IR 05000461/2002010
| ML082340631 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee, Clinton File:NorthStar Vermont Yankee icon.png |
| Issue date: | 01/24/2003 |
| From: | Gardner R NRC/RGN-III/DRS/EEB |
| To: | Skolds J Exelon Generation Co, Exelon Nuclear |
| SECY RAS | |
| References | |
| 06-849-03-LR, 50-271-LR, Entergy-Intervenor-NEC-UW_04, RAS M-242 IR-02-010 | |
| Download: ML082340631 (18) | |
Text
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DOCKETED USNRC August 12, 2008 (11:00am)
NEC-UW_04 OFFICE OF SECRETARY RULEMAKINGS AND ADJUDICATIONS STAFF January 24, 2003 Mr. John L. Skolds, President Exelon Nuclear Exelon Generation Company, LLC 4300 Winfield Road Warrenville, Illinois 60555 SUBJECT: CLINTON POWER STATION NRC INSPECTION REPORT 50-461/02-10(DRS)
Dear Mr. Skolds:
On December 13, 2002, the NRC completed an inspection at your Clinton Power Station. The enclosed report documents the inspection findings, which were discussed with Mr. K. Poison and other members of your staff at the completion of the inspection.
The inspectors examined activities conducted under your license as they relate to safety and compliance with the Commission's rules. and regulations and with the conditions of your license.
The inspectors reviewed selected procedures and records, observed activities, and interviewed:
personnel. Specifically, the inspection focused on the Evaluations of Changes, Tests, or Experiments per 10 CFR 50.59 and Permanent Plant Modifications.
No safety significant items were identified and no response to this inspection report is required.
In accordance with 10 CFR 2.790 of the NRC's Rules of Practice, a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's document system (ADAMS). ADAMS is accessible from the NRC Web site at http:/lwww.nrc..qov/readinc-rmfadams.html (the Public Electronic Reading Room).
Sincerely, IRA!
Ronald N. Gardner, Chief Electrical Engineering Branch Division of Reactor Safety Docket No. 50-461 License No. NPF-62 Enclosure: Inspection Report 50-461/02-10(DRS)
See Attached Distribution OFEEby. Appilcmilcensee~
(Ite/e'ý El-NiCtI Other____
IDENTIFEDoorU itness/PanelLd L AcmTiona: ADMITTED REJECTED WITHDRAWN c41~,O~49& )LL-0 2 S--
Mr. John
SUMMARY OF FINDINGS
IR 05000471-02-10(DRS), Exelon Generation Company, LLC; on 12/09-13/02, Clinton Power
Station; Evaluations of Changes, Tests, or Experiments per 10 CFR 50.59 and Permanent Plant Modifications.
The inspection was a one week baseline inspection of Permanent Plant Modifications and Evaluations of Changes, Tests, or Experiments. The inspection was conducted by regional engineering specialists, with the assistance of a mechanical consultant. No findings were identified during the inspection.
REPORT DETAILS
REACTOR SAFETY
Cornerstone: Mitigating Systems
1R02 Evaluations of Changes, Tests, or Experiments
Review of Evaluations and Screenings for Changes, Tests, or Experiments
a. Inspection Scope
The inspectors reviewed five 10 CFR 50.59 evaluations and nine screenings. These.
documents were reviewed to ensure consistency with the requirements of 10 CFR 50.59. The inspectors used NuclearEnergy Institute (NEI) 96-07, "Guidelines of 50.59 Evaluations," Revision 1, to determine acceptability of the completed evaluations, and screenings. The NEI document was endorsed by the NRC in Regulatory Guide 1.187, "Guidance forImplementation of 10 CFR 50.59, Changes, Tests, and Experiments,"
November 2000. The inspectors also consulted Inspection Manual,. Part 9900, 10 CFR GUIDANCE: 50.59. Documents reviewed during the inspection are listed at the end of the report.
b. Findings
No findings of significance. were identified.
1R17 Permanent Plant Modifications
.1 Review of Recent Permanent Plant Modifications
a. Inspection Scope
The inspectors reviewed eleven permanent plant modifications that were installed during the last two years. These changes affected various systems in the plant. The review of the records completed the activities required by Attachment 17 of NRC Inspection Procedure 71111. The modifications were reviewed to.verify'that the completed design changes were in accordance with specified design requirements and the licensing bases and to confirm that the changes did not affect the modified system or other systems' safety function. Calculations which were performed or revised to support the
- modifications were also reviewed. As applicable to the status of the modification, post-modification testing was reviewed to verify that the system, and associated support systems, functioned properly and that the modification accomplished its intended function. The inspectors also verified that the completed modifications did not place the plant in an increased risk configuration. The inspectors evaluated the modifications against the licensee's design basis documents and the updated final safety analysis report (UFSAR). The inspectors also used applicable industry standards, such as the American Society of Mechanical Engineers Code, to evaluate acceptability of the modifications.
