by the licensee during the inspectio (4) There was a lack of post-modification testing requirements for the basket tip installation. The inspectors noted that the licensee should determine if there were significant instrument pressure signal deviations from that expected or any line blockage, prior to declaring the system operable. The licensee agreed, and a job step for checking maintenance test data was added to the work orde The deficiencies identified above did not impact a safety-related system; however, the design control weakness was representative of other examples identified in this report, f. Field Alteration IA-F010 This field alteration modified.all 24 ftSIV, SRV, and ADS valve accumulator piping configurations by changing the common piping headers to the accumulators and the valves. The new pipe route directs air flow from the existing instrument air inlets to the accumulators, out the top of the accumulators, and into the valve Any impurity or crud in the compressed air would most likely be trapped at the bottom of the accumulators, and not be carriri to the valves which could cause valve operational problems. The modification also added a drain plug in the bottom of each accumulator. The inspectors reviewed the design documents, observed the piping installation, and identified the following deficiencies: ,
(1) The licensee's 10 CFR 50.59 safety evaluation screening covered -
HSAR Section 5'and applicable TS sections for IISIV and SRV operations, and affected li-series drawings. However, the licensee failed to evaluate two other design basis documents:
(a) USAR Section 9.3.1, Compressed Air System, in which Section 9.3.1.2.b stated that that air for ADS function and SRV valves is required to be 140 psig to 200 psig; and (b) licensee response to Generic Letter (GL) 88-14, dated April 6, 1989, which stated that all loss of air tests by gradual and fast loss of air were performed in 1986 via pre-operational testing
- procedures PTP-IA/SA-02, and PTP-ilS-01. These documents should have been considered in determining what post modification
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tests were required. During the inspection the licensee added discussion of USAR Section 9.3 and GL 88-14 to the safety evaluation screenin . . -. - .. - -- - - . - - .-
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(2) The 24 accumulator vessels were modified in two ways. -First, the vessel top 2" pipe cap was cut off for the connection of a new 2" pipe. & cond, a hole was drilled for the installation of a 1" drain plug. Both welds were nondestructi.vely examined by visual testing (VT). The 2" piping connection was considered to be a pipe weld. The VT was specified in the licensee
. procedure, and in accordance with the Code. The fillet weld on the drain plug was a vessel weld governed by ASliE Section III, ND 524 The Code stated radiography was not required for non-butt welded joints, but did not mention whether VT or liquid penetrant test (PT) (for stainless steel) should be -
utilized. The original vendor vessel fabrication drawing specified PT throughout. During the inspection, the licensee provided a written justification for the VT that they had performe (3) The seismic analysis for +".e new 2" pipe attached to the accumulator contained twc deficiencies. First, because the weight per linear foot of carbon steel material was used rather stainless steel material, the calcuiated loading and stresses were less than actual, but still had substantial safety margi Second, all the structure design formulas selected were without written justification. The licensee stated that AISC Code formulas were used, and that they would further review the validity of all the piping analyses performed by the A-E in this field alteration. The licensee's failure to verify and docur.,ent the design basis was contrary to the design control requirements of 10 CFR Part 50, Appendix B, Criterion Il (4) The accumulator and piping system flushing was not performed in accordance with procedure CPS 2800.04, as specified in the work package. Section 8.8.5 of the procedure required flushing of all drains. and other vessel openings. Section 8.8.6 required flushing of the main headers first, then other fluid paths including drains. These sections were not performed. Although the licensee's verbal justification was sound, the failure to document the basis was contrary to the design control requirements of 10 CFR Part 50, Appendix B, Criterion III. The licensee agreed to document the deviation and justificatio (5) The system post-modification functional test was Station Operating Manual Surveillance Procedure CPS No. 9361.11,
" Instrument Air Check Valve Operability," Revision 3 The post-modification test had not vet been conducted; however, CPS No. 9061.11 had been perf m ied during the 1989 refuel outage. The inspectors retiewed the test and had the following comments:
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~(a) In review of representative pre-operational and GL 88-14
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design verification tests conducted for MSIV, SRV, and ADS system _ leakage, the bases for test durations (i.e. ,
-30 minutes for MSIV AllD SRV, and 60 minutes for ADS) were without written justificatio Further,-there was no test acceptance criteri (b) Tha 90 psig test pressure specified in the post-modification-test for the MSIVs (performed during the 1989 refuel outage) was contrary to the CPS 9061.11 requirement to use operating
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range pressure,'and was without documented technical-justificatio (c) The MSIVs were not designed to fast close and the SRVs and ADS-SRVs were not designed to open solely upon loss of-instrument air, therefore the present test of approximately 30 seconds duration was considered to have little or no use in ensuring the design requirement of the accumulator to maintain pressure had been me (d) During the licensee review of the basis for the ADS l 10 minute test duration, the licensee found that the test gauges used were 0 to 600 psig range, in increments of 1 psig, readable to 0.5 psig. However, to meet the test acceptance criterion-of 0.014 psi / min. for 10 minutes, the
