U-600893, Responds to NRC Re Violations Noted in Insp Repts 50-461/86-48,50-461/86-53 & 50-461/86-54.Notice Proposed to Impose Civil Penalty in Amount of $75,000.Actions Implemented to Improve Maint & post-maint Testing
| ML20205T383 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 03/31/1987 |
| From: | Hall D ILLINOIS POWER CO. |
| To: | Taylor J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| References | |
| EA-87-011, EA-87-11, U-600893, NUDOCS 8704070279 | |
| Download: ML20205T383 (29) | |
Text
'
0?
U-600893 L4 2-8 7 (o3 - 31)-L 1A.120
~~
ILLINDIS POWER COMPANY IP CLINTON POWER STATION, P.O. box 678. CLINTON. ILLINOIS 61727 March 31, 1987
)C' Mr. James Taylor, Director Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, D.C.
20555
Subject:
Response to Notice of Violation and Proposed Imposition of Civil Penalty dated March 3, 1987, Docket No. 50-461, EA 87-11
Dear Mr. Taylor:
On March 3, 1987, the NRC issued a Notice of Violation and Proposed Imposition of Civil Penalty, EA 87-11, to Illinois Power Company (IP).
This Notice is based on violations described in NRC Inspection Reports No.
50-461/86048 (DRP), No. 50-461/86053 (DRS), and No.
50-461/86054 (DRP).
The Notice proposes to impose a civil penalty upon IP in the amount of $75,000.
Attachment A to this letter provides a description of the programs IP has implemented to improve performance in the general areas in which the violations listed in the Notice occurred.
Attachment B to this letter provides IP's Reply to the specific violations listed in the Notice of Violation, and Attachment C provides IP's Answer to the Proposed Imposition of Civil Penalty.
These Attachments describe the action IP has taken to correct the noted problems and prevent their recurrence.
As stated in the cover letter accompanying the Notice, "we (NRC] believe Illinois Power Company has made adequate progress in resolving the identified problems."
IP continues to implement the programs initiated in response to these problems and is committed to their success.
Because of the nature of the violations described in the Notice and IP's energetic response to the problems underlying the violations, as well as IP's continued commitment to improved performance in the areas in which the violations occurred, IP does not believe that the civil penalty proposed by the NRC is appropriate.
As is discussed in Attachment C, IP believes that mitigation of the proposed civil penalty is justifiable.
Therefore, IP requests i
mitigation of the proposed civil penalty.
To ensure this i
administrative issue does not interfere with the effort to prepare Clinton for licensed full power operation, a check in the amount of $75,000.00 is enclosed.
8704070279 870331 PDR ADOCK 05000461 0
)
({
')
[f3:
r-
-. \\. 5 i
__U-600893 L4 2-87 ( 03-31 )-L 1A.120 I trust that this response is satisfactory.
If you have any questions, please contact me or Frank Spangenberg, Manager.of Licensing and Safety.
S rely yours, D..
. Hall Vice President DWW/cke Enclosures B. L. Siegel, NRC Clinton Licensing Project Manager.
cc:
NRC Resident Office Illinois Department of Nuclear Safety Regional Administrator, U.S. Nuclear Regulatory Commission, Region III Document Control Desk, U.S. Nuclear Regulatory Commission.
\\'
I STATE OF ILLINOIS COUNTY OF DEWITT DONALD P. HALL, being first duly sworn, deposes and says:
I am Vice President of Illinois Power Company.
The information provided in the foregoing Response to Notice of Violation and Proposed Imposition of Civil Penalty (U-600893), dated March.3/, 1987, and the attached Generic Actions Taken by IP in the Areas in Which the Violations Occurred (Attachment A), the attached Reply to Notice of Violation (Attachment B) and the attached Answer to Proposed Imposition of Civil Penalty (Attachment C), was prepared under my supervision and direction.
I know the contents thereof, and to the best of my knowledge and belief the facts contained therein are true and correct.
Donald P. Hall Dated:
March S/,1987 Subscribed and sworn to before me this 3/dday of March, 1987 Yxb4 a
s O x.)
/
Notary Public My Commission Expires:
b n tr< is // lff0
\\
s
\\
\\'
o Attachment A Generic Actions Taken by IP in the Areas in Which the Violations Occurred IP is implementing actions to improve performance and prevent further violations in the general areas in which the viciations listed in the Notice of Violation occurred. These areas are:
Maintenance and Post Maintenance Testing Post-Modification Testing and Evaluation of Modifications Motor Operated Valves (MOVs)
Problem Identification and Correction.
IP's actions in each of these four areas are described below.
1.
Maintenance and Post Maintenance Testing The Maintenance Improvement Program was established in September,
'986, with the overall goal of ensuring excellence in the maintenance program for CPS. The main features of the Maintenance Improvement Program and actions to improve post maintenance testing, and the current status of each, are summarized below.
Action Status a.
Changing Maintenance Department management, Complete including appointment of an Assistant Plant Manager for maintenance, and performance of maintenance planning by a separate group; b.
Setting goals and standards for the quality Ongoing of work and documentation, and monitoring attributes in accordance with these goals and standards (IP is attempting to develop a method of monitoring the rework attribute);
c.
Monitoring progress through a Maintenance Ongoing Monitoring Group and internal (January 1987) and external (April 1987) progress reviews; d.
Shifting responsibility for post maintenance Complete testing from the Maintenance Department to the Operations Department; e.
Performing a top-down review of maintenance In Progress; procedures to ensure that all upper-tier require-to be ments are met by lower tier documents and imple-completed menting procedures; by 12/87 l 1
[4,.
'\\ I'
[
Action-
~ Status f.
Developing generic lists of expendable items and In progress i
lubricants normally used during maintenance, which identify acceptable alternative items and lubricants which may be used.
g.
. Developing a 40-year maintenance plan for MOVs Ongoing j
to ensure proper MOV maintenance over the life j
of the plant; j.
h.
Developing and implementing a program for
. Development documentation of test equipment calibration so complete; i
that documentation of testing adequately; implementa-l reflects calibration status of test equipment tion ongoing at the time tests are performed; 1
j i.
Establishing standard torque specifications to Complete i
be used during maintenance;-
P j.
Implementing a toolbox skills program ensuring
' Ongoing
]
that all maintenance personnel demonstrate basic j
stills for maintenance tasks; I
k.
Upgrading maintenance procedure (CPS 1029.01) to In J
provide more detailed job-stepping in MWRs and to Progress j
assure that MWRs are properly reviewed for post-
]
maintenance testing; 1
l 1.
Instructing Supervisors to spend more time' Complete 1
observing maintenance work being performed in the Q
plant; initiating a periodic newsletter to maintenance personnel highlighting department j
problems and current events; Reviewing all MWRs issued between May 1985 and Complete m.
l September 1986 to assure that appropriate post maintenance testing was performed and associated documentation was completed; n.
Improving procedures governing post maintenance Complete testing evaluation and vaulting of associated l
}
documentation to ensure that completed MWRs are
]
reviewed for compliance with post maintenance testing requirements; i
o.
Expanding the field engineering group within the Complete
)
i maintenance planning organization to ensure-that l
MWRs receive adequate review prior to performance of work.
- l-l
l' The Maintenance Improvement Program and the improvements to post maintenance testing were described to the NRC in the September 19, 1986 management meeting; the December 18, 1986 enforcement conference; and in IP's December 30, 1986 (U-600803) and March 17, 1987 (U-600860) responses to SALP 6.
IP management is continuing to implement these actions, and results to date indicate that maintenance performance has improved, as discussed in IP's March 17, 1987 (U-600860) response to SALP 6.
In Inspection Report No. 86077, RC concluded that IP's " actions have been effective in addressing short-term items; longer-term, programmatic initiatives... have largely been implemented and appear adequate at this time."
2.
Post-Modification Testing and Evaluation of Modifications In September, 1986, IP initiated a series of actions to improve performance in evaluation of modifications, post-modification testing, and preparation of associated documentation. These actions and the current status of each are summarized below:
Action Status a.