In addition to the normal review, of permanent plant modifications, the inspectors reviewed selected design changes and other licensee documents associated with the effects of the plant power up-rate on the flow accelerated corrosion (FAC) program.
This review is discussed in this section of the report.
b. Findings
No findings of significance were identified.
.2 Flow Accelerated Corrosion (FAC) Program
a. Inspection Scope
In accordance with InspectionProcedure 49001, "Inspection of Erosion-Corrosion/Flow-Accelerated-Corrosion Monitoring Programs," the inspectors reviewed documents and records to verify selected aspects of the FAC program. The review included associated design changes and calculations completed or revised to address the potential effects of the extended power up-rate (EPU) on the FAC program at the Clinton Power Plant.
Evaluation of these documents also involved extensive discussions with licensee personnel.
In the review, the inspectors noted that Revision A of calculation 01065301, "CHECWORKS FAC Analysis," was confirmed to have incorporated inputs from the General Electric up-rate heat balance into the current FAC analysis. The Safety Evaluation Report (SER) related to the EPU was issued. prior to completion of.
Revision A.of the calculation; however, the SER summarized "in-progress" results provided by licensee personnel prior to issuance of Revision A of the calculation.
By reviewing documents and records, per Inspection Procedure 49001, "Inspection of Erosion-Corrosion/Flow-Accelerated-Corrosion Monitoring Programs," the inspectors verified the following aspects of the FAC program:
The FAQ program included a systematic method to predict system and component susceptibility, analyze inspection data to determine wall thinning rates, determine inspection intervals based on past inspection results, and repair or replace piping components.
- The program had defined criteria for selection of inspection locations.
- The program procedurally included measures to support effective monitoring and management of FAC effects during the life of the plant.
The FAC program monitored the effect on FAC of expected changes. in operating plant parameters as a result of the EPU in systems as identified in the SER, including main steam and attached piping, feedwater, and other pressure boundary piping.
The program identified risk significant FAC concerns as a result of the EPU.
including identification of FAC program material replacements scheduled for installation during refueling outage RF09 in 2004.
The licensee personnel confirmed that the "in-progress" results discussedin the SER were conservative. The calculation results predicted wall thinning rates of 25 mils at 100 percent power and'27 mils at EPU conditions, an increase of approximately 8 percent.
Concerns raised by the inspectors were discussed with the licensee.
.b.
Findings No findings of significance were identified.
OTHER ACTIVITIES (OA)
40A2 Identification and Resolution of Problems
a. Inspection Scope
The team reviewed seventeen condition reports that were identified by licensee personnel and had been entered into the corrective action program. The inspectors reviewed these issues to verify an appropriate threshold for identifying issues and to evaluate the effectiveness of corrective, actions related to the permanent plant design and evaluations for Changes, Tests, or Experiments issues. In addition, the condition report, written on an issue identified during the inspection, was reviewed to Verify adequate problem identification and incorporation of the problem into the corrective action system. The specific corrective action documents that were sampled and reviewed by the team are listed in the attachment to this report.
b. Findings
No findings of significance were identified.
40A6 Meetings Exit Meeting The inspectors presented the inspection results to Mr. K. J. Poison, and other members of licensee management, on December 13, 2002. The licensee acknowledged the inspection results presented. Licensee personnel were asked to identify any documents, materials, or information provided during the inspection that were considered proprietary. No proprietary information was identified.
.5 KEY POINTS OF CONTACT
Licensee Management K. Poison, Plant Manager K. Baker, Senior Manager Design Engineering R. Frantz, Regulatory Assurance W. Iliff, Regulator Assurance Manager R. Kerestes, Engineering J. Madden, Nuclear Oversight Manager P. Marcum, Engineering E. Schwertzer, Engineering R. Schmidt, Maintenance Director J. Williams, Site Engineering Director NRC C. Brown, Resident Inspector R. Gardner, Chief, Electrical Engineering. Branch, DRS P. Louden, Senior Resident Inspector A. Stone, Chief, Projects Branch 4, DRP LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED Opened None Closed None Discussed None LIST OF
DOCUMENTS REVIEWED
The following documents were selected and reviewed by the inspectors during the Clinton
biennial inspection of Evaluations of Changes, Tests, or Experiments and Permanent Plant
Modifications conducted from December 9 through 13, 2002. The inspection was conducted to
accomplish the objectives and scope of the inspection and to support the findings and issues
noted. The list may include documents prepared by others for the licensee. Inclusion on this
list does not imply that the NRC inspectors reviewed the documents in theirentirety, but that
selected portions of the documents were evaluated as part of the overall inspection effort. Also
inclusion on this list does not imply NRC acceptance of the document, unless specifically stated
in the body of the inspection report.
