U-601040, Responds to NRC Re Violations Noted in Insp Rept 50-461/87-31.Corrective Actions:Requirements of Tech Specs Matched Against Procedures on one-by-one Basis to Ensure All Requirements Included in Procedures
| ML20235T992 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 09/21/1987 |
| From: | Spangenberg F ILLINOIS POWER CO. |
| To: | Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| U-601040, NUDOCS 8710130314 | |
| Download: ML20235T992 (8) | |
Text
.,
U-601040 L30-87(09-21)-L-ONO ILLINDIS POWER COMPANY CLINTON POWER STATION, P.O. BOX 678. CLINToN. ILLINOIS 61727 September 21,-1987-Docket No. 50-461 Mr. A. B. Davis Regional Administrator Region III U.S.' Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137
Subject:
Response.to the Notices of Violation in Inspection Report 50-461/87031, dated August 21, 1987
- 1 Iq
Dear Mr. Davis:
i l
This is in response to your letter dated' August 21, 1987, which contained Inspection Report 50-461/87031. The cover letter requested a written response regarding the actions implemented to correct deficiencies identified as violations of Clinton Power Station's l
Technical Specifications. Attachment A to this letter provides Illinois j
Power Company's response to this request. The Inspection Report also i
details certain activities which appeared to be in violation of NRC l
requirements. Attachments B-E to this letter provide Illinois Power Company's responses concerning these violations.
I trust that these responses are adequate to demonstrate compliance with KRC requirements.
Should you have any questions, please contact me.
Sincerely yours, 11 F. A. Sp ng berg, I' L
I Manager - Li ensing $ d Safety CAC/krm Attachments cc:
B. L. Siegel, NRC Clinton Licensing Project Manager NRC Resident Inspector Illinois Department of Nuclear Safety SEP 24 gggy 8710130314 870921 PDR ADOCK 05000461 d U\\
M G
PDR i
~
l 5
l
Attachment A Illinois Power Company Clinton Power Station The NRC [[letter::05000461/LER-1987-043, :on 870724,reactor Scram Occurred as Result of Turbine Control Valve Fast Closure.Caused by Loose Connectors in Turbine Trip Vibration Detection Circuitry. Connectors Corrected Under GE Supervision|letter dated August 21, 1987]], states in part:
"A written response is requested regarding the actions you have implemented to correct deficiencies you identified as violations of your Technical Specifications. That response should identify what generic corrective actions you are taking to avoid further
.J violations of your Technical Specifications.
In addition, your response should identify the date when corrective-action is expected to be completed."
Corrective Actions Taken to Prevent Recurrence In the area of Radiation Protection, the requirements'of Technical Specifications have been matched against procedures on'a one-by-one l
basis to ensure that all requirements are included in procedures. A review of Inservice Inspection (ISI) requirements has also been.
completed for testing which must be performed on a 3 month, 6 month,.18 month or. cold shutdown frequency. The review of testing for refueling, 2 year and 5 year frequency is in progress. Additionally, an ISI program manual has been issued which requires revisions to procedures i
which implement ISI requirements to be reviewed by the Nuclear Station Engineering Department (NSED) ISI section prior to approval to assure l
that ISI requirements continue to be met.
)
Specific detailed training on the content and use of Radiation Protection Technical Specifications was presented to Radiation Protection personnel to ensure that they are aware of their responsibilities and knowledgeable of the Radiation Protection Technical Specifications. Training was also presented to the Maintenance Planners 1
to ensure that they are aware of their responsibilities and I
knowledgeable of the content of the Technical Specifications.
The Manager - Nuclear Program Coordination prepared a training outline which all managers presented to their personnel. This training stressed the professional integrity which workers at Clinton Power Station must carry to the job. A fundamental portion of this training stressed the importance of compliance with Technical Specifications and the individual's responsibility-to ensure that Technical Specification problems are identified and appropriately acted on.
Date When Full Compliance Will Be Achieved Illinois' Power is now in full compliance.
,(;
Attachment B Illinois Power Company Clinton Power Station The Notice of Violation states in part:
"Between March and July, 1987,' numerous discrepancies, thought to be limited to only ' housekeeping' items,' were identified by the licensee. The licensee failed to promptly correct conditions and/or failed to evaluate and document the discrepancies that had been identified during this period."
Corrective Actions Taken and Results Achieved During a Stone and Webster Engineering Corporation (SWEC) employee exit interview, an extensive list of potential problems and concerns was submitted to SWEC management.
The employee stated that parts of this list had previously been provided to management. The list was forwarded l
to Illinois Power Company (IP) for. resolution.
IP Scheduling and Outage Management (SOM), Quality Assurance (QA), Nuclear Station Engineering Department (NSED) and Plant Staff jointly prepared a corrective action plan to investigate and resolve the identified concerns..NSED performed an initial evaluation of the list to identify potential safety concerns.
A three-man walkdown team was established to physically validate the concerns.
