ML20137F522
| ML20137F522 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 01/09/1997 |
| From: | Beach A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Connell W ILLINOIS POWER CO. |
| References | |
| CAL-RIII-97-01, CAL-RIII-97-1, NUDOCS 9704010122 | |
| Download: ML20137F522 (5) | |
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i January 9,1997 CAL No.'RIII-97-001 Mr. Wilfred Connell, Vice President l
Clinton Power Station i
Illinois Power Company Mail Code V-275 P. O. Box 678 i
Clinton, IL 61727 i
SUBJECT:
CONFIRMATORY ACTION LETTER i
Dear Mr. Connell:
i On December 16, 1996, we held a management meeting, open to the public, to j
discuss Illinois Power's (IP) plans to address deficiencies stemming from the September 5,1996, failure of the "B" reactor recirculation pump seal package at the Clinton Power Station. -The event revealed significant deficiencies in
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procedural adequacy and adherence, rigor in conducting plant operations, and
. engineering support to operations. Most significantly, the deficiencies also l
included serious lapses in safety focus by both plant management and staff in determining actions to be taken.while attempting to place the reactor in j.
single loop operation.
After reviewing IP's initial assessment of the event, we issued Confirmatory Action Letter (CAL), No. RIII-96-013, to document our understanding of additional issues IP was to review. Your letters dated September 17 and 24, i
1996, responded to the CAL and provided details of the scope, findings, and j
corrective actions from IP's expanded review.
After further IP review, and issuance of our Special and OSTI inspections j
(reports No. 96010 & 96011), your December 9, 1996, "Clinton Power Station Startup Readiness Action Plan" letter provided additional details and i
documented additional corrective actions. The letter indicated the items therein would be accomplished prior to restarting Clinton station. During the December 16, 1996, meeting, your staff outlined the Startup Readiness Action Plan contents and an assessment of its status.
IP's Startup Plan covered five major areas: procedural compliance and adequacy, conservative decision making / human performance, management i
oversight, plant material condition, and technical issues. Within each area, IP identified specific actions to be taken to enhance performance. For 4
example, written communications to your staff providing management
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i expectations, seminars on those expectations, special meetings between the f
plant manager and staff, and training in specific areas such as operator I
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RNRW'NNER 9704010122 970109 1
PDR ADOCK 05000461 P
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W. Connell 4 l-training and 10 CFR 50.59.
IP is also reviewing system operating procedures i
and surveillance procedures for adequacy and enhancements, with special emphasis on pre-conditioning, procedure completeness, and fidelity with the technical specifications and Updated Final Safety Analysis Report (UFSAR).
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l To assess the Plan's effectiveness in the operations area, IP has implemented a monitoring program to oversee operating crew wrformance. The program i
includes training for monitors and evaluation steets to provide feedback on operating crew performance. IP is also implementing a senior manager revtew of j
long term material deficiencies to ensure appropriate corrsctive actions are taken in a timely manner.
l The area which was not addressed in detail in your Startup Readiness Plan or our December 16, 1996, meeting, is the criteria IP will use to evaluate the Plan's effectiveness. Because many of the issues are not hardware related, it'is extremely important that appropriate benchmarks be developed to appropriately assess the Plan's effectiveness. This item is included as item (5) below.
Based on the referenced letters, the December 16, 1996, meeting, and a January 8,1997, telephone conversation between Mr. J. Cook and Mr. J.
Caldwell, of my staff, it is our understanding that IP has taken or will take the following actions and other actions described in more detail in your September 24 and December 9, 1996, letters, prior to restarting Clinton Power Station:
(1)
Actions will be taken to ensure operators understand their prime function is to maintain the plant in a safe condition. The actions will emphasize that other considerations e.g., schedules or facility availability, are not to interfere with decisions regarding safe operation.
(2)
To improve human perfomance and ensure staff understanding of expectations regarding conservative operations and decision making, IP will provide written guidance, conduct seminars on conservative decision making, and conduct individual discussions between the plant manager and selected staff. Emphasis will be placed on proper understanding of emergency action levels and the need to continually assess plant conditions against those levels. In addition, to enhance operator performance, limits on operation of the facility and selected equipment will be established.
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W. Connell !
(3)
To improve procedural adequacy and adherence, IP will review selected system and facility operating procedures to ensure their adequacy.
IP i
will review all surveillance procedures prior to use, with special L
emphasis on pre-conditioning, completeness, and fidelity with the technical specifications and Updated Final Safety Analysis Report j
(UFSAR). Training will be provided to staff on management expectation 1
for procedural adherence and in selected areas such as plant startup j
activities and 10 CFR 50.59.
i (4)
To improve management oversight effectiveness, IP will provide training l
for management / supervisory individuals regarding their role in overseeing activities.
In addition, during the plant startup and until stable power operation is achieved, senior managers will monitor i
i o>eration's crews and provide written documentation of their o)servations.
j (5)
To improve plant material condition, IP will conduct reviews of outstanding maintenance work request to ensure the work is scheduled j
consistent with safety significance, operator impact, and plant operating conditions. Further, IP will establish a program for senior l
manager oversight of long term material deficiencies to ensure i
corrective actions are being implemented in a manner consistent with the j
items significance.
i (6)
IP will establish quantitative and qualitative benchmarks against which to assess and monitor the effectiveness of the Startup Readiness Action
-Plan items, including those items discussed above.
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In addition, I understand IP will document in a letter to the NRC the results i
of these activities and the additional activities identified in your j
September 24 and December 9,1996, letters.
Further, IP will meet with the NRC to discuss the results of its Startup Readiness Action Plan prior to j
restarting the Clinton facility.
4 Nothing in this confirmatory action letter is intended to preclude you from taking actions which you deem necessary to place the plant in a safe condition I
or maintain it in a safe condition in the event of changing conditions.
i Pursuant to Section 182 of the Atomic Energy Act, 42 U.S.C. 2232, you are required to:
1)
Notify me immediately in-writing if your understanding differs from that set forth above; l
2)
Notify me if for any reason you cannot cosplete the actions within the specified schedule and advise me in writing of your modified j
schedule of the change; and 1
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W. Connell ;
l 3)
Promptly notify me in writing if for any reason you cannot j
complete the actions discussed above.
i Issuance of this Confirmatory Action Letter does not preclude issuance of an i
order formalizing the above commitments or requiring other actions on the-part of the licensee; nor does it preclude the NRC from taking enforcement action for violations of NRC requirements that may have prompted the issuance of this letter.
In addition, failure to take the actions addressed in this Confimatory Action Letter may result in enforcement action.
In accordance with'10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter and your response will be placed in the NRC Public Document Room (PDR). To the extent possible, your response should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction. However, if you find it necessary to include such information, you should clearly indicate the specific information that you desire not to be placed in the PDR, and provide the legal basis to support your request for withholding the infomation from the public.
Sincerely,
/s/A. Bill Beach A. Bill Beach Regional Administrator Docket No. 50-461 cc:
P. Yocum, Plant Manager Clinton Power Station R. Phares, Manager-Nuclear Assessment P. J. Telthorst, Director - Licensing Nathan Schloss, Economist Office of the Attorney General K. K. Berry, Licensing Services Manager General Electric Company Chairman, DeWitt County Board State Liaison Officer Chairman, Illinois Cornerce Commission l
Sge attached continued distribution) e
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W. Connell i l
Distribution continued)
Docket File DRP J
OC/LFDCB l'"'1 :
- - r SRI Clinton, Dresden, EIT %R i
LaSalle, Quad Cities Project Manager, NRR A. B. Beach H. B. Clayton W. L. Axelson l
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