IR 05000461/1985065
| ML20138C495 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 03/24/1986 |
| From: | Gwynn T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20138C482 | List: |
| References | |
| 50-461-85-65, NUDOCS 8604020511 | |
| Download: ML20138C495 (41) | |
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U. S. NUCLEAR REGULATORY COMMISSION
REGION III
Report No.'50-461/85065(DRP)
Docket No. 50-461 License No. CPPR-137 Licensee:
Illinois Power Company 500 South 27th Street Decatur, IL 62525 Facility Name:
Clinton Power Station Inspection At:
Clinton Site, Clinton, IL Inspection Conducted:
December 16, 1985, through January 27, 1986 Inspectors:
T. P. Gwynn P. L. Hiland D. E. Keating
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F. J. Jablonski ddkland9 * Y
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Approved By:
T. (F.
nn, Chief /
8b Projects Section IB Dat'e
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Inspection Summary Inspection on December 16, 1985, through January 27, 1986 (Report No. 50-461/85065(DRP))
Areas Inspected; Routine safety inspection by resident and regional based inspectors of construction, preoperational testing, and operational preparedness activities including applicant action on previous inspection findings; review of IE Bulletins and Circulais; review of 10 CFR 21 reports; review of a 10 CFR 50.55(e) report; employee concerns; review of alle0ations; functional or l
program areas (including site surveillance tours, administrative procedures review, operational staffing, installation of safety related components and structural integrity test /drywell leakage test witnessing and review);
headquarters / regional requests (including drywell vacuum relief valves and i
l 8604020511 960328 PDR ADOCK 05000461
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s limitorque valve actuators with unqualified wire) and readiness for fuel loading meeting report.
The inspection involved 264 inspector-hours onsite by three resident inspectors and one regional based inspector including 22 inspector-hours onsite during off shifts.
Results: Of the areas inspected, 'io violations or deviations were identified.
The corrective actions being taken by IP plant staff to address'a previously identified unresolved item were e.pparently not adequate. The unresolved item involved the adequacy of procedure reviews to assure that a workable system of plant procedures was available to control applicable plant staff activities in conformance with requirements.
The applicant was requested to provide a written response to that unresolved item (see Paragraph 8.b. of this report).
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DETAILS
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1.
Personnel Contacted Illinois Power Company (IP)
D. Antonelli, Director - Plant Operations
- K. Baker, Licensing and Safety (L&S)
G. Bell, Director, Construction.and Procurement Quality Assurance (QA)
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L. Boquist, Control and Instrument Engineer i
B. Calhoun, Quality Projects Coordinator, IP QA R. Campbell, Director - Quality Systems and Audits, QA
+*W. Connell, Manager - QA J. Cook, Assistant Manager - Clinton Power Station (CPS)
- E. Corrigan, Director - Quality Engineering and Verification, QA
- H. Daniels, Project Manager L. Davis, Supervisor, Document Control, Nuclear Support (NS)
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+G. Edgar, IP Counsel F. Espinoza, Nuclear Services Engineer, Control and Instrumentation (C&I)
- S. Fisher, Manager, NS
- J. Greene, Manager - Startup (SU)
- D. Hall, Vice President, Nuclear D. Holesinger, Director - Startup Test, SU
- D. Holtzscher, Director - Safety Analysis, L&S J. Hunsicker,. Supervising Engineer, C&I J. Jones, Supervisor - Mechanical Maintenance E. Kant, Assistant Manager, Nuclear Station Engineering (NSE)
- J. Loomis,' Construction Manager
J. Miller, Director - Startup Programs, SU K. More, Startup Group Lead Engineer
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R. Morgenstern, Director - Plant Technical H. Nodine, Supervisor, C&I M. Norris, Supervisor - Testing and Scheduling
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- J. Palchak, Supervisor - Plant Support Services
- J. Perry, Manager - Nuclear Prograe Coordination
+R. Phares, Technical Staff S. Rasor, Supervisor - Construction QA
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S. Richey, Director - Maintenance
+T. Riley, IP, Licensing Project Engineer
R. Schaller, Director - Nuclear Training
- D. Shelton, Manager - NSE
+F. Spangenberg, Manager.- L&S L. Stifter, Control and Instrumentation Engineer
+P. Telthorst, IP, Licensing Engineer D. Tucker, Lead Commitment Control Engineer M. Vandermyde, Nuclear Project Engineer D. Vincent, Startup Lead Program Engineer R. Wenborne, Control and Instrumentation Engineer
+*J. Wilson, Manager - CPS
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F. Worrell, Supervisor - Plant Operations
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Baldwin Associates (BA)
J. Brennan, Electrical Field Supervisor M. Daniell, Manager, Technical Services J. Doolin, Supervisor of Training, Quality & Technical Services B. Fraser, NDE Engineer, Level II R. Greer, Manager - Quality and Technical Services E. Rosol, Project Manager
- D. Schlatka, Project Manager D. Selva, QA Engineer J. Thompson, Manager - Quality Engineering P. Trenkle, Electrical QC Inspector D. Zimmerman, Electrical QC inspector Soyland/Wipco J. Greenwood, Manager - Power Supply Nuclear Regulatory Commission (NRC)-
+S. Black, NRR, Planning and Program Analysis Staff
+P. Boehnert, NRC, Advisory Committee Reactor Safeguards Staff
+W. Butler, NRC, Division of Boiling Water Reactor Licensing (DBL)
+K. Campe, NRC, DBL, Power Systems Branch
+P.. Gwynn, NRC-RIII, Chief, Projects Section 18
+P. Hiland, NRC-RIII, Resident Inspector
+M. Hodges, NRC, DBL, Reactor Systems Branch
+R. Housfin, NRC, DBL
+F. Jablonski, NRC-RIII, Projects Inspector
+D. Keating, NRC-RIII, Senior Resident Inspector
+G. Lainas, NRC, DBL
+C. Scheibelhut, NRC-Argonne National Laboratory
+B. Siegel, NRC, Licensing Project Manager
+M. Srinivasan, NRC, DBL
+D. Vassallo, NRR, DBL, Facilities and Operations Support
+R. Warnick, NRC-RIII, Chief, Reactor Projects Branch 1
- Denotes those attending the monthly exit meeting.
+ Denotes those attending a meeting in Bethesda, MD. on January 13, 1986, to discuss readiness for fuel load.
See Paragraph 10 of this report for details.
The inspectors also contacted others of the construction project and operations staffs.
2.
Applicant Action On Previous Inspection Findings (92701/92702)
a.
(0 pen) Open Item (461/85005-19):
Verify that valves in the fire protection water supply system, which are not electrically supervised, are keylocked open and have strict key control procedures and monthly verification of valve position.
(Safety Evaluation Report (SER) SER, Paragraph 9.5.1)
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The inspector reviewed CPS No. 9071.19, " Monthly Fire Protection Valve Lineup", Revision 0, ~ dated August 29, 1985.
The procedure required for monthly surveillance of fire protection (FP) water supply valve position to demonstrate operability of the FP system.in accordance with the Clinton Power Station (CPS) technical specifications.
The inspector reviewed the results of the monthly surveillance of FP system valves for the month of December 1985.
The inspector noted that CPS No. 9071.19 was implemented, and discrepancies'in system lineup were annotated on the valve lineup sheets.
The. inspector verified by review of drawings and physical observation of system valves that the valves necessary to supply FP water from one-of the diesel driven fire pumps to a fire main located in the auxiliary building were included in the CPS No. 9071.19 valve lineup sheet and were properly positioned.
One discrepancy was identified; valve 0FP288 was not ~ included in the valve checklist.
The inspector-noted that the valve in question had been installed under a design change in June 1985; that the valve was not identified; had a broken operator window; and i.ad not been painted.
The applicant stated that the valve was still under the jurisdiction of IP Startup; that the valve would be included on the checklist as part of the normal system turnover process; and that finishing work was required for the valve prior to turnover which was being tracked by IP.
This information was sufficient to satisfy the inspector's concern.
The inspector requested information related to the controls provided for FP valve lock keys.
The applicant was not able to provide the re_ quested information; there were no plans in place to control the keys for FP valve locks.
This matter was referred to the cognizant license reviewer in the NRC Office of Nuclear Reactor Regulation.
This item remains open pending resolution of the question concerning key control.
b.
(0 pen) Open Item (461/85005-30):
Verify that a corporate management directive has been prepared emphasizing the management responsibility of the shift supervisor and the establishment of a training program-for shift supervisors to meet the guidelines of NUREG-0578 (Three Mile Island (TMI) Item I.C.3).
The inspector reviewed IP Nuclear Policy Statement No. 7, " Supervisory Responsibilities", Revision 0, dated March 13, 1985.
That policy statement, which was distributed to all licensed operators and license.
candidates, met the quidelines of NUREG-0694, "TMI-Related Requirements for New Operating Licenses".
The inspector reviewed the information provided by the applicant concerning training for shift supervisors to meet the guidelines'of NUREG-0578.
The applicant was not able to provide information which demonstrated that the current shift supervisors had been trained to a
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program that met the applicable requirements. This matter was discussed with responsible IP management who stated that action would be taken to resolve this discrepancy.
This item remains open pending review of the required training program and verification of performance of the required training.
c.
(0 pen) Open Item (461/85005-44):
Verify that loose parts monitoring systems (LPMS) are operational prior to fuel load.
Review of the CPS SER, NUREG-0653, Paragraph 4.4.1 showed that this open item was stated as follows:
"...the applicant will have a loose-parts monitoring system (LPMS) operational at the time of initial reactor startup testing." The CPS draft technical specifications, Paragraph 3.7.7.10 requires that the LPMS be operable in operational conditions 1 & 2.
Thus the open item, as originally defined in Inspection Report No. 50-461/85005, was incorrect in that the LPMS is not required to be operational prior to fuel load.
The LPMS is required to be operational prior to initial criticality.
The inspector reviewed the applicant's information provided to close this item.
The information indicated that a surveillance procedure was available to demonstrate the operability of the LPMS for two of three applicable technical specification surveillance requirements.
The information provided did not address the third surveillance requirement. More importantly, the information provided did not address the operai.ional status of the LPMS to support initial reactor operation. This item remains open pending receipt of additional information from the applicant.
d.
(0 pen) Unresolved Item (461/85012-02):
Inspection of plant staff administrative control procedures, documented in Inspection Report No. 50-461/85012, identified several deficiencies requiring corrective action.