Eighteen of the 497 concerns investigated required corrective action. These 18 concerns consisted of breaches in fire rated barriers.
Condition Report (CR) 1-87-07-023 was issued to initiate several corrective actions. A firewatch was immediately posted in accordance with procedure 1893.01 for all fire barrier concerns. A review of each fire protection-related concern was completed to ensure adequate compensatory measures existed to ensure timely fire suppression and detection (e.g., automatic fire detection, hose stations, fire extinguishers, automatic suppression, etc.).
This evaluation concluded that continued operation of the plant would not be adversely affected by the identified discrepancies. Maintenance Work Requests (MWRs) C08054, C40283 and C40270 were issued to rework gaps and penetrations.
Corrective Actions Taken to Prevent Recurrence The need to escalate safety-related concerns to management immediately was re-emphasized during SWEC Gang Box Training, GBTA-024, " Identifying Problems and Concerns". Additionally, SWEC personnel were requested to turn in any existing lists of discrepant items.
SWEC Training verified that all SWEC personnel had attended this training.
A document on the proper handling of lists was presented to SVEC l
management / supervisory personnel during the last week of August and first week of September 1987. This paper provided guidance on handling of lists and emphasized to management the importance of properly handling lists which could contain problems and concerns.
Date When Full Compliance Will Be Achieved Illinois Power is in full compliance.
I Attachment C
' Illinois Power Company Clinton Power Station The Notice of Violation states in part:
"On July 21, 1987, Valves 1C11-F155A, B, C, and D; IC11-F158A, B, C, and D; and 1C11-F361A were found to be missing their locking devices."
1 Corrective Actions Taken and Results Achieved After the NRC Resident Inspector identified the nine valves were not locked in place, the Operations Department immediately began verifying all of the accessible locked valves in the plant. All valves requiring a locking device were verified locked or were locked with a lock or lock wire. No valves were found to be out of position during this verification.
Corrective Actions Taken to Prevent Recurrence Plastic signs are being. hung on valves that are required to be locked in place. These signs identify the valves as locked valves in order to assure that any locks removed during maintenance and testing are properly replaced. The signs for many valves are currently in place.
The remaining signs will be hung prior to startup after the next j
maintenance outage.
Date When Full Compliance Will Be Achieved Illinois Power is now in full compliance.
l i
I i
{-
l
Attachment D Illinois Power Company Clinton Power Station The Notice of Violation states in part:
1.
"On June 4, 1987, Containment Isolation Valve IVR001A was identified as not having been demonstrated operable (the-required stroke time test had not been performed) prior to
}
entry into the applicable operating condition.
i 2.
On July 10, 1987, Containment Isolation Valve IVR001B was declared operable, while in the applicable operating mode, without demonstrating its operability by performing the required stroke time test."
Corrective Actions Taken and Results Achieved 1.
On May 31, 1987, Maintenance personnel began work on Maintenance Work Request (MWR) #C30675 to troubleshoot and repair valve IVR001A. Operations review of the MWR prior to beginning work identified one Post Maintenance Test (PMT) requirement to stroke the valve via performance of surveillance procedure 9064.03 in accordance with Technical Specification 6.1.8.2.
The MWR was worked and 9064.03 was successfully completed on June 2, 1987.
This action was noted in the Operations mode change restraint book, which Operations reviewed prior to entering Mode 2 at 0740 hours0.00856 days <br />0.206 hours <br />0.00122 weeks <br />2.8157e-4 months <br /> on June 4, 1987. The PMT sheet for MWR #C30675 was subsequently presented to the Assistant Shift Supervisor for sign-off at approximately 1430 hours0.0166 days <br />0.397 hours <br />0.00236 weeks <br />5.44115e-4 months <br /> on June 4, 1987. The PMT sheet identified the completion of 9064.03 and also identified the requirement to perform surveillance procedure 9061.03 to verify the isolation time of the valve in accordance with Technical Specification 4.6.4.1.
Operations had failed to identify this requirement during their initial review.
Upon verification by Operations that 9061.03 had not been completed, the valve was deactivated in the closed position in accordance with the appropriate Technical. Specification ACTION statement. Valve IVR001A would not open during efforts to perform 9061.03 subsequent to this event. Troubleshooting determined that a solenoid was not functioning in the valve actuator control circuitry. The solenoid was replaced, 9061.03 was performed satisfactorily and the valve was declared OPERABLE.
2.
On July 10, 1987, Maintenance personnel began work on the control and power circuit for valve IVR001B under MWR #C52962. The Assistant Shift Supervisor review of this MWR prior to beginning work did not identify the Technical Specification impact of the-work; therefore, an ACTION statement for a Limiting Condition of Operation (LCO) was not entered, as required by Technical Specification 4.6.4.1.
On July 15, 1987, the plant entered Mode 2.
Subsequently on July 15, 1987, a PMT sheet for MWR #C52962 was
1 presented to the Assistant Shift Supervisor for approval.
