ML20062H304
| ML20062H304 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 11/26/1990 |
| From: | Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Jamila Perry ILLINOIS POWER CO. |
| Shared Package | |
| ML20062H305 | List: |
| References | |
| EA-90-108, NUDOCS 9012040246 | |
| Download: ML20062H304 (6) | |
See also: IR 05000461/1990005
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November 26, 1990
Docket No. 50-461
License No. NPF-62
EA 90-108
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Illinois Power Company
ATTN:
J. S. Perry
Vice President
Clinton Power Station
Mall Code V-275
Post Office Box 678
Clinton, Illinois 61727
Gentlemen:
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SUBJECT:
NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY - $112,500
(NRC INSPECTION REPORTS 50-461/90005(DRS) AND 50-461/90012(DRP))
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This refers to the special safety team inspections at the Clinton Power Station,
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conducted on March 14 - May 14, 1990, and on May 18 - May 31, 1990, of activities
authorized by NRC License No. NPF-62.
During these inspections, violations of
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NPC requirements were identified, and on June 5,1990, an enforcement conference
was held at the Clinton Power Station between you, and other members of.your
staff, and Dr. C. J. Pape'riello, and other members of the NRC staff.
Copies
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of the inspection. reports were mailed to you on May 31 and June 5, 1990, and
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the enforcement conference report was mailed to you on June 11, 1990. A final
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management meeting, to ensure that all technical issues had been resolved, was
held on November 6, 1990.
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The~ violations, which are described in the enclosed Notice of Violation and
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' Proposed Imposition of Civil- Penalties (Notice), involve three separate issues.
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Violation I concerns your failure to promptly identify and initiate appropriate
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corrective action for a potentially gignificant condition adverse to quality.
During performance testing of the shutdown servire water (SX) pump room heat
exchanger on January 24, 1990, Plant Technical Staff engineers found flow rates
significantly lower than expected. Though the flow data was forwarded to the
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' Nuclear Station Engineering Department (NSED) for trending purposes, the test
engineers failed to either initiate a Condition Report or inform the shift
supervisor.
Consequently, no action was taken to investigate the suspected
malfunction until the Supervisor of Plant festing reviewed the test data on
February.15, 1990.
As a result, your corrective action was not prompt, and
unduly extended operation with the SX system degraded. This violation
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demonstrates inadequate management attention to ensuring prompt, thorough
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evaluations of unexpected equipment indications.
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
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lilinois Power Company
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November 26, 1990
Your subsequent investigation found that the shutdown service water and control
room heating, ventilation, and air conditioning (HVAC) chilled water flow rates
were less than the design value for numerous components.
This condition had
existed since plant startup in 1987 due to initial design inadequacies (Violation
11.A), that were compounded by inadequate pre-operational testing (Violation 11.B).
While these deficiencies occurred several years ago, they resulted in your having
to do extensive engineering calculations, modifications, and flow balancing in
order to restore the systems to their design configurations.
Violation 111 concerns the May 14, 1990 startup with diesel generators (DG) 1A
and IB inoperable due to the unavailability of shutdowr. service water.
The DG
heat exchanger SX outlet valvr were incorrectly positioned by operators during
system restoration work following maintenance.
Had the diesels been called upon
in a loss of offsite power event, they would have tripped within approximately
ten minutes of starting, but would not have been physically damaged, and could
have been restarted.
Had they been called upon during a loss of coolant accident,
coincident with a loss of offsite power, the diesels would have physically failed
within approximately thirty minutes of starting, unless the operators responded
to the diesel trouble alarm, correctly diagnosed the problem, and locally opened
the valves.
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The root cause of Violation 111 appears to be that the management and administrative
controls you had established to ensure proper valve position were not clearly or
consistently communicated to your operators.
To ensure repeatability of the SX
system flow balance to the DG heat exchangers, a new methodology for throttling
the SX outlet valves had been developed with the valve position specified on a
control tag. The first problem that developed was that the tags were not
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updated after initial placement to reflect the final valve throttle positions
once the system balance was completed.
Secondly, information on how the SX
valves were to be throttled was not communicated to all members of the operations
staff.
Both the operator who manipulated the valves and the assistant shift
supervisor with whom he conferred as to the correct valve positioning method,
did not know about the new methodology.
This is particularly disturbing because
the NRC Resident Inspectors had extensive discussions with plant management
concerning the need to ensure that all responsible personnel were informed
of these changes because of the need to establish a precise and repeatable valve
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position, to ensure accurate flow rates were established.
Consequently, you went from cold shutdown (Operational Condition 4) to startup
(Operational Condition 2), and remained there for over a day before discovering
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the closed valves when DG 1A tripped during a routine surveillance test. We
were, however, encouraged by the fact that, in this instance, you took prompt
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and extensive corrective actions.
