View source for U-600656, Responds to NRC Re Violations Noted in Insp Rept 50-461/86-28.Corrective Actions:Fog Nozzle at Hose Station 1FP603Q Replaced by Straight Stream Nozzle on 860429 & All Hose Stations Inspected & Procedures Revised

{{Adams
| number = ML20203M474
| issue date = 07/24/1986
| title = Responds to NRC Re Violations Noted in Insp Rept 50-461/86-28.Corrective Actions:Fog Nozzle at Hose Station 1FP603Q Replaced by Straight Stream Nozzle on 860429 & All Hose Stations Inspected & Procedures Revised
| author name = Spangenberg F
| author affiliation = ILLINOIS POWER CO.
| addressee name = Keppler J
| addressee affiliation = NRC OFFICE OF INSPECTION &amp; ENFORCEMENT (IE REGION III)
| docket = 05000461
| license number = 
| contact person = 
| document report number = U-600656, NUDOCS 8609030478
| title reference date = 06-27-1986
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC
| page count = 4
}}

=Text=
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b U-600656 L42-86 (07 -24)-L 1A.120 ILLINDIS POWER DOMPANY CLINToN POWER STATION P.o. BOX 678, CLINTON. ILLINOIS 61727 July 24, 1986 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:==
Response to the Notice of Violation dated June 27, 1986, in Inspection Report 50-461/86028

==Dear Mr. Keppler:==

This letter is in response to the {{letter dated|date=June 27, 1986|text=June 27, 1986 letter}} identifying certain activities which were in violation of NRC requirements.
Additionally, the {{letter dated|date=June 27, 1986|text=June 27, 1986 letter}} requests Illinois Power to address the underlying cause that resulted in the programmatic breakdown of not ensuring the proper-fire protection features were installed as required by the Materials License. Attachment A provides Illinois Power Company's response to the Notice of Violation. Attachment B addresses tie cause of the programmatic breakdown.
I trust this response will ensure complignce with regulatory requirements.
Sincerely yours, F. A. Spangenberg Manager - Licensing and Safety JAB /ckc Attachment cc:   B. L. Siegel, NRC Clinton Licensing Project Manager NRC Resident Office Illinois Department of Nuclear Safety
                                       ~"
8609030478 PDR 860724 O
ADOCK 05000461 PDR g 2 B $86
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          .                                                                                          ATTACHMENT A      U 600656 ILLINOIS POWER COMPANY  L42-86(07-24 )-L CLINTON POWER STATION 1A.120 The Notice of Violation states in part:
                   " Materials License Number SNM-1886, dated August 7, 1985, Item 18, states "All fire hoses servicing the New Fuel Storage Vault area shall be equipped with solid stream nozzles."
Contrary to the above, on April 30, 1986 [ sic April 29, 1986], an inspector while performing a plant tour of tha Fuel Building, Elevation 755', observed that one recently installed length of fire hose had a fog nozzle attached to the fire hose instead of the required solid stream nozzle."
I. Corrective Action Taken and Results Achieved                                                                                          l The fog nozzle at hose station 1FP603Q was replaced by a straight stream nozzle on April 29, 1986. Maintenance Work Request LMWR)
C01237 was issued to inspect all hose stations and verify that all hose station equipment was installed correctly. MWR C0123il was completed on May 23, 1986 and verified complete in safety-related areas by Quality Control through the performance of Quality Control Inspection Plan (QCIP) C01237-1-02.                                                                                                 -
II. Corrective Action to be Taken to Avoid Further Violations
)                  CPS No. 9071.17C001, FIRE PROTECTION HOSE STATION VISUAL INSPECTION CHECKLIST FOR SAFETY RELATED EQUIPMENT, was revised to include a note stressing the requirement for solid stream nozzles at the hose stations on elevations 781 and 755 feet of the Fuel Building.
III. Date When Full Compliance Will be Achieved Full compliance was achieved on June 13, 1986.

      .                                       ATTACHMENT B                 U- 600656 ILLINOIS POWER COMPANY             L42-86 (07 L CLINTON POWER STATION            1A.120 t
The {{letter dated|date=June 27, 1986|text=letter dated June 27, 1986}} states in part:                  ,
                 "please address the underlying cause that resulted in a second programmatic breakdown of not ensuring the proper fire protection features were installed as required by your Materials License."
Investigation:
The failure to ensure that the correct fire hose nozzle was instal-led'at fire hose station IFP603Q has been attributed to inadequately implemented procedures and design drawings.
Maintenance Work Request (MWR) C04213 was issued to implement numerous design changes of the fire protection system in response to an NRC Inspection and Enforcement issue concerning the adequacy of fire hose lengths. During the development and implementation of the MWR by Stone and Webster, the following conditions occurred which contributed to the programmatic breakdown:
: 1)     The review of MWR C04213 by Illinois Power (IP) Nuclear Station Engineering (NSED) was inaccurate in determining Quality Assurance (QA) involvement. The review should have indicated that QA review of MWR C04213 was necessary.
: 2)     Review of MWR C04213.during the investigation of the non-compliance indicates that the MWR job steps could have been more explicit in that the job steps did not specify that the existing hose nozzles were to be removed from the existing hoses and attached to the new hoses.
: 3)     The S&W repairman responsibic for performing MWR C04213 failed to implement the design drawing which required a solid stream nozzle for the hose on valve 1FP603Q.
Corrective Action MWR C01237 was issued to inspect and verify that all in-plant fire hose station equipment has been correctly installed. MWR C01237 has been verified complete in safety related areas by IP Quality Contral through performance of QCIP C01237-1-02.
The NSED engineer responsible for review of MWR C04213 is no longer assigned to the MWR classification group, however, all NSED person-nel responsible for MWR classification have been recently trained on Procedure M.1, Classification of Maintenance Work Requests, due to misclassification of another MWR.
A QA review of MWR C04213 may have identified that more explicit job stepping was necessary and a QA verification of the work could have identified the incorrect material.
Stone & Webster Maintenance personnel responsible for job stepping hWRs have been made aware of this particular occurrence for con-Lideration in future job stepping.

      .                             ATTACHMENT B                 U-600656 ILLINOIS POWER COMPANY             L42-86 ( 07- 24)-L CLINTON POWER STATION            1A.120 S&W supervisors and foremen were recently instructed, due to a similar occurrence, to ensure that all personnel understand their responsibility for verifying that material used is in accordance with MWR requirements.
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