ML20071B441

Final Deficiency Rept 83-03 Re Certification of Startup Test Personnel.Initially Reported on 830114.Review Determined Event Not Reportable Under 10CFR50.55e.Problems Noted Which Require Corrective Action to Prevent Reoccurence

ML20071B441
Person / Time
Site:	Clinton
Issue date:	02/18/1983
From:	Hall D ILLINOIS POWER CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
10CFR-050.55E, 10CFR-50.55E, 83-03, 83-3, U-10028, NUDOCS 8302280302
Download: ML20071B441 (6)

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iH5N018 POWER COMPANY- .U-10028I iP CUNTON POWER STATION. P.O. 80K 678. CLINTON, ILLINOIS 61727

- -February 18', 1983 m -

~ Docket.No.L50461 I

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' Mr. i James G. EKeppler-1Eegional Administrator,-Region III-U;S.. Nuclear Regulatory Commission- -

799 Roosevelt Road

[ ', Glen Ellyn, Illinois 60137 SUMECT: - Potential-Deficiency 83 03  :

. 10CFR50.55(e) 3, Certification of Startup Test Personnel y,

)  :

Dear Mr.<Keppler:

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On January 14,-1983, Illinois Power verbally notified Mr. D..

Hayes , NRC.'- (Region ~ III) of a potentiallyEreportable deficiency

, concerning-the. certification of startup test personnel. An investigation of'the matter has been performed and has determined-that'the matter is not1 reportable under the' provisions of_ '

10CFR50.55(e). This letter provides a final report of the matter in accordance Lwith:10CFR50.55(e)(3) .

i n Background

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As a result of a discussion between Illinois Power Startup and-Quality Assurance personnel, it was determined that a *

, :particular individual assign'ed to perform-an upcoming retest'of

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certain class'1E protective relays was not certified to perform the test ~in accordance'with Startup Administrative Procedure SAP-7 Qualification and Certification ~of Test Personnel". SAP-7

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[ .provides the minimum qualification / certification requirements for

, Startup personnel who direct or supervise the conduct of Startup test activitie's as.well as those who perform these activities.

Concerned that the non-certified individual may have performed l testing previously, Startup personnel conducted a review of test 4 lresults associated _with the original tests performed on'the relays. This review revealed that this individual had performed tests on both non 1E and 1E protective relays. Although this individual was qualified and experienced to perform the tests, he l

. lacked the'Startup Certification required by SAP-7. A CPS h

8302280302 830218 j ls 1 PDR ADOCK 05000461 y 8- PDR

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Mr. J. G. K ppler- Pcg2 2 February 18, 1983

' Condition Report No. 1-83-01-029 dated January 13, 1983, was initiated to, document the problem and resulted in the initiation of the investigation under 10CFR50.55(e). The basis for init-iating-the investigation was that the validity of tests performed by personnel not certified'in accordance with applicable Startup procedures was indeterminate.

Investigation Results To determine the scope of this problem and resultant effects on previously performed tests, a review of records of testing activities performed.under Startup Group cognizance, either '

complete or in process as of January 19, 1983, was performed, and included safety related, fire protection related, augmented D/radwaste, and non safety-related testing. The review evaluated the certifications of personnel performing the test and separated the results into the categories below. No further action was taken on those test records that indicated that the personnel who performed the tests and evaluated the results were properly e ccrtified in accordance with SAP-7. Those records which indicated the test activity was performed by individuals not certified per SAP-7 were separated into three (3) categories sharing common characteristics and were further evaluated to determine acceptability. Each category is defined and the results of the evaluation in each category are tabulated as j follcws:

Category I The test activity was performed by technicians or electri-cians not certified to SAP-7, but were certified in accordance with Plant Staff Procedure 0AP-1502.04S. The test results were evaluated, when required, by personnel certified to SAP-7. The breakdown in this category is as follows:

A. Non-Safety Related 5395 test records B. Safety Related 274 test records

! C. Fire Protection Related 42 test records D. Augmented D/Radwaste 73 test records The 5784 test records that fall under this category were evaluated as acceptable based on:

1. The technicians and electricians were certified at the time the test was performed in accordance with 0AP-1502.04S, which implements the requirements of

Mr. J. G. K:pplcr- Pag 3 Fcbruary 18, 1983 ANSI /ASME N45.2.6-1978 and is endorsed by Regulatory Guide 1.58 and committed to in the CPS FSAR section 1.8.

2. Startup personnel certified in accordance with SAP-7 performed an evaluation of the test results and found

-them ceceptable.

3. The. technicians and electricians were under supervision of Startup test personnel certified in accordance with SAP-7.

Category II The test activity was performed by non certified personnel.

The test results were evaluated by personnel certified to SAP-7.

The breckda.wn in tb ts category is a.s follows.

A. Non-Sa fety Related 1273 test records B. Safety Related 42 test records C. Fire Protection Related -) test records D. Augmented D/Radwaste 5 test records The test records that fall under this category were evalu-ated as acceptable based on:

1. The 1278 test records under the non-nuclear safety related subset are non-nuclear safety related by design, and review showed no significant interaccion with safety related equipment.

