ML20138K172
| ML20138K172 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 05/05/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20138K166 | List: |
| References | |
| 50-461-97-03, 50-461-97-3, NUDOCS 9705120217 | |
| Download: ML20138K172 (3) | |
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1 NOTICE OF VIOLATJON ll;inois Power Company Docket No. 50-463 C:ir; ton Power Station License No. NPF 62 i
During an NRC inspection conducted on January 6 through March ~7,1997, violations of NRC requirements were identified. In accordance with the " General St atement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600 {60 FR 34381, June 30, 1995), the violations are listed below:
1.
10 CFR Part 50, Appendix B, Criterion ill, states,in part, that measures shall be established to assure that the design basis is correctly translated into specifications, drawings, procedures, and instructions and that the design control measures shall provide for verifying the adequacy of the design, such as, by performing desi0n reviews by the use of alternative, simplified calculational methods.
a, Contrary to the above, measures were not established to assure that the design basis for modification LO 028, involving the leak detection system, was correctly translated into design drawings. In addition, ucpropriate measures were not taken to ensure adequacy of design prior to field installation. A design error was made on drawing LD-907 and paGes 2 and 4 of ECN 29965. The error would likely have rendered the LD-028 leak.
detection system inoperable. The design error was subsequently noted by an Illirscis Power Quality Assurance inspector on January 7,1997, after fie!d installation, b.
Contrary to the above, as of January 7,1997, the licenseo fahd to perform adequate design reviews to determino suitability of a regulating transformer installed per modification AP-028. Further, design control measures were not adequate to identify the existence of a breaker in the regulating transformer. These errors resulted in the modification not being capable of performing its intended function.
c.
Centrary to the above, on January 7,1997, the licensee identified an unauthorized modification to IE Division il bus 121, specifically, an uninterruptible power supply had been added to the bus without any design control measures being irnplemented.
This is a Severity Level IV violation (Supplement 1).
2.
10 CFR 50.59(b)(1) requires, in part, that the licensee maintain records of changes in the facility and its procedures made pursuant to 10 CFR 50.69. These records must include a written safety evaluation which provides the basis for the d9 termination that the change, test or experiment does not involve unreviewed safety question.
The Clinton USAR at Sections 7.7.1.24.5 and 5.2.5 describes the recirculation pump leak detection subsystem and the reactor coolant pressure boundary leakage detection system, respectively.
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The Clinton USATI at Section E 2.4 describes the conteinment isolation system.
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Contrary to the above.
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On October 2,1993, the 10 CFR 50.59 applicability determination for the charges to Clinton Procedure 3302.01, which changed the use of and step :
order of recirculation pump seal staging / shutoff valves 1833-F075A(B),
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which affects the recirculation pumps leak detection subsystem, did not i
adequately justify that the changes did not involve an unreviewed safety question.
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b.
On November 7,1996, the 10 CFR 50.69 applicability determination for ECN 29904, which installed insulation un containment isolation system
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piping line IRF26E 3, did not adequately justify that the change did not involve an unreviewed safety question.
}i This is a Severity Level IV violation (Supplement 1).
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3.
10 CFR 50.73, paragraph (2) requires the licensee to report any event or condition j;
that was outside the design basis within 30 days after discovery of the event.
F Contrary to the above, es of January 6,1997, the licer'ses had not reported that up
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' to 21 penetrations were not evaluated inr fluid expansion of facts,.a condition 3
outside the design basis of the plant that had been discovered on October 25, j
j 1996.
l This is a Severity Level IV violation (Supplement 11.
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4.
Technical Specification 5.4.1.a requires, in part, that procedures be implemented f
for activities recommended in Regulatory Guide 1.33, Revision 2, Appendix A, 2
February 1978.
Regulatory Guide 1.33, Revision 2, Appendix A, Paragraph 1.c and 1.f, requires that equipment control and schedule for surveillance tests and calibration be covered by procedures.
Clinton Procedure 9432.48, "Off Gas Hydrogen Analyzer Channel 1N66-N012/.
U Calibration,' required, in part, that ;f any of the es found data for 1N66-N012A cr i-recordcr IN66-R605 was not within specified limits, initiato Clinton iL Procedure 1401.01 F006, CAT 'A' Instrument Failure Checklist."
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Contrary to the above, on December 9,1995, the licensee failed to initiate Clinton j
Procedure 1401.01F006, CAT 'A' inst failure Checklist," following the completion j.
of technicci specification surveitiance test on the Off Gas Hydrogen Analyzer Channel 1N66-N012A.vhere two as-found data points fnr the recorder 1N66-R605 were not within the specified limits.
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This is a Savetity Level IV violation (Supplement 1),
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No response to vio(ations 1 and 2 noted above is required since a similar violation was.
fecently cited in inspection Reports 50 461/96011,96014 and 96015. The actions you are taking to address the violations notod.in reports 9601196014 and 96015 should also 0
- apply to violations 1 and 2 in this report. The actions should also include the steps ta' ken i
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cr pienned to prevent recurrence.
Pursuant to the provisions of 10 CFR 2.201, Illinois Power Company is hereby requireci to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, i'
ATTN: Document Control Desk, Washington, DC 20555, with a copy to the Regional Adminintmtor, Region !!!, and a copy to the NRC Resident inspector, within 30 days of the i
dats of the letter transmitting this Notice. This reply should be clearly marked as a " Reply i-t to a Notice of Vicistion" and should include' for each violation: (1) the reason for the 4
j violation, or if contested, the basis for disputing the violation; (2) corrective action taken and the results achieved; (3) corrective action to be taken to avoid further violations; and q
i (4) the date when full comp!iance will be achieved. Your response may reference or include previo' s docketed correspondence, if the correspondence adequately addresses u
i the required response. Where good cause is shown, consideration may be given to extending your response time.
Because the response will ba placed in the NRC Public Document Room (PDR), to the
- 1 extent possible, it should not include any personal privacy, proprietary, or safeguards J
information so that it can be placed in the PDR without redaction. However, if necessary I
to include such informatien, clearly indicate the specific information that should not to be
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. placed in the PDR, and provide the legal basis to support the request for withholding the
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information from the public.
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Dated at Lisle, Illinois
- this 5th day of May 1997 i
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