Procedures were revised and training was Procedures conducted to provide for appropriate review of and train-completed modifications by NSED/ Plant Technical ing com-personnel to ensure adequacy of modification plete; acceptance criteria, post-modification testing, implementa-and documentation. These reviews are currently tion being performed for modifications. Prior to ongoing implementation of these procedure revisions and training, modifications which had been made after preoperational testing was conducted were reviewed by the Startup Joint Test Group (JTG) to ensure that appropriate post-modification testing had been performed and adequately documented. Discrepancies identified by JTG in completed modification packages which indicated the need for further documentation or post-modification testing were resolved by supplying the documentation or performing the required testing.
b.
In addition to the normal training on performing Complete 10CFR50.59 reviews, supplemental training was conducted for many NSED personnel on the performance of 10CFR50.59 reviews for modifications to help ensure that these safety evaluations are i
properly performed and documented.
1
\\'
Action Status c.
A test engineer (formerly with the Startup Test Complete Results Review Group) was temporarily assigned to the Configurction Management Group to review completed modifications and ensure consistency in the documentation of post-modification testing until NSED/ Plant Technical personnel completed training and no longer required assistance.
d.
Training was provided to Plant Technical and NSED Complete personnel on test requirements, acceptance criteria, documentation of testing, and data package review techniques.
e.
Process procedures were revised to incorporate Complete in-line review of quality-related ("Q")
modification packages by QA to confirm that quality program requirements are adhered to.
f.
A Quality Assurance Audit (Q38-86-67) of the Audit modification program was performed in December complete; 1986. Corrective action plans and schedules corrective were initiated for each finding, and corrective actions in actions are currently in progress.
progress These actions were described to the NRC in the management meeting on September 19, 1986; the enforcement conference on December 18, 1986; and in IP's January 23, 1987 Final Report on 10CFR50.55(e)
Notification 55-86-10 (U-600829).
IP is continuing to implement these actions, and IP management will monitor this area to ensure that progress continues.
3.
Motor Operated Valves (MOVs)
Motor Operated Valves (MOVs) have been the subject of widespread problems in the nuclear industry.
Some of these problems are described in the December 1986 report issued by the NRC's Office for Assessment and Evaluation of Operational Data. Based on the results of this report, the NRC Executive Director of Operations requested that the Nuclear Utility Management & Resources Committee (NUMARC) undertake industry initiatives to remedy these problems.
Even prior to the issuance of this report, IP took aggressive actions which were intended to prevent MOV problems from arising at CPS. For example, in November 1985, IP initiated the use of the Motor Operated Valve Analysis Test System (MOVATS) to test MOVs and to ensure that they would function properly. Concerns identified during this testing were analyzed by IP's Independent Safety Engineering Group (ISEG). Additionally, in the spring of 1986, IP hired Burns & Roe to evaluate the failure of five MOVs after
_4_
completion of MOVATS testing. As a result of concerns about valve operability which arose during MOVATS testing, additional post maintenance testing was performed on safety-related MOVs.
- Finally, in responst to these earlier concerns and others expressed by NRC Region III in June 1986, IP established an MOV Task Force:
a.
The Task Force was multidisciplinary and included personnel from IP NSED, Maintenance, Plant Technical, and QA, as well as personnel from Stone & Webster, Sargent & Lundy and General Electric. Many Task Force members had already been involved in identification, evaluation and resolution of MOV concerns.
b.
The objectives of the Task Force were to evaluate available MOV data, determine whether any reportable deficiencies existed, and provide recommendations to IP management on program improvements. As a result of this evaluation, a total of 141 concerns were identified. A summary of areas of concern and actions being taken in response is included in Table 1 to this Attachment.
c.
A number of recommendations for improvements in the area of MOVs were made to IP management by the Task Force. Many of these recommendations were adopted, including recommendations for improved training, vendor communications, procedure additions, procedure revisions, further reviews of procedures for adequacy, improvement of specifications, establishment of an MOV maintenance / testing group headed by a Supervisor, and use of "leosons learned" information. Implementation of these and other recoumendations will enhance MOV maintenance and testing efforts as well as long-term reliability.
IP has been aggressive in identifying and resolving MOV problems.
In addition to action on MOV Task Force recommendations, CPS safety-related MOV stems have been relubricated; this activity was completed in October 1986. Finally, IP will continue to develop the details of its 40-year MOV Maintenance Program which will ensure reliable MOV operability through the life of the plant. The actions and programs discussed above were described to the NRC in greater detail during the September 19, 1986 management meeting and the December 18, 1986 enforcement conference. The actions and recommendations of the MOV Task Force were particularly described in IP's October 7, 1986 Final Report on 10CFR50.55(e) item 55-86-04 (U-600716).
4.
Identification and Correction of Problems IP has taken a number of actions to improve quality programs and administrative controls affecting quality, in particular with respect to prompt identification and correction of problems. These actions and the status of each are summarized below. -
Action Status a.
QA and Maintenance Department Supervisors have Ongoing been instructed to spend more time in the plant observing work activities.
This action is improving the supervisors' knowledge and over-sight of the plant activities and is improving interfaces between Plant and QA personnel.
b.
The pace of work has been slowed and overtime Ongoing minimized to prevent mistakes. This action has helped reduce the number of personnel errors, as indicated by the decrease in the number of Licensee Event Reports being issued.
c.
Site-wide briefings have been and continue to be Ongoing held on the importance of identifying and reporting significant problems to management and following up on those problems after they have been reported.
d.
Managers' meetings are held frequently (usually Ongoing daily) to discuss current problems and establish priorities for upcoming work.
e.
As warranted, meetings are held between the Plant Ongoing Staff and the QA department to resolve current problems.
f.
Personnel briefings have been and continue to be Ongoing held on the importance of following procedures and doing the job right the first time.
g.
.An Operations Monitoring Program was implemented Ongoing in March 1986 to identify potential problem areas so that early action may be taken. This program provides for observation reports of performance in a number of areas and for trending of these reports. This program has been successful in providing useful feedback to supervision and management regarding the effectiveness of their activities.
h.
Through the BWR6 Information Exchange Owners Group, Ongoing industry lessons learned are discussed with other owners and reviewed for applicability to CPS.
i.
QA personnel have been trained to 1cok for Complete repetitive problems and trends, and to notify management when adverse trends are identified.
This action has been successful in identifying and obtaining corrective action for several trends. -
Action Status J.
The Licensing & Safety Department Procedure on Complete Licensee Event Reports has been issued to provide for a more detailed analysis of the root cause of the event.
k.
The Condition Report Procedure (CPS 1016.01) has Complete been revised to require that management be notified of prcblems within one hour of condi-tions requiring a Condition Report.
1.
Significant event critiques, designed to deter-Ongoing mine the sequence of events and formulate initial corrective actions, are held immediately following significant operating events.
Departments brief appropriate personnel on the Ongoing m.
contents of CPS Licensee Event Reports (LERs) to provide them with an understanding of the root causes of and lessons learned from the event.
n.
The Manager of QA is informed of all overdue Ongoing corrective action on QA findings and meets with the responsible department manager to expedite over-due corrective action. This action has resulted in a significant reduction in the frequency of overdue corrective actions for audit findings.
o.
The Manager of QA has directed that responsible Complete departments notify QA within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of corrective action plans for audit findings and that responsible departments provide a written response within 5 days. This action has resulted in earlier QA involvement in reviewing corrective action plans for audit findings.
p.
QA personnel have been briefed and QA procedures Complete have been revised to clarify that QA has the authority to stop unsatisfactory work immediately.
q.
To ensure that IP's actions continue to show Scheduled resultant improvements in the area of Quality for Programs and administrative controls, IP QA will completion perform an evaluation of the effectiveness of by May actions taken in this area.