Those deficiencies are summarized as follows:
(1) Several requirements of ANSI N18.7-1976, " Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants," were not reflected in the plant administrative procedures reviewed.
(2) Procedure steps tc provide for conformance to the CPS technical specifications were not reflected in the procedures reviewed and were not identified and tracked as missing information ("LATER").
(3) Several requirements of upper tier documents were identified as recommendations ("should") rather than as requirements ("shall").
(4) There were apparent conflicts between procedure requirements.
(5) Some plant administrative control procedures were misclassified as nonsafety-related in the operating manual status report.
This misclassification resulted in the procedure and changes thereto not having required reviews.
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Of particular concern was the lack of independent review of plant procedures to which the other deficiencies were attributed.
In order to corroc't the above deficiencies, the applicant verbally committed to the following:
(1) Perform a review of all procedures with a class code of N (nonsafety-related) or F (nonsafety-related, Facilities Review Group (FRG) review required) to assure that all identified procedures had been properly classified and had received all required reviews; and (2) Perform an independent technical review of specified plant procedures in order to demonstrate compliance with the facility technical speci fications.
That review was to be completed and documented prior to fuel load.
Monitoring of the above actions by the inspector, documented in Inspection Reports No. 50-461/85045 and 85053, indicated that the applicant was progressing according to a schedule that would support the facility fuel-load date.
See Paragraph 8.b. of this inspection report.
This matter remains unresolved.
s e.
(Closed) Open Item (461/83010-01):
Design verification of electrical raceway system.
This matter was previously discussed in Inspection Reports No. 50-461/83010, 83012, and 83014.
In report 50-461/83014 it was stated that IP would audit or otherwise review Sargent & Lundy's (S&L)
design process to verify the overall performance of the electrical raceway system; that is, performance would not be comoromised by interaction or cumulative effects creatediby the several deficiencies reported by IP to Region III.
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The inspector reviewed the enclosure to S&L letter to IP, SLS-I-5478, dated December 12, 1985.
The enclosure was titled " Interaction Effects of 10 CFR 50.55(e) Issues for Electrical Component Installation," and included discussions about 10 CFR 50.55(e) Reports 80-08, 80-09, 81-05, 82-01, 82-09, 83-05, 83-11, 84-02, and 84-18. Among other things, the S&L report included the engineering basis for disposition and/or corrective actions, an explanation of any impact on design' margin, and possible cumulative effect/ interaction.
The review was complete and detailed.
The report indicated that all hardware related problems were corrected to minimize or completely remove any impact on the overall design of the electrical raceway system.
The inspector agreed with S&L's conclusion that the subject 10 CFR 50.55(e) reports did not exhibit cumulative effects and there were no apparent interactions which would impact on the designed function of the electrical raceway system.
Other matters related to problems with materials and components of the electrical raceway system were documented in Inspection Reports No. 50-461/81029, 84028, and 85054.
The inspector has no further questions about this item.
This matter is closed.
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f.
(Closed) Open Item (50-461/84004-01):
Cracks in concrete slabs and walls.
A previous inspection identified visible cracks in the Power Block concrete slab walls and floors.
One~ vertical crack was identified in the Radwaste Building east wall at 737 level, location G-200.
Numerous cracks were identified in the 800 level main turbine floor-emanating from the generator hold down bolts.
This matter was referred to the applicant's Quality Assurance (QA) group for study and disposition.
0A was also requested to perform a similar surveillance of the Power Block and to address the subject of acceptability /
rejectability of cracks.
Although the acceptability or rejectability of concrete cracks was not specifically addressed in the Final Safety Analysis Report (FSAR),
there was information in the form of technical papers that provide recommended practices. These were as follows:
(1) ACI-SP-20,
"Causes, Mechanisms, and Control of Cracking in Concrete" (2) ACI-224R-80,
" Control of. Cracking in Concrete Structures" (3) ACI-SP-30,
" Cracking, Deflection and Ultimate Load of Concrete Slab Systems" These three papers specify design factors and parameters to be used for the design of beams and slabs for crack control.
The inspector requested that IP provide design calculations for one-way and two-way slabs for review of these factors.
A review of the calculations showed that whatever cracking may occur will be within normal code limits as specified for nuclear power plants.
This item is closed.
g.
(Closed) Open Item (461/85005-06):
Verify installation of automatic Reactor Core Isolation Cooling (RCIC) turbine restart on low reactor water level (SER, Paragraphs 5.4.1 and 6.3.2.3).
The inspector reviewed sheets 9 and 12 of Schematic Diagram E02-1RI99 to verify that the RCIC turbine will automatically restart on low reactor _ vessel water level.
The inspector also discussed with IP Startup personnel the methods used by them to verify by test that the circuitry changes ware made as documented in Generic Test Procedure (GTP)-40 for drawing E02-1RI99 as part of Preoperational Test Procedure.(PTP) PTP-RI-01.
The inspector was satisfied that the required circuitry changes had been made and tested.
This item is closed.
h.
(Closed) Open Item (461/85005-07):
Verify installation of a time delay relay in the logic of the RCIC system (TMI II.K.3.15, SER Paragraphs 5.4.1 and 7.3.3.3).
The inspector reviewed sheets 11 and 13 of Schematic Diagram E02-1RI99 to verify that a three second time delay relay had been installed in the RCIC steam supply line break detection circuitry to
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prevent spurious RCIC system isolation.
The inspector also discussed with IP Startup personnel the methods used by them to verify by test-that the circuitry changes were made as documented in GTP-40 for drawing E02-1RI99 as part of PTP-RI-01.
The inspector was satisfied that the required circuitry changes had been made and tested.
This item is closed.
i.
(Closed) Open Item (461/85005-08):
Verify that the high drywell pressure interlock on the High Pressure Core Spray (HPCS) injection valve is removed (SER, Paragraph 6.3.2.3).
The inspector reviewed' revisions C and D of schematic diagram E02-1HP99 to verify removal of the drywell high pressure interlock for closure of the HPCS injection valve on reactor vessel high water level.
The inspector also discussed with IP Startup personnel the methods used by them to verify by test that the circuitry changes were made as documented on sheets 4 and 5 of GTP-40 for drawing E02-1HP99 as part of PTP-HP-01.
The inspector was satisfied that the. required circuitry changes had been made and tested.
This item is closed.
j.
(Closed) Open Item (461/85005-31):
SER, Paragraph 13.1.2.2.
Review the operating organization when it can be observed functioning in more areas (6 to 9 months prior to fuel load).
At the time the CPS SER (NUREG-0853) was issued in February 1982, CPS staffing was not sufficiently complete to allow the NRC staff to conclude that the applicant met minimum requirements of the Standard Review Plan (SRP).
Since the SER was issued, a number of reports delineating the NRC staff review and verification of specific areas in the operating organization have been issued.
Inspection Report
No. 50-461/85063, Paragraph 7.c., and Paragraph 8.c. of this report,
provide the details of NRC staff inspections performed to verify the
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applicant's Operational Staffing commitments.
These inspections and
the reports referenced therein provide the basis for concluding that
the applicant's operating organization meets the minimum requirements
of the SRP and is in accordance with the FSAR.
This item is closed.
k.
(Llosed) Open Item (461/85005-40):
Verify that modifications have
been made to certain balance of plant valves, prior to fuel load, to
prevent them from reverting to their normal operating position upon
reset of a loss of coolant accicent (LOCA) isolation signal
(Supplementary Safety Evaluation Report (SSER) 2, Paragraph 7.3.3.7).
The inspector reviewed constructicn travelers and verified by field
observation that the modifications required by (SSER) 2,
Paragraph 7.3.3.7 have been completed.
The details of this review
are discussed in Paragraph 3.d. below.
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Modifications have been made to prevent certain balance of plant
valves from reverting to their normal operating position upon reset
of a LOCA isolation signal. This item is closed.
1.
(0 pen) Open item (461/85005-43): Verify that commitments listed in
SSER2, Paragraph 9.3.5 are incorporated into the Clinton Core Damage
procedure prior to fuel load (TMI Item II.B.3).
The applicant provided information for closure of this item.
SSER2,
Paragraph 9.3.5.1, subsection (1), required that the applicant
maintain a post-accident sampling system (PASS) testing and operator
training program that included the following elements:
(1) Is performed on a semiannual basis.
(2) Consists of obtaining and analyzing reactor coolant, suppression
pool, and residual heat removal (RHR) system samples chemically
and radiochemically by persons responsible for post-accident
procedures.
(3) Corrects any discrepancies found in the training exercises in a
revised procedure.
The information provided by the applicant was not responsive to the
above requirements.
The inspector advised the applicant that, in
order to provide an adequate basis for closure of this item, the
applicant must provide an implementing procedure or instruction,
approved by the FRG, which references Technical Specification
Requirement 6.8.4.c and which is responsive to the above listed SER
requirements.
The applicant acknowledged this information.
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SSER2, Paragraph 9.3.5.1, subsection (2), requires that the applicant
maintain Clinton specific core damage procedures that include the
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following:
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(1) Provide means to differentiate between cladding failure and core
melt and the degree of each type of core damage.
(2) Factor in a third core damage category between cladding failure
and core melt, namely, fuel overheating.
The applicant provided Emergency Plan Implementing Procedure (EPIP)
EC-13, " Reactor Core Damage Estimation", Revisfon 1, dated November 27,
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1985, as basis for closure of this portion of the open item. The
inspector reviewed procedure EC-13 and found it to be responsive to
the SER requirements.
The following procedural discrepancies were
oiscussed with the applicant:
(1) The table in Paragraph 1.2 was missing < and > symbols (that is,
<10% vice 10% and > 50% vice 50%).
(2) The procedure did not state when or if Paragraph 4.2 was to be
used.
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(3) Paragraph 4.1.7 did not provide guidance for estimating core
damage when the normalized I-131 concentration was less than
the upper limit.
(4) Paragraph 4.5 and the record sheet on attachment 12 were not
changed when the graph on attachment 13 was changed.
This caused
some confusion when trying to follow the procedure.
(5) The procedure never required the person implementing the
procedure to translate data obtained in terms of % clad failure
and % fuel melt to a core damage class and degree for management
use.
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The applicant stated that these discrepancies would be corrected in
a subsequent revision of the procedure.
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This item remains open pending provision of an implementing procedure
or instruction, approved by the FRG, which references Technical
Specification Requirement 6.8.4.c and which is responsive to the SER
requirements.
m.
