IR 05000461/1989009

Insp Rept 50-461/89-09 on 880227-0303.No Violations Noted. Major Areas Inspected:Implementation of Inservice Testing, Including Administrative & Technical Procedures for Controlling Work,Performing Tests & Retention of Records

ML20247L256
Person / Time
Site:	Clinton
Issue date:	03/29/1989
From:	Danielson D, James Smith NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20247L244	List: IR 05000461/1989009 ML20247L238
References
50-461-89-09, NUDOCS 8904050420
Download: ML20247L256 (10)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-461/89009(DRS)

Docket No. 50-461 License No. NPF-62 Licensee: Illinois Power Company 500 South 27th Street Decatur, IL 62525 Facility Name: Clinton Power Station Inspection At: Clinton, IL 61727 Inspection Conducted: February 27 through March 3, 1989 od71 d 4 u hw Inspector SJ. F. Smith 21/87/

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Approved By: D. H. Danielson, Chief Materials and Processes Section 3 2f //

Date Inspection Summary Inspection on February 27 through March 3,1989 (Report No. 50-461/89009(DRS))

Areas Inspected: Unannounced inspection of implementation of Inservice Testing (IST) (73756) including administrative and technical procedures for controlling the work, performing the tests, retention of records, and recording of trend Results: No violations were identified. Several anomalies were identified, however, prompt corrective action by the licensee was effected. As a result of this inspection, the following conclusions were drawn:

The IST organization is fully staffed and stabl The ISI staff is knowledgeable and conscientiou The continued review and updating of the licensee's programs leads to a more complete and refined progra No weaknesses were apparent during this inspectio %k40gyk hh o

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DETAILS Persons Cc-tacted Illinois Power Company (IPC)

+ C. Gerstner, Executive Vice President

+ R.-Bell, Supervisor, Inservice Inspection

+J. A. Brownell, Project Specialist, Licensing

+J. G. Cook, Manager, Nuclear Planning and Support B. E. DeLetter,-Engineer, Inservice Testing

+ C. Edler, Director, Maintenance and Technical Training i J. M. Emmert, Supervisor, Electrical Engineering '

J. D. Funstom, Project Engineer, Mechanical Design

+K. R. Graf, Director, Operations Monitoring

+D. P. Hall, Vice President

+D. L. Holesinger, Assistant Manager, Clinton Power Station

+ C. Hollon, Acting Director, Nuclear Program Assessment Group

+ L. Holtzscher, Acting Manager, Licensing and Safety

+ T. Kerestes, Director, Nuclear SED D L. Logan, Supervising Engineer, Mechanical Design

+J. A. Miller, Manager, Scheduling and Outage Management D. A. Parchem, Project Engineer, IST

+J. S. Perry, Assistant Vice President W. N. Sanders, Assistant Supervisor, Controls and Instrumentation Soyland/WIPC0

+J. Greenwood, Manager, Power Supply U.S. NRC

+ P. Ray, Resident Inspector

+ Denotes those who attended exit meeting on March 3, 1989. Pump and Valve Inservice Testing (IST) Program Implementation (73756)

'l The licensee's program implementation was reviewed by the NRC inspector to verify compliance with their " Pump and Valve Testing Program Plan,"

Revision 5. The review covered the program implementation from development of an organization and administrative controls through performance of testing, analysis of results, and trending of data, Administrative Control of Inservice Testing l

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The NRC inspector confirmed that administrative controls were in place to satisfy the requirements of the IST Program and that specific IST duties had been assigned to personnel. Although

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i IST procedures may be originated by other technical groups,.the procedures are ' subject to review by the Inservice Inspection (ISI)

Section before implementatio All programmatic control of IST is under the control of the ISI Section Supervisor. Because of the need to coordinate performance of pump and valve tests with Operations, the personnel who normally perform the tests are Shift Technical Advisors from the Operations Group. The data generated by those tests are reviewed and approved .,

(or anomalies are resolved) by ISI personnel, who extract the i necessary information for trending. The'ISI Section analyzes data, checks for compliance with required acceptance criteria,. initiates appropriate action when equipment falls into the " alert range" or

" required action range" and maintains trending data. Containment Isolation Valves, ECCS Valves, and all Pumps which fall into.the

" required action range" are immediately declared inoperable by the i Shift Supervisor performing the test. However, other valves could l be treated differently. -Several procedures were found to include l the option to defer declaring such valves inoperable for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> if " technical justification" was available when the valves were found to fall into the " required action range".

l For some valves which might affect the operability of other systems, I the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> delay might not be acceptable from the standpoint of a Limiting Condition for Operation which might be started when-the condition was first identified. While discussing the situation, licensee management made several pertinent point First, the option to provide technical justification to defer declaring th valve inoperable had never been exercised. Second, there was no predictable scenario under which the option would be exercise Finally, after a survey of the operators, it was confirmed that they had no intention of using it. The licensee committed to I

eliminate the questionable option from each of the several procedures during a subsequent revision. The current wording has

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not actually caused a problem to date and has now been subjected to l such extensive exposure that all personnel involved in valve testing will be familiar with it. This corrective action will effectively resolve the issu The NRC inspector reviewed the licensee's " Inservice Inspection and ?