1R02 Evaluations of Changes, Tests, or Experiments
Evaluations
CL-2001-E-01890; DCP No. 333952 Temporary Modification, Defeat RR 'A' Runback;
dated December 14, 2001
CL-2001-E-01900; DCP No. 334153 Temporary Modification, Manual RR 'A' FCV
Position Control; dated December 14, 2001
CL-2002-E-00028; Activity/DocumentNumber: CPS 3302.03 - Noble Metal Injection;*
Revision 1
CL-2002-E-00052; Clinton Unit I Cycle 9 Reload Core.Design and Licensing; Revision 0
CL-2002-E-00520; Temporary Modification EC 338256, Temporarily Disable Turbine
Control Valve #4; dated September 13, 2002
Screeninogs
CL-2001-S-0018; ECN 32439, Installation of Tie-In for WO Piping and Valves for the
New Suppression Pool Cooling Heat Exchanger; dated March 22, 2001
CL-2001-S-0115; Reduction of Main Steam Line Radiation Monitors from Four to Two;
dated October 25, 2001
CL-2001 -S-01 740; ORM 35-6, SetpointSign Changes; dated November 30, 2001
CL-2002-S-00210; USAR Change Package 8-303, USAR Change Package for
Containment and Drywell Volume Corrections Including EPU; dated February 26, 2002
CL-2002-S-00510;. USAR Change 10-095(change to 6.2.1.1.5.5 only), Evaluation of
Change in the Analysis of the Small Break LOCA with Drywell Bypass Leakage; dated
April 16, 2002
CL-2002-S-00780; EC337228, USAR Change 10-109, TS Bases Change,
Instrumentation Aspects of Diesel Fuel Tank Level Requirements; dated June 27, 2002
LS-AA-104-1001; Reclassification of RCIC Pump Tech Spec Surveillance Parameters'
from Not Nominal to Nominal; dated May 20, 2002
LS-AA-104-1003; Replacement of Cylinder Indicator Valves on Div. 1 Diesel Generator -
(1DGO0KA); dated January 11,. 2001.
1005.06F001; Replace DG Air Start Solenoid Pilot Valves per ECNs 30444 and. 30745;
dated November 6, 1998
Condition Reports Written as a result of the Inspection..
CR 00135358; Inconsistent Methods Were Used to Document the Results of 10 CFR 50.59 applicability Reviews for Modification; dated December 13, 2002
Condition Reports
CR 2-00-11-127; OD/OE Process/Procedure Does Not Provide Adequate Barriers to
Assure Timely Corrective Actions; dated November 17, 2000
CR 2-01-06-017; 50.59 Screening. Form Was Not Prepared; dated June 4, 2001
CR 2-01-05-.157-0; Inadequate Implementation of LS-AA-104; dated May 15, 2001
CR 00099796; FP Diesel Tank Level Changed Without Documentation Bases; dated
March 18, 2002
CR 00123080; Potential Expiration of TS 3.4.11 Pressure/Temperature Curve; dated
September 16, 2002
CR 00124037- 50.59 Review Not Completed as Required per CPS 1870.02; dated
September 22, 2002
Procedures
LS-AA-104; Exelon 50.59 Review Process; Revision 2
LS-AA-104-1000; Exelon 50.59 Resource Manual; Revision 0
LS-AA-104-1001; 50.59 Review Coversheet Form; Revision 0
LS-AA-1 04-1002; 50.59 Applicability Review Form; Revision 0
LS-AA-104-1006; Exelon 50.59 Training and Qualification; Revision 0
LS-AA-107; UFSAR Update Procedure; Revision 0
1R17 Permanent Plant Modifications
Modifications
31717; Replace Division II DG Crank Lockout Pressure Switches 1PSDG064C and
1PSDG065C with a Model with a Smaller Dead Band; dated November 21, 2001
2181; Remove the ERAT/RAT SVC. Freeze Input to The SVC Controller byJumpering
