ML20148H819
| ML20148H819 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 06/09/1997 |
| From: | Beach A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Jackie Cook ILLINOIS POWER CO. |
| Shared Package | |
| ML20148H822 | List: |
| References | |
| 50-461-96-09, 50-461-96-10, 50-461-96-11, 50-461-96-12, 50-461-96-14, 50-461-96-9, EA-96-412, EA-97-001, EA-97-002, EA-97-060, EA-97-1, EA-97-2, EA-97-60, NUDOCS 9706110241 | |
| Download: ML20148H819 (6) | |
See also: IR 05000461/1996009
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UNITED STATES
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NUCLEAR REOULATORY COMMISSION
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REGION 111
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801 WARRENVILLE ROAD
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USLE. ILUNOIS 60532-4351
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June 9, 1997
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[As96-412, 97-001.97-002, and 97-060
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Mr. John G. Cook
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Senior Vice President
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Illinois Power Company
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503 S. 27th Street
Decatur. IL 62525
SUEJECT:
NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTIES -
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$450.000 (NRC Routine Inspection Report 50-461/96009(DRP). Special
Inspection Report 50-461/96010(DRP), Operational Safety Team
. Inspection Re) ort 50-461/96011(DRS). Inspection Report
50-461/96012()RS). Special Inspection Report 50-461/96014(DRP).
and Office of Investigations Report 3-96-047)
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Dear Mr. Cook:
This refers to five inspections conducted from July 30. 1996, through
January 23, 1997. at the Clinton Power Station (CPS).
The inspections
included evaluations and assessments of the 1) September 5.1996. reactor
recirculation pt np seal failure. 2) operations and engineering activities
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supporting operations 3) Division III emergency diesel generator
inoperability. 4) feedwater containment isolation check valves * inoperability,
and 6) radiation protection program.
A management meeting was held on
September 23, 1996, to discuss Illinois Power Company's assessment of the
September 5,1996, reactor recirculation pump seal failure event, and a public
exit neeting was held on October 4. 1996, to present the NRC's ins]ection
findir;gs.
Exits for the other inspections were conducted on Novem)er 21.
1996.iDecember 12. 1996, and January 23, 1997.
In addition, the NRC Office of
Investigations conducted an investigation of the circumstances of the
September 5. 1996. event.
Because of the seriousness of the issues emanating
from the insaections, predecisional enforcement conferences were conducted on
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February 4. March 4. and March 20. 1997.
Based on;the information developed during the inspections and the information
CPS provided during the predecisional enforcement conferences, the NRC has
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determined that a number of significant violations of NRC requirements
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occurred from September 5. 1996, through January 23, 1997. The violations
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demonstrate a lack of conservative decision-making. pervasive procedural
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adherence problems. inappropriate procedures, and a lack of rigor in
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conducting routine plant activities.
These violations have occurred
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throughout various site organizations.
Enclosure 1 contains a Notice of
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Violation and Proposed Imposition of Civil Penalties (Notice), that describes
the violations.
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9706110241 970609
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ADOCK 05000461
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J. G. Cook
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The violations in the Notice are grouped in five sections as follows:
Section A of the Notice. " Reactor Recirculation Pump Seal Failure."
describes two significant procedure violations during an activity
undertaken on September 5.1996, to allow continued plant operaticn of
isolating the "B" reactor coolant loop, thereby stopping. or limi:ing.
the suspected leaking pump shaft seal package.
The procedural
violations directly resulted in reactor coolant leakage considera0y
exceeding the allowed Technical Specification Limit and requiring a
plant shutdown.
CPS site supervision and management inappropriately
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emphasized attaining a single loop configuration to allow continus:
power operation.
This resulted in a focus to operate the plant ra:ner
than the more conservative decision to shut down the unit. The
deliberate actions of members of the shift crew on September 5.196.
resulted in very significant violations.
Based on a review of the
evidence obtained from the Office of Investigations. NRC inspecticts.
and enforcement conferences. CPS's actions demonstrated careless
disregard for procedural requirements.
Section B of the Notice. " Failure to Follow Procedures." involves
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seventeen violations involving operations and radiation protectior
procedures which collectively demonstrates a breakdown in the con:-ci f
activities involving the adherence to procedures. The violations
demonstrated that CPS had established an environment that condonec
procedure compliance through accomplishment of the user's interpre:ati:-
of the procedures * intent without regard for the actual procedurai
steps.
Section C of the Notice. " Inoperable Emergency Diesel Generator "
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involves two violations associated with the Division III Emergent,
Diesel Generator (EDG). The licensee failed to maintain design cce:rc~
with this EDG and failed to identify and correct a condition adverse ::
quality. As a result the EDG was inoperable for more than a year
Section D of the Notice. " Failure to Perform Safety Evaluations."
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involves seven violations for a failure to perform safety evaluat":ns
required by 10 CFR 50.59.
Safety evaluations were not perforred :
justify operating the plant differently than described in the updi:ec
safety analysis report (USAR): to justify the acceptability of
performing tests on operable equipment; or to justify continued
operation when as-found plant conditions were different than the LA
description.
The examples represented a significant lack of atter:ior
toward the process for performing 10 CFR 50.59 evaluations.
Section E of the Notice. " Ineffective Corrective Actions to Resche
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Inoperable Containment Penetrations." involves two violations for
inoperable feedwater primary containment isolation valves caused t
inadequate corrective action for a longstanding equipment problem an:: e
failure to perform adequate testing to assure Technical Specifica: en
surveillance requirements were met.
This resulted in the serious
degradation of two containment penetrations such that they ma,. no: w e
been able to function when required.
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J. G. Cook
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Individually and collectively, the violations are serious.
