IR 05000461/1986078

Enforcement Conference Rept 50-461/86-78 on 861218.Major Areas Discussed:Deficiencies Identified in Maint & Mod Insps,Per Insp Rept 50-461/86-53.NRC Viewgraphs on Enforcement Issues & Util 861218 Presentation Encl

ML20212E568
Person / Time
Site:	Clinton
Issue date:	12/24/1986
From:	Hasse R, Paperiello C, Phillips M, Wohld P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20212E543	List: IR 05000461/1986078 ML20212E539
References
50-461-86-78-EC, NUDOCS 8701050358
Download: ML20212E568 (16)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No: 50-461/86078(DRS)

Docket No: 50-461 License No: CPPR-137 Licensee: Illinois Power Company 500 South 27th Street Decatur, IL 62525 Facility Name: Clinton Nuclear Power Station, Unit 1 Enforcement Conference: Clinton Site, Clinton, IL Enforcement Conference Conducted- Decemberp,1986 Conference Attendees: p 1 $ctor !k2' /6 Division f Reactor Safety Dai'e '

hkWYW M. P. Phillips, Chief /4/24[f/

Operational Programs Section Date M

P. R. Wohld, Inspector / 2 nd >

Operational Programs Section Date fk WY b,-

R. A. Hasse, Inspector /2//y/B/

Operatio 1 Programs S ction Date '

l f %W Y l% 7 / fp Approved By: aper ello, Director Div sion o Reactor Safety Date Enforcerrent Conf _erence Summar .

Enforcenent Conference on December 18,1986, (Report No. 50-461/86078]Tif)1DRSJ cation Subjec_ts Discussed: 1)TfE1Tncies identiTied Wthe maintenance and mo inspections conducted at the Clinton Nuclear Power Station, Unit 1, and documented in Inspection Report 50-461/86053(DRS).

8701050358 861224

{DR ADOCK 05000461 PDR

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DETAILS Attendees Illinois Power Company

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W. C. Gerstner, Executive Vice President D. P. Hall, Vice President, Nuclear J. W. Wilson, Manager, Clinton Nuclear Power Station J. H. Green, Manager, Nuclear Station Engineering Department R. D. Freeman, Assistant Plant Manager, Maintenance R. E. Campbell, Manager, Quality Assurance F. A. Spangenberg, III, Manager, Licensing and Safety S. A. Zabel, Attorney G. L. Edgar, Attorney

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U.S. Nuclear Regulatory _ Commission

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i C. J. Paperiello, Director, Division of Reactor Safety M. P. Phillips, Chief, Operational Programs Section P. L. Hiland, Resident Inspector, Clinton Power Station P. R. Wohld, Reactor Inspector R. A. Hasse, Reactor Inspector i Areas Discussed i Mr. Paperiello stated that the purpose of the enforcement conference was

to emphasize the seriousness of the violations, and to look to the future to ensure that the root causes of these violations were identified and that sufficient attention was placed on all quality programs as well as l correcting the maintenance and modification programs to ensure that these types of violations would not occur in the future.

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Mr. Phillips then presented a brief description of the violations that were identified by categorizing them into the four Appendix B Criteria of 10 CFR Part 50 which were not adequately implemented. Attachment 1 is a copy of the overheads which were used to make this presentation.

i The licensee presented a detailed review of the corrective actions that l

had been initiated subsequent to the inspection, as well as their assessment of root cause and corrective actions for the future. The handouts used for this presentation are included as Attachment 2 to this report. The licensee stated that the violations identified were accurate

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and were caused primarily by the change in status from being a construction

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site to an operational site; however, there was disagreement on the safety significance of the event, with the licensee representatives stating that the safety significance was minimal because hardware problems would have

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surfaced during startup or preoperational testing of the systems, rather

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than when the components were called upon to perform a safety function.

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Although not specifically addressed in the licensee's handouts, licensee

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representatives indicated that a lot of training on the conduct of 10 CFR l

50.59 reviews was being conducted to improve the level of these reviews.

