ML20055J325

Forwards Notice of Violation & Proposed Imposition of Civil Penalty in Amount of $25,000 Re 900411 Control Rod Event

ML20055J325
Person / Time
Site:	Clinton
Issue date:	07/25/1990
From:	Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Jamila Perry ILLINOIS POWER CO.
Shared Package
ML20055J326	List: ML20055J325 ML20055J328
References
EA-90-100, NUDOCS 9008020098
Download: ML20055J325 (5)

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July 25, 1990 Docket No. 50-461 License No. NPF-62 EA 90-100 Illinois Power Company ATTN: J. S. Perry Vice President Clinton Power Station Mail Code V-275 Post Office Box 678 1S(j Clinton, IL 61727 Gentlemen:

SUBJECT:

NOTICE.0F VIOLATION AND FR0 POSED IMPOSITION OF CIVIL PENALTY - $25,000 (NRCINSPECTIONREPORTNO.50-461/90009(DRP))

This refers to the inspection conducted on April'12-27, 1990, at the Clinton Power Station. The inspection included a review of the event'that you reported-to the NRC on April 12, 1990 which occurred when control rods were withdrawn on April 11, 1990 without following all required procedures. During this inspection, the NRC identified violations of regulatory requirements. The report describing the details of our inspection findings was sent to you by letter dated May 10, 1990. On May 31,-1990, an enforcement conference was conducted with your staff in the Region III office to discuss the circumstances surrounding the violations, your corrective actions, and your actions to prevent recurrence.

The violations that were identified during the inspection occurred (1) when a reactor operator performed control rod withdrawals while the mainLturbine bypass valves were not fully closed, as required, and (2) when these rod-withdrawals were not prevented by a second licensed operator-or other technically qualified member of the unit technical staff.

The violations occurred when.the operations staff decided to continue critical plant evolutions during shif t turnover. The on-shift licensed-operators performing control rod withdrawal during startup failed to remain continuously cognizant and in control of plant conditions and evolutions in progress.

Redundant, easily observable, and accurate indications were available to the "A" reactor operator and the shift technical advisor (STA) of main turbine bypass valve (BPV) position. These indications showed that two BPVs vare not fully closed during multiple control rod withdrawals, as required, 'and were.

not observed. The STA twice informed the "A" reactor operator of anomalous plant performance (indications that generator load _was not increasing, even though control rods were being withdrawn and reactor power was increasing).

The "A" operator inappropriately disregarded this information. Neither the CERTIFIED Mall iETURN RECEIPT REQUESTED 8S*0$00$b $ @ ff

c Illinois Power Company July 25, 1990 reactor operator nor the STA informed the line assistant shift supervisor

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"A" (LASS), the senior reactor operator in the control room, of this anomalous plant performanca. The LASS also was not sufficiently cognizant of plant conditions to be aware of this matter. The decision by-the LASS to continue critical evolutions during the shift turnover process was indicative of poor judgment and poor performance.

The NRC is concerned with the quality of performance of Operations Department personnel, both licensed and non-licenstd, during this event. Of-particular concern, it the fact that licensed operators failed to discharge their duties in a resp m ible mann y and the STA failed to adequately identify and resolve instrumentation discrepancies. In addition, the LASS neither took positive steps to ensure that control room personnel were properly discharging their responsibilities'and the. plant was operated safely nor ensured that adequate oversight was given to a relatively inexperienced operator, i

The NRC recognizes that the event had minor safety significance in that the~  ;

actual effect on the reactor core was mitigated by the fact that all the l control rod withdrawals were in accordance with the rod pattern and-at a rate:

of withdrawal'which was more conservative than was allowed by tha rod pattern control system. Notwithstanding this considerationi the deficiencies in performance of individuals and the operating crew are of significant concern because a series of pr3cedural violations were made that resulted in the i Technical Specification violation described in_the Notice. Therefore, in-accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," (Enforcement Policy), 10 CFR Part 2, Appendix C (1990),  ;

the violations ha'te been classified as a Severity Level III problem.

The NRC acknowledges that significant corrective actions were taken following :

the rod withdrawal event. These corrective actions included, among other  !

things: (1) placing the plant in cold shutdown; (2) briefing each shift-  ;

crew on the details of the event andLthe " lessons learned;" (3) approximately; 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> of retraining of active licensed operators, shift supervisors, and shift technical advisors; (4) meetings among the Plant Manager, Vice President ,

and individuals who underwent retraining to discuss the April 11, 1990 event j and reinforce the lessons presented in the. retraining; and (5) assigning an +

experienced senior-level individual, reporting directly to the Vice-President, to monitor and assess Plant Staff-Operations.

To emphasize the importance of' adherence to procedures, effective communication between operating crew members, turnover of information between operating crews,  ;

and management oversight and direction of operating crews, I have been authorized,  !

after consultation with the Director, Office of Enforcement, and the Deputy i Executive Director for Nuclear Materials Safety, Safeguards, and Operations  !

Support to issue the enclosed Notice of Violation and Proposed Imposition of Civil Penalty in the amount of $25,000 for the Severity Level III problem.- The  !

base value for a-Severity Level III problem is $50,000. i

f Illinois Power Company July 25, 1990 The escalation and mitigation factors in the Enforcement Policy were con!.idered.-

While the violations were eventually identified by licensee personnel, there were several earlier opportunities for discovery. Additionally, information concerning the significance of this event that was developed during the licensee critique of April 11 was not promptly communicated to senior level management. Consequently, mitigation is not proposed for your identification of the event. Once +S violations for failure to carry out a proper control rod withdrawal procedura were brought to the attention of senior management, prompt and extensive corre :tive action was taken. Bcsed on the above, we have concluded that mitigation of the base civil penalty by 50 percent for this factor is warranted. The other adjustment factors in the Policy were considered-and no further adjustment is considered appropriate.

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, the NRC will determine whether further NRC enforcement action is necassary to ensure compliance with NRC regulatory requirements.

In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter and its enclosures will be placed in the NRC Publ!.c Document-Room.

The responses directed by this letter and the enclosed Notice are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, Pub. L. No.96-511.

r Sincerely, Orbir.nl e me t,7- [

A Lnt kva '

A. Bert Davis Regional Administrator

Enclosures:

1. Notice of Violation and Proposed Imposition of Civil Penalty

2. Inspection Report No. 50-461/90009(DRP)

See Attached Distribution OE OE:D DEDS (Concurrence received via FAX)

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Distribution cc w/ enclosures: .

JJ. Cook,-Manager, Clinton' Power _ Station F. Spangenberg, III. Managero Licensing and; Safety DCD/DCB(RIDS):

Licensing-Fee Management Branch

. Resident Inspector. . RIII-J. Hickman, NRR, PM-J._McCaffrey,' Chief, Public-Utilities' Division.

H. Taylor,_QualityiAssurance Division. Sargent &:Lundy..

Engineers-.

Patricia O'Brien, Governor's-Office of. Consumer Services; - >

S. Zabel, Esquire,LSchiff, Harain,

& Waite _

L. Larson, Project' Manager -

General Electric Company-Chairman,'DeWittl County Board?

-Illinois Department'of ,

Nuclear Safety .

Robert Newman, Asst. : Director State of Illinois-Perry' SRI i

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