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To emphasize the need for additional management attention to problem identifi-
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cation and resolution, and prompter, more effective corrective actions, I have
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been authorized af ter consultation with the Director, Office of Enforcement,
and the Deputy Executive Director for Nuclear Reactor Regulation, Regional
Operations, and Research to issue the enclosed Notice of Violation and Proposed
Imposition of Civil Penalties in the amount of $112,500 1 m the Violations set
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Illinois Power Company
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November 26, 1990
forth in the Notice.
The violations have each been classified at Severity
Im/ol 111 in accordance with the " General Statement of Policy and Procedure for
Enforcement Actions," 10 CFR Part 2, Appendix C (1990) (Enforcement Policy).
The base value of a civil penalty for a Severity Level III violation or problem
is $50,000.
The escalation and mitigation factors in the Enforcement Policy
were considered for e :h violation as described below.
Violation I is cunsidered a significant failure to identify and correct a degraded
condition, and is therefore categorized at Severity Level III. The base civil
penalty was escalated by 50% for NRC identification of your corrective action
system failures. However, once the system performance problem and corrective
action deficiencies were identified, you took extensive corrective actions that
included an in-depth evaluation of the SX system design problems as well as
providing wide training to station personnel regarding their responsibility
for prompt reporting of deficient conditions.
Consequently, a 50% mitigation
is applied for these actions.
No other adjustments were considered appropriate
and a $50,000 civil penalty is assessed for this violation.
The failure to ensure that the shutdown service water and control room HVAC
chilled water systems performance (1) met their Final Safety Analysis Report
(FSAR) design bases (Violation II.A) and (2) that SX system was adequately tested
(Violation II.B), has been categorized in the aggregate as a Severity Level III
problem under Supplements I and 11 of the Enforcement Policy. These violations
resulted in system performance being significantly degraded below the design
basis described in the FSAR since initial plant startup and extensive analysis
was necessary to provide assurance that the systems would serve their intended
function.
This is of significant concern because the plant was licensed, in
part, on the basis of the statements made in the FSAR. A civil penalty is
normally proposed for Severity Level 111 problems.
However, because you identi-
fied and reported the violations, initiated comprehensive corrective action that
included significant system testing and modification, and the violation would
not reasonably be expected to have been identified by routine surveillance testing
or quality assurance audit program and is not indicative of a current performance
concern, we have decided to exercise discretion under Section V.G.3 of the
Enforcement Policy and not propose a civil penalty for these violations.
Violation 111 is considered a significant operational violation and therefore
has been categorized at Severity Level Ill.
Though you identified this violation,
it was only mitigated by 25% because the DG failure that led to the discovery
of the mispositioned SX valves is considered self-identifying. A 50% mitigation
factor was applied for your corrective actions which included significant efforts
to communicate management expectations regarding operator performance, responsi-
bilities and authorities. A 100% escalation factor was applied for prior notice
because specific NRC concerns regarding the need to communicate the new method
of setting the SX throttle valves was discussed with senior plant management
prior to the event.
No further adjustment to the base civil penalty was con-
sidered appropriate and a $62,500 civil penalty is assessed for this vic!ation.
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,
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l111nois Power Company
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November 26, 1990
you should document the specific actions token and any additional actions you
plan to prevent recurrence.
Particular emphasis should be placed on your actions
to assure that potential design and testing deficiencies similar to those in
Violations ll.A and B, are not present. 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
necessary to ensure compliance with NRC regulatory requirements.
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In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of
this letter and its enclosure will be placed in the NRC Public 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, P. L.96-511.
Sincerely,
Ll%ta r
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A. Bert Davis
Regional Administrator
Enclosures:
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1.
Notice of Violation and Proposed
imposition of Civil Penalties
2.
Inspection Reports No. 50-461/90005(DRS)
and No. 50-461/90012(DRP)
See Attached Distribution
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(Received via FAX)
WTroskoski
JLieberman
JSniezek
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11/15/90
11/15/90
11/18/90
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lilinois Power Company
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November 26, 1990
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Distribution.
cc w/ enclosure:
J. Cook, Manager, Clinton Power Station
F. Spangenberg, Ill, Manager,
' Licensing and Safety
DCD/DCB (RIDS)
OC/LFDCB
Resident inspector, Rlli
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McCaffrey, Chief, Public
Utilities Division
.H. Taylor, Quality Assurance
Division, Sargent & Lundy
Engineers
Patricia O'Brien, Governor's
Office of. Consumer Services
S, Zabel, Esquire, Schiff, Hardin,
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& Waite
L. Larson, Project Manager,
General Electric Company
Chairman, DeWitt County Board
Illinois Department of
Nuclear Safety
Robert _ Newmann, Office of Public
Counsel, State of Illinois Center
Perry SRI
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lilinois Power Company
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November 26, 1990
DISTRIBUTION:
LPDR
SECY
CA -
J.Sniczek, DEDR
J.Lieberman, OE
J.Goldberg, 0GC
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T.Murley, NRR
J.Partlow, HRR
Enforcement Coordinators
R1, Ril,-RIV, RV
F.Ingram, GPA/PA
B. Hayes, 01
D. Williams OlG
E. Jordan, AE0D
. W.Troskoski OE
Day File
EA File
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