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Licensee representatives stated that they felt escalated enforcement action would be unnecessary, since the NRC had already gotten the licensee's attention regarding the problems in the maintenance and modification area The enforcement conference concluded with the NRC stressing the importance of the licensee's quality assurance program to be involved in reviewing programs to find deficiencies, and the licensee representatives stating the intent to correct the problems identified and to have a top rate maintenance progra

Attachments:

NRC Presentation on Enforcement Conference Issues Illinois Power Company Presentation for December 18, 1986 Management Meeting

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Attachment 1 CLINTON REPORT No. 50-461/86053 ENFORCEMENT CONFERENCE ISSUES 1. BREAKDOWN IN QUALITY ASSURANCE PROGRAM 4 CRITERIA NOT ADEQUATELY IMPLEMENTED s~

, CRITERION III - DESIGN CONTROL CRITERION V - PROCEDURAL COMPLIAMCE CRITERION XI - TEST CONTROLS CRITERION XVI - CORRECTIVE ACTIONS 2. IDENTIFICATION OF VIOLATIONS THROUGH QUALITY ASSURANCE PROGRAM i

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FAILURE TO IMPLEMENT CRITERION III 1. UNAUTHORIZED MODIFICATION OF T0 ROUE SWITCH LIMITER PLATES 2. FAILURE TO INCORPORATE DESIGN CHANGES INTO CONTROLLED DOCUMENTS 3. FAILURE TO SPECIFY POSTMODIFICATION TEST ACCEPTANCE CRITERIA FAILURE TO IMPLEMENT CRITERION V 1. INADEQUATE INSTRUCTIONS TO ENSURE THAT MOTOR-0PERATED VALVE STEMS THREADS WERE PROPERLY LUBRICATED PER GTP-55, 2. FAILURE TO DOCUMENT THE BASIS FOR CONCLUDING THAT N0 UNREVIEWED SAFETY QUESTION EXISTED FOR MODIFICATIONS PERFORMED AS REQUIRED BY CPS 1005.06 3. FAILURE TO INCLUDE THE TEST RESULTS IN COMPLETED MODIFICATION PACKAGES AS REQUIRED BY CPS 1003.01 4. FAILURE TO IDENTIFY UNQUALIFIED WIRING DURING WALKD0VN OF ALL MOTOR-0PERATED VALVES FAILURE TO IMPLEMENT CRITERION XI INADEQUATE POSTMAINTENANCE TESTING TO DEMONSTRATE THAT 17 VALVES HAD MISWIRED TORQUE SWITCH BYPASS LIMIT SHITCHE ,

TRE TESTING CONFIGURATION DID NOT MATCH THAT USED FOR NORMAL US . TWO POSTMODIFICATION TESTS WERE PERFORMED WITHOUT A WRITTEN TEST PROCEDURE WHICH RESULTED IN FAILURE TO ASSURE THAT ALL TEST PREREQUISITES HAD BEEN MET AND ADEQUATE INSTRUMENTATION WAS USED

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FAILURE TO IMPLEMENT CRITERION XVI 1. FAILURE TO EVALUATE THE ROOT CAUSE OF SEVEN VALVE'S INABILITY TO MEET THEIR DESIGN THRUST REQUIREMENTS HITHOUT UNAUTHORIZED MODIFICATION OF TOROUE SWITCH LIMITER PLATE 2. ALTHOUGH FIELD ENGINEERING CHANGE NOTICE 12329 WAS IDENTIFIED BY THE LICENSEE AS A CONTRIBUTOR TO THREE VALVE MOTOR WIRING ERRORS DURING MAY 1986, AND HAD BEEN IDENTIFIED AS INAPPROP-RIATE IN CR 1-85-10-091 (OcT. 85), NO CORRECTIVE ACTION HAD BEEN IMPLEMENTE . CONDITION REPORT 1-86-06-001 DEALT lilTH CONTRACTORS PERFORMIMG UNAUTHORIZED MODIFICATION: HOWEVER, CORRECTIVE ACTION MAS UNRELATED TO ROOT CAUSE OF THE UNAUTHORIZED MODIFICATIO . MAINTENANCE WORK REQUEST B11375 COMTAINED NUMEROUS EXAMPLES OF FAILURE TO DOCUMENT CORRECTIVE ACTIONS OR COMDITIONS PHERE

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NONCONFORMING WORK WAS PERFORMED AND REPEATED WITHOUT CORRECTION. (FOR EXAMPLE, REPLACIMG THE PACKING DUE TO OVERTIGHTENING ON THREE OCCASSIONS).

