IR 05000461/1987006

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Forwards Notice of Violation Re Deficiencies in Emergency Operating Procedures Noted in Insp Rept 50-461/87-06. Enforcement Action Taken Since Deficiencies Could Have Resulted in Procedures W/Safety Significant Errors
ML20207S371
Person / Time
Site: Clinton Constellation icon.png
Issue date: 03/17/1987
From: Chrissotimos N
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To: Gerstner W
ILLINOIS POWER CO.
Shared Package
ML20207S372 List:
References
NUDOCS 8703190323
Download: ML20207S371 (3)


Text

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MAR 171987

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Docket No. 50-461 Illinois Power Company ATTN: Mr. W. C. Gerstner Executive Vice President 500 South 27th Street Decatur, IL 62525 Gentlemen:

This refers to our letter to you dated February 27, 1987, which forwarded the results of a special inspection of your Emergency Operating Procedures (E0Ps) and their conformance to your procedures generation package which the NRC had previously approved (NRC Inspection Report No. 50-461/87006).

The letter also stated that we were evaluating enforcement actions.

The evaluation has been completed and the NRC staff has determined that certain of your activities appeared to be in violation of NRC requirements, as specified in the enclosed Notice. The inspection found several examples where your E0Ps were not in conformance with your NRC approved procedures generation package, and that these examples involved technical deficiencier in your E0Ps.

In addition, the adequacy of your corrective action progrcm to correct deficiencies in a timely manner and preclude their repetition was found to be ineffective.

On March 13, 1987, an enforcement conference was held with Messrs. J. Cook, W. Connell, and others of your staff to discuss the results of our inspection. During that conference, your staff defined the corrective actions proposed to deal with the technical deficiencies that had existed in your E0Ps at the time of our inspection, and presented the results of your evaluation regarding whether an unreviewed safety question had existed as a result of the revision made to the entry level condition for Procedure CPS 4406.01. This issue could be considered a Severity Level III problem if the safety evaluation had resulted in the conclusion that an unrevhwed safety question had existed.

As a result of the enforcement conference, we have determined that no unreviewed safety question existed as a result of the revision to the entry level condition to Procedure 4406.01.

In addition, after examination of the technical deficiencies that existed in your E0Ps, we have concluded that these deficiencies would not have resulted in the inability of the E0Ps to perfom their intended function in mitigating an actual emergency. However, the events that led to the technical deficiencies could have resulted in the issuance of procedures with safety significant errors since the program to ensure procedure adequacy had broken down. On this basis, we have concluded that the appropriate enforcement action for this case is the issuance of Severity Level IV violations. A written response is required.

8703190323 870317 PDR ADOCK 05000461 G

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?2007 Illinois Power. Company

We have not issued a violation for the failure to adequately docurrent the basis.for concluding that no unreviewed safety question existed in the performance of your safety evaluation regarding the revision to Procedure 4406.01 as the adequacy of your safety evaluations conducted during.the time frame in question is already the subject of one of the violations included in the proposed civil penalty sent.to you on March 3,.1987, by Mr. A. B. Davis.

Your reply to this letter and the results of future inspections in this area will be considered in determining whether escalated enforcement action may be appropriate if similar violations are identified.

In accordance with 10 CFR 2.790 of the Connission's regulations, a copy of this letter,-the enclosure, and your response to this letter will be placed in the NRC Public Document Room.

The response directed by this letter and the accompanying Notice are not subject to the clearance procedures of the Office'of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511.

We will gladly discuss any questions you have concerning the inspection.

Sincerely, Original signed by C. W. Hehl (for)

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N. J. Chrissotimos, Acting Director Division of Reactor Safety Enclosure: Notice of Violation See Attached Distribution yu RIII RIII RIII RIII RIII Mkh tal} f.t udk Rf"' g')

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1 7 1987 MAR Illinois Power Company

Distribution cc w/ enclosure:

DCS/RSB(RIDS)

Licensing Fee Management Branch.

-Resident Inspector, RIII Richard Hubbard Gary N. Wright, Manager rNuclear Facility Safety Mark Jason, Assistant

Attorney General, Environmental Control Division H. S. Taylor, Quality Assurance Division David Rosenblatt, Governor's Office of Consumer Affairs W. G. Kennedy, HFMT, HRR i

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