ML20141K474

Notice of Violation from Insp on 970215-0329.Violation Noted:On 970331 Inspectors Identified That J/S 77 Through 87 & J/S 93 of Mwr D60080 Not Been Signed for as Work Performed

ML20141K474
Person / Time
Site:	Clinton
Issue date:	05/16/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20141K472	List: ML20141K469 ML20141K474 ML20141K478
References
50-461-97-06, 50-461-97-6, NUDOCS 9705290165
Download: ML20141K474 (5)

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l NOTICE OF VIOLATION lilinois Power Company Docket No. 50-461 Clinton Power Station License No. NPF-62 During an NRC inspection conducted on February 15 through April 5,1997, violations 1 through 4, below, of NRC requirements were identified. During an NRC inspection

, conducted on September 5 through October 4,1996, violations 5 and 6, below, of NRC l requirements were identified. In accordance with the " General Statement of Policy and l

Procedure for NRC Enforcement Actions," NUREG 1600 (60 FR 34381; June 30,1995),

the violations are listed below:

1. Technical Specification (TS) 5.4.1 requires, in part, that written procedures shall be established, implemented, and maintained covering the activities recommended in i Regulatory Guide 1.33, Revision 2, Appendix A, February 1978.

l a. Regulatory Guide 1.33, Revision 2, Appendix A, Paragraph 9.e, recommends l General Procedures for the control of maintenance, repair, replacement, and l

modification work.

(1) CPS Procedure 1501.02, " Conduct of Maintenance," revision 18 (a General Procedure for the control of maintenance, repair, replacement, and modification work), Step 8.1.4.8, required that Maintenance Work Request (MWR) Job Steps (J/Ss) be signed for as work was performed.

l l (2) CPS 1501.02, revision 18, Step 2.1.3, required that late entry sign-offs in l MWRs be supported by objective evidence that an activity had been l completed.

(3) CPS 1501.02, revision 18, Step 8.1.4.8, required that J/Ss which were performed more than once be documented on a copy of CPS 1029.01 F003, l " Maintenance Work Request Continuation Sheet."

(4) CPS 1501.02, revision 18, Step 8.9.1.2, required that engineering approval

to continue with " Risk Basis" design deviations be documented on a copy of CPS 1029.01F010, "MWR Discrepancy List."

(5) CPS 1501.02, revision 18, Step 8.9.1.5, required that " Risk Basis" design deviations be resolved prior to declaring the effected equipment operable,

b. Regulatory Guide 1.33, Revision 2, Appendix A, Paragraph 9.a, recommends in i part, procedures for maintenance that can affect the performance of safety-related I equipment.

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Notice of Violation l (1) CPS Procedure 8120.04, " Maintenance of Anchor / Darling Tilting Disc Check l Valves," revision 12 (a procedure for maintenance that could affect the performance of safety-related equipment), Step 2.1.5, required that performance of work be documented on CPS 8120.04 " Maintenance of Anchor / Darling Tilting Disc Check Valves Checklist."

l (2) CPS Procedure 8120.34, " Check Valve inspection," revision 1 (a procedure for maintenance that could affect the performance of safety-related equipment), Step 2.1.1, required that performance of work be documented on CPS 8120.34 COO 1, " Check Valve Inspection Checklist."

Contrary to the above, l l

a(1) On March 31,1997 the inspectors identified that J/Ss 77 through 87 and l J/S 93 of MWR D60080 had not been signed for as the work was  !

l performed.

a(2) On March 31,1997 the inspectors identified that a late entry s;gn-off of J/S 46 of MWR D60080 had been made without objective evidence that the subject activity had been completed.

i a(3) On March 31,1997 the inspectors identified that J/S 54 of MWR D60080 had been performed more than once, but the additional performance had not been documented on a copy of CPS 1029.01 F003.

a(4) On March 31,1997 the inspectors identified that work on MWR D60080 had proceeded with a " Risk Basis" design deviation, but the required engineering approval was not documented on a copy of CPS 1029.01 F010.

a(5) On March 14,1997 the licensee considered 1821F032A operable as a flow l path for shutdown cooling prior to resolving a " Risk Basis" design deviation associated with MWR D60080.

b(1) On March 31,1997 the inspectors identified that work which 'S/R D60080 had directed be performed in accordance with CPS 8120.04 i e not documented on CPS 8120.04C001.

b(2) On March 31,1997 the inspectors identified that work which MWR D60080 l had directed be performed in accordance with CPS 8120.34 was not l documented on CPS 8120.34C001.

l l This is a Severity Level IV violation (Supplement I).

