IR 05000461/1993024

Insp Rept 50-461/93-24 on 931115-1203.Violations Noted.Major Areas Inspected:Licensee Incorporation of GL 89-04

ML20059A295
Person / Time
Site:	Clinton
Issue date:	12/23/1993
From:	Dunlop A, Gardner R, Hansen J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20059A286	List: IR 05000461/1993024 ML20059A283 ML20059A288
References
50-461-93-24, GL-89-04, GL-89-4, NUDOCS 9312300097
Download: ML20059A295 (10)

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U. S. NUCLEAR REGULATORY COMMISSION-

. REGION III .;

' Report No. 50-461/93024(DRS)  :

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Docket No. 50-461 License No. No. NPF-62 Illinois Power Company ,

Licensee:. Mail Code V-275 P. O. Box 678 Clinton, IL 61727 Facility Name: Clinton Power Station l Inspection At: Clinton Site, Clinton, IL  ;

Inspection Conducted: November 15 through December 3,1993

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Inspectors: , ;wk '$~[,. 12 -1p t j ;

A. Dunlop Date

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s NIk { , & 1 t- 11-')

J. L. Hansen '

Date Accompanied By: L. Sage, Illinois Department of Nuclear Safety November 15-18, 29, 30 and December 1-3, 1993 Approved By: Mk D C Gardner, Chief e V O Dat f

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Plant Systems Section Inspection Summary i

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inspection conducted November 15 throuah December 3; 1993 (Report N /93024(DRS1)-

Areas inspected: Announced safety issues inspection of the licensee's incorporation of Generic Letter (GL) 89-04, " Guidance on-developing acceptable Inservice Test Programs" into the Inservice Testing (IST) Program (Tl 2515/114), the licensee's program on check valves (Tl 2515/110), and licensee's self-assessment in these area Results: The inspection disclosed one violation (Paragraph 2.b.(3))'concerning- l inadequate testing of the shutdown service water pump discharge check valves in the open direction-(Paragraph 3.d) and one inspection followup ' item (IFI)

(Paragraph 2.c.(1)) concerning the acceptance criteria associated with leak ;

rate testing containment isolation valves in groups. Based on this inspection, TI 2515/114 and Tl 2515/110 are considered close j

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s 9312300097 931223

'gDR ADOCK 05000461  !

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- Inspection Summary 2 Additional issues. identified during the inspection were as follows:

Communications between system engineering, performance engineering, surveillance scheduling, and operations groups in the IST program implementation was considered good. This was especially apparent in the areas of operability determination and scheduling of increased testin The basis document for the IST program was_ considered a good -reference document; however, in several instances it lacked some desig information or the information was not correc Administrative guidance for the Check Valve Monitoring Program _was an uncontrolled document and not updated -to reflect the current program-administration and other program aspect .r . -

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TABLE OF CONTENTS

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.l . Persons. Contacted........................'........................ 1 Inservice Testing (IST) of Pumps and Valves. . . . . . . . . . . . . . . . . . . . . . ~ 1'- Scope........................................................ 2 Pump Testing............................................... '3

, Valve Testing.............................................. 3 ,

l Procedures................................................. 4 3 Trending................................................... 5 ' Check Valve Program.............................................. 5 ; Scope...................................................... 5 ;

. Administrative Procedure.................................... 5 .i Design Application Review.................................. 5 , Preventive Maintenance..................................... 6

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> Inservice Testing.......................................... 6

' Non-Intrusive Testing...................................... '7 9 Trending................................................... 7' L i c e n s ee S el f- As s e s sme n t . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 Inspection Followup Items....................................... 7 , Exit Meeting.................................................. .. 7

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DETAILS i

1. Persons Contacted Illinois Power Comnany

• J.'S. Perry, Senior Vice President 1

• J. G. Cook, Vice President *

J. A. Miller, Manager - fluclear Station Engineering

• R. E. Wyatt, Manager - Nuclear Assessment

• J. F. Palchak, Manager - Nuclear. Support

• R. F. Phares, Director - Licensing i

• J. R. Langley, Director - De. sign & Analysis Engineering D. W. Waddell, Director - Programs & Administration

• D. E. Korneman, Director - System Engineering  !

• D. Yocum, Director - Operations ,

• Morris, Director - Nuclear Assessment '

• R. Graf, Director - Engineering Projects  !