(Closed) Violation (461/85042-01):
BA Procedures (BAPs) 3.3.1, 3.3.6,
and 3.3.14 (Installation instructions for conduit, electrical raceway,
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30d conduit supports, respectively), were not consistent with the
requirements of upper tier documents for control.of material
traceability.
The requirements of BAP 1.5, " Material Traceability,"
for QC inspectors to record the presence of a QC accept stamp on cut
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materials may not have been properly implemented as a result.
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The inspector reviewed corrective actions taken by the applicant as
described in BA Corrective Action Request (CAR) 249 dated June 7, 1985.
BA Quality Engineering evaluation of the hardware condition revealed
no hardware impact since all materials available for use were procured
as safety-related and had been determined to meet the weldability
requirements of AWS D 1.1 (Structural Welding Code).
BA made changes
to the affected procedures, trained applicable. crafts, and performed
an evaluation of nonconformance report dispositions to verify their
adequacy.
All committed actions were verified complete by BA Quality
Engineering on September-27, 1985.
Records of these actions were on
file in the IP Central Files.
In addition, the inspector independently verified that the affected
procedures had been revised to address the CAR.
This matter is closed.
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No violations or deviations were identified.
3.
Review of IE Bulletins and Circulars (92703)
a.
(0 pen) IE Circular 79-12 (461/79012-CC):
Potential Diesel Generator
Turbocharger Problem.
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IE Circular 79-12 identified a potential problem involving lack of
adequate lubrication for General Motors - Electromotive Division,(EMD)
diesel engine turbochargers when restarting a hot engine within 15
minutes to 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> of the last engine run (lube oil temperature > 140
degrees F).
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IP received this Circular on July 2, 1979.
EvaluationbyIPindidated
that the circular was applicable to the Stewart & Stevenson supplied
EMD diesel engines used at CPS to provide an onsite source of
emergency electrical power (diesel generators).
This circular was previously reviewed by Region III in Inspection
Reports No. 50-461/80004 and 82007.
Applicant actions relative to
this circular had not been completed at the time of the last
inspection.
The concerns identified in IE Circular 79-12 were stated as follows:
EMD-is currently developing a modification to improve the lube oil
system.
It is planned that this modification will be available for
installation in approximately six months.
In the interim, the
following actions are recommended for those having EMD diesel engines:
(1) Repeated fast hot starts within a minimum 15 minute to 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />
time frame after shutdown should be avoided.
Allow the engine to
cool at least 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> after it has been operated in the " loaded"
mode, or otherwise a restart should be performed within 15 minutes
of shutdown.
(2) After changing oil filter elements or draining the accessory oil
system for any reason, and upon refilling of the system make sure
that the circulating oil pump is in operation for at least 30
minutes and that the strainer box is full before starting the
engine. The engine should then be brought to an idling conditicn
to assure complete filling of accessories before any subsequent
fast start is made.
(3) Any small leak at the top of the oil cooler should be corrected.
A leak at this location allows air to be drawn into the cooler
during shutdown, which will cause the drain'back to be more rapid.
(4) Avoid testing of the redundant diesel engines concurrently..
Where it is necessary to run the redundant diesels concurrently,
maintain one diesel in the running mode for a minimum of three
hours following the shutdown of the other.
IP actions taken in response to this circular were identified as
follows:
(1) CPS Procedure 3506.01, " Diesel Generator and Support Systems,"
Sections 4.14 and 8.1.3.1 have been revised to caution against
hot restarts.
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(2) CPS Procedures 10P3506.01S, ISP908.01S through.55, and
ISP9080.085 have been revised to ensure the diesel generators
have been operated or prelubed within the last~ 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> prior to
starting.
(3) No leaks exist at the top of the oil coolers on CPS diesels.
(4) CPS Procedure 3506.01, " Diesel Generator and Support Systems,"
Section 4.15 has been revised to caution against testing the
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diesel generators concurrently and to maintain one diesel in the
running mode for a minimum of three hours following shutdown of
the others.
The only exception is a ten year operational
independence test which is performed in accordance with CPS
Procedure 9080.08, " Diesel Generator Operational Independence
Verifications."
The inspector noted that the applicant plans to install a modification
to the EMD diesel generator lube oil prelube system to address these
concerns.
Review of CPS No. 3506.01, revision 1 dated October 25, 1985, verified
the actions stated in applicant actions 1. and 4. above had been
carried out.
The inspector reviewed procedures to verify applicant action 2. as
follows:
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CPS No. 3506.01, " Diesel Generator and Support Systems,"
Revision 1, dated October 25, 1985.
CPS No. ISP9080.015. " Diesel Generator Operability Manual,"
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Revision 0, dated July 10, 1980 (TCF 85-295).
CPS No. 9080.02, " Diesel Generator 1C Operability Manual,"
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Revision 20, dated January 10, 1986.
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CPS No. 1SP9080.035, " Diesel Generator Operability - ECCS,"
Revision 0, dated May 29, 1981 (TCF 85-275).
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CPS No. 1SP9080.045, " Diesel Generator Auto Load / Reject
Verification Test," Revision 0, dated December 31, 1980 (TCF
85-276).
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CPS No. 1SP9080.055, " Diesel Generator 24 Hour Operability
Checks Division
I," Revision 0, dated June 9, 1981 (TCF 85-277).
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CPS No. 1SP9080.08S, " Diesel Generator Operational Independence
Verification," Revision 0, dated April 14, 1981 (TCF 85-278).
The inspector found that, for the procedures reviewed, temporary
change forms (TCFs) had been issued to implement the stated action.
However, CPS No. 9080.02 had been recently revised and the stated
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action included in the TCF had not been incorporated.
The inspector
requested that the applicant clarify this matter and assure that the
other TCFs were incorporated in subsequent procedure revisions.
Applicant actions in item 3 above were not specifically addressed in
the records provided to the inspector for review.
The inspector
requested that the applicant provide objective evidence that the
Division I, II, and III diesel engines had been inspected for oil
leaks in the top of the engine oil coolers.
Tho applicant's actions did not specifically address concern #2 of the
circular; however, records were provided which indicated that
applicable maintenance procedures were scheduled to be revised to
address the. concern of the circular.
Review of CPS No. 8207.02,
" Emergency Diesel Maintenance,".evision 1, dated November 26, 1985,
and CPS No. 8207.01, "8000 Hour Diesel Engine Inspection (Division I,
II, and III)," Revision 0, dated June 22, 1984, showed that CPS
No. 8207.02 had been revised to address the circular but CPS 8207.01
had not.
This circular remains open pending clarification of the status of
CPS 9080.02; pending assurance that the other TCFs will be
incorporated, if required; pending receipt of objective evidence
supporting applicant action 3. above; and pending revision of CPS
No. 8207.01 to address the circular.
b.
(Closed) IE Circular 79-05 (461/79005-CC):
Moisture Leakage In
Stranded Wire Conductors.
IP requested S&L to review IE Circular 79-05 in April and May of 1985.
The inspector reviewed S&L's response to IP in letter SLBI-17563 dated
May 21, 1985.
S&L reviewed design documents applicable to terminations
at penetrations, splices, junction boxes, terminal blocks, motors,
solenoid valves, limit switches, instruments and other equipment
penetrated by conduits.
IP reviewed BA installation procedures in
reference to the S&L letter and concluded that problems with moisture
leakage in stranded wire conductors would be precluded.
The actions recommended in IE Circular 79-05 have been completed.
IE Circular 79-05 is closed.
c.
(Closed) IE Bulletin 79-23 (461/79023-BB):
Potential Failure of
Emergency Diesel Generator Field Exciter Transformer.
IE Bulletin 79-23 identified certain deficiencies in the wiring of
emergency diesel generator field exciter transformers that could
result in failure of tne diesel generator after continuous operation
at rated load for a period of approximately 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />.
The bulletin
required the applicant to determine if the specific deficiency was
applicable to CPS, and to provide a schedule for testing of emergency
diesel generators or completed test results meeting the bulletin
requirements. Testing was required to demonstrate full load carrying
.
.
capability for an interval of not less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, of which 22
hours was to be at a load equivalent to the continuous rating of the
diesel generator and 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> at a load equivalent to the 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> rating
of the diesel generator..The test was also to verify that voltage and
frequency requirements were maintained and that the cooling system
functioned within design limits.
This bulletin was previously reviewed in Inspection Reports
No. 50-461/80011,'81001, and 84019.
Those reports verified that the
applicant had received the bulletin, had reviewed it for applicability,
and had provided a response within the time frame required by the
bulletin.
The applicant had preoperational test procedures which met the testing
requirements of the bulletin.
The inspector reviewed the following
preoperational test sections:
PTP-DG/00-01, " Division I Diesel Generator and Fuel Oil,"
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Revision 0, dated August 20, 1985; Paragraphs 7.2.1 through
7.2.20.
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PTP-DG/D0-02, " Division II Diesel Generator and Fuel Oil,"
Revision 0, dated September 20, 1985; Paragraphs 7.2.1 through
7.2.20.
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PTP-DG/D0-03, " Division III Diesel Generator and Fuel Oil,"
Revision 0, dated July 2, 1985; paragraphs 7.2.1 through 7.2.23.
This review showed that the preoperational test procedures for all CPS
emergency diesel generators complied with the requirements of the
bulletin.
Test results were.,ot available for the Division I and II
diesel generators at the time of this review.
The inspector requested
copies of selected portions of the Division III diesel generator test
results and verified that the test was conducted as committed.
Test
results had been reviewed by the applicant and were acceptable.
Results of the Division I & II diesel generator preoperational tests
are scheduled for review by Region III under thel routine inspection
program.
This bulletin is closed.
d.
(Closed) IE Bulletin 80-06 (461/80006-BB):
Engineered Safety Feature
(ESF) Reset Controls.
IE Bulletin 80-06 identified circumstances
where automatic reset of an ESF actuation signal that is, without
operator action, would cause certain equipment to return to its normal
operating condition and compromise protective actions taken in
affected systems.
At the time IE Bulletin 80-06 was issued, the applicant was a
construction permit holder and as such a written response was not
required.
However, the NRC staff (see Paragraph 2.k. above) asked the
applicant to review the electrical schematic / control circuit diagrams
for all safety-related equipment to determine whether or not, upon
.
s
reset of an ESF actuation signal, this equipment would remain in its
emergency mode.
Inspection Report No. 50-461/84-19, Paragraph 2.e.,
documented the results of the applicant's review and commitments to
modify the control circuitry.