the Breaker Aux Contact "B" from the Division 1 Diesel Generator Output Breaker; dated
November 21, 2001
330499; Authorization for an Acceptable Replacement for Obsolete Gould ITE Type HE,
JL, KM and E2 Molded Case Circuit Breakers Used in Gould ITE 5600 Series 125 VDC
Motor Control.Center; dated May 9, 2002
331074; Rotate Rosemont Transmitter 1LT-SM016 Suppression Pool Level; Revision I
331208; Install Ball Valves in the MCR Breathing Air System Fill Lines; Revision 1
331323; Feedwater Support Modification; Revision 0
331896; Replacement of Cylinder Indicator Valves on Div 1 Diesel Generator;
Revision 0
333256;. Replace the Division Ill Carbon Steel Vacuum Breakers with New Stainless
Steel Replacements (1SX315A/B and 1SX316NB); Revision 0
333417; Upgrade Woodward Controls 2301A Load Sharing and Speed Control on the
Division II Diesel Generator 1B Control Panel (1PL12JB); Revision 1
334569; ODG-ST-1 1 Line Replacement; Revision 0
335110; Allow Replacement of Existing Reactor Core Isolation Cooling (RI) Piping of
Carbon Steel Material with 2 1/4 CR-MO (Chrome-Moly) Material; Revision 0
Equivalency Evaluations
Evaluation #10718/1106915; Hydrogen Ignitors - The original AC Delco 7G glow plug is
obsolete and possesses a high failure rate per CR 2-01-02-143. The Champion CH-78
(Stock # 178) glow plug is an acceptable alternate in fit, form, and function to the
original AC Delco 7G.
Evaluation #16231/1146463; Emergency Diesel. Generator (EDG) Right Hand Air Start
Motors.- Evaluation #16231 performed lEE to approve material changes as per
equivalency performed by diesel vendor, ESI, and scanned into lEE OLE field. Part
number of motors did not change.
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Desigqn Report
DR-A020104; Design Report DR-A020104 Revision 0 for 3/4", stainless steel, ANSI
Class 600, In-line Check Valve with Screwed End Endcaps (purchase order No.
P0 00037775, BNL Shop Order No. A020104); Revision 0
Condition Reports
CR 1-96-11-252; UnauthorizedModification Installed in WS System under MWR
D74712 - System Declared Operable; dated November 16, 1996
CR 86825; RR FCV A Temp Mod Implementation Problems; dated December 15, 2001
CR 93284; Discrepancies ID'ed in D C P 32236; dated January 31,. 2002
CR 2-01-05ý157-0; Inadequate Implementation of LS-AA-104; dated.May 15, 2001
CR 00064517- 2-01-07-053 Design Change Process Breakdown for EC 331444 CO;
dated July 5, 2001
CR 00099796; FP Diesel Tank Level Changed Without Documentation Bases; dated
March 18, 2002
CR 00105636; Design Deficiency in RCIC MOD; dated May 20, 2002
CR 00108356; NON (Nuclear Operations Network) Review of Effects of Diesel Exhaust
on Charcoal Filters; completed October 30,.2002
.CR 00115251; Non-compliance w/ANSI N18.7 Configuration Changes;- completed
July 23, 2002
CR 00119318; Enhancements to OP-AA-108-101/102; completed August 26, 2002
CR 00123080; Potential Expiration of TS 3.4.11 Pressure/Temperature Curve; dated
September 16,*2002
Procedures
CI-01.00; Instrument Setpoint Calculation Methodology; Revision 2
CC-AA-102; Design Input and Configuration Change Impact Screening; Revision 4
CC-AA-103; Configuration Change Control; Revision 3
- CC-MW-103-1001; Configuration Change Control Guidance; Revision 0.