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a gauge would have be to readable to an accuracy better than or equal to 0.14 psig. CPS Condition Report tio. 1-91-01-037
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was issued on January 10, 1991, to document and evaluate the deficienc Subsequent to-the on-site inspection, the licensee upgraded its
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test program. The methodology for this test was reviewed by the inspectors and determined to be acceptable, lio deficiencies were. identified in other areas reviewed.
L 10 CFR Part 50, Appendix:B,-Criterion Ill, Design Control, as
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implemented by CPS Quality Assurance fianual and several ilSED procedures, required that design control measures be established to j '
control -and verify the adequacy of design. The deficiencies I
identified above in the calculations and testing supporting Field Alteration ES-F006, constitute an example of a violation (50-461/90027-01b(DRS)). Further discussion of the weakness
- . identified in the licensee's design control process is in Paragraph 7 of this report.
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, Field Alteration' VP F007 This field alteration provided independent Class 1E power supplies for the drywell chiller flow element instrument loop. This modification disconnected the existing single power supply in panel IPA 08J and installed new power supplies in panels IPL43JA and IPL43JB The design change was initiated to preclude the possibility of a single failure of the one power supply causing both drywell chi _llers to be inoperable. In 1988, the failure of the reserve auxiliary _ transformer lef t the plant with only Class 1E power and de-energized the chiller control loop. The licensee performed the appropriate safety evaluations and load growth calculations. The modification used two 24 volt power supplies powered from divisional class 1E power sources isolated with a fuse and a shunt trip circuit breaker, Field Alteration 00-F002 This field alteration raised the fuel oil day tank level switch setpoint for starting the fuel oil transfer pumps. The original setpoint apparently permitted the day tank level to drain below the level of the diesel engine fuel pump and allow air to enter the fuel c pump suction lines during surveillances, affecting the start times of the diesels. Raising the setpoint for starting the transfer pumps would assure fuel oil levels remained above the diesel fuel pump suctions. The licensee adequately performed setpoint calculations, safety evaluations, and post modification tests and calibration, Field Alteration C-F031 This field alteration replaced undamped amplifier and calibration cards in 45 Rosemount transmitters (models 1153 and 1154) with cards equipped with the adjustable damping option. The licensee had experienced signal spiking and false alarms caused by the undamped j: cards. The licensee performed the appropriate safety evaluations for the card replacement. . Rosemount Qualification Report flo. D8800053, Revision A, documented the qualification of the adjustable damping option to IEEE 323-1974 and IEEE 344-1974 Field Alteration RR-F016 This field alteration (completed prior to the outage) evaluated Rosemount model 1151 transmitters which had been procured from the manufacturer instead of the !!SSS vendor, General Electric Compan The licensee performed a safety evaluation screening to ascertain that procurement direct from the manufacturer instead of General Electric would have no adverse ef fect on plant safety. Results of
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the evaluation showed no safety significance related to direct procuremen '
k.- Field Alteration SX-F017
This' field alteration increased the orifice size in the residual heat removal (RHR) heat exchanger cooling water discharge to increase flow to the levels-stated in the Clinton USAR. The L,- orifice was designed by an architect engineer and reviewed by the
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- impact assessments were performed. . Post modification testing consisted of a . flow balance test of the shutdown service water (SX)
m- sys tem. Results of the test were reviewed by the architect engineer
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against USAR commitments. No deficiencies were identifie . Field Alteration SX-F009 This field alteration installed a vacuum. breaker check valve and butterfly valve downstream of valves 1SX019A, B to alleviate two phase flow conditions downstream of the vt.lves and the resultant erosion of the valves and down stream piping. Pressure taps were also installed to validate the satisfactory performance of the vacuum breaker modification. The licensee performen the appropriate safety evaluation, seismic analysis, and impact assessment Welding and non-destructive examination techniques were specified-for compliance with the applicable codes. -Post-modification test criteria were developed to prove that the vacuum breakers were 1 functional. Walkdown of the modification by the inspectors verified that-the installation met design requirements as specified in the
modificatio Field Alterations E-F028 and E-F029 These field alterations replaced Agastat GPl relays equipped with silver plated contacts with Agastat GP1A relays with gold plated
% contacts to reduce contact corrosion. At the time of the inspection the relays had been replaced in the feedwater, fuel handling,-and reactor water cleanup systems. Relay form or function was not 7 impacted by this modification.
