ML20207P437

Notice of Violation from Insp on 861117-870105

ML20207P437
Person / Time
Site:	Clinton
Issue date:	01/12/1987
From:	Harrison J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20207P431	List: IR 05000461/1986073 ML20207P430 ML20207P437
References
50-461-86-73, NUDOCS 8701160134
Download: ML20207P437 (3)

Text

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NOTICE OF VIOLATION Illinois Power Company License No. NPF-55 As a result of the inspection conducted on November 17, 1986 through January 5,1987, and in accordance with the " General Policy and Procedures for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1985), the following violations were identified:

1. 10 CFR 50, Appendix B, Criterion III, as implemented by the Illinois Power (IP) Company Operational Quality Assurance Manual, Chapter 3, requires that, design activities are conducted in a planned and systematic manner; that design requirements are correctly translated into the appropriate drawings and change document; that design coordination function consisting of selected reviews and design control monitoring programs verifying that the design control documents reflect the intended design and the as-built configuration of the plant electrical systems and components be implemented.

Contrary to the above requirements:

a. IPC failed to assure that safety related connection diagrams and design change documents associated with SGT Panel OPL39JB, and Schematic diagrams associated with the Leak Detection system were correct in that numerous design discrepancies and inconsistencies

were identified.

b. IPC failed to assure that the design drawings associated with SGT Panel OPL39JB reflect the intended design and the as-built configuration of the plant installations.

! c. IPC failed to establish appropriate measures to assure that design l

engineers use all design change documents posted against a drawing, and that the design change documents are utilized during activities relating to changes.

This is Severity Level IV violation (Supplement 1).

2. 10 CFR 50, Appendix B, Criterion V, as implemented by the IP Company Operational Quality Assurance Manual, Chapter 5, requires

that activities affecting quality shall be prescribed by documented

! instructions, procedures, or/ drawings, of a type appropriate to the l

circumstances and shall be accorplished in accordance with these instructions, procedures, or drawings...

a. Procedure CPS No. 2.51 Revision 1, Paragraph 5.3.3 does not allow posting of design change documents that have been approved but not authorized.

l 8701160134 861118 PDR ADOCK 05000461 0 PDR

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b. Procedure CPS No. D.20, Revision 5, Paragraph 3.6 defines the responsibilities of design engineering and of the cognizant engineer {

with respect to modification cancellation. -

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c. Guidelines CPS No. 1.17,Section III requires that superseded documents be removed and stamped " superseded."

d. Conceptual Change Incorporation Standard, Section 3.3 requires that in plant operating phase sub-tier "B" drawings not have more F than three outstanding change documents posted against the drawing. L A time limit-of four weeks is allowed before the drawings need to be f revised. L_

Contrary to the above the following examples of inadequate procedures and failure to follow procedures were identified:

(1) Approved but unauthorized FECN-15413 superseded FECN-13095 which had h been completely implemented in the field; Posting of FECN-13095 was removed from SGT panel connection diagrams E03-0PL39JB, Sheets 1 =

and 2; FECN-15413 which changed the design of FECN-13095 was not posted against the drawings because it had not been authorized.

- Contrary to applicable procedures this resulted in a condition in which electrical components have been added and wired in the panel while the drawings and the design change documents against the drawings did not reflect these additions to the panel. In addition, ECN-7870 had not been posted against Panel OPL39JB drawings as required by the procedure.

(2) Documented evidence (as required by applicable procedures) indicating that a walkdown and or/ document review to assure that system and components added by superseded FECN-13095 are in pre-modification configuration was not available for review.

Furthermore, the requirement to coordinate with Drafting Supervisor to ensure that all control room drawings are marked to show as-built condition relative to superseded FECN-13095 had not been acccmplished as of the date of this inspection.

(3) On October 30, 1986, contrary to applicable procedures Superseded FECN-14036 was noted to be posted against drawing E03-1P741E-002, Revision N. In addition, approved and authorized document FECN-14391 was not posted against E03-IP741E-002 as required by the procedure.

(4) As of November 20, 1986, contrary to applicable procedures Drawing E03-0PL39JB, Sheets 1 and 2, which fall into the sub-tier "B" Category (Documents requiring rapid update in order to maintain equipment) have contained more than three outstanding change documents posted against the drawings.

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

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Notice of Violation 3 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 l

action to be taken to avoid further violation; and (3) the date when full compliance will be achieved. Consideration may be given to ,

extending your response time for good cause shown.

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JA:J 121987 "Y' Dated J. J. Harrison, Chief Engineering Branch

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