The inspector verified that the modifications committed to by the
applicant were completed for both the nuclear steam supply system
(NSSS) and balance of plant (80P) system valves as follows:
The applicant committed to revise the control circuitry fc.' the RCIC
inboard isolation valve E51-F063, and outboard isolation valve
E51-FC64. The inspector reviewed construction travelers
(WA-E21A-XX-025 and WA-E21A-XX-018) and confirmed, by direct
observation, that the hand switches (IE51A-51 and IE51A-S2) -in the
control room had been modified.
Operator action was required to
reopen.these valves after the reset of a RCIC system isolation signal.
Nuclear Steam Supply Shutoff System / Nuclear Boiler System
The applicant committed to modify the circuitry for RHR sample line
valves E12-F050A, B, and E12-F075A, B and reactor water sample valves
833-F019 and B33-F020.
The inspector reviewed Field Deviation
Disposition Request (FDDR) LHI-1227 and LHI-1612 which were the
controlling construction documents to remove and reinstall control
room panels H13-P661, H13-P662, H13-P663, and H13-P664.
These control
room panels were sent to the General Electric Company, San Jose,
California facility for required modifications which included the
control circuitry above.
The inspector reviewed the control circuitry
design drawing E02-INB99 sheets 201 and 227 which identified the
seal-in circuit required for the circuit modification.
The inspector
verified by direct observation, that the required seal-in circuit card
was installed in control room panel P-662, circuit card location
C-A16-A113. Operator action after reset was required for these
valves to reopen.
BOP Systems
- The applicant committed to modify a total of 28 valves in the
Component Cooling (CC) and Process Sampling (PS) systems to provide a
seal-in on a LOCA signal.
In addition, four valves in'the Containment
Combustible Gas Control (HG) system were committed to' be modified to
seal-in with the HG system in either normal or test.
The required modifications were verified by the inspector to have been
completed by review of the following closed construction travelers:
(1) CC Valves:
Traveler H13-F4574 incorporated Field Engineering
Change Notice (FECN) 4574 which provided seal-in logic for
valves 1CC071, ICC072, ICC073, and ICC074.
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(2) PS Valves:
Traveler H13-4765 incorporated Engineering Change
Notice (ECN) 4765 which provided seal-in logic for valves
IPS003, IPS004, IPS005, IPS009, IPS010, IPS016, IPS017, IPS022,
IPSG31, IPS032, IPS034, IPS035, IPS037, IPS038, IPSO 43A,
IPS0438, IPSO 44A, IPSO 448, IPSO 47, IPSO 48, IPS055, IPS056,
(3) HG Valves:
Traveler H13-5298 incorporated ECN 5298 which revised
the wiring scheme to prevent 'IHG001, IHG004, IHG008 from
reopening after a LOCA signal has been cleared if valve switches
are in test position.
The design changes committed to by the applicant and confirmed in
the SER have been performed. IE Bulletin 80006-BB is closed.
e.
(Closed) IE Bulletin 84-03 (461/84003-88):
Refueling Cavity Water
Seal.
This bulletin notified all power reactor licensees and
construction permit holders of an incident in which the refueling
cavity water seal failed and rapidly drained the refueling cavity at
an operating reactor plant.
This bulletin requested certain actions
be taken to assure that fuel uncovery during refueling remains an
unlikely event.
Inspection of this bulletin response (see Inspection Report
No. 50-461/85012, paragraph 3.a) identified that certain information
was missing from the applicant's original response to the bulletin.
The applicant provided additional information in response to the
bulletin on June 5, 1985.
Review of this bulletin response, with the
additional information, showed that the applicant had received and
evaluated the information included in the bulletin and had responded
to all applicable portions of the bulletin.
Based on their evaluation,
the applicant concluded that the gross failure of the CPS refueling
bellows (a stainless steel design equivalent to the rubber boot seals
described in the bulletin) was a highly unlikely event and that
' adequate plant procedures were provided to detect and mitigate the
potential consequences of a refueling bellows failure.
The inspector
observed that the procedures in place would provide for detection and
mitigation of any failure which could result in draining of the
containment upper pools.
This information provided an adequate basis
.for closure of this bulletin.
4.
Review of 10 CFR 21 Reports (92716)
a.
(Closed) 10 CFR 21 Report (461/82001-PP):
Ventilation fan housings
supplied by Buffalo Forge Co. did not provide protection for adjacent
safety-related equipment from internally generated missiles.
~
This matter was previously reviewed in Inspection Report
No. 50-461/85046, Paragraph 2., open item 461/85005-34.
During that
inspection the inspector found that the applicant's corrective actions
were satisfactory to resnive the open' item and the 10 CFR 21 report.
This matter is closed.
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b.
(Closed) 10 CFR 21 Report (461/82012-PP):
Cell cracks ir. Model KC-11
batteries.
Although this item was included in the Region III Tracking System,
it had never been reported to the NRC by the vendor or applicant.
This item has been determined to be not reportable. This matter is
closed.
c.
(Closed) 10 CFR 21 Report (461/82012-PP):
STS Cable pins.
Although this item was included in the Region III Tracking System,
it had never been reported to the NRC bv the vendor or applicant.
This item has k en determined to be not reportable.
This matter is
closed.
5.
Review of 10 CFR 50.55(e) Report (92700)
(Closed) 50.55(e) Item (461/84002-EE): Material traceability.
This matter
was initially reported to the NRC as a potentially reportable construction
deficiency on January 11, 1984.
On July 9, 1985, IP reported that, based
on their completed review of the subject, a. reportable deficiency did not
exist.
No significant conditions adverse to the safety of operations were
identified.
Problems related to material traceability have been documented in
Inspection Reports No. 50-461/81003, 83010, 83014, 83019, and 85015.
Item
461/84002-EE was reported based on a combination of problems documented in
various audit, deviation, nonconformance, and corrective action reports.
The problems reported include areas where the requirements for material
traceability were unclear or in question. Areas affected were identified
as follows:
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Structural shapes and plates for electrical supports
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ASME subsection NF-2 and 3 components supports
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Strut and strut fittings for electrical and instrument supports
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Hilti anchor bolts
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Unmarked bolts
Field fabricated cable finger assemblies
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Washers and shim stock
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Corrective actions taken by the applicant included one or more of the
<
following items:
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Initiation of a corrective action report
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Develop and implement a sampling program
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Revise procedures
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Provide training
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Future procurement as safety related
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Test material
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Revise specifications
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Purge site of non-traceable items
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Inspection Report No. 50-461/85015 documented.that current measures to
identify and control materials used in construction at CPS were adequate,
sample plans met the intent of Military Standard (MIL-STD)-414 requirements,
ano analysis of chemical test results showed that no weldability problems
i
existed.
Based on that report and a review of IP interoffice memorandum Y-32325 and
'the data referenced therein, the inspector agreed with IP's conclusion that
no significant conditions adverse to safety were identified; therefore, a
reportable deficiency did not exist. This matter is closed.
6.
Employee Concerns (99014)
The inspectors reviewed concerns expressed by site personnel from time to
time throughout the inspection period.
Those concerns related to regulated
activities were documented by the inspectors and submitted to Region III.
Two concerns were transmitted to the regional office during this report
period.
7.
Review Of Allegations (99014)
i
a.
(Closed) Allegations (RIII-85-A-0196-02 thru -07/#174-02 thru -07):
An individual alleged a number of conditions existed in a Field
Document Control (FDC) station that were not in accordance with site
procedures. One additional concern (Concern #1, RIII-85-A-0196-01)
was reviewed and the results documented in Inspection Report
No. 50/461-85063, Paragraph 6.d.
The remaining specific concerns
expressed were as follows:
i
Concern # 2
" Approved for Construction" stick drawings were being checked out of
field document control center FDC3 by construction crafts for longer
than the previously accepted three work days.
This could allow
" approved for construction" drawings to be out in the field when a
r'equired change notice goes into effect.
NRC Review
The in;r
'm. reviewed the appropriate BA project procedures used at
the CPS for document control.
The governing procedure, BAP 2.0,
Revision 14, " Document Control," delineated responsibilities for the
receipt, distribution and traceability of controlled documents and
revisions.
Field Document Control station "FDC3" was. located in the
Diesel Generator Building.
Electricians were the primary users of
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FDC3.
The inspector interviewed the FDC3 supervisor, seven Stone and Webster
(S&W) electricians, four BA electricians, and three BA electrical-crew
foremen to determine the actual practice for checking out stick
drawings from FDC3. While not a precedural requirement, the inspector
determined through these interviews that the users were instructed to
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return stick drawings in their possession at the close of business on
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Wednesday and_ Friday of each week.
Stick drawings checked out on
Saturday or Sunday were to be returned at the close of business on the
day of checkout.
Control of revisions to drawings was proceduralized in BAP 2.0,
Paragraph 5.4.1.c, which required recipients of document transmittals
to " return to the Document Control Center within ten working days, a
signed copy of the transmittal in accordance with the transmittal
instructions".
Paragraph 5.4.3 required a " Followup No. 1" request to
be forwarded to recipients of document transmittals who fail to
process the applicable documents.
Paragraph 5.4.3 further stated
" Follow-Up No. 1 transmittals not returned to the Document Control
Center within five working days will be forwarded to the Manager of
Document Control for resolution within ten calendar days".
As noted
above, the approved project procedure for document control allowed a
total of 15 " wor.kdays" for document changes to be processed by the
recipients. At the end of this 15 " workday" allowance, the Document
Control Manager was responsible for resolution within ten calendar days.
The inspector interviewed the acting BA Document Control Manager in
order to ascertain the status of outstanding document transmittals.
The site Document Control Center (DCC) maintained a suspense file of
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document transmittals which the inspector reviewed with the Document
Control Manager.
The inspector concluded that the site DCC was
complying with the requirements of BAP 2.0, Revision 14, Document
Control, Paragraphs 5.4.1.c and 5.4.3 as evidenced by review of the
suspense file for outstanding document transmittals.
In November 1985, a Clinton SAFETEAM investigator identified a concern
(12416-B) that addressed a backlog of change document transmittals at
FDC3.
One of the root causes for this backlog, as stated in the
SAFETEAM report, was that " drawings are not always returned after the
three day check out to allow updating".
Corrective action was taken
in response to this SAFETEAM concern and the backlog of document
change transmittals was reduced to an acceptable level by increased
man hours devoted to FDC3.