Operations review determined that the appropriate-ACTION statement for the LCO had not been entered and the valve.had not been j
declared INOPERABLE prior to beginning work. This resulted in the required PMT not being completed to declare valve IVR001B OPERABLE j
prior to entering Mode 2.
l Immediate action was taken to declare IVR001B INOPERABLE.
Surveillance. procedure 9061.03 was performed to satisfy the.PMT requirement and the valve was declared OPERABLE at 1944 on July 15, i
1987.
'l q
Corrective Actions Taken to Prevent Recurrence
]
j The Shift Supervisor (SS) wrote a Condition Report (CR) on June 4, 1987, l
detailing the missed PMT on.1VR001A;'however, he did not trigger the
'l critique process at that time. The CR was assigned to Operations'for investigation.
Subsequent review and investigation of the CR by the Assistant ~ Plant Manager - Operations identified the Technical Specification violation. A critique was held on June 24, 1987 and the event was identified as Licensee Event Report (LER)87-032. The Shift I
Supervisor involved was counseled by.the Assistant Plant Manager -
l Operations on the importance of promptly calling critiques when warranted. Operations personnel were trained on the need to identify all required PMTs to assure Technical Specification operability and to assure that required PMTs have been completed with acceptable results l
prior to initiating a plant mode change.
l On July 15, 1987, the SS initiated a CR on the Technical Specification violation involving IVR001B. A critique was held on July 15, 1987, and the event was identified as LER 87-039. The Assistant Shift Supervisor who failed to enter the LCO was counseled.
Immediate action taken to-preclude recurrence of this event required the Maintenance Planners to job-step a Shift Supervisor / Assistant Shift Supervfaor.PMT evaluation at the end of maintenance activities associated with Technical Specification Equipment / Components. During performance of the PMT evaluation, the Shift Supervisor / Assistant Shift Supervisor.is to j
identify all Technical Specification-related PMT requirements.. All identified requirements will be performed at the time or identified as a restraint in the affected System File. A procedure is currently in draft to formalize this process and is expected to be issued by November 15, 1987. Both Maintenance and Operations are being trained on the need to evaluate the impact of maintenance activities on the operability of Technical Specification equipment and the need to assure that all Post Maintenance Testing required to confirm operability has been identified and completed with acceptable results prior to returning equipment to 1
operable status. This training will be completed by October 2, 1987.
The delay in identifying corrective action for LER 87-032 is not l
believed to be a contributing factor in the occurrence of LER 87-039.
The training prescribed in LER 87-032 created a heightened awareness'of the requirement to review and complete PMTs prior to changing modes; however, failure to enter the ACTION statement for the LCO in the LER 87-039 event resulted in the work on IVR001B not even getting into the
" system" for evaluation of PMT requirements prior to changing modes.
In addition to the actions stated above, three Plant Manager Standing Orders (PMS0s) have been issued to provide additional instructions to personnel. PMS0-046, Post Maintenance Testing Guidelines, was issued on August 3, 1987, and provides guidance on the establishment of PMT requirements.
PMS0-047 Technical Specification Operability Requirements, was issued on August' 13, 1987, and provides emphasis on the responsibility of the Shift Supervisor / Assistant Shift. Supervisor to make timely accurate assessments of equipment operability.
PMS0-049, Work Authorization, was issued on September 1, 1987, to impose more stringent work controls on maintenance activities.
Date When Full Compliance Will Be Achieved Illinois Power will be in full compliance on November 15, 1987.
I 1
l l
l l
1 Attachment E Illinois Power Company Clinton Power Station The Notice of Violation states in part:
" Control Room Ventilation. System Train-A [ sic] was made inoperable on June 23, 1987, and remained inoperable until July 15, 1987.
From June 23 to July 15, the plant was in Operational Condition 1, 2, or 3.
The Action Statement requirements were not satisfied within the time' allotted by the Action Statement."
4 Corrective Actions Taken and Results Achieved-4 l
On July 14, 1987, Maintenance Work Request (MWR) C50654 was issued to j
properly install the leads on Control Room Ventilation (VC) System L
Train-B,.and surveillance procedure 9070.01 was conducted satisfactorily.
Corrective Actions Taken to Prevent Recurrence All safety-related fans were evaluated for proper rotation, and no
{
deficiencies were found. All MWRs performed 30 days before the July 14, 1987, event which involved lifted motor leads were reviewed to determine i
if proper-testing was performed.
No improper tests were identified I
during this review. All technicians involved with lifting and landing leads were trained on the lessons learned from this event.
Procedure 8801.16, " Wire or Component Removal / Jumper Installation," was modified to include the requirement to label leads not marked prior to lifting.
The Vice President issued a letter to all personnel relating the incident and stressing the importance of performing tasks completely and accurately with integrity.
Date When Full Compliance Will Be Achieved Illinois Power is now in full compliance.
2 i
i 1
1 j
l n