ML20210D050

Notice of Violation from Insp on 860707-0829

ML20210D050
Person / Time
Site:	Clinton
Issue date:	09/16/1986
From:	Hehl C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20210D020	List: IR 05000461/1986052 ML20210D015 ML20210D050
References
50-461-86-52, NUDOCS 8609190046
Download: ML20210D050 (2)

Text

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NOTICE OF VIOLATION Illinois Power Company Docket No. 50-461 As a result of the inspection conducted on July / through August 29, 1986, and in accordance with the " General Policy and Procedures for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1985), the following violations were identified:

1. 10 CFR 50, Appendix B, Criterion XVI, as implemented by Illinois Power's Quality Assurance Manual, Chapter 16, requires that measures shall be established to assure that conditions adverse to quality, such as deficiencies and nonconformances are promptly identified and corrected. In the case of significant conditions adverse to quality, the measures shall assure that the cause of the conditon is determined and corrective action taken to preclude repetition.

a. Contrary to the above, on August 28, 1986, adverse conditions identified by Condition Report No. CR-1-86-03-086 were not corrected in that measuring and test equipment (M&TE) information required for traceability was still not included on maintenance work requests (MWRs) after the condition report was dispositioned.

b. Contrary to the above, on August 28, 1986, adverse conditions identified by Condition Report No. CR-1-86-03-086 were not corrected in that trcining required by the disposition of the condition report war r.ot effective. The procedure which was intended to preclude .etitionofthecondition(M&TEnotrecorded)andwhich was used to ; rain personnel did not correct or preclude repetition of the sig,ificant condition adverse to quality.

c. Contrary to the above, on August 28, 1986, a contributing cause of a significant condition adverse to quality was not adequately determined in that a lower tier Procedure No. QAP 510.04, used to verify the quality of safety related equipment required for safe shutdown, failed to n.cet the requirements of an adminstrative, higher tier Procedure No. CPS 1029.01 in that QAP 510.04 allowed M&TE to be recorded on something other than the MWR. As such, the corrective action failed to correct a significant condition adverse to quality and may have contributed to repetition.

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

2. 10 CFR 50, Appendix 8, Criterion V, as implemented by Illinois Power's Quality Assurance Manual, Chapter 5, requires that activities affecting quality shall be prescribed by procedures and shall be accomplished in accordance with these procedures. Clinton Procedure CPS 1029.01,

" Preparation and Routing of Maintenance Work Requests," requires a listing of all M&TE used on the work request, reference or inclusion of procedures used in the MWR package, and attachment to the MWR of all supporting data and documentation.

8609190046 860716 PDR 0 ADOCK 0D000461 PDR.

NOTICE OF VIOLATION 2 Contrary to the above, between January and May, 1986, as identified to Illinois Power on August 28, 1986, maintenance work requests were not

. accomplished in accordance with Procedure CPS 1029.01 in that measuring -

and test equipment used were not documented; supporting procedures were not referenced; supporting data was not documented on the maintenance work request; and supporting documentation was not attached as required.

This is a Severity Level V violation (Supplement II).

3. 10 CFR 21.51(c) requires that records related to evaluations, as defined by 10 CFR 21.3(g), which must be accomplished to determine whether a particular deviation could create a substantial safety hazard, shall be retained.

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Contrary to the above, on August 21, 1986, it was determined that Illinois Power had failed to document and retain the engireering evaluation that determined that safety-related valves found with excessive stem hardness would not create a substantial safety hazard.

This is a Severity Level V violation (Supplement II).

With respect to Item 3, the inspection showed that action had been taken to correct the identified violation ar.d to prevent recurrence. Consequently, no reply to the violation is required and we have no further questions regarding this matter. With respect to Items 1 and 2, pursuant to the provisions of 10 CFR 2.201, you are required to submit to this office within thirty days of the date of this Notice a written statement or explanation in reply, including for each violation: (1) corrective action taken and the results achieved; (2) corrective action to be taken to avoid further violations; and (3) the date when full compliance will be achieved. Consideration may be given to extending your response time for good cause shown.

l SEP 181986

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Dated thiirWsT.~TiehWChWf Operations Branch i

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