ML20196A347

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-461/99-11 Issued on 990430.Corrective Actions Will Be Examined During Future Inspections

ML20196A347
Person / Time
Site:	Clinton
Issue date:	06/16/1999
From:	Kozak T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Mcelwain J ILLINOIS POWER CO.
References
50-461-99-11, NUDOCS 9906220196
Download: ML20196A347 (2)

See also: IR 05000461/1999011

Text

.. ..

June ~16, 1999

i

i Mr. John P. McElwain '

Chief Nuclear Officer <

. Clinton Power Station

Illinois Power Company

Mail Code V-275 4

P. O. Box 678

Clinton,IL 61727'

SUBJECT: NOTICE OF VIOLATION (CLINTON INSPECTION REPORT 50-461/99011(DRP))

i

Dear Mr. McElwain:

This will acknowledge receipt of your letter dated May 28,1999, in response to our

4

. letter dated April 30,1999, transmitting a Notice of Violation associated with inspections '

Report 50-461/99011.' We have reviewed your corrective actions and have no further questions

at this time. These corrective actions will be examined during future inspections.

Sincerely,

/s/ T. Kozak

Thomas J. Kozak, Chief .

Reactor Projects Branch 4

Docket No. 50-461

License No. NPF-82. ,

~

cc:. G. Hunger, Station Manager .

R. Phares, Manager, Nuclear Safety .

and Performance improvement i

J. Sipek, Director - Licensing

cc w/itr dtd 5/28/99: M. Aguilar, Assistant Attorney General j'

G. Stramback, Regulatory Licensing

Services Project Manager

General Electric Company

.

Chairman, DeWitt County Board

. State Liaison Officer

' Chairman, Illinois Commerce Commission

DOCUMENT'NAME: G:\CLi \CLl99011.TY

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liknois Power Company

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Tel 217 935 8881 x3900

Fax 217 935-4632

-

John P. McElwain

Chief Nuclear Officer

P9WER uam3

An tilinova Company

May 28, 1999

Docket No. 50-461

Document Control Desk

Nuclear Regulatory Commission

Washington, D.C. 20555

Subject: Response to Notice of Violation Contained

in Inspection Report 50-461/99011(DRP)

Dear Madam or Sir:

The attachment to this letter contains the Clinton Power Station (CPS) response

to the Notice of Violation of Nuclear Regulatory Commission (NRC) requirements

documented in NRC Inspection Report 50-461/98011 (DRP). CPS admits that the

violation occurred.

CPS believes that the actions described in the attached response addresses the

concerns identified in the Notice of Violation.

Sincerely yours,

$40- if-

k John P. McElwam

ChiefNuclear Officer

MRS/krk

Attachment

cc: NRC Clinton Project Man;ger

NRC Resident OfIice, V-690

Regional Administrator, Region III, USNRC

Illinois Department of Nuclear Safety

JUN 7 8

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Attachment

to U-603213 j

Page1of2

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Response to Notice of Violation 50-461/99011-02

. The violation states in part:

"10 CFR Part 50, Appendix B, Criterion XVI, " Corrective Actions," states, in

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part, that measures shall be established to assure that conditions adverse to quality,

such as failures, malfunctions, de6ciencies, deviations, defective material and

equipment, and nonconformances are promptly identified and corrected.

10 CFR Part 50, Appendix B, Criterion III, " Design Control," states, in part, that

measures shall be established to assure that applicable regulatory requirements and

the design basis as speci6ed in the license application, for those structures,

systems, and components to which this appendix applies are correctly translated

into speci6 cations, drawings, procedures, and instructions.