1987 IP believes that these actions will substantially improve performance in identifying and correcting problems at CPS. These actions and others were described to the NRC in IP's December 30, 1986 Response to SALP 6 (U-600803), and March 17, 1987 Supplemental Response (U-600860) to SALP 6.
In Inspection Report No. 86077, NRC reviewed-IP's activities with respect to corrective action and concluded that "the licensee had been reviewing and improving the program in this area during the inspection period. Deficiency reviews and trending had been improved with an increase in frequency and quality of trend-reviews."
The programs described above demonstrate IP's continuing commitment and efforts to improve performance in the areas in which the violations identified in the Notice of Violation occurred. These programs are broader in scope than the specific violations and reflect IP's emphasis on discovering root causes of problems and taking action to ensure that similar problems do not recur.
i f
.I 1
i j
i l
4 4
4 i
i l
i._ - _.
t*
Attachment A TABLE 1 Summary of Corrective Actions Which Are Being Taken for Items identified by the Motor Operated Valve Task Force Area Corrective Action Valve Operator Prepare Standard Valve / Operator Specifications Problems and MOVATS which reflect " lessons learned" from MOV Testing deficiencies. Review procedures and establish hold points in CPS and vendor shops to assure proper attributes are inspected. Formally advise vendors of problems identified in CPS MOVs.
Issue specific ctandards for adjustments to valves which MOVATS testing indicates are needed.
MOV Maintenance and Evaluate CPS MOV Procedures 8451.01 and 8451.02
- . Repair for required changes, and revise these procedures to simplify task descriptions, clarify which lubricants are required, and incorporate QC signoff requirements for maintenance activities. Incorporate appropriate valve testing steps from preoperational test procedure GTP-55 into CPS MOV procedures. Provide training on the need for recording adequate information on MWRs.
Develop an MOV qualification / maintenance program including " hands on" and classroom training. Improve machinery history program to allow trending of common problems and identification of multiple causes of failure.
Test Control /
Create an MOV maintenance / testing group headed Jurisdiction by a supervisor. Review criteria for post maintenance testing of MOVs.
Identify those valve / operator maintenance and testing activities which require that MOVATS testing be re-performed.
Design Control Review ECNs and FECNs against MOV K-Specs for appropriate incorporation / posting on affected documents. Conduct additional training of Plant Staff and NSED personnel on Configuration Management. Provide training on the need to document design-related questions and to clarify use of quality-related MWRs.
Training / Procedures Provide criteria specifying when inspection of work performed ac vendor facilities is required for MOV components. Other training and procedure improvements are described above.
9
r l'
b Attachment B Illinois Power Company's Reply to Notice of Violation (EA 87-11)
The Notice of Violation organizes the described violations according to the four criteria from 10CFR Part 50, Appendix B under which the violations occurred. Illinois Power Company's (IP) response pursuant to 10CFR2.201 is accordingly organized into four parts, each corresponding to the specific criterion of Appendix B which was allegedly violated. Within each of these parts, the specific issues required to be addressed by 10CFR2.201, the Notice of Violation and the accompanying cover letter are discussed. An accompanying table-(Table
- 1) describes the specific actions IP has taken to correct violations included in NRC Inspection Report Nos. 86048, 86053 and 86054 which were not specifically mentioned in the Notice of Violation.
A.
Violations of Criterion III A1. The Notice of Violation states in part:
Contrary to [10CFR Part 50, Appendix B, Criterion III),
design control measures did not ensure that the design bases for structures, systems,-and components were correctly translated into specifications, drawings, procedures and instructions..Specifically:
Approximstely 36 motor operated valves (MOVs) were modified ow:*as the first six months _of 1986 in such a way that valvo speration under~the design conditions of low voltage could not be assured. Section 8.7.3.12 of Maintenance Procedure CPS 8451.02 incorrectly allowed the modification of the limiter plate _for Limitorque valve operator torque switches and therefore rendered the valves inoperable under low voltage conditions.
This violation was described in NRC Inspection Report No.
86053 as item 86053-01c, and was the subject of an IP notification to the NRC pursuant to 10CFR50.55(e) on July 15, 1986 (55-86-04).
I.
Admission or Denial of the Violation IP admits that this violation occurred as stated in the Notice of Violation.
=-
t-II.
Reasons for the Violation The reasons for this viointion were described by IP in Attachment A to its October 7, 1986 final report to the NRC concerning 50.55(e) Notification 55-86-04 (U-600716);
they were:
a.
The modifications to the_ limiter plates were made with the concurrence of the manufacturer in order to achieve manufacturer's recommended thrust values.
The bases for establishing the valve manufacturer's recommended thrust values were not initially recognized; this resulted in the unnecessary modifications (shaving) of the limiter plates.
b.
Nuclear Station Engineering Department (NSED) personnel incorrectly identified the Limiter Plate Modification as an internal-adjustment to equipment instead of a design change. This resulted in a change to CPS Procedure 8451.02 to allow modification of limiter plates without testing at 90% undervoltage.
III. Steps Taken to Correct the Problem and Results Achieved This problem was initially detected by IP.
An investigation, consisting of review of the safety-related MOVATS data sheets, was performed to determine the extent of the problem, and 36 valves were identified as having been modified to permit the torque switch to be set above the level originally permitted by the limiter plate.
Consultations were held with valve and operator manufacturers to formulate a technical solution. After the correct bases for establishing recommended thrust values were determined, testing was performed on the valves concerned. Appropriate adjustments were then made to each valve. Testing revealed that seven of the valves would have to remain set above the limiter plates.
Accordingly, modification docismentation was prepared for each of these valves accepting the limiter plate shaving which had been done to permit this setting. Each of the seven valves was tested at 90% undervoltage and it was determined that these valves would perform properly during undervoltage conditions. IP has confirmed that i
these actions are complete.
IV.
Corrective Steps to Avoid Further Violations NSED personnel were trained on the importance of evaluating changes to vendor supplied equipment under the Plant Modification Program (10 CFR 50.59 review), and CPS Procedure 8451.02 was revised to prohibit raising the 1
! l 1
\\'
s torque switch above the limiter plate without NSED evaluation and approval. IP has confirmed these actions 3
are complete.
IP performed an investigation to determine the cause of the. failure of the seven valves to develop their design thrusts without shaving of the limiter plates. IP determined that this failure was caused by a. lack of. shop-tests by the vendor to verify that the valves' operators t
would develop their design thrusts at the calculated-I torque switch setting.
IP is preparing standard valve /
I operator specifications to assure proper shop l
verification of required thrust prior to shipment.
4 1
i Details of the actions taken to avoid further violations-i were described to the NRC in Attachments A~and B to IP's-1 Final Report on 50.55(e) notification 55-86-04, dated'
)
October 7, 1986 (U-600716). Other actions IP has taken on a generic level to improve its modifications program, performance in the area of MOVs, and identification and 3
correction of problems are described in Sections 2, 3.and t
't 4 of Attachment A.
The NRC closed'this item in Inspection Report No. 86077.
V.
Date When Full Compliance Will be Achieved IP is currently in compliance.
l i
i A2.
The Notice of Violation states in part:
i i
Contrary to [10CFR Part 50, Appendix.B, Criterion III]
j design control measures did not ensure that.the design bases for structures, systems and components were.
l correctly translated into drawings, procedures and i
instructions. Specifically:
Field Engineering Change Notice No. 12329, issued on i
September 28, 1985, changed the configuration of the power wiring to valve motors from that specified on design drawings. However, this change was not, incorporated or referenced on later electrical wiring drawings.
This violation is described in NRC Inspection Report 86053 as I
item 86053-Olb, and was included in IP's Final Report to the NRC concerning 50.55(e) Notification 55-86-04..
I.
Admission or Denial of the Violation i
IP. admits that this violation occurred as stated in the :
j; Notice of Violation. ;
p
___..m_
. _. _. _.. _ ~
m.
-1..
2 II.
Reasons for the Violation The reasons for this violation are described in i
Attachment B to.IP's.0ctober 7, 1986 Final Report (U-600716) on.10CFR50.55(e)' notification 55-86-04.