The inspector reviewed the backlog of document transmittals at FDC3
on two occasions during this report period.
The inspector noted a
reasonable backlog of 10 to 15 transmittals, none of which was past
the initial 10 workday process time allowed by BAP 2.0,
Paragraph 5.4.1.c.
Results
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The allegation that " Approved for Construction" stick drawings were
being checked out of FDC3 for longer than the accepted three days was
substantiated.
However, as delineated in BAP 2.0, recipients of
change documents had 15 workdays before the Manager of Document
Control was required to resolve (within 10 calendar days) failures
to process applicable documents.
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It was noted that Clinton SAFETEAM Concern #12416-B stated that
failure to return drawings after the three day checkout was a
contributing factor to a large number of document transmittals being
backlogged in November 1985. That backlog has since been corrected.
Limiting the checkout time to " Approved for Construction" stick
drawings to three days was-not a procedural requirement. The
procedurally imposed requirement for a recipient of change documents
to incorporate changes with 15 workdays was being accoaplished.
The
inspector verified by review of the site.DCC suspense file that-
document change transmittals were being' handled in accordance with
site approved procedures.
The problem had been identified to the licensee and corrected.
The
inspector's review indicated that the corrective action was acceptable.
This matter is closed.
No violations or deviations were identified.
Concern #3
Electricians don't realize that drawings reproduced on green paper
are for reference only; they use them in the field for construction
purposes.
NRC Review
The inspector reviewed BAP 2.0 Paragraph 5.2.g, Exception 2, which
stated that " Drawings reproduced on green paper shall not be used for
construction / inspection purposes."
i
The inspector interviewed six S&W electricians, four BA electricians,
and four electrical crew foremen to ascertain their level of under-
standing on the use of " green drawings". -These interviews were
conducted at the worksite in order for the inspector to witness actual
.
use of construction drawings.
All the personnel interviewed had an
accurate understanding of the procedural requirements.
In each case,
the interviewee stated that only drawings stamped " Approved for
Construction"-were to be used in the actual construction of electrical
items.
The interviewees acknowledged, and the inspector confirmed through
direct observation, that " green drawings" were used by electricians
when performing nonsafety related construction activities and there
was no evidence to suggest that they were being issued and u.ed for
safety-related construction activities.
The inspector observed
electricians using " green drawings" to install nonsafety-related
lighting circuits.
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Results
This allegation was partially substantiated.
Electricians were using
" green drawings" in the field; however, the usage was limited _to
nonsafety-related activities.
The inspector concluded through
interviews with electricians and observation of actual work practices
that electricians working at the CPS were aware that " green drawings"
were to be used for reference only.
See Concerns #6 and #7
for further discussion on " green drawings." This item is closed.
No violations or deviations were identified.
Concern #4
BA DCC was not maintaining Field Document Control Center.FDC3. This
would be evident if an audit of FDC3 were performed.
NRC Review
The inspector conducted an unannounced inspection at FDC3 during this
report period.
The purpose of the inspection was to ascertain if the
~
BA site DCC was maintaining F3C3.at an acceptable level.
The inspector randomly selected a representative sample of 26 drawings
being maintained at FDC3.
The drawings selected were stamped
" Approved for Construction".
The drawings selected were representa-
tive of detailed design drawings used in construction of structures,
systems, and components in the Containment Building, Fuel Building,
Auxiliary Building, Diesel Building, and Control Building.
For the
drawings selected, the inspector noted the actual revision at FDC3 and
current design change postings annotated on the FDC3 drawing.
The inspector requested site DCC to identify the current revision and
required design change postings for each of the drawings selected.
With the inspector present, site DCC identified, through their
computer terminal, the current revision and dasign change postings for
each'of the drawings selected by the inspector. No discrepancies were
identified.
The inspector noted that an extensive review of work done by Field
Document Control technicians had been performed by IPQA in response
to document control problems identified in Inspection Report
No. 50-461/85063.
That review was documented by IPQA in Surveillance
.
Report #CQ-01701 dated December 12, 1985.
That surveillance report
provided additional information relevant to the quality of work
performed by BA Field Document Ccntrol stations in that only a small
number of posting discrepancies were identified based on a very large
~
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sample population.
This inspection confirmed the results of the IPQA
surveillance.
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Results
The allegation was not substantiated.
This item is closed.
No violations or deviations were identified.
Concern #5
An activity which was believed to be a SAFETEAM audit of FDC3,
undertaken in response to a concern, was inadequate as the
investigator only selected one drawing at the FDC3 reproduction
satellite sta' ion to review.
NRC Review
The inspector contacted the SAFETEAM director and requested an
interview with the SAFETEAM investigator (s) that had performed any
activities at the FDC3 reproduction satellite station.
The FDC3
reproduction satellite station was located in the Diesel Generator
Building, one elevation below the FDC3 station.
The purpose of the
FDC3 satellite station was to provide "information only" copies of
design change documents (ECNs, FCRs, NCRs, etc.) and "information
only" copies of drawings from aperture card files.
'One SAFETEAM. investigator was interviewed by the inspector to
determine if a SAFETEAM audit of FDC3 reproduction satellite station
had taken place.
The SAFETEAM investigator stated that during the
investigation of concern #12416, a brief review of activities
conducted at the FDC3 reproduction satellite station was performed.
The SAFETEAM investigator stated that an " Audit" was never planned or
-performed by SAFETEAM at the FDC3 reproduction satellite station.
The
SAFETEAM investigation was focused on a concern regarding the
capabilities of a Field Document Control supervisor.
The inspector reviewed the SAFETEAM investigation file on concerns
- 12416-A and #12416-B and concluded that an " Audit" of FDC3
reproduction satellite station was not planned or performed.
The
SAFETEAM investigator did identify a backlog at the reproduction
office in the filing of aperture cards transmitted to that satellite
station.
The backlog was corrected by assigning two people to the
reproduction office.
The inspector conducted three unannounced inspections of the FDC3
reproduction satellite station during this report period.
For each
inspection, the' inspector observed the activities of the Field
Document Control technician on duty and conducted interviews to
determine the purpose of that satellite station.
The inspector noted
during each inspection that the Field Document Control technician was
aware of the "information only" (not to be used for inspection /
construction) status of documents distributed from the FDC3
reproduction satellite station and that procedures were being
adequately followed.
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Results
This allegation was not substantiated.
The SAFETEAM did not conduct
an audit of the FDC3 reproduction satellite station nor was there any
apparent reason to do.so.
The FDC3 reproduction satellite station
distributes "information only" documents.
This item is closed.
No violations or deviations were identified.
Concer'n #6
Aperture cards being used at the Field Document Control station FDC3
were not stamped correctly (that is safety-related, for construction
only, or for reference only).
NRC Review
The inspector reviewed BA procedure BAP 2.0, Revision 14, " Document
Control," and conducted an unannounced inspection of Field Document
Control station FDC3.
The inspector reviewed the existing files at the FDC3 reproduction
satellite station and noted that some aperture cards were stamped
" safety-related" and some did not have any stampings.
The inspector's
review of BAP 2.0, did not identify any procedural requirement for
stamping aperture cards under the control of BA Document Control.
The
inspector noted that the. aperture cards at the FDC3 reproduction
satellite station were being used to produce "information only" prints
for site personnel.
The status of the print was defined by either
stamping "For Reference Only" on the copy or by use of " green paper"
as previously discussed above in Concern #3.
If a drawing was safety-
related, this annotation appeared in the title block in the printed
copy of the aperture card.
BAP 2.0, Paragraph 5.2.g.3 stated that " Aperture cards shall be
issued "For Reference Only"."
The inspector noted that aperture
cards under the control of PA Document Control, if issued in
accordance with site procedures, should be identified "For Reference
Only".
Based on conversations with cognizant personnel the inspector
determined that no requests had ever been made for issuance of
aperture cards.
The inspector noted that FDC3 reproduction satellite station did not
issue aperture cards.
The aperture cards on file at this station
,
were used to reproduce "Information Only" drawings.
Results
This allegation was substantiated; however, the fact that the aperture
cards themselves were not stamped was of no significance.
It was the
responsibility of the Field Document Control technicians to identify,
in accordance with approved procedures, the status of-drawings
reproduced from aperture cards when issued at the Field Document
Control station.
This item is closed.
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No violations or deviations were identified.
Concern #7
Craft were using from drawings reproduced from the above (Concern #6)
3per.ture cards to perform work in the field.
NRC Review
The inspector determined that the drawings produced from aperture
cards were the same " green paper" drawings discussed above in
Concern #3.
Results
As identified in Concern #3 above, this allegation was partially
substantiated that is, reference only " green drawings" were being
used to perform work in the field; however, it was determined that
the use of " Reference Only" drawings during installation of
nonsafety-related hardware, such as lighting, does not have any
safety significance.
This item is closed.
No violations or deviations were identified.
^
b.
(Closed) Allegation (RIII-85-A-0184, #172):
Intimidation of QC
inspectors at Clinton by use of Daily Inspection Report Log.
Concern
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Afraid that the Daily Inspection Report Log could be used
against inspectors when compiling a lay-off list;
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Production placed ahead of quality;
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Misuse of Daily Inspection Report Log,-for example, in legal
matters such as Department of Labor hearings.
NRC Review
It has been previously established and verified in Inspection Report
No. 50-461/85046 that the primary purpose of the Daily Inspection
Report Log (Log) is to track daily QC inspection activities and
provide management with trends of individual and group performance to
determine overall department capabilities.
Note:
In inspection
Report No. 50-461/85046 the Daily Inspection Report Log is referred to
as the Quality Control Daily Report.
The Log is described in BA memorandum JRM-85-144, dated October 26,
1985. Management of personnel is usually based on results of
performance.
If any person, including a QC inspector, chronically or
habitually performs below the established norm then management must
take corrective action, including termination or layoff if necessary.
The Log can also be used as a reference if an inspector's work is
suspect of an impropriety.
.
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There were no specific references made by the allegers about how
quality was sacrificed in favor of production.
As.previously stated,
similar allegations were reviewed in Inspection Report 50-461/85046;
the allegations pertaining to the Daily Inspection Report. Log were not
substantiated. The allegations do not state there was any evidence
that the individuals were unwilling to raise safety issues or identify
-nonconforming conditions, or that the individuals were discharged or
otherwise discriminated against with respect to compensation, terms,
conditions, or privileges of emp1cyraent as stated in Section 210 of
the Energy Reorganization Act.