• E. Mueller, Director - Nuclear Training

• J. R. Taylor, Director - Administration

• J. V. Sipek, Supervisor - Regional Regulatory Interface, Licensing

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• S. R. Bell, Supervisor - ISI ,

R. L. Neeb, Supervisor - Mechanical Design & Analysis  ;

• K. E Moore, Supervising Engineer Reliability Engineering '

• B. J. Puckett, Project Specialist, IST Program

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o M. R. Stookey, Project Engineer, Check Valve Program '!

J. J. Claus, Project Engineer  ;

• F. A. Spangenburg, Strategic Change Leader

• C R. Huttes, Principal Assistant to Senior Vice President J. F. Kaczmarek, Mechanical Design & Analysis Engineer

• S. S. Guron, Staff Engineer - Licensing ~ -

F. A. 01 ender, Project Operations Planning Specialist .i

• J. W. Pruitt, Assessor - Nuclear Assurance t

• T. W. Parrent, Project Engineer - Engineering Assurance  !

• J. M. Lewis, Supervising Specialist Nuclear Program Analysis j Additional plant personnel were contacted during the inspectio U. S. Nuclear Requlatory Commission (NRC)

• P. G. Brochman, Senior Resident inspector F. L. Brush, Resident Inspector  ;

• Denotes those personnel attending the exit meeting on December 3,199 . Inservice Testina (IST) of Pumns and Valves 1

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The inspectors reviewed IST procedures and completed IST surveillance i Generally, the methods used for the testing of pumps and valves were !

adequate. The test frequencies and acceptance criteria were specified 1 and provisions were made for prompt operability determinations. Areas )

reviewed are discussed belo j

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F t .'.f , Scope The scope of the licensee's.IST Program appeared adequat Selected plant systems, Technical Specifications . (TS)-and Emergency Operating Procedures'(E0Ps). were reviewed to. evaluate the program scope. Several valves were identified that. appeared to have safety functions that would require inclusion into the IST program and are discussed belo .;

(1) The IST program did not include a closed safety function for i the three residual heat removal (RHR) pump discharge check .

valves. It appeared that the valves perform a closed safety function to ensure the RHR piping would not drain to the suppression pool. If the piping was not filled, a possible water hammer event could occur upon starting the ' pump and .

prevent the system from performing its intended functio l The licensee's IST basis document, HE-01.00, " Pump / Valve 1 Safety Function Data Sheets," stated that the check valves did not have a closed safety function because the water leg pumps would keep the system filled with water. The wate i leg pumps would not, however, .be able to keep the system

filled if the valves failed open because of the limited pump capacit The safety significance of this. issue was minimal since the three discharge check valves were verified to be in the closed position after the RHR pump operability tests. This was: accomplished by verifying that the water leg pumps could maintain the pressure in the RHR piping above the low level i alarm setpoint. The licensee also identified the discharge check valves for the high pressure core spray and .the low pressure core spray pumps did not include a closed safety function in the IST program, although testing was performed similar to the RHR system. The licensee committed to incorporate the closed safety function for these valves in the IST program and annotate testing was being accomplished during the respective pump test (2) Valve cold shutdown justifications were not included in the IST program. References to previous program submittals or Technical Specifications were listed for the justifications'

location. These documents, however, did not-in all cases contain distinct cold shutdown justifications for all referenced valves. For example, valve IC41-F006 had two references identified in'the IST program, although one'

reference did not contain a cold shutdown justificatio The licensee agreed to review the adequacy and organization of the -IST program cold shutdown justification (3) The basis document for the IST program, tie-01.00, was considered a good reference document, however, in several instances it lacked some design information or the

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information was not correct. For example, the data s'heets for the shutdown service water pump discharge check valves did not contain the flow rate necessary for_ an adequate open exercise test. .In order for this document to be useful i should be maintained as_ a living document.-

(4) Communications between' system engineering,-performance-engineering, surveillance scheduling, and operations groups'

in the IST program implementation was considered good. This was especially apparent in the areas of operability determination and scheduling of increased testin Pump Testina Generally, testing of pumps in the licensee's IST program was performed in accordance with ASME Code requirements and the recommendations of Generic letter (GL) 89-04, " Guidance on-Developing Acceptable Inservice Testing Programs."' The following issue was noted during the inspection:

