ML20137K431
| 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: |
| References | |
| EA-97-133, NUDOCS 9704070029 | |
| Download: ML20137K431 (6) | |
See also: IR 05000461/1996015
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March 21,1997
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'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
in which the use of procedures achieves controlled, predictable results for planned
>
activities
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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
,;
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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
,
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9704070029 970321
ADOCK 05000461
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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
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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:
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
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OFFICIAL RECORD COPY
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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,
ames L. Caldwell, Director
4
Division of Reactor Projects
Docket No.: 50-461
,
License Nos: NPF-62
Enclosures:
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
State Liaison Officer
'
Chairman, Illinois Commerce Commission
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