ML20196D154
| ML20196D154 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 11/25/1998 |
| From: | Dapas M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Walter MacFarland ILLINOIS POWER CO. |
| Shared Package | |
| ML20196D161 | List: |
| References | |
| 50-461-98-19, EA-98-505, NUDOCS 9812020167 | |
| Download: ML20196D154 (4) | |
See also: IR 05000461/1998019
Text
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November 25, 1998
Mr. Walter G. MacFarland IV
Senior Vice President
Clinton Power Station
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liiinois Power Company
Mail Code V-275
P. O. Box 678
Clinton,IL 61727
SUBJECT:
CLINTON INSPECTION REPORT 50-461/98019(DRS) AND
NOTICE OF ENFORCEMENT DISCRETION
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Dear Mr. MacFarland:
On October 9,1998, the NRC completed an engineering and technical support (E&TS)
inspection at your Clinton Power Station (CPS). The purpose of the E&TS inspection was to
evaluate the effectiveness of your engineering organization in performing routine and reactive
site activities, including controls for the identification, resolution and prevention of technical
issues and problems that could degrade the quality of plant operations or safety. In addition, .
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selected items of the Clinton Restart Action Plan for Design and Configuration Control (Case
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Specific Checklist Matrix Items VI.1, VI.2 and VI.3) were reviewed. The enclosed report
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presents the results of that inspection.
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Overall, the E&TS inspection team concluded that your engineering staff was effective in the
identification of technical problems. Based on a review of selected system modifications, the
team did not identify additional problems that had not been previously identified by your
organization. 'Self-assessments exhibited a pro-active trend in the attempt to disclose
performance problems within the engineering organization. The technical quality of the selected
engineering reviews was generally sound. Based on a review of the status of your efforts to
address the restart case specific checklist items, the team concluded that additional work
remained before the items were ready for closure by the NRC.
We are concemed, however, about one violation of NRC requirements that pertained to a
sel'-revealing event involving the loss of the residual heat removal (RHR) system suppression
pool cooling (SPC) capability. Specifically, the installation of minor modification ECN 30211,
,
" Install Annunciator Bypass Switch," changed the RHR system's original configuration such that
a complete loss of SPC could occur during a design basis accident. The failure to identify,
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during the modification review process, that a change to the plant's original design basis
occurred constitutes a significant concem because the review process was established to
prevent such occurrences. There have been similar occasions where your staff did not
recognize during the design change process that a change to the original design basis had
occurred which resulted in CPS's inability to meet NRC requirements (e.g., inspection Report
G-461/98014(DRP) dated September 17,1998, pertaining to the operability of the Division ill
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9812020167 981125
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W. MacFarland
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Emergency Diesel Generator). The failure to identify that a minor modification placed the plant
in a condition that was outside the plant's original design basis was a violation of the
requirements of 10 CFR Part 50, Appendix B, Criterion Ill," Design Control."
However, I have been authorized, after consultation with the Director, Office of Enforcement and
the Acting Regional Administrator, to exercise enforcement discretion for this violation in
accordance with Section Vll.B.2, " Violations identified During Extended Shutdowns or Work
Stoppages," of NUREG 1600 " General Statement of Policy and Procedures for NRC
Enforcement Actions"(Enforcement Policy), and not issue a Notice of Violation in this case. The
decision to apply enforcement discretion was based on consideration of the following:
(1) significant NRC enforcement action was previously taken against the Illinois Power Company
for design control problems; (2) additional enforcement action was not considered necessary to
achieve remedial action for the violation due to CPS's commitment in its Plan For Excellence to
take actions to address design control issues prior to plant restart; (3) the violation was related
to problems which were present prior to the events leading to the shutdown; (4) the violation
was not classified at a severity level higher than Severity Level ll; (5) the violation was not willful;
and (6) CPS must provide reasonable assurance that safety-related systems, structures and
components will perform their intended safety functions as described in the design and licensing
basis prior to plant restart as noted in the NRC Manual Chapter 0350 Restart Panel's Case
Specific Checklist, item VI.1. Effective corrective actions for the violation will need to be
demonstrated prior to restart.