Essentially, this violation resulted from issuance of a j
Field Engineering Change Notice (FECN) which was not translated onto appropriate drawings.
)'
III. Steps Taken to Correct the Problem and Results Achieved Change documents were issued against drawings affected by the FECN to eliminate incorrect information. NSED and f
' Plant Technical personnel received training on Configuration Management. Other ECNs and FECNs related l
to MOVs were reviewed against MOV K-Specs to ensure that they are appropriately posted or incorporated on affected l
documents. IP has confirmed that these actions are l
complete.
I IV.
Corrective Steps to Avoid Further Violations 5
On August 27, 1986, a task force was established to identify any areas of concern regarding MOVs and root 1 causes of problems in these areas, and actions are'being i
taken on these recommendations to prevent future MOV
]
problems from arising. This effort is described in Attachment B to IP's Final Report on 10CFR50.55(e)
}
Notification 55-86-04, dated October 7, 1986 (U-600716).
Further actions taken by IP.are described in Section 3 of Attachment A.
In addition, ECNs and FECNs are now-reviewed by NSED to ensure that testing and configuration management requirements are implemented.
IP management will continue to monitor progress in this-area to ensure that further violations do not occur. The-NRC closed this item in Inspection Report No. 86077.
V.
Date When Full Compliance Will be Achieved IP is currently in compliance.
l i
A3.
The Notice of Violation states in part:
l Contrary to (10CFR 50,. Appendix B, Criterion III], design:
control-measures did not ensure that the design bases for structures, systems and components were correctly l
translated into drawings, procedures and instructions.
Specifically:
The design bases for flood protection of the circulating water screenhouse was not correctly translated into specifications, drawings, procedures.-and-instructions in i
I*
l L
that Shutdown Service Water -(SSW) system valves ISX011A and ISX011B and the SSW system equipment in the Division II pump cubicle, located below the maximum probable flood level in the circulating water screenhouue, had not been protected against the effects of flooding as described in FSAR Sections 9.2.1.2.3 and 3.4.1.1.
A construction opening, a manway, and four piping penetrations would have allowed water into the.screenhouse, directly.
affecting the operability of the SSW system equipment.
I This violation was described in NRC Inspection Report Nos.
j 86048 and 86054 as item 86048-03, and was the subject of an IP j
notification to the NRC-on August 28, 1986 pursuant to 10CFR50.55(e) (55-86-06).
I.
Admission or Denial of the Violation.
i IP admits that this violation occurred as stated in the Notice of Violation.
4 l
II.
Reasons for the Violation The reasons for this violation were described in IP's presentation to the NRC on this issue on August 29, 1986 and in IP's' Final Report for 10CFR50.55(e) item 55-86-06, i
submitted on November 24, 1986 (U-600765). They include:
I i
a.
The impact of flooding was not adequately accounted for in determining area-related design attributes.-
b.'
Security system work items (including installation of a non-floodproof manway cover) were performed under an MR rather than an MWR per Revisions 8 and 9 of 1
CPS Procedure 1029.01, " Preparation and~ Routing of Maintenance Work Requests." -Procedure 1029.01 was j
deficient in that it specified that all security -
i related work would be performed under MRs, which do j
not require the same levels of control as MWRs for safety-related work. This allowed items to be I
worked without being subject to controls' ordinarily applied.to safety-related work,' including QA/QC review.
c.
There was insufficient attention paid in the I
commodity turnover program concerning area-related:
design-attributes that could impact design bases or hazards analyses that are not associated with a l
particular system (however, other aspects of the commodity turnover system were adequate).
t f
4 --
g
.. _.... ~ _ -
,~..-
i III. Steps Taken to Correct the Problem and Results Achieved ECNs, Plant Modifications, Condition Reports, and-Nonconforming Material ~ Reports were issued, and work was performed to render the circulating water screenhouse floodproof. IP has confirmed that these actions are complete.
IV.
Corrective Steps to Avoid Further Violations IP prepared and implemented an extensive investigation plan to determine che extent of any floodproofing deficiencies and to determine whether the procedures
-governing work document development and review could be improved to assure that design requirements are incorporated into the work document. A 100% review of Security MRs was perforned to identify MRs that should have been performed under controls applicable to safety-related work. The recommendations resulting from this investigation and review were implemented, including revisions to procedures and instructions for preparation, routing and review of MWRs. These revisions ensure that safety-related work is performed under appropriate controls, including proper QA/QC review. These actions were more fully described in IP's presentation to the NRC on August 29, 1986, in IP's Final Report on 10CFR50.55(e) i Notification 55-86-06, submitted to the NRC on November 24, 1986 (U-600765), and in IP's supplemental Final Report on this item dated January 26, 1987 (U-600825).
Based on these reports, the NRC, in Inspection Report No.
87002, concluded that "the licensee's corrective actions had been completed;... and that the licensee's corrective actions had addressed both the specific and the generic implications of the identified deficiency."
IP has confirmed that these corrective steps are complete.
Other actions taken by IP to improve performance in the areas of maintenance and modifications are described under Sections 1 and 2 of Attachment A.
V.
Date When Full Compliance Will be Achieved IP is currently in compliance.
B.
Violations of Criterion V-Bl.
The Notice of Violation states in part:
Contrary to [10CFR Part 50, Appendix B, Criterion V),
activities affecting quality were not adequately accomplished in accordance with the prescribed procedures. Specifically: '
Although Section 8.1.3 of Procedure CPS 1005.06 requires analyses be performed to support any statements made on
~ the safety evaluation form, including the bases for the determination that the change, test, or experiment does not involve an unreviewed safety question, licensee personnel did not document the bases for the conclusion that no unreviewed safety question existed for modifications DG-24 and SX-12.
This violation was described in NRC Inspection Report No.
86053 as item 86053-02d.
I.
Admission or Denial of the Violation.
IP admits that this violation occurred as stated in the Notice of Violation.
II.
Reasons for the Violation The reason for this problem was failure of personnel to adequately follow CPS Procedures requiring documentation of reasons why the proposed modification did not present an unreviewed safety question.
III. Steps Taken to Correct the Problem and Results Achieved Modifications DG-24 and SX-12 were rereviewed and the-basis foc concluding that no unreviewed safety question was presented has been documented. Procedure changes have been implemented to require greater detail in documentation and improve the quality of these reviews. IP has confirmed that these actions are complete.
IV.
Corrective Steps to Avoid Further Violations IP has implemented a series of actions to improve its modifications process and documentation included in modification packages. These include:
Procedures were changed to provide more specific documentation requirements for modification packages, including more specific acceptance criteria by NSED, more thorough test procedure definition by Plant Staff, and subsequent review of test results. Prior to implementation of'these procedure changes and associated training, a review was performed by the Startup Joint Test Group of modifications which were made after preoperational testing had been completed.
Modification packages are currently reviewed by the Configuration Management Group for adequacy of documentation. __
L' An in-line review of quality-related modification packages is performed by QA to confirm that quality program requirements are being adhered to.
In addition to the normal training for performing 10CFR50.59 reviews, many NSED and Plant Staff personnel have received supplemental ~ training to help improve the quality of reviews performed-pursuant to 10 CFR 50.59.
IP has confirmed that these actions have been or are being implemented. These and other actions were described to the NRC in the September 19, 1986 management meeting; the December.19, 1986 enforcement conference; and in IP's January 28, 1987 Final Report-on 10 CFR 50.55(e) item 55-86-10 (U-600829). IP's generic program for improving performance in the area of modifications I
and post-modification testing is described in Section 2 of Attachment A.
In Inspection Report No. 86077, NRC~
concluded that IP had corrected the deficient safety evaluations and had prepared adequate training lesson plans, but left this violation open pending further NRC review of the effectiveness of the training.
V.
Date When Full Compliance Will be Achieved IP is currently in compliance.
d B2.