Shutdown service water (SX) pump ISX0lPC failed to start durin quarterly ASME pump testing on May 24, 1990. The root cause analysis identified tight packing as the' proble The packing was loosened and the pump successfully- starte The pump, however, failed to start on the next quarterly test in August of 199 The root cause analysis performed following the second failure identified the problem as bearing wear, which was increased by silt buildup in the inner shaft tub Recommendations to limit the silt buildup and provide additional assurance that the pump would start included running the pump on-a weekly basis, running the pump for a longer period of time, and trending the pump coastdown time. These recommendations were-implemented by the licensee in 1990. Long term corrective action consisted of designing a modification to limit silt-buildup around the pump shaft. Although engineering has been completed and the parts obtained, the modification package implementation has not been scheduled until the 1995 refueling outag Although the weekly testing verified pump operability, the implementation of long term corrective action was not considered timely to address a problem with a safety related pus .

c. Valve Testina in most cases the guidance of GL 89-04 was incorporated into the IST program for valves. Issues regarding the testing of check ,

valves were documented in paragraphs 3.c and 3.d of th.is repor (1) Containment isolation valve (CIV) water leak rats testing -

was performed in groups as allowed by relief from, the ; Code:

requirement for testing the valves individually; howede- : no 3 '

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b justification for the test acceptance criteria was include ,

in the IST program. .The test acceptance criteria used was l '

gpm multiplied by the number of CIVs in the group being tested. This criteria was specified in TS 3.6.1. .

Discussions between the inspectors and NRR indicated that the TS requirement was not in it selfl sufficient-justification to meet the intent for the NRC's approval of Relief Request 2034. The licensee committed to develop a '

justification for the acceptance c'r iteria used in group testing CIVs. This'will be considered an Inspection followup Item (IFI) (461/93024-01(DRS)) pending review of ~ l the acceptance criteria justificatio ,

(2) The CIV air test procedure, CPS No. 9861.02, contained a provision in Appendix H that check valves could be seated using pressure higher than allowed by the test procedur ,

t Use of this higher pressure would be considered preconditioning the valve prior to the test, which would not >

be allowed. The licensee stated it was not normal practice i to use this provision and a comment control form (CCF) was -

initiated to delete Appendix H from the' procedur (3) The relief valve bench test procedure allowed the use of nitrogen as the test medium for valves in liquid servic .

Based on industry experience, OM-1 no longer allows this option, however, the licensee has not yet committed to OM- The licensee was committed to the 1980 Code,- which did allow l this optien. although consideration would be~taken witn -

respect to the OM-1 requirements. The licensee-indicated ,

that liquid service valves tested this outage were' tested with water, d. Procedures Several minor procedural deficiencies were identified during the ,

inspection. Some of these had previously been identified by the :

licensee. All deficiencies had CCFs initiated to revise the l procedure. These deficiencies included the following:

(1) Standby liquid control pump test procedure did not include a l 1 minute waiting period after flow rate was established prior to recording data as required by Relief Request 3005.

x (2) Several procedures were missing applicable TS limiting !

condition of operations in the acceptance criteria section on the Supplemental Review Sheet (i.e. Procedure 9069.01-should list 3.7.I.1, Procedure 9069.03 should list 3.7.1-l.b).

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< Irendina The IST coordinator maintained the' data from completed IST tests for all pumps and valves in the IST program to trend pump and valve performance, although the data was not graphically- .

represented to allow easy interpretation and comparison of test results. All examined instances of components .in the alert or; action range and the subsequent corrective actions were handled .

appropriatel . Check Valve Proaram

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The check valve program scope was defined in the Check Valve Program computer data base and was considered. acceptable. It included valves identified in INP0 50ER 86-03, " Check Valve Failures or Degradation," check valves in the IST program, and ,

other plant check valves based on maintenance history. There were .:

186 check valves included in the program. There was a 100%

overlap between check valves in the IST program and the check valve program (excluding the hydraulic ' control unit check valves). - Administrative Procedure The program management was recently transferred from NSED -

Mechanical Design & Analysis to Reliability Engineerin Administrative guidance was contained in' the Check Valve Monitoring Program, which was an uncontrolled document and:not updated to reflect the current program administration and other program aspects. This issue was previously identified and was scheduled to be resolved in early 199 .

