ML20140D792
| ML20140D792 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 06/04/1997 |
| From: | Connell W ILLINOIS POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-461-97-03, 50-461-97-3, WC-230-97, NUDOCS 9706110092 | |
| Download: ML20140D792 (8) | |
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litinois Power Company s
_I Clinton Power Station j
P.o. Box 678 Clinton. IL 61727 Tel 217 935-5623 I
Fax 217 935-4632
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Wilfred Connell i
ILLIN91S Vice President P&WER
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WC-230-97 June 4, 1997 Docket No. 50-461 Document Control Desk Nuclear Regulatory Commission
- Washington, D.C. 20555
Subject:
Reply to Notices of Violation Contained in Inspection Report 50-461/97003 (DRS)
Dear Madam or Sir:
L The attachments to this letter contain the Illinois Power (IP) responses to the two Notices of Violation of Nuclear Regulatory Commission (NRC) requirements i
documented in NRC inspection report 50-461/97003 (DRS). IP admits that the violations occurred. The first Notice of Violation addresses to the failure to report a condition outside the design basis of the plant within thirty days as required by 10 CFR 50.73, paragraph (2). The response to this Notice of Violation is contained in Attachments A to this letter. The second Notice of Violation addresses the failure to properly implement a procedure as required by Technical Specification 5.4.1.a. The response to this Notice of Violation is contained in Attachment B to this letter.
IP believes that the actions described in the attached responses address the 3
concerns identified in these Notices of Violation.
Also, Illinois Power would like to point out three minor technical maccuracies m the inspection repoit. These minor inaccuracies are included in Attachment C to this r
letter.
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S.mcerely yours, f
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ilfred Connel
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9706110092 970604 ice President gDR ADOCK 05000461 PDR h
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l U-602750 l:
Page 2 l
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Attachments cc:
NRC Clinton Project Manager NRC Resident Office, V-690 Regional Administrator, Region III, USNRC lllinois Department of Nuclear Safety i
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Attachment A i
to U-602750 l:
Page 1 of 2 Response to Notice of Violation 50-461/97003-06
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The violation states in part:
"10 CFR 50.73,' paragraph (2) requires the licensee to report any event or condition that i
was outside the design basis within 30 days after discovery of the event.
Contrary to the above, as ofJanuary 6,1997, the licensee had not reported that up to 21 penetrations were not evaluated for fluid expansion effects, a condition outside the design l
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basis of the plant that had been discovered on October 25,1996."
Backaround and Reason for Violation i
Condition report 1-96-10-360 was initiated to document the susceptibility of certain containment penetrations to rupture due to the increase in pressure of the fluid trapped
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between containment isolation valves. During initial review of the condition for j
reportability, conducted in accordance with the requirements of CPS No. 1016.01 " CPS I
' Condition Reports," the condition was not identified as reportable. This was based on the j
description in the condition report and discussions with engineering personnel that further l
evaluation was necessary to determine if the containment penetrations were acceptable. It l
had not yet been determined if the overpressure condition during a loss of coolant accident l
(LOCA) existed.
L Engineering believed that the section of the ASME Code that addresses overpressure i
protection was written to consider protection for expected system operating conditions i
and not for faulted conditions such as a LOCA. The event that causes the overpressure
' condition is a LOCA due to a line break of ASME Code designed pressure piping. The l
l ASME Code assumes that properly designed piping is not postulated to fail and therefore l
a LOCA due to a line break of ASME Code piping would not occur. Consequently the scenario was considered beyond the scope of the ASME Code. Also, ASME Code Section III interpretation 1-95-19 that states that ASME Code Section III does not i
require that isolated portions of a system be protected from overpressure when the system l
is out of service and performs no required function. This was part of the basis for the decision not to report this condition. Because it was believed that this section of the ASME Code applied to the conditior. identified in condition report 1-96-10-360 they did
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not believe that this condition was contrary to the licensing design basis of the plant and therefore was not reportable. Licensing also reviewed the information on whether or not this condition was reportable since other utilities had reported similar conditions i
discovered during their review ofNRC Generic Letter 96-06. Licensing concurred that i
the condition was not outside the design basis of the plant since the ASME code did not j
l specifically require overpressure protection during a faulted or an accident condition.
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Therefore, the condition was not reported in accordance with 10 CFR 50.73. The reason for the violation was a difference in understanding of the ASME Code Section III 1
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requirements with that of the NRC.
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I Attachment A to U-602750 Page 2 of 2 l
Corrective Steps Taken and Results Achieved-The potential overpressure condition was reported in accordance with 10 CFR 50.73, paragraph (2) on March 13,1997 Corrective Steps to Avoid Further Violations The personnel involved in the decision to not report the potential overpressure condition identified in CR l-96-10-360 are now aware of the NRC position that ASME Code Section III requires protection ofisolated piping from thermal expansion of the fluid during a LOCA.
Date When Full Comojlance Will Be Achieved Illinois Power is in full compliance with 10 CFR 50.73 concerning reporting this overpressure condition.
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Attachment B i
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Page 1 of 3 Response to Notice of Violation 50-461/97003-04 The Notice of Violation states in part:
" Technical Specification 5.4.1.a requires, in part, that procedures be implemented for activities recommended in Regulatory Guide 1.33, Revision 2, Appendix A, Febmary 1978.
