ML20202E485

Discusses Insp Repts 50-461/96-15,50-461/97-07 & 50-461/97-20 Conducted from Dec 1996 to Aug 1997.Insp Identified Issues Re Failure to Adequately Implement CA Program & Inadequate Conduct of Maint Activities

ML20202E485
Person / Time
Site:	Clinton
Issue date:	01/08/1998
From:	Beach A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Jackie Cook ILLINOIS POWER CO.
References
50-461-96-15, 50-461-97-07, 50-461-97-20, 50-461-97-7, EA-97-133, EA-97-467, NUDOCS 9802180161
Download: ML20202E485 (5)

See also: IR 05000461/1996015

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PUBUC DOCUMEHT ROOM

EA 97-133

EA 97-467

Mr. John G. Cook

Senior Vice President

Clinton Power Station

Illinois Power Company

Mail Code V-275

P.O. Box 676

Clinton,IL 61727

SUBJECT: EXERCISE OF ENFORCEMENT DISCRETION (NRC inspection Reports

50-461/96015 and 50 461/97007 and NRC Special inspection Report

50-461/97020)

Dear Mr. Coolc

This refers to three inspections conducted from December 1996 to August 1997, at the l

Clinton Power Station (CPS). The inspections identified issus associated with procedure

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adherence and adequacy; failure to adequately implement the corrective action program;

and inadequate conduct of maintenance activities. The NRC discussed the significance of

each issue and the need forlasting and effective corrective action with members of the

f CPS staff at the inspection exit meetings conducted on February 14, May 22, August 11,

and August 29,1997.

The inspection reports documented that the NRC would contact CPS management to

establish a date for a predecisional enforcement conference. You previously indicated that

a conference on the procedure adherence and adequacy issue was unnecessary because

this issue was a subset of a prior enforcement action (EA)', for which the CPS

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management team was still implementing corrective action. After further deliberation, the

NRC determined that a predecisional enforcement conference was not necessary for any of

these issues based on the fact that these issues are each subsets of problems that

represent a breakdown in CPS systems for corrective action, work control, and procedure

adherence / adequacy. In addition, lilinois Power representatives have stated during several

meetings with the NRC that effective corrective actions for these problems will be

implemented prior to retuming the unit to service. Lastly, the corrective actions for the

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1 EA Nos: 96-412,97-001,97-002 and 97 060 A Notice of Violation and Proposed Impoemon of CM'

Penalbes of $450.000 was issued on June 9.1997, for a Severity Leveill problem and several Seventy Levellit

problems. These pertained to a programmatic breakdown in plant operations and radiation protection, the failure to

follow procedures, the inability to implement effective corrective actions, and the failure to perform safety evaluations.

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programmatic problems will be addressed by the NRC throupS the oversight program, as

provided in NRC Inspection Manual Chapter 0350, " Staff Gu% lines for Restart Approval."

The NRC determined that violations of NRC requirements occurred. This determination

was based on the information identified during the inspections and at the exit interviews.

The apparent violations have been grouped into four areas. -

The first and second grouping of violations addressed procedure adherence and adequacy

- problems. The first group of violations pertained to an upper tier document that

inadequately addressed adherence to procedures. These violations were documented as

two apparent violations in inspection Report 461/96015. The upper tier document was

inadequate because it contained guidance that permitted personnel (with a supervisor's

approval) to deviate from a procedure solely based on their assessment of the need and

acceptability. This document was inadequate because it circumvented the Technical

Specification temporary change process. The Technical Specification temporary change

process permitted temporary procedure changes if the change did not alter the intent of the

procedure, the change was documented, and two members of plant management approved

the change. The second grouping documented procedure violations that collectively

demonstrated a programmatic breakdown in con' ' of activities involving adherence to -

procedures and the adequacy of procedures. Tt. i violations were documented as

sixteen apparent violations in inspection Reports 4o1/96015 and 461/g7007. Clinton Power