Participation on the Nuclear Industry Check Valve Committee (NIC).

by personnel from Reliability Engineering was a positive commitment and should allow the check valve program to evolve based on expanding industry experience and knowledg Desian Application Review Design application reviews were performed by internal and-external engineering organizations to develop the current check valve -

program. The reviews were based on the SOER and EPRI report NP-5479, " Application Guidelines for Check Valves in Nuclear Power Plants," and determined which check valves were more susceptible

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to degradation. The. reviews, in most cases, contained' minimum velocity calculations to determine if the check valves fully open,.

actual flow rates through check valves, maintenance history -

evaluations, valve orientation, and other design issues. These reviews were not consistent for all the valves in the program and not always' formally documented. Nevertheless, the program scope was considered acceptable as statec' previousl '

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', Preventive Maintenance  :

Preventive maintenance program for check ' valves was initially ,

disassembly / inspections (D/1), while non-intrusive testing (filT)

techniques were developed. After the first two outages under this format, the program has shifted totally to filT. The f4RC_has encouraged the use of filT, although selected D/I_ may further validate the results of diagnostic testin .:

Maintenance work requests and inspection results were reviewed to ensure proper implementation of the D/I program. The process for :

visual inspections of check valves appeared to be acceptable. The D/I included verifying free disc movement in the as-found ,

condition. The inspection checklist did not appear to be consistently used for all D/I, although sufficient documentation -

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existed when deficiencies were identifie Inservice Testina Check valve testing was in accordance with GL 89-04 with the .

following exception:

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The shutdown service water (SX) pump discharge check valves were not adequately tested in the open direction as required by ASME Section XI, IWV-3522 or the guidance contained in GL 89-04. ' CPS tio. 9069.01, " Shutdown Service Water Operability Test," was .l written to verify the SX pump discharge check valves cpened when :

pump flow was applied through the valves. The pump flow '

requirement, however, was developed to support consistent quarterly pump testing and not' the system flow requirements under an accident condition necessary to satisfy an open test for the check valves. The acceptance criteria stated in CPS 110. 9069.01 .

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was 8937-9070 gpm for ISX001A and ISX0018, and 743-757 for ISX001C. The required flow rates to verify the check valves fully-opened were determined to be 11,655 gpm for ISX001A, 11,632 gpm for ISX001B and 839 gpm for ISX001C. Based on these' flow rates,

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the testing to verify that the valves fully opened on. a quarterly '

frequency was inadequate. This was considered to be a violatio of ASME Section XI and Technical Specification 4.0.5 (50-461/93024-01(DRS)).

The valves had been full stroked open on an infrequent basis during SX system flow balancing in accordance with CPS ti .10, SX System Flow Balance. The most recent system flow l balance was completed in April of 199 !

The valves were successfully tested on flovember 23, 1993. CPS fi .01 was in the process of being revised to ensure the valves were full stroked on a quarterly basis. In addition, IST program '

check valves with an open safety function were reviewed and determined to be adequately tested. The licensee also agreed t make the necessary changes to update the IST program. The- ,

response was timely, thorough, and considered acceptabl '

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, Non-Intrusive Testina  :

a The station has' incorporated NIT'in the check valve progra .

Ultrasonic / acoustic signatures for opening / closing and stead !

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state operation were being .taken on valves based on their accessibility. There were 65 valves requiring HIT. The schedule of NIT for check valves was included in MS-05.00, " Predictive !

Maintenance Program". Use of this system should provide a '

consistent method of identifying the internal . condition of valves without frequent D/ l Trendina The check valve coordinator was responsible for reviewing D/I and NIT results for all valves in the program. These results can then ;

be trended and analyzed for incorporation back into the progra l The trending process allows for program optimizatio . 1.icensee Self-Assessment

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The licensee performed several self-assessments (biennially schedule) in the IST area and one for the. check valve program. These assessments identified several issues and recommendations to improve the programs, lhe assessments were considered to be acceptabl The check valve assessment was performed by engineering and was based on TI 2515/110. Many of the issues identified by the inspectors had ,

previously been identified by the assessment. Two action items were ,

initiated to address the concerns identifie A contractor assessment on the IST program contained several ,

recommendations, although no formal process was in place to followup ,

their resolution. Several recommendations were researched and found to be adequately incorporated into the progra . Inspection Followup Items

. Inspection followup items are matters which have been' discussed with'the

~1icensee which will be reviewed further by the inspector and which involve some action on the part of the NRC or ' licensee or. both. One inspection followup item was identified during this inspection and is described in Paragraph 2.c.(1). Exit Meetina ,

The inspectors met with licensee representatives (denoted in Paragraph 1) at the conclusion of the inspection on December 3,1993. The inspectors summarized the purpose, scope and findings of the inspection and discussed the likely informational content of the inspection repor The licensee identified none of the documents or processes reviewed by the inspectors during the inspection to be proprietar .

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