The Notice of Violation states in part:
Contrary to [10CFR Part 50, Appendix B, Criterion V]
activities affecting quality were not adequately accomplished in accordance with the prescribed procedures. Specifically:
Although Section 8.1.13.2 of Procedure CPS 1003.01 requires testing documentation to be attached to the Plant Modification Package, licensee personnel failed to place test results in the modification package for seven modifications (PR-11, AP-12, SX-12, HP-17, RH-17, DG-24, and DG-39) performed between March 26 and August 5, 1986.
This violation was described in NRC Inspection Report No.
86053 as item 86053-02e, and was the subject of an IP notification to the NRC on September 19, 1986 pursuant to 10CFR50.55(e) (55-86-10).
[
I.
Admission or Denial of the' Violation.
IP admits that this violation occurred as stated in the Notice of Violation. 4-
'I*
~
II.
Reasons for the Violation-The reasons for this violation were described in IP's January 28, 1987, Final Report to the NRC concerning 10CFR50.55(e) Notification 55-86-10 (U-600829). They l
1 are:
I-a.
Plant Technical and Supervisory reviews failed to identify the inadequate testing.
7; b.
Tais was the result of inadequate-training of Plant Staff and NSED personnel.who specified, directed and reviewed the documentation of the' testing' associated t
with plant modifications..
I III. Steps Taken to Correct the Problem and Results Achieved 1
I The Joint Test Group (JTG), which is ordinarily responsible for review of preoperaticnal test procedures-and results, reviewed modifications.which were made after preoperational testing'was completed (including the seven listed in this. violation) to determine the adequacy of acceptance criteria and. testing for those modifications.
Those modifications requiring additional testing or-documentation were identified and any needed. testing or documentation was performed. IP has confirmed that these actions are complete.
i IV.
Corrective Steps to Avoid Further Violations a
1.
Training was given to NSED and Plant Technical personnel on test requirements, acceptance criteria, documentation of testing, and data package review techniques.
i b
2.
The procedures-governing the modification process l
were revised to require more specific acceptance criteria by NSED, more thorough-test procedure definition by Plant Staff,'and subsequent test.
j results review. Procedures were also revised.to-incorporate an in-line QA review of quality-related modification packages to confirm that quality i
program requirements are being' adhered:to.
3.
A test engineer:(formerly with the Startup Test.
Results Review Group) was temporarily assigned.to the Configuration Management Group to review
. completed modifications and ensure consistency'in documentation of post-modification testing until NSED/ Plant Technical personnel completed training and no longer required assistance. The Configuration Management Group now reviews all completed modifications, and Plant Staff Technical or NSED personnel review all~ post-modification testing.
- 1
....a
~ _ _ _..... _ _.....,....
o
~
These and other actions which will preclude recurrence of problems in this area were' described to the NRC in the management meeting held on September 19, 1986; the enforcement conference held on December 18, 1986; and in IP's Final. Report on 10CFR50.55(e) Notification 55-86-10,' submitted on January 28, 1987. IP's generic actions in the area of modifications and post-modification testing are described in Section 2 of Attachment A.
The NRC closed this item in Inspection Report No. 86077.
V.
Date When Full Compliance Will be Achieved IP is currently in compliance.
4 33.
The Notice of Violation states in part:
Contrary to [10CFR Part 50, Appendix B, Criterion V],
I activities affecting quality were.not adequately accomplished in accordance with the prescribed procedures. Specifically:
CPS Procedure GTP-55 was found to be inadequate.to ensure that valve stem threads were completely lubricated in that some threads cannot be checked because they are within the valve operator or are lubricated through a-fitting.
This violation was described in NRC Inspection Report No.
86053 as item 86053-02a.
I.
Admission or Denial of the Violation IP admits that this violation occurred as stated in the Notice of Violation.
II.
Reasons for the Violation This violation resulted from failure of plant procedures to include provisions for examination and lubrication of valve stem threads.
III. Steps Taken to Correct the Problem and Results Achieved An MWR was issued for lubrication of valve stems on safety-related Motor Operated Valves (MOVs). Work pursuant to this MWR was completed in October 1986, Revisions were made to CPS maintenance procedures to provide special instructions for lubrication of valve J
stems, including stems not exposed by removal of the stem protective cover or requiring lubrication through a fitting. IP has confirmed that these_ corrective actions are complete.
IV.
Corrective Steps to Avoid Further Violations As noted above, procedure revisions were implemented to ensure that lubrication of valve stems _ is properly performed. As described _in Section 3 of Attachment A, IP has undertaken a series of actions to provide assurance that motor operated valve problems will not occur during CPS operation. In addition, IP's Maintenance Improvement Program, described in Section 1 of Attachment A, will provide assurance that. inadequacies in maintenance procedures are detected and corrected.
The NRC closed this item'in Inspection Report No.,86077.
V.
Date When Full Compliance Will Be Achieved IP is currently in compliance.
C.
Violations of Criterion XI C1.
The Notice of Violation states in part:
Contrary to [10CFR Part 50, Appendix B, Criterion XI] the test program did not demonstrate that systems would perform satisfactorily or that all prerequisites for a given test had been met.
Specifically:
Post Maintenance testing did not identify that a modification to 17 valves resulted in the limit switches being set backwards.
This resulted in the failure of one of the 17 valves, t
This violation was described in NRC Inspection Report No.
86053 as item 86053-03a.
I.
Admission or Denial of the Violation IP admits that this-violation occurred as stated in the Notice of Violation.
II.
Reasons for the Violation The reason for this violation was the failure of valve switch operation in the " Test" position to reveal the valve operability problem which would exist during 1
" Normal" operation.
This was the result of an individual who improperly reset contact rotors during MOVATS testing.
, 4
' I '-
l III. Steps Taken to Correct the Problem and Results Achieved IP initially discovered this problem. - The technician who improperly reset the rotors was terminated. The rotors of all of-the MOVs. involved were reset and have been retested. The MOVs now operate properly. In addition, a comprehensive post maintenance test is being performed on safety-related MOVs, with switches in both the " Test"~and
" Normal" positions, training on lessons learned on MOVATs i
was given, and MOVATS procedures were revised to ensure proper switch settings..
1 In NRC Inspection Report.86053, it is noted that "The licensee had responded adequately to the switch setting problem at the time of the inspection, including a comprehensive post maintenance test requirement that i
should detect the type of problem noted above before a valve is declared. operable."
IV.
Corrective Steps.to Avoid Further Violations IP has undertaken extensive corrective action both to resolve this particular issue and to improve MOV j
performance at CPS generally, including appointment of an j
MOV Task Force to identify problems in MOV maintenance i
and testing, and creation of an MOV maintenance testing group headed by a supervisor. This activity is described in Section 3 of Attachment A.
Also, IP has undertaken
[
activities which have substantially improved the quality of post maintenance and post-modification testing, as described in Sections 1 and 2 of Attachment A.
These actions were described in detail at the management meeting with the NRC on September 19, 1986; at'the 4
enforcement conference on December 18, 1986; in IP's October 7,.1986 Final Report on 10CFR50.55(e) item 4
55-86-04 (U-600716); and in IP's December 30, 1986-(U-600803) and March 17, 1987 responses to SALP 6 (U-600860). The NRC closed this item in Inspection Report No. 86077.
f V.
Date When Full Compliance Will be Achieved IP is currently in compliance.-
4 C2..The Notice of Violation states in part:
Contrary to [10CFR Part 50, Appendix B, Criterion XI],
the test program did not demonstrate that systems would perform satisfactorily or that all prerequisites for a given test had been met.
Specifically:
I -
r
,-...,-w m-,
,a
,a e-,
I*
Modification DG-24 for-the changing of a seal-in feature for the Diesel Generator start signal, was completed and released for operation on April 19, 1986, without acceptance criteria being identified or testing being performed to verify the adequacy of the modification.
In addition, nine other modifications (HP-06, PR-11,.AP-12, SX-12, SX-15, HP-17, RH-17, DG-35,.and DG-39) were completed and released for operation between March 26 and August 13, 1986, without acceptance criteria for verifying the adequacy of the modification. Although post-modification testing was performed in each instance, the lack of acceptance criteria precluded the evaluation of test results.
