ML20137K431

Discusses Insp Rept 50-461/96-15 on 961213-0214 & Forwards Notice of Violation.Violation of Concern Because of Lack of Rigor in Ensuring That TS Surveillance Was Performed as Described in TS & FSAR Sys Discussion

ML20137K431
Person / Time
Site:	Clinton
Issue date:	03/21/1997
From:	Caldwell J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Connell W ILLINOIS POWER CO.
Shared Package
ML20137K435	List: ML20137K431 ML20137K447 ML20137K462
References
EA-97-133, NUDOCS 9704070029
Download: ML20137K431 (6)

See also: IR 05000461/1996015

Text

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March 21,1997

'

'EA 97-133 '

Mr. Wilfred Connell, Vice' President -

Clinton Power Station

- lilinois Power Cornpeny

. Mail Code V 275

' P. O. Box 678

Clinton, IL 61727

. SUBJECT: NRC INSPECTION REPORT NO. 50-461/96015 (DRP)

Dear Mr. Connell:

On February 14,1997, the NRC completed an inspection at your Clinton Facility. The

enclosed report presents the results of that inspection.

During the inspection period, activities at the Clinton facility were marked by continuing

problems with procedure adequacy and adherence, and conservative decision making. The

observed problems extendeo beyond operations and engineering to encompass radiation

protection and maintenance staffs. The continuing problems indicate that Clinton Power

Station's (CPS) corrective actions following the September 5,1996, reactor recirculation

pump seal failure have not been fully effective in establishing an operational environment

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in which the use of procedures achieves controlled, predictable results for planned

L activities

During this period we also identified that CPS's upper tier administrative program for f

. procedure adherence contains flaws similar to those described during the February 4,

1997, Predecisional Enforcement conference. Specifically, CPS's administrative process

'

authorizes plant staff to deviate from written procedures without the appropriate reviews [-

or approvals specified in the Technical Specifications and Operational Requirements

Manual. The continuing performance problems and the inadequacies in the upper tier

administrative procedures program reflect poorly on the effectiveness of CPS's Startup

. Readiness Action Plan (SRAP) actions and progress. Along with the concerns about CPS's

l performance', we are concerned that CPS has yet to develop quantitative and qualitative

benchmarks for rnessuring the effectiveness of your SRAP actions, as discussed in our

,

Confirmatory Action Letter dated January 9,1997.

Based on the results of this inspection, the NRC has determined that three violations of

NRC requirements occurred. These violations are cited in the enclosed Notice of Violation

,; (Notice) and the circumstances surrounding them are described in detail in the enclosed

j report. The first violation involves two examples of the failure to perform safety

evaluations for changes in the operation of the facility as described in the Updated Safety

, Analysis Report (FSAR). The first example is of concern because in involved a lack of rigor

,

Lin ensuring that a, Technical Specification (TS) Surveillance was performed as described in

/

9704070029 970321

PDR ADOCK 05000461

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PDR

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_ -- . - __ .- _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ -

~ - . . - . - . - . - - . - ._ - - _

W. Connell -2-

the TS basis and FSAR system discussion. The second example is of concern because it

demonstrates your staff's willingness to live with degraded material conditions without

'

regard to the system design as described in the FSAR. The second violation involves a

failure to identify and correct diesel driven fire pump fuel filter clogging problems. This  ;

violation is of concern because it indicates a lack of sensitivity to fuel filter clogging ,

problems despite two previous NRC violations for similar but unrelated diesel fire pump c

fuel filter clogging issues. T9 third violation involves the failure to perform required

radiological surveys prior tc, pressurizing a radwaste transfer pipe. This violation is of

concem because it indicates a lack of conservative radiological safety perspective on the

part of your staff. ,

You are required to respond to this letter and should follow the instructions specified in the

enclosed Notice when preparing your response. The NRC will use your response, in part,

- to determine whether further enforcement action is necessary to ensure compliance with

regulatory requirements.

in addition to the three identified violations, two apparent violations. with 18 separate

examples, were identified and are being considered for escalated enforcement actioriin )

accordance with the " General Statement of Policy and Procedure for NRC Enforcement

Actions" (Enforcement Policy), NUREG 1600. These violations are associated with

inadequate procedures and inadequate procedure adherence, as discussed above.

Accordingly, no Notice of Violations is presently being issued for these inspection findings.

In addition, please be advised that the number and characterization of apparent violations

described in the enclosed inspection report may change as a result of further NRC review.

You will be advised by separate correspondence of the results of our deliberations on this

matter. No response regarding these apparent violations is required at this time.

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 Public Document Room (PDR).

Sincerely,

Original signed by

John A. Grobe for

James L. Caldwell, Director

Division of Reactor Projects j

Docket No.: 50-461

License Nos: NPF-62

Enclosures:

1. Notice of Violation

2. Inspection Report

No. 50-461/96015

(See attached distribution)

____ _ ._ _ __

. . _ _ _ _ _ _ _ . _ . _ _ _ _ . _ . _ _ _ _ . _ __ . _ _ _ . . _ . . _ . _ _

l

W. Connell -3-

Distribution:

,

cc w/oncl: . 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, Licensin9 Services Manager

General Electric Company

Chairman, DeWitt County Board

State Liaison Officer

Chairman, Illinois Commerce Commission

. Docket File w/enci DRP w/enci

OC/LFDCB w/enci PUBLIC IE-01 w/ encl

SRI Clinton, Dresden, Rill PRR w/ encl

LaSalle, Quad Cities CAA1 w/enci (E-mail)

