IR 05000461/1989006

Forwards Notice of Violation & Proposed Imposition of Civil Penalty in Amount of $75,000 Resulting from Insps 50-461/89-06 & 50-461/89-14.Penalty Issued to Emphasize Importance of Adequate Planning & Procedures

ML20247C491
Person / Time
Site:	Clinton
Issue date:	07/20/1989
From:	Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Hall D ILLINOIS POWER CO.
Shared Package
ML20247C497	List: IR 05000461/1989006 ML20247C505
References
EA-89-059, EA-89-59, IEIN-84-47, NUDOCS 8907240359
Download: ML20247C491 (4)

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July 20, 1989 Docket No. 50-461 License No. NPF-62 EA 89-59 Illinois Power Company ATTN: Mr. D. P. Hall Senior Vice President Clinton Power Station Mail Code V-275 P. O. Box 678 Clinton, IL 61727 Gentlemen:

SUBJECT: NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTIES (NRC INSPECTION REPORTS NO. 50-461/89006(DRS) AND NO. 50-461/89014(DRP))

This refers to the NRC inspections conducted during the period February 6 through March 3 and March 16 through May 30, 1989, at the Clinton Power Station, of activities authorized by NRC Operating License No. NPF-62. The inspections included, among other things, a review of your environmental qualification program and your corrective ections taken in response to the previous identification of significant problems with your environmental qualification program. The reports documenting the inspections were sent to you by letters dated March 16 and June 12, 1989. The NRC concerns relative to the inspection findings were discussed with your staff during enforcement conferences conducted in the NRC Region III office on March 21 and June 14, 1989. Summary reports of the conferences were sent to you by letters dated March 29, 1989 and June 23, 198 Violation A described in the enclosed Notice of Violation and Proposed Imposition of Civil Penalties is indicative of a significant problem in your environmental qualification (EQ) corrective action program. After the NRC identifled deficiencies in your EQ program and imposed a $75,000 civil penalty on October 20, 1988, and after you assured us that as of November 1987 all rework had been completed on unqualified Kynar splices and junction boxes that lacked required weep holes, you later identified additional similar problems during routine maintenance activities. Specifically, in December 1988 when your staff completed a walkdown of all EQ devices having Kynar butt splices, it identified a total of six additional unqualified Kynar butt splices in five Limitorque operators. In addition, it found fifteen 10 CFR 50.49 designated EQ junction boxes that did not have required weep holes for draining any potential accumulation of wate All of these junction boxes are inside the containment or high energy line break areas and would be exposed to spray and internal condensation during an accident and therefore require weep hole i 8907240359 890720 -

PDR ADOCK 05000461 Q PDC l({

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Illinois Power Company 2 July 20, 1989 Violation B described in the enclosed Notice of Violation and Proposed Imposition of Civil Penalties concerns the failures on the part of your engineering staff to ensure the installed configurations were the same as tM tested configuraticas, to disposition a nonconforming material report cc: ectly, to classify equipment as EQ, and to properly review test data. The unqualified hydrogen igniters, instrument racks, safety relief valve solenoids, one standby I gas treatment damper assembly, and Conax electrical penetration enclosures .

inside containment had been installed since the beginning of plant operations I and represented significant equipment problems that could have led to equipment failures and system loss of function during postulated accident conditions in ]

numerous systems important to safety. The NRC believes the root cause of this violation to be inadequate engineering controls and expertise during initial q EQ planning, installation, and oversight. Further, the NRC is concerned that l these problems were not discovered earlie ]

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To emphasize the importance of adequate planning, procedures, involvement of qualified personnel, and engineering control, I have been authorized, after consultation with the Director, Office of Enforcement, and the Deputy Executive i Director for Material Safety, Safeguards, and Operations Support, to issue the j enclosed Notice of P olation and Proposed Imposition of Civil Penalties in the cumulative amount of Sveanty-Five Thousand Dollars (575,000) for the violations described in the enclosed h tice. Ir. accordance with the " General Statement of l

Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C l 53 Fed Reg 40019 October 13, 1988 (Enforcement Policy), the violations described in the enclosed Notice have each been categorized at Severity Level II The base value of a civil penalty for a Severity Level III violation is $50,00 The escalation and mitigation factors in che enforcement policy were considered for Violation A and it was concluded that 50 percent reduction in the base civil ,

penalty was appropriate because of your identification, reporting, and corrective q action once you becam'e aware of the scope of the violation. The escalation and i mitigation factors were considered for Violation B and we concluded that no I adjustment to the base civil penalty was appropriate because your good identification, reporting and corrective actions were offset by the prior notice provided by the earlier EQ civil penalty and issuances such as Information Notice 84-4 You are required to respond to this letter and should follow the instructions !

specified in the enclosed Notice when preparing your response. In your response, you should document the specific actions taken and any additional actions you plan to prevent recurrence. After reviewing your response to this Notice, <

including your proposed corrective actions and the results of future inspections, 1

! the NRC will determine whether further NRC enforcement action is necessary to ensure compliance with NRC regulatory requirement '

l In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 20, Title 10, Code of Federal Regulations, a copy of this letter and its  !

enclosures will be placed in the NRC Public Document Roo l L _ _ --_ _-- -------_.-_--._--------------.- --- -- -- -

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-Illinois Power Compa'ny 3 July 20, 1989

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The responses 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

Sincerely,

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Dr1Gim:1 C W od by L Eart ky:a A. Bert Davis Regional Administrator Enclosures: Notice of Violation and Proposed Imposition of Civil Penalties Inspection Report No. 50-461/89006(DRS);

No. 50-461/89014(DRP) Enforcement Conference Reports No. 50-461/89015(DRS);

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.No. 50-461/89023(DRS)

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cc.w/ enclosures:

J. S. Perry, Assistant Vice President R. D. Freeman, Manager, Nuclear Station Engineering Departmen DCD/DCB (RIDS)

Licensing Fee Management Branch Resident Inspector, RIII Richard Hubbard J. W. McCaffrey, Chief, Public Utilities Division H. S. Taylor, Quality Assurance Division, Sargent & Lundy Engineers David Rosenblatt, Governor's Office of Consumer Services Sheldon Zabel, Esquire, Schiff, Hardin, & Waite L. Larson, Project Manager, General Electric Company Chairman of DeWitt County OE OE:D DEDS RIII RII RI RIII F 4 7-u Bo.)

JLuehman fay ? it-gg JLieberman O y ?-t? 83 HThompson u%/g Pederson r

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Illinois Power Company 4 July 20, 1989 Distribution (Cont'd)

Illinois Department of Nuclear Safety l D. Schopfer, Project Manager,  !

Sargent & Lundy Engineers PDR SECY 4 CA i DCD/DCB (RIDS) j J. M. Taylor, DEDR i H. Thompson, DEDS

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i J. Lieberman, OE l

J. Goldberg, OGC j T. Murley, t4RR F. Ingram, GPA RA0:RIII PAO:RIII SLO:RIII M. Stahulak, RIII I Enforcement Coordinators RI, RII, RIV, and RV J

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M. Malsch, OIG i B. Hayes, OI  ;

E. Jordan, AE00 J. Luehman, OE EA File ES File

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