CC-AA-107; Configuration Change Acceptance Testing Criteria; Revision 2
CC-AA-107-1001; Post Modification Acceptance Testing; Revision 0
CC-AA-309; Control of Design Analysis; Revision 3
SM-AA-300; Procurement of Engineering Support; Revision 0
SM-AA-401; Material Procurement; Revision 2
Miscellaneous Documents
Assessment. of Maintenance Effectiveness 10CFR50.65 (a)(3) Assessment, Clinton
Power Station, March 1, 2000 to ,October 20, 2002
Flow Accelerated Corrosion Issues
CSI Calculation No. 01065301; CHECWORKS FAC Analysis - Clinton Power Station;
Revision A (For Use); dated January 11, 2002
ER-AA-430; Conduct of Flow Accelerated Corrosion Activities;. Revision 0
ER-AA-430-1 001; Guidelines for Flow Accelerated Corrosion Activities; Revision 0
ER-AA-430-1002; Feedwater Heater Shell Inspection for Detection of Flow Accelerated
Corrosion; Revision 1
LIST OF ACRONYMS USED
ADAMS Agency-wide Document Access and Management System
CFR Code of Federal Regulations
DRS Division of Reactor Safety
EPU Extended Power Up-rate
FAC Flow Accelerated Corrosion
NEI Nuclear Energy Institute
NRC Nuclear Regulatory Commission
PARS Publicly Available Records System
SDP Significance Determination Process
SER Safety Evaluate Report
UFSAR Updated Final Safety Analysis Report
II
Inspection was rescheduled from July 29, 2002 to December 9, 2002
MODIFICATION AND 50.59 INSPECTION DOCUMENT REQUEST
The following information was provided electronically to the licensee prior to the inspection:
E-mailed on June 7, 2002
Lead Inspector: Zelig Falevits
Team Members: Gerard O'Dwyer, Ken O'Brien, Bob Winter
Information Needed for In-Office Preparation Week (July 22-26,2002)
The following information is needed by July 19, 2002, or sooner, to facilitate the
selection of specific items that will be reviewed during the onsite inspection week. The
team will select specific items from the informaticin requested below and submit a list to
your staff by July 24, 2002. We request that the specific items selected from the lists be
available and ready for review on the first day of onsite inspection (July 29, 2002). If
you have any questions regarding this information, please contact me at (630) 829-9717
or e-mail zxf@nrc.gov as soon as possible. All lists requested.should cover thetime
frame July 2000 until present. All information should be sent electronically if at all
possible.
Permanent Plant Modifications
1. List of permanent plant modifications/ design changes. In addition to the list,
please provide a brief (one paragraph) description of each modification (e.g.,
copy of modification description from DCP or safety evaluation.)
2. List of setpoint changes. (Identify system and instrument).
3. List of equivalency evaluations or suitability analysis.
4. List of commercial grade dedications.
5. List of condition reports (open or closed.) issued to address permanent'plant
modification issues, concerns, or process.
6. Copy of procedures.for the following: modifications, design changes, set point
changes, equivalency evaluations or suitability analyses, commercial grade
dedications, and post-modification testing.
Changes, Tests, or Experiments (10 CFR 50.59)
1. List of all 10 CFR 50.59 completed evaluations involving: (A) changes to facility
(modifications); (B) procedure revisions; (C) tests or non-routine operating
configurations; (D) changes to the UFSAR; or (E) calculations
2. List of all 10 CFR 50.59 screenings that have been screened out as not requiring
a full evaluation involving: (A) changes to facility (modifications); (B) procedure
revisions; (C) tests or non-routine operating configurations; (D) changes to the
UFSAR; or (E) calculations
3. List of.condition reports (open or closed) issued to address problems. associated
with 10 CFR 50.59 evaluations, screenings, or process.
4. Copy of procedures that specify how 10 CFR 50.59 evaluations and screenings
are performed.
5. Copy of procedures that delineate how 10 CFR 50.59 FSAR updates are
prepared by engineers or staff and how the licensee submits 10 CFR 50.59
FSAR updates.
6. List of special tests or experiments and non-routine operating configurations in-
the last two years (if any.)
General Information
1. Latest engineering organization chart
2. Site phone list
3. System and Design Engineering lists
4. List of maintenance rule high safety significant systems
5. List of maintenance rule (a)(1) systems. (Those systems presently in (a)(1) and
systems that were (a)(1) in 2001 or 2002 andreturned to (a)(2) [List date system.
went to (a)(1) and date system returned to (a)(2)1)
Information to be Available on First Day of Onsite Inspection
We request that the following information be available to the inspectors once they arrive
onsite. (Copies of the updated final safety analysis report, independent plant evaluation
probabilistic safety analysis, vendor manuals, or technical specifications do not need to
be solely available to the team as-long as the inspectors have ready access to them.)
The latest 10 CFR 50.59 Final Safety Analysis Report Update Submittal
Updated Final Safety Analysis Report
Technical Specifications
Independent Plant Evaluation Probabilistic Safety Analysis Report
Vendor Manuals
Equipment Qualification Binders
Relevant Calculations And Analyses (for selected modifications and 50.59s)
Copies of previously selected modifications, permanent plant changes, design
- changes, setpoint changes, procedure changes, equivalency evaluations,
suitability analyses, calculations, commercial grade dedications, 10 CFR 50.59
evaluations and screenings and condition reports.
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