L4 Field Alteration FC-012'
, 'l; Hi This field alteration (completed prior to the outage) replaced the environmentally unqualified motors on the fuel pool cooling and cleanup (FC) system with motors qualified for post-LOCA condition o Motor rating was increased from 350 to 400 horsepower (hp) because t
of the unavailability of qualified 350 hp motors. The licensee
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performed a safety evaluation pursuant tc the requirements of i
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10 CFR 50.59. The licensee performed post modification test CPS 2810.09, " Functional Test Procedure for Plant itods FC-012 and FC-017," Revision 1, to verify that the modification would perform its design function. The inspectors identified discrepancies in the test report between the data recorded for pumps A and Pump A recorded the differential pressure readings for use in determining flow from the flow meter curves. There was no requirement in the procedure for recording differential pressure when taking data for pump B. Although this discrepancy did not affect the test results, the usefulness of the data for future test comparisons was questionable. The discrepancy indicated a weakness in the licensee's review-of this test procedure, o.- Field Alteration tis-F025 This field alteration removed the itSIV position indication lights from the non-class '1E reactor protection system (RPS) invertor, and reconnected the light circuits to independent Class 1E power sources to comply with the requirements of Regulatory Guide 1.97. The modification involved removing the light circuits from their terminals in control room panels and rerouting wiring to Class 1E terminals in another panel. The indicating light circuits were connected to the Class'1E circuits through two fuses in series to isolate the non-class 1E indicating light circuit from the Class IE power source. The licensee performed the appropriate safety evaluation screening, interdisciplinary reviews, and safety evaluation, to determine the safety impact of this modification. The licensee performed calculations to verify the natural frequency of the indicating lamps and lamp holders used in Wyle laboratory seismic qualification Report flo. 48424- Field Alteration FC-017 I' This field alteration (completed prior to the outage) involved changes in piping and instrumentation in the FC system. Safety evaluations were performed by_the licensee, and installation and quality control requirements specified by engineering were adequately-referenced or included in the work documents. Post installation testing included nondestructive examination (NDE) of welds, flushing, and hydrostatic testing to 171-176 psi. This modification was included in the functional test for Field Alteration FC-012 (Paragraph 4.n above), "
It5" Field Alterations flSED Procedure I-l.5, " Field Changes to Work Documents," provided -the instructions and guidance to change technical requirements, methods, or data, contained in work documents, such as, errors in original design documents. This program basically authorized performance
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of field work far-a field alteration or modification to be performed before any of the paperwork had been completed. The >
paperwork would be completed prior to the end of the outage. The licensee acknowledged that there was some risk associated in proceeding in-this fashion. The inspectors reviewed the following 115 Field Engineering Change flotices (FECNs):
(1) FECils 25482 and 25484, Remove flange and increase length of ;
pipe entering the suppression pool These FECNs were worked to eliminate a potential air leakage path from containment in the event of a loss of Coolant Accident (LOCA). Prior to this change, air leakage was possible from both the flanges and from the outlet orifice itself following suppression pool drawdown. The inspectors reviewed the FECNs and witnessed a portion of the fabrication of a test connection for the FECH. No problems were identifie (2) _FECH 25483, Installation of a blind coupling in the residual heat removal-(RHR) steam condensing vent lines This FECN eliminated the need to Type C test valves 1E12-F074A and B with. air. The RHR vent line had vacuum breakers which could have provided a dirn t air leakage path to these valves during a LOCA. The licensee determined that leaving the line as-is would require a change to the Technical Specification The inspectors reviewed the FECH and had no problems with i The inspectors noted that changes to the USAR would be necessary as a result of this alteratio (3) FECN 25485, Replacement of the RCIC/RHR vacuum breaker isolation valve with a blind coupling spool
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This FECH eliminated the RCIC/RHR vacuum breaker line to RHR relief valves 1E12-F055A and B. The licensee determined, based upon a letter from General Electric (RTR90032) dated
, December 12, 1990, that the vacuum' breaker capability was not needed. The inspectors reviewed the FECN and had no problems with i As with the previous FECH, a change to the U$AR would be required as a result of this alte m io One violation was identified in the area of permanent plant design-changes, with examples in Paragraphs 4.a and 4.f above. The violation and other deficiencies were representative of a weakness in the
