U-600829, Final Deficiency Rept 55-86-10 Re Plant Mods Performed W/O Adequate Specification of Required Testing & Test Acceptance Criteria.Initially Reported on 860919.Revised Mod Process to Incorporate in-line QA Review Initiated
| ML20209J242 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 01/28/1987 |
| From: | Hall D ILLINOIS POWER CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| 55-86-10, U-600829, NUDOCS 8702060252 | |
| Download: ML20209J242 (6) | |
Text
I N!M A 1
U-600829 L14-87( 01-28)-L 1A.120
/LLINO/S POWER COMPANY CLINTON POWER STATION P.O. BOX 678. CLINTON. ILLINOIS 61727 JAN 281937 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:
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 have now been completed.
Illinois Power has reviewed and evaluated the findings associated with this investigation and has determined that extensive engineering evaluations would be required to determine the effect of these deficiencies on the associated plant systems to perform their required safety function.
On this basis, the subject deficiency is evaluated to be reportable under the provisions of 10CFR50.55(e).
Illinois Power's investigation of this matter is complete.
This letter represents a final report in accordance with the requirements of 10CFR50.55(e).
Attachment A provides the details of our investigation.
8702060252 870128 JAN 2 <J E07 POR ADOCK 05000461 TGc27
U 600829 L14-87(01 28)-L 1A.120 We trust that this final report provides you sufficient background information to perform a general assessment of this reportable deficiency and adequately describes our overall approach to resolve this issue.
Sincerely yours, 3
e.
al Vice President RLC/bsa Attachment cc:
NRC Resident Office Illinois Department of Nuclear Safety INPO Records Center
ATTACHMENT A ILLINOIS POWER COMPANY CLINTON POWER STATION DOCKET NO. 50-461 Reportable 10CFR50.55(e)
Deficiency 55-86-10:
Plant Modifications Made Without Adequate Documented Specification of Required Testing and/or Test Acceptance Criteria FINAL REPORT Statement of 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 packages).
3.
Modifications required for Fuel Load which were 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 (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 adequate assurance that appropriate testing had been specified and performed either during the modification, startup testing, or in subsequent post maintenance tests or surveillances.
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ATTACHMENT A (continu;d)
Initial review of the modification packages by the JTG revealed various deficiencies of an administrative nature (i.e., incomplete forms, failure to initial changes, etc.)
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 which 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.
In order to resolve this issue, the following corrective actions were taken:
1.
Revised affected procedures to require JTG approval of completed modifications as an interim resolution until training and revision of NSED and Plant Staff procedures could be completed.
2.
Prepared list of modification packages and determined test requirements and acceptance criteria.
(Category 1 and 2) 3.
Compared test requirements and acceptance criteria to documentation of testing and resolved discrepancies.
4.
Obtained JTG approval for completed modifications identified in Item 2 above which were complete or in-process at the start of this investigation.
5.
Initiated resolution of administrative comments and supplements for the modification packages and records in the vault.
This action will be complete by 1/31/87.
6.
Provided training to Plant Technical and NSED personnel on test requirements, acceptance criteria, documentation of testing, and data package review techniques.
7.
Reviewed a sample of modifications completed prior to the system preoperational test.
This review did not identify aav technical deficiencies in this category.
(Category 4) 8.
Revised modification process to incorporate an in-line Quality Assurance review of modification packages.
Procedure changes to support this program change are in place.
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ATTACHMENT A (continutd)
In addition to these corrective actions which deal specifically with the testing of plant modifications, some additional corrective actions were initiated as a result of concerns with the adequacy of the modification program.
They are as follows:
1.
A test engineer (formerly with the Startup Test Results Review Group) was assigned to the Configuration Management Group to review completed modifications and ensure consistency in post-modification testing.
2.
A Quality Assurance Audit (Q38-86-67) of the modification program was initiated.
This audit revealed various program deficiencies.
These deficiencies are being resolved in response to the audit findings.
Results, to date, have not indicated any deficiencies with the adequacy of safety-related systems or components.
3.
Some deficiencies with regard to implementation of modifications were identified during the investigation associated with 55-86-06.
These were documented on Condition Reports 1-86-12-014 and 1-87-01-014.
Investigation into these deficiencies determined that they related to failure to implement some non-operational design requirements (painting and sealing) which were unrelated to post-modification testing.
The JTG reviews described in item 4 above ensured the operational design requirements were implemented.
Root Cause NSED engineers were not adequately specifying the testing requirements and acceptance criteria for plant modifications.
Subsequent Plant Technical and Supervisory reviews failed to identify the inadequate testing.
This was the result of inadequate training of the engineers and supervisors who specified, directed and reviewed the documentation of the testing associated with plant modifications.
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.
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/
ATTACHMENT A (continuad)
Safety Implications / Significance The results of the JTG reviews of plant modifications indicate that the test requirements, acceptance criteria, and documentation of testing were inadequate.
Extensive engineering evaluations would be required to determine the effect of these deficiencies on the associated plant system to perform their required safety function.
On this basis, this matter is considered reportable under the provisions of 10CFR50.55(e).
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