U-600689, Responds to NRC Re Violations Noted in Insp Rept 50-461/86-37.Corrective Actions:Procedure CPS 9052.02, LPCS Valve Operability Checks, Revised to Incorporate Criteria for Opening Time of LPCS Injection Valve

Responds to NRC Re Violations Noted in Insp Rept 50-461/86-37.Corrective Actions:Procedure CPS 9052.02, LPCS Valve Operability Checks, Revised to Incorporate Criteria for Opening Time of LPCS Injection Valve

ML20203N595
Person / Time
Site:	Clinton
Issue date:	08/25/1986
From:	Spangenberg F ILLINOIS POWER CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
U-600689, NUDOCS 8610090289
Download: ML20203N595 (6)

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U- 600689

.k L42-86 ( 08-25)-L 1A.120 ILLINDIS POWER COMPANY CLINTON POWER STATION. P.o. BOX 678, CLINToN. ILLINOIS 61727 August 25, 1986 Mr. J. G. Keppler Regional Administrator Region III U.S. Nuclear R'egulatory' Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137

Subject:

Response to the Notice of Violation, dated July 23, 1986, in I6E Inspection Report 50-461/86037

Dear Mr. Keppler:

This letter is in response to the July 23, 1986, letter identifying certain activities which appeared to be in noncompliance with NRC requirements. Attachment A provides Illinois Power Company's response to the Notice of Violation concerning inadequacies in Procedure CPS No.

9052.02, LPCS Valve Operability Checks, Revision 20. Attachment B provides the Illinois Power Company response to the potential generic concerns.

I trust that our response is satisfactory to ensure compliance with regulatory requirements.

Sincerely yours, F. A. pang nberg h Manager - Licensinj; and Safety JAB /ckc Attachment cc: B. L. Siegel, NRC Clinton Licensing Project Manager NRC Resident Inspector Illinois Department of Nuclear Safety 8610090289 860825 7 1986 PDR ADOCK 05000461 G PDR , g L _ MO

Attachment A Illinois Power Company Clinton Power Station The Notice of Violation states:

"10CFR50, Appendix B, Criterion V, as implemented by the Illinois Power Company Operational Quality Assurance Manual (0QAM), Chapter 5, Instructions, Prccedures, and Drawings, requires ~the following:

1. Instructions, procedures, or drawings shall include appropriate qualitative and/or quantitative acceptance criteria for determining that important activities have been satisfactorily accomplished.

2. Instructions, procedures, or drawings for fabrication, installation, testing, and operation shall contain step-by-step instructions in the degree of detail necessary for performing a required function or task.

Contrary to the above:

1. Procedure CPS No. 9052.02, LPCS Valve Operability Checks, Revision 20, did not contain sufficient acceptance criteria to assure that the Low Pressure Core Spray (LPCS) injection shutoff valve (1E21-F005) would open in the time required to support the Clinton Power Station (CPS) Final Safety Analysis Report (FSAR); did not provide acceptanca critaria for inservice inspection (ISI) stroke time testing of-two containment isolation valves (1E21-F001 and 1E21-F005) in the close direction; and did not provide acceptance criteria for ISI of at least two additional LPCS valves (1E21-F003 and 1E21-F006) identified in the CPS ISI program.

2. Procedure CPS No. 9052.02, Revision 20, did not contain sufficient detailed. instructions to assure that the following required tasks were accomplished:

a. Timely notification of the shift supervisor of failure to meet CPS FSAR requirements for LPCS system operability.

b. ISI of two LPCS valves (1E21-F003 and 1E21-F006) identified in the CPS ISI program.

c. CPS Technical Specifications 4.6.4.1 and 4.8.4.2.2. for the

- LPCS system.

This violation had potential generic applicability to other CPS surveillance procedures."

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F Attachment A Illinois Power Company Clinton Power Station I. Corrective Action taken and Results Achieved Procedure CPS No. 9052.02, LPCS Valve Operability Checks, was revised to:

1. Contain the acceptance criteria for the opening time of the LPCS injection valve (1E21-F005). The CPS FSAR requirement is for the valve to open in 40 seconds. The ISI acceptance criteria in 9052.02 Section B is 25 seconds which is within the FSAR commitment.

2. Provide acceptance criteria for ISI stroke time testing in the closed direction for the containment isolation valves 1E21-F001 and 1E21-F005.

3. Notify the Shift Supervisor of the failure to successfully meet any acceptance criteria.

4. Indicate the use of the procedure when returning specific valves to service after maintenance repair or replacement work on valves, actuator or control / power circuits as required by Technical Specifications 4.6.4.1.

5. Verify Technical Specifications 4.8.4.2.2 for thermal overload protection.

IP evaluated the need to revise procedure 9052.02 to exercise valve 1E21-F003. This valve is exercised quarterly in procedure No. CPS 9052.01, Low Pressure Core Spray Operability Checks, as required by the ISI program. Based on this, IP determined that it would not be necessary to revise 9052.02 to perform this exercise.