5. FAILURE TO IMPLEMENT CORRECTIVE ACTIONS REGARDING PROCEDURAL VIOLATIONS (SEVERAL EXAMPLES) AFTER ROOT CAUSE IS DETERMINED

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FAILURE OF ILLIN0IS POWER COMPANY'S QUALITY ASSURANCE PROGRAM TO IDENTIFY AND CORRECT CONDITIONS ADVERSE TO QUALITY INVOLVING MAINTENANCE ACTIVITIES l

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Clinton s llenort No. 50-461/86053 CR055 REFERENCE: VIOLATION EXAMPLES TO REPORT DETAILS Tracking Page Appendix B Number Paragraph Criterion Violation Number 02a 4 V Failure to lubricatz valves per GTP-55, failure to correct

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procedure, and failure to provide an adequate procedur . :V Failure to identify n 02b 6 unqualified conditions during implementation of 8451.0 .a III Improper handling of a 013 modification regarding the filing down of torque switch

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limiter plate .b XVI' Failure to properly evaluate 04a the cause of equipment

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failure during torque switch

' adjustment .a.(3) XVI Failure to implement 04b 10 corrective actions regarding procedural violations of ( 8106.01.

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5.a.(3) XVI Failure to implement 04c 10 corrective actions regarding

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inadequate procedure 8227.0 Failbre to incorporate design

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Olb 13 6.a.(1) III changes into controlled design output document d 13 6.a.(1) XVI Failure to take corrective

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action regarding Condition

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Report No. 1-85-10-09 XI Failure to conduct adequate

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03a 14 '6.a.(2) testing which allowed miswiring of 17 torque switch bypass limit switche , ,

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04e 16 6.b.(1) XVI Failure to evaluate root cause and take corrective actions regarding problems identified in WR No. B3117 f 17 6.b.(2) XVI Failure to evaluate root cause and take corrective action regarding wobble of ,

valve in WR No. B2423 .b.(4) V Failure to document torque 02c values for WRS No. C22713, C05813, and C18057; and lack of material a

REGION lli MANAGEMENT MEETING DECEMBER 18,1986

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l AGENDA l

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l INTRODUCTION D.P. HALL .

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MAINTENANCE R. FREEMAN l

MODIFICATIONS J.GREENE i

SUMMARY D.P. HALL i

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STATUS OF SEPTEMBER 1986 INITIATIVES THE OBJECTIVES 0 EXPAND MANAGEMENT - DONE

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0 CONSOLIDATE MAINTENANCE PLANNING - DONE O ESTABLISH MAINTENANCE STANDARDS - DONE o EVALUATE PROGRESS - SCHEDULED JANUARY 19, 1987 0 TAKE PROMPT CORRECTIVE ACTION - ONGOING STATUS OF UPGRADING PROGRAMS O STANDARDIZED WORK IASKS - STARTS JANUARY 1987 0 MWR CLOSEOUT REVIEW - UNITIAL TRAINING COMPLETED 0 TOP DOWN REVIEW OF PROCEDURES - STARTS JANUARY 1987 0 VALVE LUBRICATION / PACKING PROGRAM - IN PROGRESS 0 MOV 40 YEAR MAINTENANCE PROGRAM - CONCEPT APPROVED 0 DOCUMENTATION OF IEST EQUIPMENT - REQUIRES FURTHER UPGRADIN STILL FINDING PROBLEMS 0 STANDARD TORQUE SPECIFICATIONS - SCHEDULED JANUARY 1 0 TOOLB0x SKILLS PROGRAM -^- 30% COMPLETE O GENERIC LISTS FOR CONSUMABLES - SCHEDULED JANUARY 19

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ACTION PLAN RESOLUTION OF NRC CONCERNS REGARDING MAINTENANCE PROGRAM PROBLEM CONCERN EXPRESSED FOR ADEQUACY OF CONDUCT OF MAINTENANCE AS INDICATED BY:

0 DOCUMENTED PROBLEMS WITH MOTOR OPERATED VALVE IESTING (MOVAT)

0 UNTIMELY CORRECTION OF IDENTIFIED PROBLEMS

- STATION BATTERY TURNOVERS

- POSTING OF CRANE HAND SIGNALS

- PROVIDING INSTRUCTIONS ON HOW TO CHANGE OIL 0 FAILURE TO FOLLOW UP ON DEFICIENCIES IDENTIFIED AS A RESULT OF OTHER MAINTENANCE

- VALVE REPACKING

- WOBBLY VALVE O LACK OF A LONG TERM VALVE OPERABILITY PROGRAM THE COMMON THEME IS INADEQUATE CORRECTIVE ACTION BY MAINTE MANAGEMEN . - - - - - .