2. The components represented in the 42 test records under the nuclear safety related subset, and the 5 test records under the Aug D. subset were satisfactorily retested using qualified personnel, establishing that the as-tested condition of the component was acceptable.

3. Startup test personnel certified in accordance with SAP-7 perfer.'ed an evaluation of the test results and found them acceptable.

4. The technicians and electricians were under the super-vision of Startup personnel certified in accordance with SAP-7.

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Mr.-J - G. Keppler- 'Page'4i- February 18,,1983' >

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. Category III~ . l

!~ .The:testLactivity-was' performed and/or evaluatedTby non

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certified test personnel. . The breakdown:in this category is as follows: -

-A.

Non-Safety Related 44 test results 2 .

B.  : Safety.Related 0 test results l C. Fire Protection Related 0 test-results ll .D. Augmented D/Radwaste '0' test results i

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The forty four (44) test records that fall under thi;.

_ - category are considered acceptable based on

, 1. These components /systens are ncn-nuclear safety reusted l j

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by design, and review showed no significant interaction with safety related equipment.  ;

2. These tests were performed early in the test program.

The systems:have been.successfully placed in op3 ration or have undergone further testing at the system level  :

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In addition to the reviews of Startup test records, a review i of various documents, which define requirements for the certifi-i

. cation of-Startup-test! personnel, was performed to assure-that all and, documents were commitments. - Thisconsistent review included and reflect the CPS regulatory FSAR and. requirements commit--

. ments to Regulatory Guides'l.8 (ANSI /ANS-3.1-1978) and 1.58-(ANSI /ASME N45.2.6-1978), Startup Administration Procedures

SAP-7,1" Qualification'and Certification of Test Personnel", SAP-5

' " Test' Procedure Results Evaluation & Approval", SAP-ll " Conduct '

i of. Tests", 0AP-1502.04S " Qualification and Certification of Personnel for Inspection, Testing and' Examination", and other i

. associated documents. This review found~that the procedures did not clearly ~and' consistently delineate the qualifications and-

! certification requirements for-technicians and electricians who-

! perform' testing functions under'the Startup program, and is

, considered to be the root cause of this problem.

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Corrective Action i.

Although this problem was found not to be reportable under i - the provision of 10CFR50.55(e), several problems were uncovered

! with regard to the Startup program for the certification of test P personnel which require corrective action. Actions taken to j correct and prevent this problem from recurring are as follows:

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Mr.cJ. G.gKcppl~er? Page.5u February 1

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Retesting of the fortyrseven-(47) quality.related

(safety related, fire protection, augmented D) category-

' II. components;has been. performed by properly: certified. t

/i personnel.-

'2. Training was~ conducted by the Supervisor-Startup:on January =14, 1983, to discuss-Condition Report

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l-83-01-029- and to clarify thel qualification and. .

, certification requirements for individuals who perform i -

testing 1under the Startup Program. . ,

, 3. Startup Administrative Notice' SAN 3-83 was issued 1 January 26, 1983 to endorse. Plant ~ Staff Procedure .

0AP-1502.04S for qualification and certification of-  !

Maintenance Department. technicians and electricians.

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4. Startup-Administrative Procedure SAP-7 will be revised  !

to identify the qualification and certification j requirements for-technicians and electricians uho l-

!' perform startup test activities.

E 5. Startup Administrative Procedure SAP-5 will be revised 1 to clarify Startup's intent relative ~to the evaluation of test records that are prerequisites to preopera-l' tional' tests.

f-1 6. Startup Administrative Procedure SAP-ll will be revised j;

to clarify its reference.to SAP-7 relative to the certification requirements for technicians and electri-i cians.

Corrective ~ actions 4, 5,- and 6 abo're will be complete i by April 30, 1983.,

p Safety Implications / Significance I This investigation reveals a deficiency in the implementa- ,

1- tion of the requirements of 10CFR50 Appendix B, Criterion XI, Test Control, with regard to the certification of test personnel.

1 The results of this investigation, however, indicate that there

(has been no impact on testing activities or system operation.to i

date. As this condition has no adverse safety implications and

is-considered to~be non-significant, it is not considered to be reportable under the provisions of 10CFR50.55(e). However, corrective actions are being taken to resolve procedural defi-

ciencies which led to'this problem and to prevent further recur-rences of this nature.

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l Mr'..J. G. Kcppler

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-Page'6 Februnry-18,;1983.

This :letteriis hereby ;'s'ubmitted1as ta1finalL report in ' accor-

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dance.with:10CFR50.55(e), and I trust that it is sufficient for

- analysis ; and evaluation of the problem and corrective action.- -

Yours very truly,

~

Hall Vice President cc: -NRC Resident Inspector.

Manager-Quality Assurance

-Director-Office of I&E, USNRC Washington DC 20555 p Illinois _ Department of Nuclear Safety

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