ML20151K013

Notice of Violation from Insp on 970407-0523.Violation Noted:On 970408,2 Members of Plant Staff Failed to Perform Step 8.1.7 of Procedure CPS 9170.02, CR HVAC Chilled Water Valve Operability Test, Rev 26,in Order Written

ML20151K013
Person / Time
Site:	Clinton
Issue date:	07/25/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20151J994	List: ML20151J988 ML20151K013 ML20151K019
References
50-461-97-011, 50-461-97-11, NUDOCS 9708050304
Download: ML20151K013 (4)

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NOTICC OF VIOLATION Illinois Power Company Docket No. 50-461 Clinton Power Station License No. NPF-62 During an NRC inspection conducted on April 7 through May 23,1997, nine violations of NRC requirements were identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG 1600 (60 FR 34381: June 30, 1995), the violations are listed below:

1. Technical Specification 5.4.1 required, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978.

Regulatory Guide 1.33, Revision 2, Appendix A, Paragraph 1.d, recommended procedures governing procedural adherence.

Procedure CPS 1005.15, " Procedure Use and Adherence," Revision 0, Step 8.1.3.

required that unless otherwise directed by individual procedures, procedural steps be performed in the order stated.

Contrary to the above, on April 8,1997, two members of plant staff failed to perform Step 8.1.7 of Procedure CPS 9170.02, " Control Room HVAC Chilled Water Valve Operability Test," Revision 26, in the order written.

This is a Severity Level IV violation (Supplement 1).

2. Technical Specification 5.4.1 required, in part, that written procedures shall be i established, implemented, and maintained covering the applicable procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978.

Regulatory Guide 1.33, Revision 2, Appendix A, Paragraph 9e, recommended  !

general procedures for the control of maintenance, repair, replacement, and i modification work. 4 Procedure CPS 1501.02, " Conduct of Maintenance," Revision 18, Step 4.8, required that a system impact matrix be completed and attached to the work document for all work which required lifting electrical leads or otherwise performing i activities interrupting electrical circuit continuity. '

Contrary to the above, on May 14,1997, a controls and instrumentation technician performing work document "PCIFWM 135" failed to complete a system impact matrix prior to lifting electrical leads which interrupted electrical circuit continuity.

This is a Severity Level IV violation (Supplement 1).

3. Technical Specification 5.4.1 requires, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978.

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i Regulatory Guide 1.33. Revision 2, Appendix A, Paragraph 1.c, recommends procedures governing Equipment Control (e.g., locking and tagging).

Procedure CPS 1401.01, " Conduct of Operations," Revision 26, Section 8.5.2, a procedure for Equipment Control, required that components, the unauthorized i

manipulation of which could compromise plant safety or availability, be chained,  ;

lockwired, or otherwise suitably locked.

Contrary to the above, on April 24,1997, the Division lil Emergency Diesel ~

l Generator (EDG) fuel oil supply cusoff valve and EDG air start system valves 1DG150 through 1DG165, the unauthorized manipulation of which could compromise plant safety, were not chained, lockwired, or otherwise suitably locked.

This is a Severity Level IV violation (Supplement 's.

4. Technical Specification 5.4.1 required, in part, that written procedures shall be 1

established, implemented, and maintained covering the applicable procedures J recommended in Regulatory Guide 1.33, Re /ision 2, Appendix A, February 1978.

Regulatory Guide 1.33, Revision 2, Appradix A, Paragraph 1.c, recommended that procedures be established for equipmer.t control (e.g., locking and tagging).

Procedure CPS 1014.01, " Safety Tsgging," Revision 22, Step 8.6.3, specified that the position required for proper component restoration be identified on the tagout sheet addendum.

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Contrary to the above, on April 4,1997, the tagout sheet addendum for Tagout 97-9330 failed to identify the required restoration position for a safety related local trip switch.

This is a Severity Level IV violation (Supplement 1).

5. Technical Specification 5.4.1 required, in part, that written procedures shall be (stablished, implemented, and maintained covering the applicable procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978.

. Regulatory Guide 1.33, Revision 2, Appendix A, Paragraph 9e, recommended general procedures for the control of maintenance, repair, replacement, and modification work.

Procedure CPS 1501.02, " Conduct of Maintenance," Revision 18 (a general l

procedure for the control of maintenance, repair, replacement, and modification work), Step O .4.6, required that information be provided to succeeding shift l personnel to assure work is completed in a sale and effective manner for all work performed during more than one shift.