Personnel Review," Instruction EP-2, Revision 1, issued December 28,.

1988, and " Pump and Valve Test Results, Evaluation and Tracking," j Instruction EP-3, Revision 0, issued August 23, 1988. Both were found to conform to the requirements of the IST Program, b. Instrument Control and Calibration Guidance in the calibration and control of measuring and test i equipment is provided in Administrative Procedure 1012-01. The detailed procedures for achieving these objectives are included in

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Procedure 1512-01, " Calibration and Control of' Measuring and Test Equipment." The NRC Inspector reviewed Revision 10 cf this document, dated December 7, 1988, and found it to be acceptable. The procedure provides instructions on the identification of Measuring and Test Equipment (M&TE), control of calibration and calibration interval, history and trending of calibration and recording of application history. The technical aspects of calibration were not included *

in this documen Portable M&TE is stored in the C&I Laboratory in the Radwaste Building. Instruments utilized for IST include pressure gaugas, flowmeters, stopwatches, and vibration meters. All calibrations are done to standards traceable to the National Bureau of Standards (NBS). The pressure gauges are normally fixed in the system and carry individual calibration stickers showing identity and calibration dates. The gauges are usually removed from the system and calibrated y at the licensee's C&I Calibration Laboratory. In some cases, both ;

local and remote reading instruments are available to measure the '

same characteristic. For example, pressure gauges might be mounted on a pump where a pressure sensing element transmits a signal to the ,

control room. In those cases, ambiguity is avoided by specifying I the instrument number to be used in the work document and including steps in the work document requiring written confirmation of the instrument number and the validity of the calibration date Flowmeters are usually calibrated in place by comparison with a temporarily installed standard flowmeter in the same lin Stopwatches are calibrated by comparison with an NBS  ;

radio-transmitted frequency signa The " Weekly MTECAL Schedule" is a computer generated tabulation of measuring and test equipment on which calibration dates are approaching, due, or past due. It is assembled from computer input of equipment on which the calibration date should be considered and on those manually added items on which previous calibration dates have not been met. It provides the guidance necessary to plan for equipment calibration. The NRC inspector found the schedule to be clear and effectiv c. Training and Qualification of Personnel Performing IST Inservice testing of pumps and valves is ordinarily performed by the Shift Technical Advisor (STA). The STA is a part of Operations and is trained, tested, and certified to perform his IST functions as a part of his Operations qualification. The training involved in IST is not so extensive as observed in some other plants, but the reduction in emphasis is justified on the basis of the simplicity -

of the equipmen The IRD Vibration Measuring Instrument, Model 306, which is used for IST provides only one reading: mils displacemen If this equipment becomes upgraded, additional training will be mandator . .

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Training records for employees are computerized to provide.in-depth

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details of training provided for each employee. In addition, an Employees Task Check List which is manually maintained, provides i

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quick reference for checking training on a "go-no go" basis. The licensee indicated that the Maintenance Training Programs at Clinton are INPO-accredited in Electrical, Mechanical,,and Control and Instrumentation. The NRC' inspector reviewed the" training records, l tFe training facilities, and the training and qualifice, tion of l- instructors. No deficiencies were.noted in any of these' system Tne training facilities were of adequate size and contained a reasonably representative group of motor operated-valves and pumps, d. Charging Water Ball Check Valve Testing -

Twocontrolroddriveaccumulatorchargingw[terballcheckvalves at another Region III facility recently failed leak testin Upon disassembly, they were found to be missing the internal balls. In order to provide assurance that a similar problem did.not exist at Clinton, previous test records and future test procedures and schedules were examine Procedure PTP-RD-01, Revision 1, WP was reviewed by the NRC inspector and found to prescribe an effective test for these valve Long term testing of these valves is covered by procedure 9115.01,

"CRD Accumulator Check Valve Leak Test," Revision 20, dated August 10, 1988. This procedure included a ten minute minimum leak time requirement for accumulators to drop from 2750 psig to 1520 psi Unless technical justification is available, any valve which does not meet the time limit shall be declared inoperabl This test is scheduled at each refueling outag These tests will continue to demonstrate the operability of the control rod drive accumulator charging water ball check valve e. Full Stroke Testing of Testable Check Valves Experience at other power plants has shown that the valve operators provided for testing testable check valves are often not intended to full stroke test the valve. Instead, the intention is to prove that the disk will promptly lift at the force provided by the operato In some cases, the actual motion provided to the disk is estimated at about 10% of full stroke. This problem was anticipated by the Clinton staff and a potential resolution exists in Relief Request No. 2014 (Revision 1).