Station had implemented a policy that resulted in casual procedure compliance which-

essentially permitted procedure compliance through accomplishment of the procedures'

intent as determined by the personnel performing the activity. This policy was implemented -

without regard for the actual procedural sters or the Technical Specification temporary

change process.-

The third grouping of violations perisined to the CPS staff failure to adequately implement

the corrective action program and evaluate neon light failures (16 were identified in the first

half of 1997) to determine if a significant condition adverse to quality existed. The noon

lights are used in the control room in association with hand switches to signify component

status.- Significant NRC involvement was necessary before the CPS staff performed an in-

depth review. The review determined that a recent repair resolving an unrelated problem .

resulted in the use of a soldering flux that was not intended for electrical applications. This

flux Mused the neon light failures and could blow the control power fuse to the associated

components. Loss of control power would prevent automatic or remote operation of the

components.

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J. Cook -3-

The fourth grouping of violations portainoa to the inadequate control of materials and work

procedures. As stated in the previous paragraph, after extensive NRC intervention, CPS -

determined that the flux used was not intended for electrical applications. In addition,

CPS's evaluation determined that the work procedures were not adequate to compensate

for the inexperience of the electricians performing the activity.

Individually and collectively each grouping of violations is a significant regulatory concem

because the barriers and processes in place at the time of the inspections were not

adequate or effective to assure that; (1) conditions adverse to quality were promptly  ;

identified and corrected, (2) written procedures were implemented and maintained for

safety-related activities, and (3) the conduct of maintenance activities did not affect the -

design of the system and the quality of procedures was sufficient for successful

performance by inexperienced personnel. Each group of violations would be designated as

a Severity Level 111 problem in accordance with the NRC's NUREG-1600, " General

Statement of Policy and Procedures for NRC Enforcement Actions,"(Enforcement Policy).

Normally, such problems would be subject to civil penalties. However, I have been

authorized after consultation with the Director, Office of Enforcement, to exercise

enforcement discretion in accordance with Section Vll.B.6, "Vanations involving Special

Circumstances," of the Enforcement Policy and not issue Notices of Violation or propose

civil penalties in this case. The decision to apply enforcement discretion was based on

consideration of the following: (1) significant NRC enforcement action (EAs96-412,

97-001, 97-002,97-060, and EA 97-132) was taken against the lilinois Power Company for

several programmatic breakdowns (including procedure adherence / adequacy and use of an -  !

unapproved lubricant on safety related breakers) for which CPS's corrective actions

encompassed the root causes for these violations; (2) some of the violations were related

to activities before the enforcement action was issued; (3) the violations would not be

classified at a severity level higher than Severity Level lil; and (4) lilinois Power Company

will meet with the NRC to explain their efforts to resolve these issues prior to restart as

reflected in the NRC's September 26,1997, Demand for Information (EA 97-435). Effective

corrective actions will need to be demonstrated prior to restart. The NRC must emphasize

that failure to achieve effective performance improvement would lead to more significant

regulatory sanctions.

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J. Cook 4

In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter will

be placed in the NRC Public Document Room (POR).

Sincerely,

d

A. Bill Beach

Regional Administrator

License Number:- NPF-62

cc: W. D. Romberg, Assistant

Vice President

R. Phares, Manager, Nuclear Safety

and Performance improvement

J. Sipek, Director- Licensing '

Nathan 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:

PUBLIC IE-01

SECY [

CA

LCallan, EDO

AThadant, DEDE

LChandler, OGC

JGoldberg, OGC

SCollins, NRR

RZimmetman, NRR

Enforcement Coordinators

RI, Ril and RIV

Resident inspector, Clinton

G. Marcus, NRR

D Pickett, NRR

JGilliland, OPA

HBell, OlG

GCaputo,01

TMariin, AEOD

OE:ES

OE:EA (2)

RAO:Rlll

SLO: Rill

PAO: Rill

OCFOILFARB

DRP

Docket File

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