These violations
included a pervasive problem regarding procedural quality and adherence which
you acknowledged during the predecisional enforcement conference, weaknesses
in the conduct of operations. and weaknesses in engineering support to
operations.
CPS management failed to ensure that its economic expectations
had been put in proper focus with safe.. conservative facility operation.
In
the aggregate, given the depth and breadth of the violations, it is evident
that existing management control systems were not used effectively to ensure
early detection and timely resolution of conditions adverse to safe )lant
operation.
For example, a number of procedures, written to ensure tlat
systems were operated and tested consistent with the facility's design bases,
were inappropriately changed or not followed.
Site-wide procedures were
usually looked upon as guidance rather than as requirements to be followed.
Tests were performed on operating systems without procedures and without
required reviews to ensure that unreviewed safety questions did not exist.
Beyond the operations oriented-violations, significant deficiencies existed in
the engineering 3rogram with regards to safety evaluations and operability
essessments.
Otler inspection activities identified a significant issue
involving the Division III EDG being inoperable for almost a year due to an
inadequate calibration procedure.
In addition. the feedwater outboard
containment isolation valves' ability to fully perform their intended safety
function was not determined over the past operating cycle due to inadequate
test configurations.
Lastly, several radiation protection violations were
caused by procedure compliance problems which were similar to those identified
in operations and erigineering.
These violations occurred well after the
September 5.1996, reactor recirculation pump seal failure event indicating
CPS was having difficulty implementing effective corrective actions for
procedure compliance problems.
In that regard, it is of particular concern
that the corrective actions discussed at the March 20. 1997, predecisional
radiation protection enforcement conference were narrowly focused on the
individual items.
Your staff failed to discuss the issues as an integrated
theme from a radiation protection perspective and as they related to the
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broader procedure compliance problems discussed at the two previous
enforcement conferences.
This indicated that CPS was not looking at the
identified problems in an integrated fashion.
In summary, the inspection findings demonstrated 1) a lack of conservative
decision-making. 2) pervasive procedural adherence problems as indicated by
individuals believing it was acceptable to not follow existing procedures in
order to accomplish work activities. and 3) poor-quality procedures.
Extensive NRC intervention was recuired to ensure CPS recognized and
understood the problems' scope anc magnitude.
This included management's lack
of recognition of its failure to make the conservative decision to shut down
the unit on September 5.1996, and CPS's lack of understanding of the
associated procedure violations.
Due to the safety significance of the violations discussed above. their
relationship to operational safety. and in accordance with the NRC Enforcement
policy. NUREG-1600. the violations in Section A of the Notice have been
categorized in the aggregate as a Severity Level II problem.
The violations
in Sections B - E have each been categorized as Severity Level III problems.
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J. G. Cook
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Significant civil penalties are warranted to emphasize to you and to other
reactor licensees the importance of strong management oversight and direction
from both the site and utility in maintaining a clear focus on operational
safety; the need for plant personnel to challenge and investigate
discrepancies; the need to adequately plan safety-significant activities: the
need to take timely and effective corrective actions: and the need for a
strong self-assessment program.
Enforcement discretion is being exercised as
provided by Section VII.A. of the Enforcement Policy to assess civil penalties
of $200.000. (the maximum statutory amount) for the violations in Section A of
the Notice. and civil penalties of $100.000 for the violations in Section B.
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In accordance with Section VI.B.2 of the Policy, civil penalties of $50.000
for the violations in each of Sections C - E are being assessed.
The
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assessments are more fully described in Enclosure 2.
Accordingly. I have been authorized after consultation with the Director.
Office of Enforcement, and the Deputy Executive Director for Regulatory
Effectiveness, to issue the enclosed Notice of Violation and Proposed
Imposition of Civil Penalty in the amount of $450.000.
But for the extended
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shutdown of CPS and the substantial corrective actions taken during this
shutdown period to improve performance, a larger civil penalty would have been
proposed.
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
necessary to ensure compliance with NRC regulatory requirements.
I further
note that my staff continues to review activities at CPS, and further
enforcement actions may be taken if additional violations are identified.
In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice." a copy of
this letter, its enclosure (s). and your response will be placed in the NRC
Public Document Room (PDR).
Sincerely.
uv. O
/A. Bill Beach
Regional Administrator
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Enclosures:
1.
Notice of Violation and Proposed
Imposition of Civil Penalties
2.
Civil Penalty Assessment
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J. G. Cook
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cc w/encls:
W. D. Romberg, Assittant
Vice President
P. Yocum. Plant Manager
Clinton Power Station
R. Phares. Manager-Nuclear Assessment
J. Sipek Director - Licensing
Nathan Schloss, Economist
Office of the Attorney General
G. Stramback. Regulatory Licensing
Services Project Manager
General Electric Company
Chairnan. DeWitt County Board
State Liaison Officer
Chairman. Illinois Commerce Commission
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J. G. Cook
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DISTRIBUTION.
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PUBLIC JE 4f
SECY
CA
L. Callan. EDO
E. Jordan. DEDO
J. Lieberman. OE
L. Chandler. OGC
J. Cn.'dberg. OGC
S. Collins. NRR
R. Zimmerman. NRR
Enforcement Coordinators
RI. Ril and RIV
SRI-Clinton. Dresden. LaSalle,
and Quad Cities
T. Pruett. RIV
G. Marcus. NRR
D. Pickett, NRR
J. Gilliland OPA
H. Bell. OIG
G. Caputo. 01
L. Tremper. OC
D. Ross. AE00
OE:ES
OE:EA (2)
G. Johnson. OC/DAF
RAO: Rill
SLO:RIII
PAO: Rill
OC/LFDCB
Docket File
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