ML20153C681

Notice of Violation from Insp on 880217-0404.Violation Noted:Licensee Failed to Promptly Identify Condition Adverse to Quality on RCIC Instrumentation & Correct Condition Prior to Placing HPCS out-of-svc

ML20153C681
Person / Time
Site:	Clinton
Issue date:	04/28/1988
From:	Knop R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20153C678	List: IR 05000461/1988004 ML20153C674 ML20153C681
References
50-461-88-04, 50-461-88-4, NUDOCS 8805060280
Download: ML20153C681 (2)

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NOTICE OF VIOLATION Illinois Power Company License No. NPF-62 As a result of the inspection conducted on February 17 through April 4, 1988, and in accordance with the 10 CFR Part 2, Appendix C - General Policy and Procedure for NRC Enforcement Actions (1987), the following violations were identified:

1. 10 CFR 50, Appendix B, Criterion XVI and the IP Operational Quality Assurance Manual, Chapter 16 state in part: Conditions adverse to plant safety and/or quality are promptly identified and corrected.

Contrary to the above:

On February 23, 1988, during the performance of a Technical Specification Channel Check on a Reactor Core Isolation Cooling (RCIC) steam line flow instrument, the licensee noted a 9% full scale delta between instruments 1E31-N683A and IE31-N683B. Identification of this condition as adverse to quality was not prompt in that the licensee did not establish a request for calibration of the subject insturments as a priority activity until February 24, 1988. During the time period that the RCIC steam line flow instruments were in a degraded condition, the licensee removed the High Pressure Core Spray (HPCS) system from service.

The licensee's failure to promptly identify the condition adverse to quality on the RCIC instrumentation and correct it prior to placing HPCS out of service is a Severity Level IV violation (Supplement I)

(50-461/88004-01(DRP)).

2. Technical Specification 6.8.1.a. and IP administration procedure CPS No. 1029.01, revision 21, dated December 21, 1987, state in part:

A maintenance request shall be evaluated for any impact to plant systems or component operability.

Contrary to the above:

On February 25, 1988, the shift supervisor authorized work to start on the Division II Essential Switchgear Heat Removal (VX) system.

At the time of work authorization, the Division III HPCS system was removed from service. Division II VX is an engineered safety feature that provides a support function (coolir.g) to the Division II ECCS components. Technical Specification 3.5.1. ACTION c.2 required a plant shutdown if HPCS (Division III) and either Division I or II ECCS become inoperable.

Failure to adequately evaluate the impact to plant systems or component operability when authorizing work to start on Division II VX is a Severity Level IV violation (Supplement I) (50-461/88004-02(DRP)).

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Notice of Violation 2

3. 10 CFR 50.59 requires a written safety evaluation which provides the basis for a change to the facility as described in the safety analysis report.

Contrary to the above:

On March 16, 1988, while operating at 90*4 power, plant staff personnel staged material and equipment in containment directly over the suppression pool. The material was staged in preparation for a plant outage scheduled to cocunence on March 18, 1988. Material stagir.g included two 55 gallon drums, Radiation Protection signs, and approximately 1,000 yards of Herculite. In addition, Herculite had been taped to the grating (directly over the suppression pool) between the containment and drywell personnel air locks. Material staged was performed under verbal instructions and constituted a change to the facility as described in the safety analysis report without a written safety evaluation.

This is a Severity Level IV violation (Supplement I) (50-461/88004-03(DRP)).

4. Technical Specification 3.4.3.1 ACTION statement requires grab samples of the drywell atmosphere to be obtained and analyzed at least once per 24 nours when the required particulate radioactive monitoring system is inoperable.

Contrary to the above:

On February 16, 1988, at about 11:40 a.m. CST the drywell atmosphere particulate radioactivity monitor alarmed. A grab sample of the drywell atmosphere w s performed at about 2:00 p.m. on February 16 and plant staff concluded that the alarm was invalid. However, the drywell atmosphere particulate radioactivity monitor was not declared inoperable untti February 18. A grab sample was obtained at about 10:40 p.m. on February 18. The licensee failed to obtain and analyze a drywell atmosphere grab sample between 2:00 p.m. on February 16 and 10:40 p.m.

on February 18 which exceeded the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> time limit of the Technical Specification 3.4.3.1 ACTION statement.

This is a Severity Level IV violation (Supplement I) (50-461/88004-04 (DRP)).

Pursuant to the provisions of 10 CFR 2.201, you are required to submit to this office within thirty days of the date of this Notice a written statement or explanation in reply, including for each violation: (1) corrective action taken and the results achieved; (2) corrective action to be taken to avoid further violations; and (3) the date when full compliance will be achieved.

Consideration may be given to extending your response time for good cause shown.

!APR 2 919M g C 7f 7 Date R. C. Knop, Chief Reactor Projects Branch 3