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CORRECTIVE ACTION o EXPANDED MANAGEMENT OF MAINTENANCE DEPARTMENT

- IPC FREEMAN

- SWEC LANE O VISIT DAVIS-BESSE TO STUDY SUCCESSFUL PROGRAM o BROUGHT IN EXPERIENCED CONTRACTOR TO EVALUATE CLINTON MAINTENANCE o CONSOLIDATED ACTIVITIES UNDER ASSISTANT PLANT MANAGER - MAINTENANCE

- SWEC NOW USES IPC PROCEDURES

- ALL QUALITY CONCERNS (CONDITION REPORTS, AUDIT FINDINGS, ETC.) INVESTIGATED BY ONE GR0uP REPORTING TO ASSISTANT PLANT MANAGER - MAINTENANCE

- FREQUENT IP/SWEC MAINTENANCE MANAGEMENT MEETINGS

- ALL WORK PLANNED BY IPC 0 INCREASED WORK SUPERVISION

- SLOWED THE PACE

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- SUPERVISORS SPEND MORE IIME IN FIELD l

- MOVED WORK PLANNERS INSIDE PROTECTED AREA l

0 REDUCED TIME ALLOWED To DEVELOP PLAN FOR RESPONSE TO QUALITY CONCERNS

- QA AUDITS - 1 HOUR To DEVELOP - 1 WEEK To RESPOND

- CONDITION REPORTS - 1 HOUR

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P@ST MAINTENANCE TEST .

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PROBLEM l e MWR's VAULTED WITHOUT PMT EVALUATION ATTACHED

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CAUSE

! e INADEQUATE MWR REVIEW FOR PMT REQUIREMENTS i

CORRECTIVE ACTION e AUDITED ALL MWR's DURING PERIOD OF MAY 1985 TO JULY 1986

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APPROXIMATELY 140 PMT's REQUIRED FROM AUDIT

e ALL MWR's FROM JULY 1986 TO SEPTEMBER 1986 HAVE l

PREVIOUSLY BEEN AUDITED e ALL PMT's WILL BE PERFORMED BEFORE THElR APPLICABLE l MILESTONE e REVISED PMT VAULTING PROCESS

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e PMT EVALUATION PROCESS IMPROVED

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RESOLUTION OF NRC CONCERNS REGARDING MODIFICATION PROGRAM PROBLEM 0 DEFINITION OF TEST REQUIREMENTS AND ACCEPTANCE CRITERIA 0 TESTING TO ASSURE MODIFICATIONS WERE PROPERLY INSTALLED 0 DOCUMENTATION OF TESTING 0 MANAGEMENT ATTENTION TO THE QUALITY OF THE MODIFICATION PROGRAM CAUSE O PROCEDURE NON-COMPLIANCE CORRECTIVE ACTION OBJECTIVE o REVIEW MODIFICATIONS

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O TRAIN PERSONNEL AND MONITOR FUTURE PACKAGES i

0 REVIEW PROCEDURES STATUS 0 ALL MODIFICATIONS WERE REVIEWED BY THE JOINT TEST GROUP DURING THE INTERIM PERIOD 0 REVIEW SIMILAR To JOINT TEST GROUP NOW PERFORMED BY CONFIGURATION MANAGEMENT

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O MODIFICATIONS INCLUDED ON ORIGINAL LIST WHICH WERE f SELECTED AS POTENTIALLY HAVING PROBLEMS ARE NOW APPROVED

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AND IN THE VAULT, WITH THE EXCEPTION OF ONE MODIFICATION PACKAGE O ALL ACTION ITEMS (WITH THE EXCEPTION OF THE ONE MODIFICATION PACKAGE) ARE NOW COMPLETE SUPPLEMENTAL CORRECTIVE ACTION o STONE & WEBSTER PERFORMING A REVIEW OF THE MODIFICATION PROCESS TO MAKE RECOMMENDATIONS FOR IMPROVEMENTS o ORGANIZATIONAL CHANGES MADE TO STRENGTHEN CONFIGURATION MANAGEMENT ORGANIZATION o SPECIAL CONSULTANT UTILIZED TO MAKE RECOMMENDATIONS FOR IMPROVING THE QUALITY OF INFORMATION PROVIDED IN MODIFICATION PACKAGES FOR MAINTENANCE USE O QUALITY ASSURANCE AUDIT IN PROGRESS TO IDENTIFY ANY ADDITIONAL WEAKNESSES OR SHORTCOMINGS

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