This Relief Request, submitted to NRR, proposes to partial stroke exercise these valves using the air operators during cold shutdown and full stroke exercise the valves during refueling outages. The full stroke exercising will be done by disconnecting the air operators and exercising the disk by use of a wrenc _ _ _ _ _ _

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f. Backseating of Valves The electrical backseating of motor operated valves can damcge the valve or operator and can cause the MOV to become inoperabl I Nuclear power plant licensees are encouraged to avoid this practic I The NRC inspector interviewed cognizant licensee ISI personnel concerning their philosophy on the backseating of valves by use of ,

their motor operators. The prevailing philosophy is that each MOV l is. manually adjusted to operate the "open limit switch at a fixed I distance off the backseat. (Some adjustment is provided for valve size). Every MOV in the plant was tested by the Motor Operated Valve Analysis and Test System (M0 VATS) to demonstrate, among other-things, that no backseating took place. Evidence of backseating was cause for readjustment of the limit switch until no backseating occurred. The licensee reports that this was done for every'MOV in the plant, whether or not it was safety-related. No further review is considered necessary. The MOVATS provides a permanent record of switch settings which will be reviewed during the next inspectio g. Effect of Limit Switch Adjustment on Stroke Timing The maximum stroke time allowed for the operation of isolation valves, based on the requirements of the system, is normally much greater than the time required by the actuator to open or close the valves. In order to provide a stroke time which is useful in the detection of degradation of the system, it is usually based on the manufacturer's stated stroke time or the observed stroke tim In practice, stroke time is normally measured by observation of position indication lights in the control room. These lights are controlled by limit switches in the motor operator which operate relative to stem position. In some cases, the switches serve multiple purposes and the position adjustment must be a compromise between the requirements of the- competing functions. _The most frequent source of conflict is in the sharing of i.he torque switch bypass function with the position indicating light function. This occurs most frequently in two rotor control systems in which alternatives are limited. In order to effectively bypass the torque switch on the opening stroke, the limit switch rotor must sometimes be set at approximately 20% of the stroke distanc If the position indication light is on the same rotor, it will indicate that the valve is closed when it is still actually 20% ope Stroke tests performed on such a valve would only measure the stroke time for 80%

of the full stroke time. As a result, stroke times up to 20% over maximum acceptable time would still provide an acceptable indicated stroke tim _ _ - _ - _ _ _ _ _ _

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In discussing this subject with t'he licensee, it was deterained that all MOVs at Clinton are of the four. rotor. design. The limit switch on which the position. indication lights are located is the "close" switch,'which is set slightly before the point at which the torque switch drops out the power when the valve is fully seated. The

"open" switch is set just before the point at which the stem can coast into the backseat. The arrangement described appears to provide the maximum efficiency possible in timing stroke time using the position lights. This does not appear to be a potential source of problems at Clinton Statio h. Inservice Testing of Check Valves Check valves are included as a part of the routine IST' Programs and are not normally-isolated for separate evaluation. However, information from several sources, including SECY-88-297, " Program for l Testing and Inspecting Check Valves" and previous inspection results indicated that additional attention would be appropriate. .In order to determine the surveillance effort assigned to check valves by the licensee, the NRC inspector reviewed the activities and program in place at Clinton Statio In addition to the testing required by the IST Program, the licensee's staff responded to the 50ER 86-03, " Check Valve Failures or Degradation" by analyzing how well each check valve is suited to-its application and identifying' valves in questionable applications

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I to allow additional surveillance. The reviews of check valves are L

based on the EPRI Report NP-5479, " Application Guidelines for Check Valves in Nuclear Power Plants." The two check valves in the applications most-likely to have caused damage were dismantled and-examined. No serious degradation was evident in either valv Additional valves in applications most likely to cause degradation will be dismantled and examined'at future refueling outages. Panding the detection of finite evidence of degradation, no corrective action is planned.

l 1. Remote Position Indication Tests Questions have arisen in the reliability of position indication lights which are not routinely checked to show conformance with the position of the valv Some licensees test the position indicating lig' hts only from the location at which the valve stroke timing is performe The licensee's procedures allow testing the position indicating lights at any location where the lights are found. The circuits of several position indicating light circuits confirmed the

