ML20247A087
| ML20247A087 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 05/12/1989 |
| From: | Miller H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20247A079 | List: |
| References | |
| 50-461-89-03, 50-461-89-3, NUDOCS 8905230038 | |
| Download: ML20247A087 (4) | |
Text
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NOTICE OF VIOLATION Illinois Power Company Docket No. 50-461 Clinton Power Station License No. NPF-62 As a result of the inspection conducted on January 23-26, February 27-18, March 13 through April 7, 1989, and in accordance with 10 CFR Part 2, Appendix C - General Statement of Policy and Procedure for NRC Enforcement Actions (1988), the following violation was identified:
1.
10 CFR 50, Appendix B, Criterion V, as implemented by the Illinois Power Nuclear Power Operational Quality Assurance Manual, Chapter 5,
" Instructions, Procedures, and Drawings," requires that activities affecting quality be prescribed by documented instructions, procedures and drawings, and that those activities be accomplished in accordance with those instructions, procedures and drawings.
Contrary to the above:
a.
Thirteen maintenance procedures in three work packages, D02668, PEMSY053, c id PEMSY054 had not been reverified prior to use to ensure that current revisions were included as required by CPS Procedure NP&S 2.51,
" Document Control," Revision 1, Section 3.9(461/89003-01A(DRS)).
b.
A person was not assigned to physically monitor reactor recirculation pump operations for excessive noise or unusual conditions on the initial start after major repair as required by the work instructions contained in MWR 811970 (461/89003-01B(DRS)).
c.
The oil level of reactor recirculation pump 1A was not verified before starting the pump as required by surveillance Procedure 9840.01 (461/89003-01C(DRS)).
d.
A " limited calibration" Mean Square Analog Test Fixture, with a required input voltage of 122 to 124 volts, was used to calibrate the Intermediate Range Monitors without verifying the input voltage or using a voltage regulated power rupply as required by Procedure CPS 1512.01, " Calibration and Control of Maintenance and Test Equipment," Revision 10 (461/89003-01D(DRS)).
e.
Color coding of seven of twenty three contaminated tools in the hot tool storage area was not accomplished as required by Procedure MSQ-030 (461/89003-01E(DRS)).
f.
Safety-related equipment such as RHR Pump / Motor and Division III battery charger were not identified as specified in Sargent and Lundy Specification K-2999 (461/89003-01F(DRS)).
This is a Severity Level IV violation (Supplement I).
Pursuant to the provisions.of 10 CFR 2.201, you are required to submit to this 4
office within thirty days of the date of this Notice a written statement or i
I 8905230038 89051'
{DR ADOCK 05000461 PDC 1
'2 explanation in reply, including for each violation:
(1) the corrective actions that have been taken and the results achieved; (2) the corrective actions that will 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.
hs.
f Dated
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Hu(grtJ. Miller,. Director Division of Reactor Safety
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4 EXECUTIVE
SUMMARY
An announced team inspection of maintenance was conducted at the Clinton Power Station during the periods of January 23-26, February 27-28, and March 13 to April 7. 1989. The inspection was conducted to evaluate the extent that a mainter.ance program had been established and implemented at Clinton to assure the preservation or restoration of the availability and reliability of plant structures, systems, and components to operate on demand. Three major areas were assessed including overall plant performance as affected by maintenance, management support of maintenance, and implementation. To accomplish this, several maintenance related activities were evaluated to determine if maintenance was accomplished, effective and self-assessed.
STRENGTHS The inspection team noted specific strengths in the areas of:
rolling maintenance schedule; housekeeping; use of reliability centered maintenance; management support and involvement in maintenance; motor operated valve testing and preventive maintenance; timeliness in performance of preventive maintenance; quality control inspections; maintenance work instructions and procedures; material control interfaces; control of limited life material; trending; knowledge and experience of maintenance planners and craftsmen; tracking of vendor, regulatory, and other outside source information; documentation of work performed; vendor manual control and knowledge of control and instrumentation supervisors.
WEAKNESSES The inspection team noted a number of specific weaknesses; however, none had an impact on plant or system / component operability. Weaknesses were identified in the following areas: compliance with procedures; scope of preventive maintenance program; untimely evaluation and implementation of vendor recommended maintenance; lack of use of maintenance and material control tags; lack of engineering involvement causing potential for inadequate post maintenance test requirements; excessive use of " plant aging" cause code for safety-related equipment failures; cumbersome power plant maintenance planning system and preventive maintenance forms; instances of inadequate systems engineering support of maintenance activities and knowledge of assigned systems; material storage; untimely repair and random use of failed components in storage; and instances of lack of supervision involvement in maintenance activities and technical reviews of some maintenance tasks.
CONCLUSION Results of this inspection showed overall satisfactory performance in the establishment and implementation of an effective plant maintenance process at the Clinton Power Station.
Based on the review of past work activities, i
observations of ongoing work activities, work controls, and self-assessment, the inspectors determined that overall, electrical, mechanical, and instrument maintenance and support activities were adequately performed to maintain operability of components at a level commensurate with the components' i
functions. However, some of the activities identified were in violation of regulatory requirements as noted. Sections 2.6 through 2.8 of the inspection report provide a more complete summary of the maintenance process.
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'\\s l[t l
l' CONTENTS' Section-L l
Cover Sheet' E
Inspection Summary and Results Section Pa2L
'1. 0 '
Persons Contacted........................ :3 -
2.0 Introduction to the Evaluation and Assessment of Maintenance...
3' 2.1 Historical Data...........................
4-2.2 Description 'of Maintenance Philosophy..............
4-2.3 Review and Evaluation,of~ Maintenance Accomplished......~. '. '5 2.3.1
' Maintenance Backlog Assessment and Evaluation..
.t.
5 2.3.2 Review and' Evaluation'of Completed Electrical Maintenance...=.. 6 2.3.3 Engineering'and Technical ~ Support................. 14-2.3.4.
Work Control........................... 17 2.3.5 Personnel Control.......................
19 2.4-Observation of Current Plant Conditions and Ongoing Work Activities.......................
20 2.4.1 Observation of Material Condition................'21 2.4.2 Observation of Ongoing Work Activities...........
23 2.4.3 Radiological Controls.....................
30 2.4.4 Maintenance Facilities, Material Control, and Control of Tools and Measuring and Test Equipment............
30 2.5 Licensee's Assessment of Maintenance (Quality Verification)..
33 2.6 Overall Plant Performance Related to Maintenance........
34 2.7 Management Support of Maintenance...............
35 2.8-Maintenance Implementation...................
36 3.0 Exit Meeting..........................
38 Appendix A:
Acronyms.........................
40
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