ML20247C861

Notice of Violation from Insp on 890109-0214.Violations Noted:Procedure 8117.05 Not Appropriate,In That Procedure Did Not Address Area Radiation Monitor Interlock on Containment Polar Crane or Actions in Event of Alarm

ML20247C861
Person / Time
Site:	Clinton
Issue date:	03/20/1989
From:	Miller H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20247C859	List: IR 05000461/1989002 ML20247C854 ML20247C861
References
50-461-89-02, 50-461-89-2, NUDOCS 8903300293
Download: ML20247C861 (3)

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. NOTICE OF VIOLATION Illinof* Power Company ~ Docket No. 50-461' License No. NPF-62 As a result of the inspection conducted on January 9 through February 14, 1989, and in accordance with 10 CFR Part 2, Appendix C - General Statement of Policy-and Procedure for NRC Enforcement Actions (1988), the following violations were identified:

1. 10 CFR 50, Appendix B, Criterion V, requires in part, tha't activ' ities affecting quality.shall be prescribed by documented instructions, procedures, or drawings, of the type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings. . Clinton Power Station (CPS) Procedure No. 8117.05," Steam Dryer / Separator and Shroud Head Removal," provides the instructions for dryer and separator removal. Plant Manager Standing Order PMS0-041, " Override of Interlocks," provides the established controls for defeating or overriding an interlock (e.g.,

management noti Mation and concurrence.)

Contrary to the above, CPS No. 8117.05, was not appropriate, in that, it did not address an area radiation monitor (ARM) interlock on the containment polar crane or the actions to be taken in the event of the alarm. Further, PMS0-041 was not adhered to during movement of the dryer and separator on January 7 and 8,1989, in that, the ARM interlock was overridden without appropriate management knowledge.

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

2. Technical Specification (TS) Section 3.9.10.1 allows one control rod and/or drive mechanism to be removed from the core provided that certain requirements are satisfied. One requirement states, in part, that the reactor mode switch is operable and in the refuel position per Specification 3.9.1. TS 3.9.1.a states that a control rod shall not be withdrawn unless the refuel position one-rod-out interlock is operable.

The action statement 3.9.1.b requires the licensee to lock the mode switch in the Shutdown position with the one-rod-out interlock inoperable.

Contrary to the above, on January 7, 1989 (between 1327 and 1809 hours0.0209 days <br />0.503 hours <br />0.00299 weeks <br />6.883245e-4 months <br />),

with the mode' switch in Refuel and control rod 36-09 fully withdrawn (uncoupled from its drive), the one-rod-out interlock was defeated.

This condition existed until 0025 hours2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br /> on January 8, when the licensee

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identified the LCO and locked the mode switch in Shutdown. j This is a Severity Level IV violation (Supplement I).

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3. TS~Section 6.8.1~ requires written procedures to be establis'ed, h

implemented, and maintained covering activities'such as refueling operations. CPS No.1019.04, " Tool and Material Control for the Refuel Flo:r and Fuel Handling floor During Refueling Outages," requires tools, equipment, and material to be logged prior to entry into defined areas over flooded pools. Further, a Material Controller shall be designated and be responsible. for maintaining the inventory logs.

Contrary to the above, on January 20, 1989, CPS No. 1019.04 was not being implemented on the refuel floor in containment, in that, a Material Controller was not present, and the inventory log was not maintained t as evidenced by material found in the exclusion area which had not been logged in.

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

4. TS Section 3.9.2.b requires that at least two source range monitor (SRM) channels shall be operable, one of which is located in the quadrant where core alterations are being performed and the other detector located in.an adjacent quadrant. The action statement requires that core alterations be immediately suspended with the specification not satisfied.

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Contrary to the'above, on January 22, 1989, fuel was moved in quadrant A with SRM A operable, and both adjacent SRM channels B and D inoperable.

This condition existed from approximately 0140 to 0545 hours0.00631 days <br />0.151 hours <br />9.011243e-4 weeks <br />2.073725e-4 months <br />, when the licensee identified the LC0 and suspended core alterations.

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

5. 10 CFR 50, Appendix B, Criterion II, requires in part, that the licensee shall provide for indoctrination and training of personnel performing activities affecting quality as necessary to assure that suitable proficiency is achieved and maintained.

Contrary to the above, the following examples were identified in'which training was either lacking, inadequate, or ineffective in assuring suitable proficiency was achieved or maintained.

a. On January 7 and 8,1989, IP and GE personnel involved in the dryer and separator removal, overrode an ARM interlock on the containment polar crane, unaware of PMS0-041, which provided the established controls for overriding the interlock. Contractor personnel had not been trained on PMS0-041.

b. On January 20, 1989, material control was not being maintained on the refuel floor in containment (CPS No. 1019.04). Contractor i.

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[ 4 No ice'of Violation .3 personnel did not adequately: understand the; responsibilities as-stated in the procedure and provided by informal direction from the licensee,

c. On February 3,1989, personnel involved in the source retrieval operation were_not aware of the existence of an interlock which prohibited refueling. bridge. movement over the core when the mode switch was in Shutdown. .Two attempts were made.to move the bridge; the licensee subsequently suspended operations to identify and resolve the problem.

These examples are a Severity Level IV violation (Supplement I).

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) 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.

M't fa-CL 10, i'il'1. l Dated- Hubft J. Miller, Director j Division of Reactor Safety  !

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