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Contrary to the above, on April 24,1997,information was not provided to succeeding shift personnel to assure that work was performed in a safe and effective manner in that a safety related valve was damaged during testing.

This is a Severity Level IV violation (Supplement 1).

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6. Technical Specification 5.4.1 required, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978.

j Regulatory Guide 1.33, Revision 2, Appendix A, Paragraph 7.e.4, recommended that procedures be established regarding contamination controls.  !

Procedure CPS 1024.02, " Radiological Work Control," Revision 4, Section 6.0,  !

specified, in part, that personnel performing radiological work were not permitted to  !

deviate from established radiological control requirements without specific written or verbal guidance from responsible radiation protection personnel.

Radiation Worker Information Sheet (RWIS) 5.6, " Minor Radiological Risk Work  !

Rules for Mechanical Maintenance,". dated January 14,1997, established radiological control requirements, including contamination controls, for activities with a "C" radiological classification. Instruction 7 of RWIS 5.6 specified that orotective clothing be wom for entry into contamination areas.

Contrary to the above, on May 8,1997, an individual performing an activity with a "C" radiological classification failed to wear protective clothing when he crossed a contamination boundary while checking a valve label.

This is a Severity Level IV violation (Supplement IV).

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10 CFR Part 50, Appendix B, Criterion V, " Procedures," requires, in part, that activities affecting quality be prescribed by procedures of a type appropriate to the circumstances.

Contrary to the above, Procedure CPS 1019.05, " Control of Transient Equipment / Materials," Revision 3, Section 8.8, a procedure prescribing activities affecting quality, was not appropriate to the circumstances in that it failed to provide for adequate control of material which could clog Emergency Core Cooling System strainers in a post accident environment.

This is a Severity Level IV violation (Supplement 1).

i 8. 10 CFR Part 50, Appendix B, Criterion V, " Procedures," requires, in part, that

! activities affecting quality be prescribed by procedures of a type appropriate to the j circumstances.

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Notice of Violation .

Contrary to the above, on April 28,1997, CPS 8901.10 " Scaffold Erection /Use/ Dismantling," Revision 0, was not appropriate in that it did not specify performing appropriate stress analyses when attaching scaffolding to the minimum flow line piping for the "B" residual heat removal pump.

This is a Severity Level IV violation (Supplement 1).

9. 10 CFR Part 50, Appendix B, Criterion V, " Procedures," requires, in part, that activities affecting quality be prescribed by procedures of a type appropriate to the circumstances.

Contrary to the above, on October 9, December 11 and 30,1996, Procedure CPS 8410.05, " Type HE Molded Case Circuit Breaker Revision Level Test," Revision 4, and Procedure CPS 8410.04, " Molded Case Circuit Breaker Functional Testing and Maintenance," Revision 9 were inappropriate in that the procedures permitted pre-conditioning Breakers 1 AP73E13C,1 AP41E2C, and 1DC14EA/15, prior to the breakers' functional tests.

This is a Severity Level IV violation (Supplement I).

Pursuant to the provisions of 10 CFR 2.201, Illinois Power Company is hereby required to submit a written statemant or explanation to the U.S. Nuclear Regulatory Commission, ATTN: Document Contr6. Desk, Washington, DC 20555, with a copy to the Regional {

i Administrator, Region 111, and a copy to the NRC resident inspector at the facility that is the subject of this Notice, within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply should be clearly marked as a " Reply to a Notice of {

Violation" and should include for each violation: (1) the reason for the violation, or, if contested, the basis for disputing the violation, (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved. Your response may reference or include previous docketed correspondence, if the correspondence adequately addresses the required response. If an adequate reply is not received within the time specified in this Notice, an order or a Demand for information may be issued as to why the license should not be modified, suspended, or revoked, or why such other action as may be proper should not be taken. Where good cause is shown, consideration will be give to i extending the response time.

Because the response will be placed in the NRC Public Document Room (PDR), to the extent possible, it should not include any personal privacy, proprietary, or safeguards l information so that it can be placed in the PDR without redaction. However, if it is t

necessary to include such information, it should clearly indicate the specific information that should not be placed in the PDR, and provide the legal basis to support the request for withholding the information from the public.

Dated at Lisle, Illinois this 25th day of July 1997