It appeared from the review that the
primary concern was certain individuals were afraid the Daily
inspection P.; port Log could be used to establish layoff lists.
There
was no evidence to suggest that the Log was used to place production.
ahead of quality.
It should be noted that all documents used in the construction of the
Clinton Power Station have the potential of being used in a judicial
~
hearing; therefore, the use of the Log in a Department of Labor
proceeding does not appear to be inappropriate.
Resul ts
It is concluded that the primary concern with the Daily Inspection
Report Log information is that it could be used by their management
for the stated purposes as well as establishing layoff lists; however,
no regulatory requirements prohibit such management actions unless it
~
would intimidate an individual to not raise safety issues or identify
nonconforming conditions.
Discrimination, ac defined by the Energy
Reorganization Act, did not occur and there was no evidence that
production was being substituted for quality.
No further NRC action
will be taken.
This matter is closed.
No violations or deviations were identified.
c.
(Closed) Allegation (RIII-85-A-0183, #168):
Improper certification
of BA QC Electrical Inspectors.
Concern #1
The person making the allegations named three BA QC electrical
Level II inspectors who were certified without having prior inspection
experience. The person stated that tnere were five to six other
inspectors who did not have prior inspection experience; however, the
person would not name them.
,
NRC Review
Requirements for QC inspectors are delineated in Section 5 of the BA
QC Training and Qualifications Manual.
The manual includes the same
inspector qualifications, that is, minimum personnel capabilities,
education, and experience levels, as ANSI N45.2.6-1978, " Qualifications
of Inspection Examination and Testing Personnel for Nuclear Power
Plants".
Capabilities for QC inspectors are verified by written
examination and satisfactory completion of specified practical factors.
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Education and previous work experience are verified by BA by
telephone contact with previous employers and schools. As stated
in the manual, education and experience requirements can be met in one
of four ways.
Three of the sour ways include the phrase "related
experience in equivalent inspection, examination, or testing
activities".
The selection of this wording allows the user of
ANSI N45.2.6 to identify and assess the relevance and equivalence of
previous experience compared to the user's needs.. This is necessary
since no two persons have identical backgrounds or directly related
experience.
One of the identified QC inspectors' qualifications were previously
reviewed as documented in Inspection Report 50-461/84032.
The
individual was listed as Inspector "E" in Paragraph 4. of that
report.
The NRC inspection resulted in Open Item No. 461/84032-028.
That open item was satisfactorily closed in Inspection Report
No. 50-461/85041 where it was documented that the individual was
qualified as a Level II QC electrical inspector.
The inspector reviewed the certification records for the other two
identified QC inspectors. The records showed that both of the QC
inspectors had extensive backgrounds in electrical construction,
including electrical QC inspection experience. Although one of the
QC inspectors appeared "more qualified" than the other, both of them
met the requirements as previously stated.
The inspector randomly selected six other QC inspector certification
records for review.
The records showed a wide range of "related
experience".
As a result, some of the QC inspectors had " limited
certification", and others were only certified in one or two of the
six possible classifications.
In all cases, the QC inspectors
appeared to be properly certified for the type of inspections
indicated in the record.
Results
The allegation could not be substantiated.
In all cases reviewed by
the inspector, the QC inspectors were properly certified based on the
level of education and prior r~ elated experience.
No violations or deviations were identified.
Concern #2
The person making the allegations stated he had heard that one of the
identified BA QC inspectors was given a copy of the written test with
answers prior to taking the written portion of the QC electrical
Level II examination.
The person said that this was common knowledge
among the QC inspection staff.
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NRC Review
The inspector interviewed IP and BA supervisory personnel and
electrical QC inspectors, including the individual identified as
being given the written test with answers, and reviewed the
available documentation of the incident.
The inspector interviewed individuals A and B on January 21,.1986.
Individual A stated that he did not have any knowledge of the
incident described in the above allegation.
The inspector was told by
individual B that sometime during mid-1984, on the night shift, while
looking for a pencil in individual C's desk, an unidentified person
found what appeared to be handwritten questions and answers to the
Level II QC electrical examination.
Individual B believed this
matter was made known to someone in BA management.
The inspector interviewed individual C on January 22, 1986.
The
inspector was told by individual C that when first reporting to the
CPS, one of his assignments was preparing questions for QC inspector
examinations.
After preparing 17 questions for an upcoming Level II
QC Electrical Equipment Inspector examination, individual C stated
that he felt uneasy about the assignment because he was not certified
as a Level II inspector and there was potential for him to be so
certified.
Individual C stated that during the middle of May 1984,
he notified his supervisor who agreed with individual C about his
concern.
The inspector determined that the task of preparing QC
electrical inspector test questions was assigned to individual D who
was a qualified Level II QC electrical inspector in all six possible
classifications including electrical equipment.
Individual C stated
that he gave the 17 questions to individual D to use as individual D
saw fit.
Individual C stated that he was transferred to a new work
location during this same time frame.
Individual C stated that his
personal effects were removed from his desk by laborers and relocated
to the new work location.
On June 22, 1984, individual C stated that
he and others were administered the examination for Level II QC
Electrical Equipment Inspector; individual C received a passing grade.
On or about June 24, 1984, an unknown individual found the 17
questions in individual C's desk drawer.
Individual C stated that
this matter was looked into by his supervisor, and to remove any doubt
about the examination results, all persons who were tested on
June 22, 1984, were retested; again, individual C received a passing
grade.
According to a memorandum which was attached to BA Interoffice
Memorandum BAQC-CV-25, hand written by individual D, on or about
May 18, 1984, individual D prepared questions for an upcoming Level II
QC Electrical Equipment Inspector examination while working in an area
where he was not rcrmally assigned.
After proof reading the questions
he placed them into a drawer of the desk he was temporarily using,
which coincideatly belonged to individual C.
According to individual
D's memoreadum, the contents of the desk were subsequently removed and
transferird to a different field office.
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The inspector also discussed this matter with the BA Supervisor of
Training for Quality and Technical Services.
The BA supervisor told
the inspector that this matter was reviewed by BA management as
described in BA Interoffice Memorandum BAQC-CV-25, dated June 25,
1984.
A review of the memorandum by the inspector confirmed that
individual C's desk drawer did contain 17 questions, 12 of which
were included in the examination administered on June 22, 1984;
however, the memorandum also confirmed that BA management was
convinced cheating did not occur and individual C did not know the
questions were in his desk drawer.
BA management's conclusions were
based on verbal information provided by individual C and substantiated
by individual D in his hand written memorandum.
The memorandum also
showed that BA recognized a weakness in control of examinations.
According to memorandum BAQC-CV-25, all personnel who were tested on
June 22, 1984, would be retested to a completely revised examination.
Personnel records reviewed by the inspector indicated that individual
C successfully passed the new examination in July 1984.
The inspector discussed this matter with the IP Director of Quality
Systems and Audits who stated to the inspector that IP did not perform
a formal investigation into this matter; however, they did monitor
BA's actions end reviewed BA's conclusions.
The inspector reviewed a
Memorandum to File, dated January 23, 1986, wherein IP documented its
conclusion that "there was no impact on the quality program at CPS as
a result of the test questions being found in the desk at the field QC
office".
Based on numerous NRC inspection in the area of BA QC inspector
certifications the above incident appears to be isolated.
Past NRC
inspections have shown that BA's methods and procedures meet pertinent
requirements.
Results
Based on the above review of documents and interviews, the allegation
was not substantiated.
However, a QC inspector identified as the
individual given a copy of the written test prior to taking the
written portion of the QC electrical Level II examination, had
prepared 17 questions for future Level II QC Electrical Equipment
examination and 12 of those questions subsequently appeared on the
test.
The identified individual and all other persons who were
tested on June 22, 1984, were retested.
This matter is closed.
Note:
BA recognized a weakness in control of QC test preparation
and corrective actions were taken to improve test security.
No violations or deviations weta identified.
Concern #3
The person making the allegation stated he had heard that a copy of
the written test for QC electrical Level II inspector was removed from
a QC inspector's desk 11/2 years ago and given to an unidentified NRC
inspector who apparently did nothing about it.-
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NRC Review
This concern appears to be based on hearsay information in that the
person making the allegation did not have any first hand knowledge of
-the incident.
There is no record of this incident in the Region III
file, and discussion in Region III did not disclose any information
about this matter.
Results
This matter will be referred to the appropriate NRC Office for review.
~
No violations or deviations were identified.
d.
(Closed) Allegation (RIII-85-A-0190, #175):
Illinois Power
supervisors within the Nuclear Station Engineering Department (NSED)
Control and Instrumentation (C&I) data sheet review group emphasized
quantity over quality; they deviated from and diluted the established
guidelines; and reviewers were denied access to computers.
NRC Review
As stated by the individual when originally reporting this
allegation to the NRC, examples of diluting and deviating from
established " guidelines" included not typing-notes from telephone
calls to vendors, and not including library documents w'
i data
sheet packages.
The inspector determined that ther
no
regulatory or IP procedural requirement to perfor
.er task.
The individual had contacted the SAFETEAM and prr.
- ed the NRC with
the SAFETEAM report number.
The inspector reviet
the SAFETEAM
report and determined that it correctly stated 1
-urpose of the
IP NSED C&I data sheet review group; that is, to
'acifically add more
detailed information to instrument data sheets for calibration of
nonsafety-related, non-augmented D; and non-fire protection
instruments. As such, NRC does not have jurisdiction over these
matters.
However, interviews were conducted with five members of the
IP NSED C&I' data sheet review group including the supervising engineer,
the lead reviewer, and three reviewers.
Based on those interviews the
following information was obtained:
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The purpose of the IP NSED C&I data sheet review group was to
provide complete calibration information to the field in order to
support startup.
Information such as device manufacturer, model
number, range, set point, and accuracy was obtained in several
different ways including field inspection of the device, review
of catalogues and instruction books, and telephone contact with
the manufacturer. The IP NSED C&I data sheet review group was
exclusively responsible for nonsafety related devices.
General
Electric Company and S&L were responsible for providing
calibration data for safety-related devices.
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The review started September 4, 1985, and was completed
December 31, 1985. The task included the review of about 10,000
devices and was accomplished by nine contract employees.
Three
of the contract employees were still under contract to IP.
From
the onset, reviewers understood that overtime would be required
to complete the task on time.
