ML20137K447

Notice of Violation from Insp on 961213-970214.Violation Noted:Licensee Failed to Maintain Written Safety Evaluation to Document Basis for Determining That Change to Facility Described in FSAR Did Not Involve Safety Question

ML20137K447
Person / Time
Site:	Clinton
Issue date:	03/21/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20137K435	List: ML20137K431 ML20137K447 ML20137K462
References
50-461-96-15, NUDOCS 9704070032
Download: ML20137K447 (3)

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1 NOTICE OF VIOLATION ,

Illinois Power Company Docket No. 50-461 Clinton Power Station License No. NPF-62 During an NRC inspection conducted on December 13,1996, through February 14,1997,

! violations of NRC requirements were identified. In accordance with the " General '

Statement of Policy and Procedure for NRC Enforcement Actions," NUREG 1600 (60 FR 1

34381; June 301995), the violations are listed below-t

1. 10 CFR 50.59, " Changes, Tests and Experiments," requires, in part, that written j

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safety evaluations that provide a bases for the determination that changes to the facility as described in the FSAR do not involve an unreviewed safety question be maintained.

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a. TS Surveillance Requirement 3.5.1.8 stated that the ECCS response time for ench ,

ECCS injection / spray subsystem shall be verified to be within limits every 18 months.

The Updated Safety Analysis Report (FSAR), Chapter 16, Revision 6, TS Bases for surveillance requirement 3.5.1.8, Revision 1, stated that the response time testing i acceptance criteria for surveillance 3.5.1.8 were included in Table 6.3-2, -

"Significant loput Variables Used in the Loss-of-Coolant Accident Analysis (Large ]

Break)." l 8

Updated Safety Analysis Report (FSAR) Table 6.3-2 stated that one of the

acceptance criterion for the high pressure core spray (HPCS) system was that the

maximum allowed delay time from a loss of offsite power / loss of coolant accident

, initiating signal to the time that the HPCS pump reached rated speed be less than or

, equal to 27 seconds.

Contrary to the above, the inspectors identified that in May,1995, the licensee i performed a TS 3.5.1.8 required surveillance that used acceptance criteria other

than the HPCS pump at rated speed criterion described in FSAR Table 6.3-2, but failed to maintain a written safety evaluation to document the basis for determining

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3 that this change to the facility as described in the FSAR did not involve an unreviewed safety question.

b. Updated Safety Analysis Report (FSAR) Section 9.2.2.2, Revision 6, stated that the

. component cooling water system expansion tank had an automatic drain valve to i protect the tank from overfilling, and an automatic make-up system to maintain minimum tank level. .

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9704070032 970321 PDR ADOCK 05000461 0 PDR

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1 l Notice of Violation l

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. l Contrary to the above, licensee condition report 1-96-11-382 documented that the facility had been operated without an operable automatic drain valve or automatic

' make-up system in the component cooling water expansion tank, and that the licensee had failed to maintain a written safety evaluation to document the basis for determining that this change to the facility as described in the FSAR did not involve  :

' an unreviewed safety question.

This is a Severity Level IV violation (Supplement 1).

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2. 10 CFR 50 Appendix B, Criterion XVI, requires, in part, that conditions adverse to  ;

quality such, as failures, are promptly identified and corrected. j j- Clinton Updated Safety Analysis Report (FSAR), Table 3.2-1, specified that the j

quality assurance requirements of 10 CFR 50, Appendix B, were applicable to the

diesel driven fire pumps.

Contrary to the above, on July 9,1996, the "A" diesel driven fire pump experienced failure, the causes of which were not all adequately identified and corrected.

This is a Severity Level IV violation (Supplement 1). F

3. 10 CFR 20.1501 requires that each licensee make or cause to be made surveys

that may be necessary for the licensee to comply with the regulations in Part 20 L j and that are reasonable under the circumstances to evaluate the extent of radiation -

1 levels, concentrations or quantities of radioactive materials, and the potential

! radiological hazards that could be present.  ;

i Pursuant to 10 CFR 20.1003, survey means an evaluation of the radiological conditions and potential hazards incident to the production, use, transfer, release, disposal, or presence of radioactive material or other sources of radiation.

Contrary to the above, the inspectors identified that on January 9,1997, the licensee did not make surveys to assure compliance with 10 CFR 20.120(a), which ,

limits radiation exposure 5 rems total effective dose equivalent. Specifically, the licensee fai!ad to perform surveys on the piping upstream of a resin transfer line to determine the radiological hazards that could have been present prior to pressurizing ,

the line, when those hazards may have resulted in exposures greater than 5 rem TEDE.

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' This is a Severity Level IV violation (Supplement 1).

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j Notice of Violation  ;

Pursuant to the provisions of 10 CFR 2.201, Illinois Power Company is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555, with a copy to the Regional Administrator, Region lil, and a copy to the NRC resident inspector at the facility that is ,

6 the subject of this Notice, within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply should be clearly marked as a " Reply to a Notice of  !

Violation" and should include: (1) the reason for the violation, or, if contested, the basis for disputing the violation, (2) the corrective steps that have been taken and the rerults  :

achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved. Your response may reference or include ,

previous docketed correspondence, if the correspondence adequately addresses the required response if an adequate reply is not received within the time specified in this Notice, an order or a Demand for information may be issued as to why the license should  ;

not be modified, suspended, or revoked, or why such other action as may be proper should not be taken. Where good cause is shown, consideration will be give to extending the response time.

i Because the response will be placed in the NRC Public Document Room (PDR), to the ,

extent possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the FDR without redaction. However, if it is necessary to include such information, it should clearly indicate the specific information that should not be placed in the PDR, and provide the legal basis to support the request for withholding the information from the public.

Dated at Lisle, lilinois, ,

this 21st day of March 1997 1

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