In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter and the
enclosure will be placed in the NRC Public Document Room.
We will gladly discuss any questions you have concerning this inspection.
Sincerely,
Original /s/ Marc Dapas
Marc L. Dapas, Deputy Director
Division of Reactor Projects
Docket No.: 50-461
License No.: NPF-62
Enclosure:
Inspection Report 50-461/98019(DRS)
See Attached Distribution
DOCUMENT NAME: G:\\DRS\\CLl98019.wpd
- SEE PREVIOUS CONCURRENCE
To receive a copy of this document. Indicate in the box "C" = Copy w/o attach /enci"E" = Copy w/ attach /end "N" = No mpy
OFFICE
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NAME
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DATE
11/19/98
11/19/98
11/
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11/
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11/l25/98
OFFICIAL RECORD COPY
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W. MacFarland
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modification placed the plant in a condition that was outside the plant's original design basis was
a violation of the requirements of 10CFR Part 50, Appendix B, Criterion Ill," Design Control."
However, I have been authorized, after consultation with the Director, Office of Enforcement and
the Acting Regional Administrator, to exercise enforcement discretion for this violation in
accordance with Section Vll.B.2, " Violations identified During Extended Shutdowns or Work
Stoppages," of the " General Statement of Policy and Procedures for NRC Enforcement Actions"
(Enforcement Policy), and not issue a Notice of Violation in this case. The decision to apply
enforcement discretion was based on consideration of the following: (1) significant NRC
"
enforcement action was previously taken against the lilinois Power Company for design control
problems; (2) additional enforcement action was not considered to be necessary to achieve
remedial action for the violation due to CPS's commitment in its Plan For Excellence to take
actions to address design control issues prior to plant restart; (3) the violation was related to
problems which were present prior to the events leading to the shutdown; (4) the violation was
not classified at a severity level higher than Severity Level 11; (5) the violation was not willful; and
(6) CPS must provide reasonable assurance that safety related systems, structures and
components will perform their intended safety functions as described in the design and licensing
basis prior to plant restart as listed in the NRC Manual Chapter 0350 Restart Panel's Case
Specific Checklist, item VI.1. Effective corrective actions for the violation will need to be
demonstrated prior to restart.
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in accordance with 10CFR2.790 of the NRC's " Rules of Practice," a copy of this letter and the
enclosure will be placed in the NRC Public Document Room.
We will gladly discuss any questions you have conceming this inspection.
Sincerely,
!
.
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Marc L. Dapas, Deputy Director
Division of Reactor Projects
Docket No.: 50-461
License No.: NPF-62
Enclosure:
Inspection Report 50-461/98019(DRS)
See Attached Distribution
DOCUMENT NAME: G:\\DRS\\CLl98019.wpd
To receive a copy of this document, Indicate in the box *C" = Copy w/o attach /enci"E" = Copy w/ attach /eaci"N" = No copy
l OFFICE
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DATE
11/19/98
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11/7 / 298
11/
/98
OFFICIAL RECORD COPY
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W. MacFarland
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cc w/ encl:
G. Hunger, Station Manager
R. Phares, Manager, Nuclear Safety.
and Performance improvement
J. Sipek, Director- Licensing
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N. Schloss, Economist
Office of the Attomey General
G. Stramback, Regulatory Licensing
Services Project Manager
General Electric Company
Chairman, DeWitt County Board
State Liaison Officer
Chairman, Illinois Commerce Commission
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Distribution:
J. Lieberman, OE w/enci
J. Goldberg, OGC w/enci
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B. Boger, NRR w/enci
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Project Mgr., NRR w/enci
J. Caldwell, Rlli w/enci
C. Pederson, Rill w/enci
B. Clayton, Rlli w/enci
SRI Clinton w/enci
DRP w/ enc!
TSS w/enci
DRS (2) w/enct
Rlli PRR w/enci
PUBLIC IE-01 w/enct
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Docket File w/enci
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GREENS
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LEO (E-Mail)
DOCDESK (E-Mail)
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G10017
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