This violation is based on. facts described by NRC Inspection Report No. 86053 in items 86053-01c, -02e, and -03b.
The problem underlying this violation was also the subject.of an IP notification to the NRC on September 19, 1986, pursuant to 10CFR50.55(e) (55-86-10).
I.
Admission or Denial of the Violation IP admits that this violation occurred as stated in the Notice of Violation.
II.
Reasons for the Violation The reasons for this violation were described in IP's January 28, 1987 Final Report on 10CFR50.55(e) item 55-86-10 (U-600829). These were:
a.
NSED engineers were not adequately specifying testing requirements and acceptance criteria for plant modifications.
b.
Plant Technical and Supervisory reviews failed to I
identify the inadequate testing.
c.
(a) and (b) above were caused by inadequate training of the engineers and supervisors who specified, directed and reviewed the documentation of the testing associated with plant modifications.
III. Steps Taken to Correct the Problem and Results Achieved Prior to iritiation of the reviews which are now performed by NSED/ Plant Technical,:the Startup Joint Test Group reviewed modifications made after preoperational testing had been completed to determine whether *esting and documentation for these packages were adequare, and actions needed to bring these modifications into conformance with requirements were performed. Each of
.the modifications at issue in this violation was reviewed and any required testing and additional documentation
- ~
were supplied as necessary. IP has confirmed that these actions are complete.
.L..
IV.
Steps Taken to Prevent Further Violations Training has been held.for NSED and Plant Technical i
personnel, and proceduras have been reviewed and revised, including addition of' requirements for stricter
. acceptance criteria for modifications, more detailed test instructions, and an in-line QA review of quality-related modification packages. A test engineer (formerly with the Startup Test Results Review Group) was temporarily assigned to the Configuration Management Group, which now 2
reviews documentation of completed modifications, until NSED/ Plant Technical' personnel completed training in this area and no longer required assistance.
IP has reviewed these corrective actions and has
~
confirmed that they are complete. These actions and l
others were described in detail during IP's meetings with the NRC on September 19, 1986,' and December. 18, 1986, and in IP's January 28, 1987 Final Report on 10CFR50.55(e) item 55-86-10 (U-600829). The generic actions IP has taken in the area of modifications and post-modification NRC closed noncompliances 86053-02e and 86053-03b in. The testing are described in Section 2 of. Attachment A.
j Inspection Report No. 86077 (noncompliance 86053-01c remains open pending further evaluation of the effectiveness of IP training).
l V.
Date When Full Compliance Will be Achieved k
IP is currently in compliance.
D.
Alleged Violations of Criterion XVI D1.
The Notice of Violation states in part:
j Contrary to [10CFR Part 50, Appendix B,-Criterion XVI],
r established measures to assure that conditions adverse to quality are promptly identified.and corrected were not adequately implemented. Specifically:
The torque switch limiter plates of 36 safety-related valves were improperly modified during the first_six months of 1986 without adequately determining the cause of the low thrust output found during testing..The-low-thrust values were later found to be in error and the modification was not actually necessary..
4 l-This violation was described in NRC Inspection Report No, 85053 as item 85053-04a.- The problem underlying this j
violation was also described in an IP notification to the NRC1 i
pursuant to 10CFR50.55(e) on July 15, 1986 (55-86-04).
a f
f 1 a
w...
e,
.,,w,,
e
,, - - 4 v.,
y
,e
-,m,,-,m.
.-w
4.-
I.
Admission or Denial of the-Alleged Violation IP admits that this violation occurred as stated in the Notice of Violation.
II.
Reasons'for the Violation The reasons for this violation are listed under section A.I.II above.
III. Steps Taken to Correct the Problem and Results-Achieved See A.I.III above.
IV.
Corrective Steps to' Prevent Further-Violations See A.I.IV above. The NRC closed this item in Inspection Report 86077.
V.
Date When-Full Compliance Will Be Achieved i
{
IP is currently in compliance.
4 1
?-
D2.
The Notice of Violation states in part:
Contrary to [10CFR Part 50, Appendix B, Criterion XVI),
established measures to assure that conditions adverse to quality are promptly identified and corrected were not adequately implemented. Specifically:
Condition Report No. 1-85-10-091,. doted October 17, 1985, identified a deficiency in Field Engineering Change l
Notice (FEC'J) 12329 which changed the wiring i
configuration for MOVs; however, as of September 5, 1986 j
valve schematic drawings were still not corrected to preclude repetition of the problem.
This violation was described in NRC Inspection Report No.
86053 as item 86053-04d. The problem underlying this violation was also described in an IP notification to the NRC on July 15, 1986, pursuant to 10CFR50.55(e) (55-86-04)..
I.
Admission or Denial of the Violation IP admits that this violation occurred as stated in the Notice of Violation.
II.
Reasons for the Violation The reasons for this problem are described under item
'A.2.II above.
m
,-m,
=..
III. Steps Taken to Correct the Problem and Results Achieved The required changes to the valve wiring drawings have been made.
IV.
Corrective Steps to Prevent Further Violations IP has undertaken an extensive series of actions to improve CPS MOV performance, as described in Section 3 of Attachment A.
Also, a number of actions have been taken-to improve IP's identification and correction of problems. These actions include procedure revisions, event critiques, management meetings, and enhancements to trend analysis and root cause analysis. These actions were described to the NRC in IP's December 30, 1986, and March 17, 1987, responses to SALP 6, and are summarized in Section 4 of Attachment A.
IP will continue to implement these actions and believes that these actions will ensure future compliance. The NRC closed this item in Inspection Report No. 86077.
V.
Date When Full Compliance Will Be Achieved IP is currently in compliance.
D3.
The Notice of Violation states in part:
Contrary to [10CFR Part 50, Appendix B, Criterion XVI],
established measures to assure that conditions adverse to quality are promptly identified and corrected were not adequately implemented. Specifically:
The corrective action for Condition Report No.
1-86-06-001, dated May 19, 1986, for the unauthorized replacement of a motor, was found to be inadequate in that the corrective actions did not address contractor activities.
This violation was described in NRC Inspection Report No.
86053 as item 86053-04g.
I.
Admission or Denial of the Violation IP admits that this violation occurred as stated in the Notice of Violation.
II.
Reasons for the Violation Maintenance contractor support personnel replaced a 1/3 horsepower motor with a 1/2 horsepower motor. This occurred because the equipment (Containment Air Monitoring Assemblies) manufacturer had replaced the 1/3
, i
m
~.
.i..
'I h.p. motor-originally' supplied withja 1/2 h.p. motor and L
stated that the new motor would.be acceptable. To ensure that such unauthorized modifications would not continue,
~
h
.NSED revised its own procedures for approval of' modifications. The contractor took specific action to i
verify the acceptability of the motor replacement, but generic corrective action was not'taken to assure.that
- this problem did not recur.
III. Steps Taken to Correct the Problem and Results Achieved 1.
An evaluation.was performed and itlwas determined that 4
the 1/2 horsepower motor would be acceptable. IP has confirmed that this action is complete.-
i IV.
Corrective Steps to Avoid Further Violations i
Maintenance contractor personnel received training
.u stressing that work performed must be properly authorized Plant Modification requirements must be iL complied with,' commitments to configuration control must be met, and work must be properly executed (including adherence to procedures and Standing Orders). IP has confirmed that this action is complete. In addition, f
both routine ongoing training and new hire orientation i
for maintenance contractor personnel stress'like-for-like replacement philosophy and-increased attention to configuration control. IP has also instituted a number of generic actions to improve prompt identification and correction of problems and strengthen controls on the modification process. These actions are described in Sections 2 and 4 of Attachment A.
V.