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The lead reviewer was characterized by the three reviewers
and the supervising engineer as technically competent with
more than 15 years experience as an engineer.
The lead reviewer
was characterized by two reviewers as not having very good
interpersonal relationships although the pressure of.the task
at hand could have been a contributing factor.
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Even though the IP NSED C&I data sheet review group task was of
relatively short duration, there were personnel actions including
the termination of two reviewers.
According to two reviewers,
the lead reviewer, and the supervising engineer one of the
terminated reviewers had poor work habits and the other was
characterized as being less productive than the other reviewers
because of his pre-occupation with over attention to detail.
According to-two reviewers and the supervising engineer the
latter individual's personality was in conflict with the lead
reviewer.
None of the persons interviewed felt that either of
the terminated individuals was unfairly terminated.
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Reviewers were allowed access to computers, for example, mistakes
or changes were documented on Field Engineering Change Notices
(FECN) which were cross checked with other FECNs by use of a
-computer.
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Every. person interviewed expressed the basic principle that
production of an inaccurate data sheet strictly for production
sake would have been counter productive and that a complete and
accurate instrument data sheet was key to completing startup
activities.
Results
'
The allegation could not be substantiated in that there was no
direct evidence to suggest that supervision was emphasizing quantity
over quality or that they deviated or diluted the established
guidelines.
Interviews with reviewers and other reviews indicated
that the review task had a known time limit and it's associateo'
pressure; that the group was small and everyone had to carry their
load; that certain extras such as typing notes and copying reference
material was not justified; and that since the information assembled
was being directly applied to field startup activities, it would be
counter productive not to provide accurate information.
This matter
is closed.
No violations or deviations were identified.
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8.
Functional or Program Areas Inspected
a.
Site Surveillance Tours (71302)
At periodic intervals during the report period, surveillance tours of
selected areas of the site were performed. Those surveillances were
intended to assess:. cleanliness of the site; storage and maintenance
conditions of equipment and material being used in site construction;
i
potential for fire or other hazards which might have a deleterious
effect on personnel or equipment; storage conditions of new fuel; and
to witness construction, maintenance, and preoperational testing
activities.in progress.
The inspector witnessed portions of safety-related welding activities
performed by the plant staff.
Plant staff welders were working to an
approved Maintenance Work Request (MWR) to perform Plant Modification
- LP-3.
The inspector noted that the work being performed was in
accordance with the Weld History Report (WHR) available at the
workplace; weld rod used was per the WHR requirements; unused weld rod
was properly stored in an energized rod caddy; and QC holdpoints were
properly annotated.
The inspector witnessed initial performance of the Division-2 diesel
generator preoperacional test procedure (PTP-DG/00-02, Revision 0).
The inspector verified that the prerequisite steps identified in
Paragraphs 7.3.1, 7.3.2, and 7.3.3 of the' procedure were signed off
before commencement of the test.
The inspector toured the Division-2
diesel generator room with the applicant's Start-Up (SU) test engineer
just prior to diesel start and noted that the test engineer was aware
of the pre-test conditions and was knowledgeable of the test procedure.
The inspector witnessed plant staff electricians conducting motor
operated valve analysis and test system (M0 VATS) testing on motor
operated valve ISX074A.
The testing was conducted in accordance with
approved MWR-824271.
The current revision to the M0 VATS test
procedure (CPS No.-8451.02, Revision 1) was at the workplace and being
followed.
Wire or component removal log (CPS No. 8801.01F001) was at
the workplace and properly completed.
The-inspector identified and brought to the applicant's attention
one safety-related cable (cable IRH68K) that was cut or broken in
two.
The applicant documented the identified deficiency on NCR
- 39913 to provide for corrective action. The subject cable was one
of three cables that exited their respective conduits and was routed
three to four feet off the floor directly across a normal construction
walkway in the containment.
The inspector noted that routine
construction traffic through this walkway could easily cause the noted
damage.
.No violations or deviations were identified.
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b.
Administrative Procedures Review (42400)'(35744)
This inspection continued a review (see Inspection Reports
No. 50-461/85005, Paragraph 9, 85012,. Paragraph 5, and 85063,
Paragraph 8.b.) of procedures to be used during the plant operations
phase. The purpose of the review was to confirm that the scope of
the plant procedures system is adequate to control safety related
i
plant operations within applicable regulatory requirements, and to
verify.the adequacy of management controls in implementing and
maintaining c workable procedure system.
See paragraph 2.d. of this
report for relevant background information.
(1) Procedures Reviewed
(a) CPS No. 1003.01, " Design Control and Modification,"
Revision 4.
(b) CPS No. 1003.01, " Design Control and Modification,"
Revision 5, dated January 14, 1986.
(2) Discussion
CPS No. 1003.01, Revision 4., was selected for review because it
was subject to unresolved item (461/85012-02) and because it was
obviously deficient on its surface. The Corporate NJclear
Procedures, which were the basis for the applicant's design
control and modification program, had undergone substantive
changes in October 1985.
CPS 1003.01, revision 4, had not
been revised at that time.
Discrepancies noted in the procedure,
other than the lack of required review, included the following:
i
(a) The procedure did not incorporate all ANSI N18.7-1976
requirements.
(b) The procedure did not provide for compliance to applicable
technical specification requirements.
(c) The procedure did not reflect the current organizational
structure and responsibilities defined in the corporate
nuclear procedures and interfacing plant staff procedures.
(d) Interfaces between organizational units were not clearly
established.
(e) Requirements of the Code of Federal Regulations were either
not. reflected in the procedure or were identified as
recommendations of the procedure.
The missing information
was not identified with "LATER".
The inspector met with cognizant applicant personnel on January 8,
1986, to discuss the above review results.
The applicant's
representatives stated that revision 5 to CPS No. 1003.01 was pending
review and approval by the FRG at the time of the meeting.
A copy of
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the draft procedure. revision was presented to the' inspector who
briefly reviewed it with the applicant's representatives.
The revised
procedure was obviously a substantial improvement over the previous
revision.
As a result of this preliminary review, one question
related to compliance to 10 CFR 50.59 was left unresolved. The
applicant's representatives agreed to respond to the unresolved item
prior to January 27, 1986.
The inspector subsequently performed a detailed' review of several
sections.of revision 5 to CPS 1003.01 which had been approved for use
on January 14, 1986.
That review indicated continuing problems in
establishing compliance to ANSI N18.7-1976, Paragraph 5.2.15, CPS
Technical Specifications 6.5.1.6.d., 6.5.1.7.a. and b.,
and
Of particular concern was the use of the word "should"
where a requirement ("shall") was needed; the processing of "=:Wited"
plant and minor modification requests which bypassed several technical
specification requirements and at least one ANSI-requirement;
and the
use of a modification package classification of " safety-related" or
"nonsafety" as the sole criteria for determining if a safety
evaluation was required in accordance with 10 CFR 50.59 (the inspector
noted that a "nonsafety" modification could affect nuclear safety and
that the CPS technical specifications require that the FRG review all
proposed changes or modifications to unit systems and equipment that
affect nuclear safety).
The above review results were discussed with the applicant's
representative and cognizant management personnel on January 24, 1986.
At that meeting, the applicant's representative indicated a clear
understanding of the nature and substance of the above review results.
The inspector stated that, at the time of issuance of the operating
license (when the plant technical specifications and 10 CFR 50.59
become binding requirements), the applicant could be in violation of
the referenced requirements if the identified deficiencies have not
been corrected.
The inspector clearly identified that only a portion
of the procedure had been reviewed.
In addition, the inspector stated
that the types of discrepancies identified during this review were
similar in scope to earlier findings which were the basis for
unresolved item (461/85012-02).
Resolution of the above discrepancies
will be reviewed prior to issuance of the operating license under the-
previously identified unresolved item.
Revision 5 to CPS 1003.01 had been subject to an independent technical
review which was the applicant's committed corrective action under
unresolved item (461/85012-02).
The procedural deficiencies
identified above had not been identified and corrected by that
independent review process.
This failure indicated the need for
management attention to assure the adequacy of corrective actions
to address unresolved item 461/85012-02 (that is procedural reviews
being currently performed by plant staff).
This matter was discussed
with the Manager, CPS on January 9, 1986, and again on January 27,
1386. A written response to the unresolved item was requested.
One unresolved item was confirmed.
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c.
Operational Staffing (36301)
This inspection continued a review isee Inspect'on Report
No. 50-461/85063, Paragraph 7.c.) to verify _that the applicant's current
operational staffing plar. fas in accordance with the FSAR and proposed
Technical Specificatic.is; that staff positions were filled; and that
staff qualifications were adequate for their designated assignments.
This inspection included licensed and unlicensed plant operators,
.
technicians, electricians, and Shift Technical Advisor (STA) staff.
(1) Documentation Reviewed
(a)
IPC Nuclear Organization Staffing Plan, Revision 7, dated
August 30, 1985.
(b) CPS Organization Chart (IP Memo SBF-0366-85), dated
November 1, 1985.
(c) CPS No. 1302.04, " Shift Technical Advisor Training,"
Revision 0, dated December 27, 1985.
(d) CPS No. 1402, "Non-licensed Training," Revision 3, dated
.
November 30, 1984.
(e) CPS No. 0AP1502.03N, " Personnel Qualifications for
Maintenance Activities," Revision 2, dated July 16, 1982.
(f) FSAR, Chapter 13, " Conduct of Operations," Amendment 35,
'
dated October 1985.
(2) Discussion /Results
(a) The inspector interviewed the applicant's Control and
Instrumentation (C&I) Maintenance Supervisor and the
applicant's Electrical Maintenance Supervisor to ascertain
current C&I/ Electrical maintenance capabilities.
The
inspector noted that all positions in.the C&I and electrical
departments were filled..The qualification matrices
(Appendix A to CPS No. 0AP1502.03N) available in the C&I and
electrical offices provided documented evidence of the
training programs provided to maintenance personnel ir. both
of these groups.
Review of the matrices and discussion with
the C&I supervisor and the electrical supervisor indicated
that a continuing program of both general and specialized
training was-provided.
This information was adequate to
demonstrate that sufficient numbers of qualified C&I
-maintenance personnel and electrical maintenance personnel
were.available to support routine maintenance tasks during
operation of CPS.
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(b) The inspector interviewed the applicant's Supervisor - Plant
Operations to ascertain current licensed and non-licensed
operator staffing.
The " normal" shift crew for the CPS was
delineated in the FSAR, Paragraph 13.1.2.3.
