U-600733, Interim Deficiency Rept 55-86-10 Re Plant Mods Performed W/O Adequate Spec & Required Testing & Test Criteria. Initially Reported on 860919.Mods Affecting Structures,Sys or Components Reviewed

Interim Deficiency Rept 55-86-10 Re Plant Mods Performed W/O Adequate Spec & Required Testing & Test Criteria. Initially Reported on 860919.Mods Affecting Structures,Sys or Components Reviewed

ML20197B177
Person / Time
Site:	Clinton
Issue date:	10/21/1986
From:	Hall D ILLINOIS POWER CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
55-86-10, U-600733, NUDOCS 8610280111
Download: ML20197B177 (5)

Text

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b rn 0 U- 600733 L14-86(10 41 )-L 1A.120 ILLINOIS POWER COMPANY CLINTON POWER STATION. P.C. BOX 678. CLINTON. ILLINOls 61727 OCT 211986 Docket No. 50-461 Mr. James G. Keppler Regional Administrator Region III U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137

Subject:

Potentially Reportable 10CFR50.55(e) Deficiency 55-86-10: Plant Modifications Made Without Adequate Documented Specification of Required Testing and/or Test Acceptance Criteria

Dear Mr. Keppler:

On September 19, 1986, Illinois Power Company (IP) notified Mr. Knop, NRC Region III (Ref: IP Record of Coordination Y-203225, dated September 22, 1986) of a potentially reportable condition under the provisions of 10CFR50.55(e) concerning plant modifications performed without adequate specification of required testing and test acceptance criteria. The results of IP's reviews of plant modifications completed to date determined that the specification of testing requirements, acceptance criteria, and documentation of testing results were inadequate for certain modifications. All modifications affecting structures, systems, or components required for fuel load were reviewed and where additional testing was specified, this testing was completed prior to issuance of the Low Power License. The remaining actions required to resolve this issue will be completed and a final report submitted prior to Initial Criticality.

Illinois Power's investigation of this matter is

. continuing. This letter represents an interim report in accordance with the requirements of 10CFR50.55(e).

Attachment A provides the details of our investigation to date.

8610280111 861021 PDR ADOCK 05000461 S ,

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U- 600733 L14-86( 10 21)-L

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. We trust that this interim report provides you sufficient background information to perform a general assessment of this potentially reportable deficiency and adequately describes our overall approach to resolve this issue.

S rel yours, D. . Hall Vice President RLC/cke Attachment cc: NRC Resident Office Illinois Department of Nuclear Safety INPO Records Center i

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ATTACHMENT A ILLINOIS POWER COMPANY CLINTON POWER STATION DOCKET NO. 50-461 Potentially Reportable 10CFR50.55(e)

Deficiency 55-86-10: Plant Modifications Made Without Adequate Documented Specification of Required Testing and/or Test Acceptance Criteria INTERIM REPORT

. Statement of Potentially Reportable Deficiency / Background On September 19, 1986, Illinois Power Company (IP) notified Mr. Knop, NRC Region III (Ref: IP Record of Coordination Y-203225, dated September 22, 1986) of a potentially reportable condition under the provisions of 10CFR50.55(e) concerning the performance of plant modifications without adequate documented specification of required testing and/or test acceptance criteria.

Investigation Results/ Corrective Action Illinois Power's investigation of this matter divided the completed plant modifications into four categories as follows:

1. Modifications required for Fuel Load which were completed after system preoperational testing (91 packages).

2. Modifications not required for Fuel Load which were

completed after system preoperational testing (76 I packages).

3. Modifications required for Fuel Load which were i comaleted before system preoperational testing (0 packages).

( 4. Modifications not required for Fuel Load which were completed before system preoperational testing (15 packages).

In order to establish the adequacy of completed plant modifications with regard to testing, IP revised departmental procedures as an interim measure to require review of completed modifications by the Joint Test Group i

(JTG). Although the JTG's primary function has been the review of preoperational phase test procedures and results, it was determined that the review of plant modification packages by the JTG would provide adecuate assurance that appropriate testing had been specifiec, and performed either during the modification, startup testing, or in subsequent post maintenance tests or surveillances.

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ATTACHMENT A (continued)

Initial review of the modification packages by the JTG revealed various deficiencies of an administrative nature [A, (i.e., incomplete forms, failure to initial changes, etc.)#fS/ '"?

as well as possible deficiencies with actual testing performed. To expedite the JTG review and identify those actions required to support Fuel Load, it was agreed that the administrative comments that did not affect the validity of the modification or the acceptance testing would be resolved by the Nuclear Station Engineering Department (NSED) subsequent to the JTG approval of the modification package.

Illinois Power's investigation of this matter is continuing in accordance with the investigation plan which includes the following:

1. Revise appropriate departmental procedures to require JTG approval of modification as an interim measure (This action is complete).

2. Prepare list of modification packages and determine test requirements and acceptance criteria. (This action is complete for Fuel Load systems and will be complete for the remaining systems by Initial Criticality).

3. Compare testing requirements and acceptance criteria to documentation of testing results and resolve discrepancies. (This action is complete for Fuel Load systems and will be complete for the remaining systems prior to Initial Criticality).

4. Obtain JTG approval for completed modification packages. (This action is complete for Fuel Load systems and will be completed for the remaining systems prior to Initial Criticality).

5. Resolve administrative comments where such comments were noted during the JTG review and supplement the modification packages and records in the vault. (This action will be completed prior to Initial Criticality).

6. Provide training to Plant Technical and NSED personnel on test requirements, acceptance criteria, documentation of testing, and data package review techniques. (This action is complete).

7. Review a sample of modifications completed prior to the system preoperational tests. None of these modifications affected systems required for Fuel Load.

(This action will be completed prior to Initial Criticality).

8. Monitor modification program until assurance is provided that the JTG review can be discontinued (This action will be complete prior to Initial Criticality).

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ATTACHMENT A (continued)

, Root Cause Illinois Power's investigation into this matter has determined the root cause to be inadequate training of Plant Technical Staff and NSED engineers regarding modification test requirements, acceptance criteria, and documentation of testing results associated with the review of plant modification packages.

To preclude recurrence of the subject deficiency, training has been provided to Plant Technical and NSED personnel on test requirements, acceptance criteria, documentation of testing, and data package review techniques.

Safety Implications / Significance Illinois Power Company's investigation of this matter is continuing. The safety implications and significance .

will be assessed after all applicable modification packages have been reviewed and evaluated.

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