Contrary to the above, as of April 9,1999, the licensee, despite having considered

the issue closed in its corrective action program, had failed to correct a condition

adverse to quality. This resulted in an erroneous design value being maintained in

a design basis calculation and correspondingly, a continuing violation of Criterion

III. Specifically, on July 2,1997, the NRC informed the licensee that they had not

established measures to translate the horsepower rating of the hydrogen mixing

compressors into design basis load calculation 19-AK-05, Revision 5, " Calculation ,

for Diesel Generator Load Monitoring." The licensee documented this issue in j

their corrective action system and closed the issue when they believed corrective I

actions were implemented. Subsequent NRC inspections concluded, despite the

closure in licensee's corrective action system, that the licensee had not correctly

translated, as of April 9,1999, the horsepower rating of the hydrogen mixing ]

compressors into the design calculations for loading of the emergency diesel

generator."

Backaround and Reason forViolation

Condition report 1-97-07-105 identified that the horsepower requirements for the

g6 ogen mixing compressors were greater than the horsepower used in the calculation

performed to determine the maximum room temperature ofequipment in the hydrogen

mixing compressor room. This calculation is used to support the environmental

qualification of equipment in the hydrogen mixing compressor room. The use of the

incorrect horsepower for the hydrogen mixing compressor in the calculation was

discovered during resolution of the concerns with degraded offsite electrical power supply

voltage. The corrective actions for condition report 1-97-07-105 identified several items

that may need to be changed to correct the error in the horsepower requirements of the

hydrogen mixing compressors. The potential items impacted included, surveillance

procedures, Updated Safety Analysis Report, and some calculations. The change to the

diesel generator loading calculation was evaluated as part of one of the corrective actions

for the condition report.' However, the resolution to the condition report did not identify

that calculation 19-AK-05 " Calculation for Diesel Generator Load Monitoring" needed to

be revised to correct the horsepower requirement error for the hydrogen mixing

compressors.

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Attachment

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to U403213

,

, Page 2 of 2

Calculation 19iAK-05 was revised as part of the resolution of the degraded offsite voltage ,

project; however, the new revision did not include changes to the horsepower  !

requirements for the hydrogen mixing compressors. Investigation revealed that individuals

revising and reviewing the revision to calculation 19-AK-05 were aware of the need to

p change the horsepower requirements for the hydrogen mixing compressors because of i

/ previous verbal communication, but apparently forgot to revise the calculation to reflect

the horsepower change. The need to revise calculation 19-AK-05 was not formally

documented, and the calcula: ion revision was being performed as part of a larger scope of

work for the degraded offsite voltage project. The reason for the violation is that during

the resolution ofcondition report 1-97-07-105, the individual that identified the

calculations affected by the change in horsepower requirements for the hydrogen mixing

compressors failed to identify calculation 19-AK-05 as requiring revision. Since

calculation 19-AK-05 was not identified as requiring revision, it was not included as a

calculation requiring revision in the resolution to condition report 1-97-07-105.

/

Corrective Steos Taken and Results Achieved

.

Calculation 19-AK-05 " Calculation for Diesel Generator Load Monitoring" was revised

using the correct horsepower for the hydrogen mixing compressors. A review was

performed to identify if there were any other calculations impacted by the change to the

horsepower requirements for the hydrogen mixing compressors that were not identified  !

during the resolution ofcondition report 1-97-07-105. This reviewidentified several i

other electrical calculations that require revision that were not listed as impacted in ,

condition report 1-97-07-105. These revisions will be completed as part of the corrective

action to condition report 1-99-07-105.

Correedve Steos to Avoid Further Violations )

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Since 1997, when the problem with the incorrect horsepower for the hydrogen mixing

compressors was identified, the impact review process for calculations has been improved.

' A revision to Nuclear Station Ragia-ing procedure E.1 Calculation has been completed

which revised the process for coaWing Calculation-Impact Assessments. Review of this

new process concludM that the new process is adequate and most likely would have

identified that calculation 19-AK-05 required revision to change the horsepower

requirements for the hydrogen mixing compressors.

Date when Full Comoliance Will Be Achieved

Clinton Power Station is in full compliance with 10 CFR 50, Appendix B, Criterion XVI

. and Criterion III, with regards to the failure to revise diesel loading calculation 19-AK-05

for a change to the hydrogen mixing compressor horsepower.