Procedure 9052.02 Section 8.2, Testable Check Valve 1E21F006 Operability Checks, provides instructions for exercising valve 1E21F006 during refueling outages. This exercise along with the testing frequency meet the requirements of the ISI program.

II. Corrective Actions Taken to Prevent Recurrence CPS Procedure 1011.05, CPS Surveillance Guidelines, and CPS No.

1011.05C001, Surveillance Review Checklist, were revised to require all proposed revisions to Surveillance Testing Procedures be reviewed for FSAR, Tech. Spec. and ISI program requirements. This review is formally documented and approved by appropriate levels of management.

III. Date by When Full Compliance will be Achieved Illinois Power will be in full compliance by August 31, 1986.

Attachment B Illinois Power Company Clinton Power Station Pump operability procedures are currently being revised to remove "laters" and incorporate pump baseline data. A review of pre-operational test procedures was performed to obtain initial baseline data for the pump operability procedures. This data was used to establish the initial reference values, acceptable and required action ranges for inservice test quantities for all ECCS pumps. Several Inservice tests will be performed using the initial reference values.

If necessary, these reference values will be adjusted to account for differences in test conditions as compared to the preoperational tests.

In regard to the valve operability procedures, recent changes were made to the Technical Specifications, FSAR, and the ISI program to delineate new valve stroke times. Due to the extent of these changes, CPS Valve Operability procedures require revisions. The following is a summary of the changes to these documents and the scope of the procedure revisions:

1) FSAR Table 6.2-47 (Amendment 38)

The Maximum Allowable Stroke Times for containment isolation valves were determined based upon the type of line, to ensure that the dose at the site boundary is within the guidelines of 10CFR100.

The individual valve stroke times are established by pre-service testing or by specific system design requirements.

2) Tech Spec Section 3/4.6.4 (Final Draft)

The Maximum Isolation Times (MIT) for primary containment automatic isolation valves are either the analytical times used in the accident analysis; described in the FSAR; or times derived by applying margins to the test data obtained by performing testing in accordance with the ISI program outlined in Section XI of the ASME Code. For non-analytical automatic primary containment isolation valves, the MIT is derived as follows:

a) Valves with full stroke times less than or equal to 10 seconds, MIT = Initial Base Line Time X 2 b) Valves with full stroke time greater than 10 seconds, MIT = Initial Base Line Time X 1.5

3) Inservice Inspection Program Maximum Allowable Stroke times were determined using the moet conservative of the following values:

a) System design stroke times b) Tech Spec stroke times c) 150% of preservice test values

Attachment B Illinois Power Company Clinton Power Station Within the ISI program, valves are identified in one of the following categories:

a) Group A Valves - those valves which are in the main flow path of an ECCS system or provide for containment isolation. Group A valves which exceed their maximum stroke time shall be declared inoperable immediately.

The effect on system operability shall be evaluated and appropriate actions taken in accordance with the Technical Specifications.

b) Group B Valves - Those valves which are not in the main flow path of an ECCS system and do not provide for containment isolation. Group B valves which exceed their maximum stroke time shall have corrective action initiated immediately and if not corrected within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> shall be declared inoperable.

The effect on system operability shall be evaluated and appropriate actions taken in accordance with the Technical Specifications.

Valve operability procedures are being revised to include the new ISI valve group designations and new stroke times.

These procedures are currently in the revision process to incorporate pump baseline data and valve stroke times, and will be completed to support fuel load and initial criticality:

CPS 9015.01, Standby Liquid Control System Operability CPS 9051.01, HPCS System Pump Operability CPS 9051.02, High Pressure Core Spray (HPCS) Valve Operability Test CPS 9052.01, Low Pressure Core Spray Operability Checks CPS 9053.04, Residual Heat Removal (RHR) A/B/C Valve Operability Checks CPS 9053.05, Residual Heat Removal (RHR) Valve Operability Checks (Shutdown)

CPS 9061.03, Containment /Drywell Isolation Valve 3 Month Operability CPS 9061.06, Containment /Drywell Isolation Valve 18 Month Operability CPS 9061.07, Reactor Water Clean-Up Operability Checks CPS 9061.08, Main Steam System Drain Valves Operability CPS 9062.03, Suppression Pool Make-Up Operability Checks CPS 9069.01, Shutdown Service Water Operability Test CPS 9069.02, Shutdown Service Water Operability Test CPS 9170.01, Main Control Room Ventilation Chilled Water Pump Test i

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CPS 9041.04, Reactor Recire Sample Line Isolation Valve Operability Check CPS 9054.01, RCIC System Operability Check CPS 9054.02, RCIC Valve Operability Checks CPS - 9061.09, Main Steam /Feedwater (MS/FW) Systems Valve Operability CPS 9061.10, Fuel Pool Cooling and Cleanup Valve Operability CPS 9061.11, Main Steam System Air Supply Check Valve Operability CPS 9063.03, MSIV Leakage Control System Functional Test CPS 9150.01, FC Pump Test CPS 9864.01, Excess Flow Check Valves

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