-licensee's design control process. This is_ discussed further in
- Paragraph 7 of this report.
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. ~ Temporary Plant Itodifications The licensee's temporary modification program was controlled by CPS Procedure fio. 1014.03, " Temporary liodifications." Plant alterations allowed by the program included electrical lifted leads and jumpers, mechanical jumpers, blocks, and piping devices. Less than thirty (30)
temporary modifications were instclied in the plant at the time of the inspection. The inspectors reviewed a sampling of the installed temporary modifications and assessed the program controls. The inspectors noted that a 10 CFR 50.59 safety evaluation was performed for all temporary modifications, which was considered to be a very conservative practic The temporary modification program appeared to be adequate for controlling simple alterations; however, an example was identified in which the design and engineering aspects of a temporary modification were considered weak. The modification did not impact a safety related system; however, the design control weakness was represe.netive of other examples identified
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in this repor Temporary flodification 90-050 removed the function of the SJAE B sensing and control line pressure regulator by removing its internals. The regulator function (closure at 200 psig) for controller instrument protection was replaced by installing three relief valves (set to lif t at 200 psig) on the regulator body. The licensee's 10 CFR 50.59 safety evaluation, including failure mode analysis, was reviewed by the inspectors, and considered adequate. In the area of design, there was a lack of relief valve lift thrust consideration.- Because the total relief valve discharge steam flow openings exceeded the inlet steam flow supply tubing internal cross sectional area, and because they were blowing in the same direction, this condition created the equivalent of a tube rupture blowdown at 200 psig and above, and could create a structural instability problem for the tubing system (non-safety related and non-seismic category).
The licensee failed to recognize the thrust effects on the tubing because all three relief valves were bench tested for lift pressure setup and-a post-modification test was not conducted after installation. The licensee agreed to review the situatio flo violations -were identified in the area of temporary plant modification . 10 CFR 50.59 Safety Reviews The licensee's safety review program was controlled by CPS tlo. 1005.06,
" Conduct of Safety Reviews," and other plant procedures. The Safety Evaluation llanual was actually the governing document for preparing and reviewing 10 CFR 50.59 safety evaluations. This manual provided detailed guidance to meet the 10 CFR 50.59 requirements, and incorporated flVi1 ARC and IflP0 recommendations. Formal training and qualification requirements '
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The inspectors reviewed the licensee's safety review program and implementation. For each design change, the licensee conducted a safety evaluation screening using' Form SE-1.to. document the justification for not performing a full 10 CFR 50.59 safety evaluation. The inspectors noted that all temporary plant modifications received a full. safety evaluation as a' matter of routine (although not required). The inspectors reviewed the safety evaluations and screening performed for each design - -
change described in Paragraph 4 of this report, and for a sampling of temporary modifications (Paragraph 5). A few examples were identified in which the safety screening had not addressed all affected USAR section These examples did not result in a full safety evaluation being require The licensee had identified (prior to this inspection) a problem with documentation of the screening, and had taken action to resolve the deficiency. A planned revision to the manual added more restrictive guidance on documenting the safety review. The full safety evaluations reviewed by the inspectors were generally of high quality. The evaluations were well documented, and demonstrated a technical understanding of the safety issues involve No violations were identified in the area of 10 CFR 50.59 safety reviews, 7. Conclusions The licensee'.s tenporary modification program cdequately controlled simple plant alterations; however, an example was identified in which the design and engineering aspects of a temporary moo.fication were considered weak. The inspectors noted that a full 10 CFR.50.59 safety evaluation was performed for all temporary modifications, which was considered to be a very conservative practice. All the 10 CFR 50.69 safety evaluations reviewed by the inspectors were well documented, an demonstrated a technical understanding of the safety issues involve The licensee had a revision to the Satety Evaluation Manual in progress to add more restrictive guidance on documenting the safety reviews.
