ML20199A968

NOV from Insp on 970707-0825.Violations Noted:Operability Determinations Were Not Performed within 24 H of Discovery of Nonconforming Condition

ML20199A968
Person / Time
Site:	Clinton
Issue date:	11/12/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20199A962	List: IR 05000461/1997015 ML20199A958 ML20199A968
References
50-461-97-15, NUDOCS 9711180168
Download: ML20199A968 (4)

Text

NOTICE OF VIOL.ATION tilinois Power Company Docket No. 50-461 Clinton Power Station License No. NPF-62

, During an NRC inspection conducted on July 7 through August 25,1997, four 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 301995), the violations are listed below.

1. 10 CFR Part 50, Appendix B, Criterion V, " Instructions, Procedures, and Drawings,"

states, in part, that activities affecting quality shall be prescribed by documented instructions or procedures appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, and drawings.

A. Procedure CPS 1014.06, " Operability Determinations," Revision 1, Section 2.1.5, requires, in part, that operability determinations, an activity affecting quality, be pedormed within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of discovery of a nonconforming condition.-

Contrary to the above, on June 2, June 25, and July 2,1997, operability determinations were not performed within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of discovery of a nonconforming condition. Specifically; (1) An operability determination evaluating the use of an unapproved, conductive, and corrosive soldering flux on the cables for the intermediate range monitors was not performed until 44 days after the initial discovery of the nonconforming condition. ,

(2) An operability determination evaluating khe impacts on the emergency diesel generators and associated ventilation system, when outside ambient temperatures were outside the temperature limits described in Section 2.3.1.1 of the Updated Safety Analysis Report (USAR), was not performed until 22 days after the initial discovery of the nonconforming condition.

(3) An operability determination regarding the use of an unapproved, conductive, and corrosive soldering flux for 592 neon indicating lights in the control room was not performed until three days after the initial discovery of the nonconforming condition.

B. Procedure CPS 1016.01, " Condition Reports," Revision 29, Section 8.1.1, requires, in part, that any person becoming aware of a condition adverse to safe reliable power production initiate a condition report. Section 2.2.4 of Procedure CPS 1016.01 defines a condition adverse to safe reliable power production as failures or malfunctions, deficiencies, defective items, and nonconformances.

9711100168 971112 PDR ADOCK 05000461 G PDR l

Notice of Violation- Contrary to the above, on August 15,1997, a condition report was not initiated

• after mechanical maintenance personnel became aware of a deficient seal on the ,

door of the Residual Heat Removal Pump A room, a condition adverse to safe re0able power operation.

C. Procedure CPS 8433.01, " Generic Procedure for 125 VDC Battery Maintenance,"

Revision 14, Section 8.7,3, requires, in part, that a Class 1E portable battery charger be used while equalizing indivMoa7 battery cells. -

Contrary to the above, between June 1989 and July 8,1997, a Class 1E portable battery charger was not used while equalizing individual cells on the Division 1, ll, and ill batteries.

D. Procedure CPS 1019.05, " Control of Transient Equipment / Materials," Revision 5, Section 8.3, " Securing Equipment from Sliding," requires, in part, stable equipment that is not "in use" should not be set within 3 feet plus its height of adjacent equipment unless positively secured. Procedure CPS 1019.05, Section 2.2.6, defined "in use" as an item that is under the control of an individual with maintenance, testing, or other work activity in progress.

Contrary to the above, on July 8,1997, a not "in use" Class 1E portable battery charger connected to the Division ill battery was within 3 feet of the battery and was not positively secured.

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

2, 10 CFR Part 50, Appendix B, Criterion V, " Instructions, Sf rocedures, and Drawings,"

states, in part, that activities affecting quality shall be prescribed by documented instructions or procedures appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, and drawings.

Contrary to the above, on July 8,1997, instructions and procedures for performing maintenance on the Division til battery were not appropriate to the circumstances.

Specifically, Procedure CPS 8433.01, " Generic Procedure for 125 VDC Battery Maintenance," Revision 14, did not provide instructions regarding the selection of a new pilot cell following the completion of an individual cell equalizing charge.

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

3. 10 CFR Part 50, Appendix B, Criterion ill, " Design Control," requires, in part, that measures be established to assure that the design basis for structures, systems, and components are correctly translated into specifications, drawings, procedures, and instructions.

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d  ;

Notice of Violation -

4  ;

t Contrary to the above, on July 2,1997, adequale measures were not established to .  ;

anure that the design bues for the hydrogen mixing comprenors, the control room - a ventiistion system, and the diesel generator venmation system were es.T.cuy translated  :

, into speamoations, drowings, procedures, and insimctions. specmcally, the information -

regarding the her+;-r;;;; required by the hydrogen mixing compressors and the kilowatts -

required by the control room ventilation and emergency diesel generator ventilation 3 systems was not sufficient to prevent a nonconservative cheni;;s to the maximum

emergency diesel generator loading values specified in the 3,) dated Safety Analysis

. Report . '

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

- 4. License Condition 2.E requires, in part, that the licensee implement and maintain in effect '

all provisions of the Commission-approved physical security plan including amendments .

made pursuant to provisions of the Miscellaneous Amendments and Search

Requirements revisions to 10 CFR 73.55 and to the authority of 10 CFR 50.90 and -

10 CFR 50.54(p),

Clinton Power Station Physical Security Plan, Revision 13, Section 4.3.1, requires the L minimum illumination level throughout the protected area be 0.2 foot candles.

Contrary to the above, on July 18,1997, the minimum illumination level was not 0.2 foot-l candles in that 8 of 23 nample locations in the RCIC storage tank berm area were between 0.033 to 0.131 foot-candles.

l - This is a Severity Level IV violation (Supplement 111), w o -

L The NRC has concluded that information regarding the reason for Violation 4, the corrective i

actions taken and planned to correct the violation and prevent recurrence and the date when full compliance will be (was) achieved should be adequately addressed on the docket in Illinois Power Company's response to Violation 3 in inspection Report No. 50-97014(DRP) dated October 14,1997. Therefore, no response to Violation 4 is required. Pursuant to the provisions of 10 CFR Part 2.201, Illinois Power Company is hereby required to submit a written statement or i explanation to the U.S. Nuclear Regulatory Commission, ATTN: Document control Desk, l Washington, DC 20555, with a copy to the Regional Administrator, Region Ill, and a copy to the NRC resident iqspector 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 inc!ude for_ Violations 1 through 3: (1) the reason for

, the violation, or, if contested, the_ basis for disputing the violation (2) the corrective steps that m 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, orwhy such other action as may be proper should not be taken. Where good cause is shown, consideration will be given to extending the response time.

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- Notice of Violation  !

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 information so that '

it can be placed in the PDR without redaction. However, if it is 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 1-public, Dated at Lisle,Jllinois, this 12th day of November 1997=

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