ML20148H819

Discusses Insp Repts 50-461/96-09,50-461/96-10,50-461/96-11, 50-461/96-12 & 50-461/96-14 on 960730-970123 & Forwards NOV & Proposed Imposition of Civil Penalty in Amount of $450,000

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: ML20148H819 ML20148H825
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

E REGION 111

! U E 801 WARRENVILLE ROAD

,#, USLE. ILUNOIS 60532-4351

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June 9, 1997

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L [As96-412, 97-001.97-002, and 97-060

l Mr. John G. Cook

! Senior Vice President

! Illinois Power Company

l 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

! 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 l

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  !

determined that a number of significant violations of NRC requirements j

occurred from September 5. 1996, through January 23, 1997. The violations i

demonstrate a lack of conservative decision-making. pervasive procedural 1

, adherence problems. inappropriate procedures, and a lack of rigor in

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conducting routine plant activities. These violations have occurred

l throughout various site organizations. Enclosure 1 contains a Notice of

l Violation and Proposed Imposition of Civil Penalties (Notice), that describes

the violations.

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9706110241 970609  ?

PDR ADOCK 05000461 o

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J. G. Cook -2-

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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 )

emphasized attaining a single loop configuration to allow continus: l

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

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 "

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."

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

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 -3-

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l 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 '

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 -4-

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 l

of $200.000. (the maximum statutory amount) for the violations in Section A of l

the Notice. and civil penalties of $100.000 for the violations in Section B. i

In accordance with Section VI.B.2 of the Policy, civil penalties of $50.000 l

for the violations in each of Sections C - E are being assessed. The '

assessments are more fully described in Enclosure 2.

Accordingly. I have been authorized after consultation with the Director. l

Office of Enforcement, and the Deputy Executive Director for Regulatory

Effectiveness, to issue the enclosed Notice of Violation and Proposed l

Imposition of Civil Penalty in the amount of $450.000. But for the extended l

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

c e o.

Enclosures: 1. Notice of Violation and Proposed

Imposition of Civil Penalties

2. Civil Penalty Assessment

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J. G. Cook -5

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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DISTRIBUTION.

PUBLIC JE 4f

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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

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OE:ES

OE:EA (2)

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RAO: Rill

SLO:RIII

PAO: Rill

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Docket File

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