The applicant
committed to provide a minimum of five operating shift c.ews.
1.
Review and discussion of the current qualification
status of Auxiliary Operator and 'Jnit Attendant
positions (non-licensed) with the Supervisor-Plant
Operations indicated that a sufficient number of
non-licensed personnel were available to fill the five
operating shift crew reouirements.
The inspector noted
that due to ongoing construction activities some of the
practical factors prescribed in qualification checklists
(CPS No. 1402.02C002, C003, C004) for the non-licensed
. operators had been waived.
The inspector also noted
that non-licensed training was a prerequisite to being
licensed.
The Supervisor - Plant Operations indicatd that an
on going training program (CPS No. 1402.02F005) was
in place to upgrade non-licensed training as systems
become available to plant staff.
The inspector will
verify the implementatin of required trairing prior
to fuel load.
This is an open item (50-461/85065-01).
-2.
The inspector noted that a sufficient number of
licensed personnel were currently filling all the
positions required to support five operating shifts.
i
However, at the time of thi_s inspection, the final
examination results were not available. This resulted
in some personnel, currently assigned shift duties,
being in a SRO/R0 license " candidate" status at the
conclusion of this i.nspection period.
The inspector
will verify.that each operating shift.is manned by a
sufficient number of licensed personnel prior to fuel
load.
This is an open item (50-461/85065-02).
(c) The inspector interviewed the applicant's Director - P %nt
Technical to ascertain the current status of the STf,
training and qualification program.
At the time of the
inspection, seven individuals were in the final stages of
qualifying STA in accordance with the applicant's procedure
(CPS No. 1302.04, STA Training).
The inspector noted that a sufficient number of personnel
were participating in the STA training program to support
the five " normal" operating shift crews.
However, at the
conclusion of the inspection pe'riod, verification of STA
qualification was not completed.
The inspector will verify
that operating shifts are manned by qualified STAS prior to
fuel load. This is an open item (50-461/85065-03).
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No violations or deviations were identified.
d.
Installation of Safety Related Components (MSRV) (50073C)
This is a continuation of an inspection documented in Inspection
Report No. 50-461/85063.
The inspector observed the installation of
four Main Steam Relief Valves (MSRV) and repair work on two valves.
The inspector observed installation of the following four valves:
Serial No. 160779, MPL IP21-F047A
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Serial No. 160783, MPL 1821-F051B
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Serial No. 160780, MPL~1821-F047B
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Serial No. 160536, MPL 1821-F0418
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The. inspector observed machining operations on the following two
valves:
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Serial No. 160538, MPL 1821-F041C
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Serial -No. 160535, MPL 1821-F041A
The repair method.(machining) used on these valves was different than
(
that indicated in the referenced inspection report.
'
had reevaluated the initial nonconformance report (NCR) disposition
and determined that certain flanges on ten of the affected valves
should be machined rather than stoned. ~The machining observed on the
two valves referenced above was done on the inlet flanges.
NCRs 38071
and 38446, written by IP, and NCRs 39782 and 39811, written by BA~ to
identify the adverse conditions, were reviewed by the' inspector.
The
inspector also reviewed BA travelers B21-088 and 093, which provided
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instructions for the installation work to be performed.
The observations and reviews performed showed that control of these
l
activities was maintained through QC sign-offs at required hold points.
No violations or deviations were identified.
e.
Structural Integrity Test and Drywell Leakage Test (63050B)
This inspection was performed to ascertain that the CPS containment
structural integrity test and drywell leakage test ~(PTP-SIT-01) was
'
performed consistent with regulatory rcquirements, applicable national
standards, and applicant commitments contained in the CPS FSAR.
This inspection consisted of a detailed review of the applicable test
procedure; independent verification of selected test prerequisites;
participation in a pre-test walkdow'n inspection of the CPS drywell;
verification of instrumentation installation, checkout, and
calibration; direct observation of test setup, test crew performance,
and independent verification of data acquisition; interviews of
cognizent test personnel to ascertain their level of knowledge and
familiarity with test requirements and expected test results; and
review-of preliminary test results to verify their validity.
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(1) Documentation Reviewed
(a) PTP-SIT-01, "Drywell Structural Integrity
Test," Revision 1, dated December 12, 1985.
(b) Drawing SK-ILRT, " Location of Dewcells and
RTDs," Revision A
(c) Drawing SK-FPR-6586, "As Built Locations of
LVDTs for SIT and Attachment Details,"
Revision A, sheets 1 and 2
(d) Drawing W249-77418-C-SIT-1, " Embedded Strain
Gauge Locations," Revision 3
(e) Drawing E27-1301, " Embedded Strain Gauge Instrumentation
Conduit Layout," Revision G
j
(2). Procedure Review
The inspector performed a-detailed review of PTP-SIT-01.
The
procedure was reviewed with respect to the applicable requirements
of the CPS FSAR, ANSI /ANS 56.8-1981, " Containment System Leakage
Testing Requirements," and applicable regulatory requirements.
The inspector determined that the procedure was consistent with
all applicable requirements reviewed.
(3) Test Witnessing
The inspector observed the conduct of a pre-test walkdown by
,
f
cognizant test personnel, accompanied the test director during
the walkdown, and discussed walkdown results with the test
director.
Several minor deficiencies identified during the
walkdown were corrected-prior to start of the test.
The inspector selected a sample of test prerequisites and
verified that they were met.
Prerequisites verified included
the placement of certain instrumentation; observation of
instrumentation checkout and calibration procedures; location of
selected concrete crack mapping grids, strain gauges, dewcells,
RTDs, and LVDTs; and the establishment and maintenance of access
!
control to the CPS drywell.
The inspector noted that the
j
instruments checked were located in accordance with applicable
E
drawings; that the instruments had been checked and calibrated
using appropriately qualifi.ed personnel; that concrete crack
i
mapping preparations were appropriate and in compliance with
l
. applicable drawing requirements; and that strict access controls
I
had been established and were maintained throughout the test.
Instrument locations that deviated from applicable requirements
due to physical interferences had been properly documented and
identified on "as built" instrumentation location drawings.
The
grids for concrete crack mapping were handled in the same manner.
O
.
Interviews with cognizant test personnel and observation of test
crew performance indicated that the personnel were knowledgeable
of the test procedure, test program requirements, and applicable
code requirements.
Test crew actions were timely, coordinated,
and reflected a thorough understanding of the evolutions in
progress.
Unanticipated problems that occurred during the test
performance were handled quickly and properly by the test crew.
Data was recorded accurately by cognizant personnel on the data
sheets provided.
Concrete mapping crews plotted and recorded
concrete cracks in excess of 0.04 inches in width that were greater
than 6 inches in length.
Independent data recorded by the
inspector was consistent with data recorded by the test crew.
(4) Test Results Review
Review of preliminary test results indicated that the CPS
containment had performed as expected; that the drywell leakage
rate was well within the acceptance criteria established by the
architect engineer; and that no significant concrete cracking
had occurred during performance of the test.
(5) Results
Based on these reviews and observations, no violations or
deviations were identified.
9.
Headquarters / Regional Requests (92701)
a.
Drywell Vacuum Relief Valves
The NRC Cffice of Inspection & Enforcement (IE) requested that the
inspector notify the applicant of a construction deficiency reported
by Perry Nuclear Power Plant (PNPP) under the requirements of
10 CFR 50.55(e) and determine if the deficiency was also applicable to
CPS.
The deficiency was related to the actuation logic for the
drywell vacuum relief valves (PNPP) Construction Deficiency Report
50-440 RDC 141 (85).
The inspector forwarded the request to cognizant applicant
representatives who reviewed the matter with respect to'the CPS
drywell vacuum relief valve design.
The applicant reported that the
CPS design did not use actuation logic and that the PNPP deficiency
did not apply to CPS.
The inspector reviewed S&L drawing M5-1063,
" Combustible Gas Control System," Revision G, and verified that the
drywell vacuum breakers were self-actuating; there was no actuation
logic involved in the CPS design.
This information was provided
verbally to IE.
o
.
b.
Limitorque Valve Actuators With Unqualified Wire
Region III requested that the inspector notify the applicant of a
generic deficiency reported by Commonwealth Edison Co. under the
requirements of 10 CFR 21 and determine if the deficiency was
applicable to CPS.
The deficiency related to the use of unqualified
wire in environmentally qualified limitorque valve actuators (LER 304/85018).
The inspector forwarded the request to cognizant applicant
representatives who began a review of the matter with respect to the
CPS environmental qualification program.
This matter was still
under review at the conclusion of this inspection.
The applicant
stated that their review was scheduled for completion by January 31,
1986.
This matter will be reviewed further by the inspector when
the applicant's review is completed.
This is an open item
(461/85065-04).
10.
CPS Readiness For Fuel Load Meeting (30702)
A meeting was held in the NRC Offices in Bethesda, Maryland on January 13,
1986, between NRC Region III, NRR representatives, and IP management to
discuss the readiness of CPS for fuel load.
Attendees at the meeting are
denoted by a (+) in Paragraph 1 of this' report.
The applicant provided a briefing for the attendees which addressed the
following topics:
(1) CPS " Readiness To Load Fuel" Letter
,
(2) SER And I&E Issues Status
(3) FSAR Certification
(4) Site Wide Statusing System
(5) Construction And Testing Status
(6) Specific Arras Of Regulatory Interest
(7) Power Ascension Program Acceleration (PAPA) Program
Questions and answers were discussed during the meeting.
Region III
observed that IP anticipated having a large number of deferrals which was
not consistent with Region III policy.
This matter will be discussed
further during a future meeting.
11. Open Items (92701)
Open items are matter that have discussed with the applicant, which will be
reviewed further by the inspector, and which involve some action on the
part of the NRC, applicant, or both.
Open items disclosed during this
inspection are discussed in Paragraphs 8.c. and 9.b.
-e
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T
e.
12.
Exit Meetings (30703)
'
The inspectors met with applicant representatives (denoted in Paragraph 1)
throughout the inspection and at the conclusion of-the. inspection on
January.27, 1986.
The inspectors summarized the scope and findings of
the inspection activities.
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.
The
applicant did not identify any such documents / processes as proprietary.
.The applicant acknowledged the inspection findings.
'
The resident inspectors attended exit meetings held between Region III
and/or headquarters based inspectors and the applicant as follows:
'
Inspector (s)
Date
Hare
1/9/86
Love-
1/16/86
Ulie
1/24/86
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