Date When Full Compliance Will Be Achieved, i
IP is currently in compliance.
h j
D4.- The Notice of Violation states in part:
h Contrary-to [10CFR Part 50, Appendix B, Criterion XVI, 1
established measures to assure that conditions adverse to quality are promptly identified and corrected were not l
adequately implemented. Specifically:
i Condition Report No. 1-86-02-089, dated February 6, 1986, identified deficiencies in Procedure CPS 8227.01 for maintenance on the Standby Liquid Control Pump; however, as of August-28, 1986, the procedure had not been revised to provide adequate instructions.'
i t
This violation was described in NRC Inspection Report No.
86053 as item 86053-04c.
4 t 4
.---..e.,r-
-,. --~
y,r..,-.,
y
,rm.
y,,,e
.m.,
--,,,.r__.
y 4
m n-
,,p,
I.
Admission or Denial of the Alleged Violation IP denies that the violation occurred as stated in the Notice of Violation.
Condition Report No 1-86-02-89, dated February 6, 1986, pertains to a change in oil in the crankcase of the Standby Liquid Control (SLC) pump' pursuant to MWR No.
B15099. The job step description section of MWR B15099 references Procedure CPS 8227.01 and specification K 2801-0019, both of which specify use of SAE 20 weight oil. However, the workman who performed the oil change pursuant to MER B15099 was directed by his supervisor to use DELVAC 1 lubricant instead of SAE 20 weight oil (the use of DELVAC 1 lubricant had been previously approved by NSED).
Condition Report No. 1-86-02-089 was initiated by the workman who performed the oil change under MWR B15099.
The " Description of Condition" in this report states as follows:
Given MWR B15099 to change oil in pump IC41C001B [in accordance with] CPS 8227.01 and K 2801-0019. Both the procedure and the K-spec indicate use of SAE 20 When this was pointed out to [the supervisors.] we were told to use DELVAC 1.
We requested to get a change to the procedure thru (the supervisors] and were told no, it does not need to be changed.
Procedure CPS 8227.01 did not address work steps for changing crank case oil; instead it specified the use of SAE 20 weight oil for lubricating packing and sliding parts during maintenance. Nevertheless, in order to avcid possible confusion in this area, Procedure CPS 8227.01 was revised on May 31, 1986 to provide for the use cf DELVAC 1 oil, or its equivalent. Based upon the revision, Condition Report 1-86-02-089 was closed on June 9, 1986. A subsequent revision to CPS 8227.01 changed that procedure to require using the lubricant specified in the NSED Approved Lubricant List and to specify the amount of lubricant.
Thus, contrary to the Notice of Violation, Condition Report 1-86-02-089 does not identify deficiencies in Procedure CPS 8227.01, but instead identifies a condition in which a workman was directed to use a different (but approved) lubricant _than that specified in Procedure CPS 8227.01. Ta clear up any possible confusion in this area, Procedure CPS 8227.01 was revised. This procedure revision was approved approximately three months prior to the August 28, 1986 date specified in the Notice of Violation.
It may be noted that Procedure CPS 8227.~ 01 currently does not describe or address the steps for changing the oil in the crankcase for the SLC pump. This process is within the skill-of-the-craft and need not be specified in procedures.
II.
Reasons for the Violation Not Applicable.
III. Steps Taken to Correct the Problem and Results Achieved Not Applicable.
IV.
Corrective Steps to Avoid Further Violation Not Applicable. The NRC closed this item in Inspection Report No. 86077.
V.
Date When IP will be in Compliance IP is currently in compliance.
In addition to the responses required by 10CFR2.201, the letter accompanying the Notice of Violation requests that IP direct its response to three areas. First, IP is requested to " confirm the completeness of the actions you have taken to correct the violations cited in the Notice as well as additional examples of similar problems described in the subject inspection reports." As noted under the responses given above for each of the violations described in the Notice of Violation, IP has confirmed the status of completion of these corrective actions.
IP has also confirmed the status of completion of corrective actions described in the attached Table 1, which lists the corrective actions being taken in response to violations which were noted in Inspection Report Nos. 86048, 86053 and 86054, but which were not included in the Notice of Violation. Confirmation of the status of completion of corrective actions was achieved by having each IP department confirm the status of completion of those corrective actions for which it was responsible. The methods used by these departments for confirming status of completion of' corrective actions were as follows:
a.
Where procedure changes were made, the responsible department examined the procedures in question to verify that these changes were in fact made, b.
Where training was conducted, the responsible department reviewed written records of' training to verify that.such training was in' fact performed.-
c.
Where organization changes were made, the responsible department reviewed documentation and/or interviewed personnel to verify that these changes were implemented. J
~
d.
Where other action was taken (e.g., a series of drawings revised, rewiring performed, or modification packages supplemented), the responsible department either reviewed the hardware or documentation involved to verify that the action had been performed. or. where large numbers of items were involved,-reviewed a random sample of the items to verify that the. action had been performed.
In addition, IP's Quality Assurance department has reviewed a' sample of the corrective actions to verify their completeness. Thus, the status of completion of IP's corrective actions has been confirmed.
Second, the l'etter requests that IP " confirm how you have changed or strengthened the implementing procedures to preclude similar violations in these subject areas during future modification or maintenance activities." Th6 changes and improvements made to implementing-procedures to preclude future violations are described under part'IV.of IP's response for each of the items above. Generic improvements IP has made or is in the process of making to implementing procedures to preclude violations in the areas of maintenance and modifications are described in Sections 1 and 2 of Attachment A.
Finally,' the letter accompanying the Notice requests that IP " confirm the steps you have taken to ensure that continuing att tion by management will be provided to prevent the recurrence of these kinds of failures." The steps of this kind which management has taken, as they relate to particular violations, are. described in part IV of the response to each violation. In addition, the generic programs which IP
~ [
management has initiated and will continue to' implement in the. areas in
]
which the violations occurred are described in Attachment A.
In particular, the actions which have been taken to ensure that potential problems are quickly brought to IP management's attention are described 4
in Section A of Attachment A.
IP believes these actions will ensure that management attention continues to be focused in these areas.
i 5
k i
e l
l.
a 6
l i
I Attachment B Table 1 IP Responses to Problems Noted in IE 86048, 86053, and 86054 but Not Included in The Notice of Violation Item No.
Description IP Corrective Action Closure Status 86-48-02 MWR C06466, covering work MWR C22363 was written and Closed by NRC Criterion V performed on annunciators, was performed to complete the work in Inspection Severity signed off as completed by omitted from MWR C06466.
Report 86060, Level IV maintenance technician and Following completion of work dated October maintenance supervisor when work under MWR C22363, a functional 17, 1986.
required by the MWR had not been test was completed demonstrating completed.
the operability of the annunciators worked on. The personnel who signed-off on MWR C06466 ware counseled on proper completion and review of MWRs, and control and instrumentation personnel who perform work under MRRs have been trained to stress following MWR job steps as written and seeking supervisory help if questions arise.
Supervisory personnel were trained on thorough review of MWRs.
86-48-01 Contrary to FSAR requirements, IP explained to KRC that Closed by NRC Deviation independent verification of verification of valve lineups in Inspection system lineups was not required was done only on major flow Report 86064, by procedures for all equipment paths in order to maintain dated October important to safety. In personnel radiation exposure 15, 1986.
particular, ir. dependent position ALARA. Flow paths not required verification was provided for for system emergency function, only 19 of approximately 53 such as drain lines, vent lines, valves in the Low Pressure Core and flush lines, are checked by Spray System. In addition, other means, such as system discrepancies existed between pressure checks. The CPS FSAR system valve lineups such that has been revised to clarify this valves of similar function approach. One LPCS valve required independent previously independently verification in one ECCS system verified during RHR alignment and not in the other.
verification will now also be independently verified under LPCS verification.
- a e
- 3 Item No.
Description IP Corrective Action Closure Status 86-53-02b Unqualified wire and a missing MWR C10294, closed 9/25/86, Closed by NRC Criterion V conduit plug were not detected visually checked exposed areas in Inspection during environmental of each safety related MOV and Report 86077, qualification walkdowns or operator for any deleterious dated March 26, during conduct of maintenance conditions, and corrections were 1987 procedure 8451.03.
made to the conditions found.