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Notice of Violation 1

2. 10 CFR Part 50, Appendix B, Criterion V, " Instructions, Procedures, and Drawings,"

g requires, in part, that activities affecting quality shall be prescribed by documented i instructions, procedures, or drawings, of a type appropriate to the circumstances. I Procedure 2800.03, " Reactor Coolant System Leak Test," revision 14, and procedure 9059.01, " Reactor Coolant System Leak Test," revision 2, were documented procedures which prescribed system leakage tests at pressures which were specified as being not less than the nominal operating pressure associated with 100 percent rated reactor power.

Contrary to the above, on April 20,1995 a leak test was performed using procedure 2800.03, revision 14, and on March 23,1997 a leak test was performed using procedure 9059.01, revision 2, procedures which were inappropriate to the circumstances because they specified leak test pressures which were less than the actual nominal operating pressure associated with 100 percent rated reactor power.

I This is a Severity Leval IV violation (Supplement 1). j

3. Technical Specification (TS) 5.4.1 requires, in part, that written procedures shall be established, implemented, and maintained covering the activities recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978. l Regulatory Guide 1.33, Revision 2, Appendix A, Paragraph 7.d(5), recommends, in part, procedures for Control of Radioactivity to limit materials released to the environment from gaseous effluent ventilation systems.

Contrary to the above, on February 27,1997, the inspectors and plant staff jointly identified that CPS Procedure 2104.02 "VQ/RA Charcoal Absorber Leak Test,"

Revision 3, a procedure required by technical specification 5.4.1, was not adequate assure the Containment and Drywell gaseous effluent ventilation system charcoal absorbers functioned properly.

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

4. 10 CFR Part 50, Appendix B, Criterion V, " Instructions, Procedures, and Drawings,"

requires, in part, that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances.

Contrary to the above, on November 11,1996 freeze seats were installed on a portion of the reactor coolant system boundary, an activity affecting quality, using CPS Procedure 8208.01, " Freeze Seals," revision 9, a procedure which was not appropriate to the circumstances.

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

J Notice of Violation 5. 10 CFR 50.59(a)(1)(l), " Changes, Tests and Experiments," st::tes, in part, the holder of a license authorizing operation of a utilization facility may make changes in the facility as described in the safety enalysis report without prior Commi:sion approval, unless the proposed change involves a change in the technical specifications incorporated in the license or an unreviewed safety question.

10 CFR 50.59(b)(1) requires, in part, that the licensee maintain records of changes in the facility made pursuant to this section to the extent that these changes constitute changes in the facility as described in the safety analysis report. These records must include a written safety evaluation which provides the bases for the determination that the change does not involve an unreviewed safety question.

Contrary to the above, on September 17,1996, the inspectors observed annunciator response books on top of the P-680 main control room panel. USAR section 3.1.2.2.1.0.1 states that the control room had been designed to meet seismic Category I requirements. The change was make without performing a written safety evaluation to determine that the change did not involve an unreviewed safety question.

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

6. 10 CFR 50 Appendix B, Criterion V requires activities affecting quality shall be prescribed by documented instructions or procedures of a type appropriate to the circumstances.

Contrary to the above:

a. As of September 1996 procedures CPS 9080.01, Rev. 40, " Diesel Generator 1 A (18) Operability - Manual and Quick Start Operability" and CPS 9080.02, Rev 37,

" Diesel Generator 1C Operability - Manual and Quick Start Operability," activities affecting quality, were not appropriate to the circumstances. Specifically, Step 5.11 in both procedures prescribed preconditioning of the emergency diesel generators, by priming the fuel oil system prior to diesel generator starting, thereby negating the test's validity in demonstrating the emergency diesel generators' ability to perform satisfactorily in service,

b. As of September 1996 procedures CPS 9080.01, Rev. 40, " Diesel generator 1 A (1B) Operability - Manual and Quick Start Operability" and CPS 9080.02, Rev. 37,

" Diesel Generator 1C Operability - Manual and Quick Start Operability,' activities affecting quality, were not appropriate to the circumstances. Specifically, Step 5.5.4 in both procedures prescribed preconditioning of the emergency diesel generators, by "barring over" the diesel prior to starting, thereby negating the test's validity in demonstrating the emergency diesel generators' ability to perform satisfactorily in service.

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Notice of Violation c. As of October 1996, procedure CPS 9080.02, Rev. 37, " Diesel Generator 1C Operability - Manual and Quick Start Operability," an activity affecting quality was inappropriate to the circumstances in that it failed to require the high pressure core spray (HPCS) emergency diesel generator to be declared inoperable during testing.

d. On September 18,1996, procedure CPS 9861.020019, Rev. 26, "LLRT for 1MO45" (LLRT for portions of the main steam system), an activity affecting quality, was not appropriate to the circumstances in that it failed to provide necessary steps to bypass and restore a group I cor'tainment isolation signal.

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

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 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 for each violation: (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 results 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.

Because the response will be placed in the NRC Fublic 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 PDR 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, Illinois, this 16th day of May 1997

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