Project Manager, NRR w/enci A. B. Beach, w/enci

Rlli Enf. Coordinator, w/ encl W. L. Axelson, w/ encl

TSS w/ encl DRS (3) w/enci

R. Zimmerman, NRR J. Lieberman, OE

J. Goldberg, OGC

Document: R:\lnsprpts\ powers \ clin \cli96015.drp

To receive a copy of this document, Indcate in the box "C" = Copy without attach /enci

"E". - Copy with attach /enci "N" = No copy ,

OFFICE Rlli _

Rlll M Rlll M N 6

NAME w ri s h p xorsk & ) ,caidwW cl4 &c

DATE 03$/97 03/ 697 h3/2(/97 I 3/M//7

OFFICIAL RECORD COPY

.. . _ . - . _ . . _ ._ _ __

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UNITE 3 STATES

1. g** "2%* NUCLEAR REGULATORY COMMISSION

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REGloN lit

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U " 801 WARRENVILLE ROAD

USLE, RINolS 60632-4361

(..... March 21,-1997

EA 97133 -

Mr. Wilfred Connell, Vice President

Clinton Power Station

lilinois Power Company

- Mail Code V-275

P. O. Box 678

Clinton, IL 61727

. SUBJECT: NRC INSPECTION REPORT NO. 50-461/96015 (DRP)

Dear Mr. Connell:

'

' On February 14,1997, the NRC completed an inspection at your Clinton Facility.~ The

enclosed report presents the results of that inspection.

During the inspection period, activities at the Clinton facility were marked by continuing -

problems with procedure adequacy and adherence, and conservative decision making. The

observed problems extended beyond operations and engineering to encompass radiation

protection and maintenance staffs. The continuing' problems indicate that Clinton Power

Station's (CPS) corrective actions following the September 5,1996, reactor recirculation

pump seal failure have not been fully effective in establishing an operational environment

in which the use of procedures achieves controlled, predictable results for planned

activities

During this period we also identified that CPS's upper tier administrative program for

procedure adherence contains flaws similar to those described during the February 4,

1997, Predecisional Enforcement conference. Specifically, CPS's administrative process

authorizes' plant staff to deviate from written procedures without the appropriate reviews

or approvals specified in the Technical Specifications and Operational Requirements

Manual. The continuing performance problems and the inadequacies in the upper tier

administrative procedures program reflect poorly on the effectiveness of CPS's Startup

Readiness Action Plan (SRAP) actions and progress. Along with the concerns about CPS's

performance, we are concerned that CPS has yet to develop quantitative and qualitative

,

benchmarks for measuring the effectiveness of your SRAP actions, as discussed in our

- Confirmatory Action Letter dated January 9,1997.

Based on the'results of this inspection, the NRC has determined that three violations of ., ,

NRC requirements occurred. These violations are cited in the enclosed Notice of Violation 1

(Notice) and the circumstances surrounding them are described in detail in the enclosed

- report. The first violation involves two examples of the failure to perform safety

evaluations for changes in the operation of the facility as described in the Updated Safety

,

Analysis Report (FSAR). The first example is of concem because in involved a lack of rigor

in' ensuring that a Technical Specification (TS) Surveillance was performed as described in i

!

.

- . . -- _

_

W. Connell -2-

the TS basis and FSAR system discussion. The second example is of concern because it

demonstrates your staff's willingness to live with degraded material conditions without

regard to the system design as described in the FSAR. The second violation involves a

failure to identify and correct diesel driven fire pump fuel filter clogging problems. This

violation is of concern because it indicates a lack of sensitivity to fuel filter clogging ,

problems despite two previous NRC violations for similar but unrelated diesel fire pump

fuel filter clogging issues. The third violation involves the failure to perform required

radiological surveys prior to pressurizing a radwaste transfer pipe. This violation is of

concern because it indicates a lack of conservative radiological safety perspective on the

part of your staff.

You are required to respond to this letter and should follow the instructions specified in the

enclosed Notice when preparing your response. The NRC will use your response,in part,

to determine whether further enforcement action is necessary to ensure compliance with

'

regulatory requirements.

In addition to the three identified violations, two apparent violations, with 18 separate

examples, were identified and are being considered for escalated enforcement action in

accordance with the " General Statement of Policy and Procedure for NRC Enforcement

Actions" (Enforcement Policy), NUREG-1600. These violations are associated with

inadequate procedures and inadequate procedure adherence, as discussed above.

Accordingly, no Notice of Violations is presently being issued for these inspection findings.

In addition, please be advised that the number and characterization of apparent violations

described in the enclosed inspection report may change as a result of further NRC review. ,

You will be advised by separate correspondence of the results of our deliberations on this

matter. No response regarding these apparent violations is required at this time.

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 Public Document Room (PDR).

Sincerely,

4 ames L. Caldwell, Director

Division of Reactor Projects l

Docket No.: 50-461 ,

1

License Nos: NPF-62

Enclosures:

1. Notice of Violation

2. Inspection Report

No. 50-461/96015

(See attached distribution)

_

- - - . . . - .. .. . - . . .. .. ..

!

.

W. Connell -3- j

-

Distribution: )

cc w/ encl: 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 I

State Liaison Officer  !

'

Chairman, Illinois Commerce Commission

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