Additionally, Procedure 8451.01 for Preventive Maintenance added inspection criteria for MOVs.
Unqualified wire was identified in 3 valves and was corrected (see item 86-46-07). A part 21 investigation concluded that this was not a reportable condition. The Part 21 issue was closed in inspection report 86-67 86-53-04b Failure to correct violation of HWR C31377 was issued to post Closed by NRC Criterion CPS 8106.01, which requires hand hand signal signs. MWR was in Inspection KVI signals to be conspicuously clored 9/23/87.
Report 86077, posted (hand signals were not dated March 26, posted as required during heavy 1987.
load landing).
86-53-02c Failure to document torque MWR C05813 and C18057 contained Closed by NRC Criterion V values af ter performing MWR Nos specific torque values per CPS in Inspection C22713, C05183, and C18057, 8492.01 and General Electric Report 86077, which required bolt torquing.
(GE) Torque Specifications. CPS dated March 26, Lack of material accountability 8492.01 has been revised to
and recording of the specified torque valves. MWR C22713 pertained to a bolted flange connection which did not require torquing per Specification K-2882 and Field Change Request 3477. This flange was required only to be snug tight. Quality Control has verified the torquing of the bolts identified in the first two MWRs and the tightening of the bolts identified in the third MWR. At the time work pursuant to MWR C06655 was performed, the storeroom issued materials such __
r:
'e.
~
e *. ;- to.
e Iten No.
Description IP Corrective Action Closure Status as bolts, nuts and washers in the received unit of purchase.
- An actual count of the items was made only on return of unused portions. This practice has been revised to allow personnel to withdraw the quantity needed.
to perform the work,'which will provide more accurate accountability of material.
85-53-04e Failure to evaluate root cause See response'to iten Al in' text.-
Close'd by NRC Criterion and take corrective actions Also, torque values for the in Inspection XVI regarding problems identified in packing adjustments on MDVs-Report 86077, Criterion V MWR No. B31775 (related to have been obtained from the dated March 26, modification of torque switch vendors and been incorporated 1987.
limiter plates on HDVs).
~into CPS procedure 8451.01. In addition MWR C28300 was issued to assure that no safety related MOV packing had been adjusted past the maximum allowed valve.
This MWR was completed 1/29/87.
CPS 1029.01 has been revised to require a full description of all work performed and the conditions found in sufficient-detail to reconstruct the work performed or conditions found.
This description will allow for more accurate assessment of failures.
86-53-04f Failure to evaluate root cause of The original stem wobble was' Closed by NRC Criterion wobble of valve in MWR No.
examined by both maintenance in Inspection XVI B24239.
supervisors and a Technical
-Report 86077,-
staff engineer. Acceptability dated March 26, was not documented on the MWR;-
- 1987, however it was annotated as "OK" by the engineer on the MDVATS' Test Data Sheet. There were no degradations observed in the MDVATS signatures as noted on the documentation. The stem wobble has since been evaluated
.as satisfactory by NSED and the valve manufacturer. ~
e,.b e
0 *.o
'O Item No.
Description IP Corrective Action Closure Status 86-54-04 Failure to write Condition IP issued Condition Report Closed by NRC Criterion Report (CR) providing for
- 1-86-09-083 on September 10, in Inspection
- KVI, evaluation of cause of 1986. This CR addressed the Report 86065, Severity installation of unauthorized installation and removal of the dated November Level IV steel plate surrounding Low steel plate as well as the 26, 1986.
Pressure Gas Spray outboard potential operability status of containment isolation valve.
the LPCS valve. In addition, SWEC supervisory and management personnel having responsi-bilities in activities involving work authorization attended training emphasizing that work shall be properly authorized, including awareness of Plant Modification requirements, commitments to configuration
-control, and procedures governing execution of work (including adherence to Standing Orders). A Standing Order has been issued to supervisors directing that they be aware of other equipment in work areas and potential impact on that equipment. The CPS Plant Manager issued a letter to Plant Staff personnel stressing requirements of adhering to procedures for reporting indeterminate or adverse conditions.
s/Pll*
O Attachment C Illinois Power Company's Answer to Proposed Imposition of Civil Penalty (EA-87-11)
The Notice of Violation and Proposed Imposition of Civil Penalty describes 12 items which allegedly violate one of four criteria of Appendix B, and states:
Collectively, the above violations have been categorized as a Severity Level III problem (Supplement II).
Cumulative Civil Penalty - $75,000 assessed equally among the violations.
The letter accompanying the Notice of Violation and the Proposed Imposition of Civil Penalty states that:
The base value of a civil penalty for a Severity Level III problem or violation is $50,000.... Because of the multiple examples of violations in these functional areas, the base civil penalty has been increased by 50 percent.
A.
IP has taken Prompt and Effective Action to Prevent Recurrence of these Types of Violations and the Base Civil Penalty Should Therefore Have Been Mitigated by 50%
Appendix C of 10CFR Part 2 states that civil penalties may be reduced by as much as 50% for unusually prompt and effective corrective action. One-half of the items listed in the Notice of Violaticn concern problems related to motor operated valves (MOVs). As recently as December, 1986, the NRC's Office for the Assessment and Evaluation of Operating Data (AEOD) reported that MOV problems are widespread and recommended a major industry effort to improve MOV performance and reliability. Also in December 1986, the NRC's Executive Director of Operations requested that the Nuclear Utility Management & Resources Committee (NUMARC) initiate industry programs to resolve MOV problems. IP took aggressive action well in advance of these requests to resolve potential MOV problems at CPS. For example, IP's MOVATS program was established in 1985 (the first year this technology was known) and implemented to provide assurance that MOV problems would be solved prior to plant operations. When other MOV concerns arose in the summer of 1986, IP not only corrected the individual problems, but, as described in Section 3 of Attachment A, formed a multidisciplinary MOV Task Force which concluded an extensive review, identified further problems for resolution, and made a number of recommendations which are being implemented to improve MOV performance and reliability at CPS. ]
E p.As G
.o o-In addition, as noted in Attachment B, corrective action has been completed for each of the violations described in the Notice. IP responded vigorously to these violations by initiating and implementing extensive, detailed programs in the areas of Motor Operated Valves, Maintenance Improvement, Post Maintenance Testing, Post Modification Testing, and Identification and Correction of problems.
In these areas, reviews, retraining, procedure revisions and management and organization changes have been made to improve IP's performance, as described in Attachment A.
These actions were also described to the NRC at the September 19, 1986 management I
meeting; the December 18, 1986 enforcement conference; in IP's submittals in connection with 10CFR50.55(e) items 55-86-04 and 55-86-10; and in IP's responses to SALP 6.
IP continues to implement these actions and remains committed to improved performance in these areas.
In view of the promptness and effectiveness of these actions, IP believes that the base civil penalty should be mitigated by 50%.
B.
IP Believes that the NRC's Proposed 50% Increase Over the Base Civil Penalty was Inappropriate 10CFR Part 2, Appendix C, Supplement 2, provides that the NRC may collectively categorize a number of less serious violations as Severity Level III.
In this case, the Notice of Violation states that " Collectively, the above violations have been categorized as a Severity Level III problem."
10CFR Part 2, App. C, section V.B.5 allows the base civil penalty to be increased where there are multiple instances of a violation. With respect to the civil penalty proposed to be levied upon IP, the NRC also apparently relied upon this section; the letter accompanying the Notice states:
"Because of the multiple examples of violations in these functional areas, the base civil penalty has been increased by 50%."
IP submits that it is inappropriate to double-count the violations in this fashion. The number of violations was already considered in determining that the listed violations constituted a Severity Level III problem. Thus, the number of violations should not be used again as a basis for increasing the base civil penalty for the Level III problem. IP therefore believes that the proposed 50% increase over the base civil penalty is inappropriate.
1 i