- The inspectors reviewed twenty (20) permanent plant' design changes.
, Weaknesses were identified in the licensee's design control process, including design verification and testing. Engineering evaluations in the form of calculations were generally adequate in regard to the final results; however, they were not always complete and did not document design assumptions or verifications. One violation was identified'for ,
failure to satisfy the design control requirements of 10 CFR Part 50, '
Appendix B, Criterion III. Criterion III specified that measures be !
established to assure that the design basis is correctly translated into l specifications, drawings, procedures, and instructions, and that the design control measures provide for verifying or checking the adequacy of i the design, such as performance of design reviews, the use of alternate l or simplified calculational methods, or by the performance of a suitable testing program. One example of the violation (Paragraph 4.a) involved a i
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i series of calculations in which the design basis for calculated volumes was not traceable and the design assumptions were not documented. Design verifi:ation was'not evident in some of the calculations. The second example of the violation (Paragraph 4.f) involved calculations and specified testing.- The design verification was deficient, in that,
-(1) incorrect piping material weights were used in the seismic calculation, and the basis for structure design formulas used in the calculation was
.not. documented; (2) justification for not performing system flushing, as required-by CPS 2800.04 functicial(airleakage}wasnotdocumented;and(3)thepost-modification testing criteria was without technical basi Other exacoles were identified which were representative of the design control we Kness: (1) A calculation (Paragraph 4.b) contained numerous calculational and transcription errors. Although the final results were adequate, there was no documentation to show that these errors-had been previously reviewed. (2) The nonsafety-related portion of a field alteration (Paragraph 4.e) lacked design calculations and post-modification testing requirements. (3) A (nonsafety-related) temporary modification
'(Paragraph 5) lacked sufficient design verification and post-modification testiog requirements.
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Additional technical overview of contracted and in-house design (e.g.,
calculations) was necessary. According to the licensee, reviews of design work performed by contractors would be conducted only-for specific concerns, NRC initiates, or use of design assumptions and criteria provided to the contractor by the licensee. The inspectors reviewed licensee quality assurance (QA) audits performed in 1990 of S&L and HSED. The audits identified some technical discrepancies in engineering calculations performed by S&L for CPS. The audits of HSED were generally administrative in nature and resulted in no significant findings related to design activities.-
The licensee had previously recognized the need to strengthen their control of design activities. Since 1989, the licensee has taken
- initiatives to enhance NSED design control. In February-1990, a design transition action plan was developed to strengthen design control capabilities which would allow HSED to perform certain design functions in-house including safety-related activitie In November 1990, an-action plan to strengthen design control was initiated. These plans included document and procedure upgrades, additional engineering staffing, and the implementation of an Engineering Assurance Assessment Progra An engineering assurance (EA) group within USED was being staffed at the time of this inspection. The effectiveness of these initiatives can not be assessed until after full implementation by the license . Exit Meeting The inspectors met with the licensee representatives (denoted in Paragraph 1) on January 11, 1991. The inspectors summarized the scope
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and findings of the inspection. The licen,ee acknowledged the statements made by the inspectors with respect to the violation and other concern 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 and the licensee did not identify any such documents / processes as proprietary. Further discussions with licensee representatives (regarding the violation) were held via teleconference on January 25 and 30,199 _