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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, "OfTGas Hydrogen Analyzer Channel IN66-N012A Calibration," required, in part, that if any of the as found data for IN66-N012A or recorder IN66-R605 was not within specified limits, initiate Clinton Procedure 1401.01F006, " CAT ' A' Instrument Failure Checklist."
i Contrary to the above, on December 9,1995, the licensee failed to initiate Clinton Procedure 1401.01F006, " CAT 'A' Inst Failure Checklist," following the completion of technical specification surveillance test on the Ofr Gas Hydrogen Analyzer Channel IN66-N012A, where two as-found data points for the recorder IN66-R605 were not within the specified limits."
Background and Reason for Violation A CAT "A" instrument, also known as a Category 'A' instrument, is an installed plant instrument used in determining the acceptance criteria of a Technical Specification Surveillance Requirement. During the investigation of this condition it was identified that condition report 1-94-05-027 was initiated when the Shift Supervisor was not notified when CAT "A" instruments failed their calibration. One of the corrective actions for this condition report was to add a specific step to initiate Clinton Power Station (CPS)
Procedure 1401.01F006, which requires Shift Supervisors notification, when a CAT "A" instrument fails its calibration. CPS Procedure 9432.48 had this step added on June 5, 1995. CPS Procedure 1401.01F006 requires an evaluation of acceptability of pimiously performed surveillance tests that used the out of calibration i=t:=;rd. During the investigation of this violation performances of CPS Procedure 9432.48 conducted since June 1995, were reviewed and revealed that on two other occasions CPS Procedure 9432.48 had a failed calibration and a CPS Procedure 1401.01F006 was not initiated.
Also, a review of other surveillance procedures that require the initiation of a CPS Procedure 1401.01F006 when the calibration of the instrument fails disclosed two additional occurrences of the failure to initiate a CPS Procedure 1401.01F006 when required by the surveillance procedure.
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Attachment B to U-602750 Page 2 of 3 l
The results ofinterviews of Control and Instmmentation (C&I) technicians revealed that generally they were not aware of the need to initiate a CPS Procedure 1401.01F006 when a calibration of a CAT 'A' instmment failed during the performance of a surveillance procedure. However, they were aware that it was necessary to initiate a CPS Procedure i
1401.01F006, " CAT ' A' Instrument Failure Checklist," when a calibration performed in a preventive maintenance task failed. When the step to initiate a CPS Procedure 1401.01F006 was added to surveillance procedures that calibrate CAT 'A' instruments in 1995, it was added in a location in the procedure after the check of the calibration of the instrument was complete. At the point in the calibration process the C&I technicians had, from their point of view, completed that section of the procedure and therefore were not aware of the step that required the initiation of CPS Procedure 1401.01F006.
The reason for the failure to properly initiate a CPS Procedure 1401.01F006 was a failure by the C&I technicians to follow the procedure step that required initiation of CPS Procedure 1401 OlF006 and a lack of awareness by the C&I technicians that its initiation was required for a surveiibnce calibration failure as well as a preventive maintenance failure. Contributing to this lack of awareness was tha location of the step that required the initiation of CPS Procedure 1401.01F006. The step was near the end of the procedure in a section of the procedure after the calibration of the instrument was complete and was afler a step that directed you to proceed to another section of the procedure.
Corrective Steps Taken and Results Achieved Condition report 1-97-05-261 was initiated to identify and track the resolution of the failures to properly initiate CPS Procedure 1401.01F006 for the additional instances uncovered during the investigation of this violation. The evaluation of the failure to initiate a 1401.01F006 on December 9,1995, determined that no additional actions were necessary to determine the operability of any plant systems.
Corrective Stens to Avoid Further Violations In October 1996, a seminar was given to site personnel, including all C&I technicians, on complying with procedures. A review of CPS Procedure 1401.01F006 initiations since the completion of this training reveals an increase in the number of CPS Procedure 1401.01F006 evaluations initiated for failure of CAT ' A' instrument calibrations using surveillance procedures. This shows an increased sensitivity to this requirement. CPS Procedure 1011.02F001 " Surveillance Test Package Cover Sheet" which is placed on each completed surveillance test and summarizes the results of the procedure, will be revised to I
direct that a CPS Procedure 1401.06F006 be initiated when a calibration of a CAT ' A' I
instrument fails.. Also, during a C&l shop meeting information was presented to the C&I technicians on the requirement to initiate a CPS Procedure 1401.01F006 when a CAT 'A' instrument fails during the performance of surveillance testing.
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Attachment B to U-602750 '
Page 3 of 3 Date When Full Compliance Will Be Achieved 1
l lilinois Power is in compliance with Technical Specification 5.4.1.a in regards to initiating a CPS 1401.01F006 for failed calibrations of CAT 'A' instruments in surveillance procedures.
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Attachment C e
to U-602750 Page1of1 L
Comments On Inspection Report 50-461/97003 (DRS) 1.
Page 8, paragraph numbered "3", stated that the cause of failure was noted as setpoint drift and mechanical binding and sticking. We would like to point out that this failure was on the "C" phase overcurrent relay and that the relay is not part of the breaker internals, as it is mounted on the front of the breaker cubicle door, t-l 2.
Page 11, next to last paragraph, refers to a PM to " clean and inspect and relubricate..." This report states that the re-lubrication did not require removal of l
the old grease. We would like to point out that the PM does require that surfaces be " Wiped Clean and Reapply."
3.
Page 14, paragraph numbered "4," the last sentence refers to "two greases that had been out of stock for years," including D6A15A1. We would like to point out that D6A15Al is a new grease that is not in stock yet.
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