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licensee's belief that all lights are joined at the Motor Control Center (MCC), rather than at the' M0V. . Wir.ing errors are less likely to occur at the MCC than at the MOV because they are more conveniently located, more accessible, and less likely to be damaged by work performed on adjacent equipment. Any work performed at the MCC would also necessitate a recheck of the wiring because it is obviously a potential' proble In addition to the position indication tests sometimes performed on the remote position indication lights, they are also periodically subjected to maintenance examinations, at which time they are also l checked for function. The combination of tests is considered adequate to ensure that the remote indication lights are not reversed with respect to the control. panel lights.

l j. Scheduling, Records Retention, and Trending The NR( inspector reviewed the licensee's system of scheduling IST wit h cognizant personnel. The permanent data involved in the schedu?ing of IST is stored in a computer data base, "PV Test 7 DBF."

The woiking document which is periodically generated from this base also in:1udes changes based on testing which was performed out of sequense. This document is simply titled " Monthly Report." It identit1es the testing which was performed during the previous month a nd the testing which is to be performed during the following month. It does not identify work in progress during the month for which it is printed. A typical example was Monthly Report 110-89(02-22)-6; Y-90759 February 22, 1989, "ISI Pump and Valve Testing - Testing Performed January 1989; IST Requirements -

March 1989." In addition to gi,ing testing done and to be done, it also identifies pumps and valves which are on increased frequency testing. This report was reviewed by the inspector and found to be effective in scheduling IS Completed records of IST surveillance are reviewed by the ISI group for analysis of results and for initiation of appropriate action if the data falls into the " alert range" or the "requbed action range."

After the review, pertinent data are retained for trending and

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the original is shipped to the licensee's Records Center for storag The NRC inspector reviewed " Performance Evaluation," NPP-REl-01, Revision 0, dated December 29, 1988, and observed the results of i its implementation in the form of recorded trend data of selected equipment. The NRC inspector found the trending data to be readily accessible, coherently assembled, and curren i k. Procedure Review The NRC inspector reviewed the following test procedures for technical content and conformance to required codes and standards:

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9115.01, CRD Accumulator Check Valve Test, Revision 20, dated August 10, 1988. (Includes 10 minute leak time for accumulator pressure to drop from 1750 psig to 1520 psig.)

9061.06, Containment Drywell Isolation Valve Cold Shutdown 18 Month Operability, Revision 28, dated February 1, 198 *

9069.01, Shutdown Service Water Operability Test, Revision 27, Dated February 1,198 .02, Shutdown Service Water Valve Operability Test, Revision 24, dated October'7, 198 The only significant observation derived from the review of these documents was that, for some valves, . if technical justification was available when they fell within the " required action range of test results, they would be declared inoperable 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after it was found that they were in the " required action range. Resolution of this item was discussed in Paragraph 3.b. abov l 1. Pump and Valve Inservice Testing Records '

Records of selected samples of completed IST work packages were requested by the NRC inspector and provided promptly by the licensee. .The NRC inspector reviewed the following packages:

9061.03, Su-veillance Procedure, " Containment /Drywell isolation Valves Three Month. Operability," Official Working Copy (0WC),

February 2, 198 .01, RCSPIV/Non-RCSPIV Leak Rate Test (0WC), January 18, 198 .02, Type "C" LLRT Data Sheet (0WC), February 12, 1989 (MC78).

9861.02, Type "C" LLRT Data Sheet (OWC), February 15, 1989 (MC64).

9861.02, Type "C" LLRT Data Sheet (OWC), February 12, 1989 (MC88).

No deficiencies were detected in the review of these document m. Witnessing of Tests Only one test could be witnessed as a result of scheduling conflicts during the inspection. That'was the vibration testing

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of SX Pump 18. The vibration test was performed as a part of Surveillance 9069.01. The vibration test was performed after the pump was warmed up for five minutes, using an IRD Model 306 vibration meter which was identified to be calibrated until October 27, 198 The vibration signature was taken at a position identified to be at 270 degrees on the pump housing. The meter was placed on the permanently identified area on the housing and the reading was taken directly from the meter. The meter reading was compared with the acceptance criteria and recorded. The reading was marginally acceptable. No irregularities were observed in the performance of the tes . Exit Interview The Region III inspector met with the licensee representatives denoted in Paragraph I at the conclusion of the inspection on March 3, 198 The inspector summarized the purpose and findings of the inspectio The licensee representatives acknowledged this information. The inspector also discussed the likely informational content of the inspection report

, with regard to documents or processes reviewed during the inspectio The licensee representatives did not identify any such documents / processes as proprietary.

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