ML20206F211

Informs That NRC Considers Util Actions Associated with demand-for-info Pursuant to 10CFR50.54(f) Re C/A Program Performance at Clinton Power Station,Satisfactory & Therefore DFI Closed

ML20206F211
Person / Time
Site:	Clinton
Issue date:	04/27/1999
From:	Dyer J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Mcelwain J ILLINOIS POWER CO.
References
EA-97-435, NUDOCS 9905060042
Download: ML20206F211 (4)

Text

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\*****/ April 27,1999 EA 97-435 -

Mr. John P. McElwain

. Chief Nuclear Officer -

Clinton Power Station Illinois Power Company Mail Code V-275 P. O. Box 678 Clinton,-lL 61727

SUBJECT:

CLOSURE OF DEMAND-FOR-INFORMATION PURSUANT TO 10 CFR 50.54(f)

REGARDING CORRECTIVE ACTION PROGRAM PERFORMANCE AT CLINTON POWER STATION l

Dear Mr. McElwain:

On September 26,1997, the NRC issued a Demand-for-information (DFI) pursuant to 10 CFR 50.54(f) regarding the corrective action program at Clinton Power Station (CPS). The DFl was issued due to continuing NRC concems with the ineffectiveness of Illinois Power (IP) in identifying, evaluating, and resolving potential safety issues at CPS.

l The NRC's concems were initially raised following the September 5,1996, reactor recirculation pump seal failure event, when IP's senior management and CPS staff failed to identify significant procedural adherence issues. The NRC subsequently issued Confirmatory Action Letters (CALs) because of what the NRC perceived as'a narrow focus in IP's corrective actions for a number ofidentified problems.

1 Following the NRC Senior Management Meeting (SMM) in January 1997, IP was notified by letter dated January 27,1997, that NRC senior managers had identified the safety performance at CPS as trending adversely. Performance issues discussed by NRC senior managers included examples of nonconservative safety focus in decision-making, poor procedural adherence and adequacy, weak engineering and maintenance support to operations, and a lack of discipline and rigor during the conduct of operations. The trending letter was intended to i provide early notification to IP management that corrective measures were necessary to address the areas of concern. g

' Equipment problems identified subsequent to issuance of the trending letter continued to require  ;

NRC involvement to ensure proper resolution. As noted in the June 23,1997, Systematic Assessment of Licensee Performance report, the inspection findings and NRC effort required to achieve acceptable issue resolution, indicated that IP's management had not provided sufficient oversight to ensure the program for problem identification and resolution was effective. lilinois 9905060042 990427 POR ADOCK 05000461 8 PDR

J. McElwain I i

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Power and CPS management often did not understand the significance of hardware issues and i did not ensure that effective measures were taken to address the issues.

As a result of these continuing NRC concerns, and following the Senior Management Meeting ,

review in June 1997 of CPS improvement initiatives, IP committed to perform an Integrated i Safety Assessment (ISA) similar to an NRC Diagnostic Evaluation. In an August 21,1997, letter )

to IP, the NRC informed CPS management that the NRC would perform a Special Evaluation Team assessment to independently evaluate the thoroughness of CPS's integrated Safety '

l Assessment.

Subsequent to the June 1997 SMM and prior to the ISA, electrical circuit breaker failures on July 22 and August 5,1997, indicated that IP's preventive maintenance program for circuit breakers was inadequate. This performance insight was particularly significant given that IP had implemented a special breaker inspection program to address previously identified weaknesses  !

in breaker preventive maintenance activities. As a result of growing concerns with IP's corrective action program at CPS and the associated impact on maintaining operability of safety-related structures, systems, and components (SSCs), the NRC issued a DFl which required IP j to provide the NRC with information addressing why IP had: (1) reasonable assurance that actions taken to address the recurring weaknesses in the corrective action program had been effective, and (2) reasonable assurance that the operability of safety-related SSCs had not been adversely affected by IP's activities. ,

l' lilinois Power Company provided an initial response to the DFl on December 23,1997, and a revised response containing more detail on June 19,1998. The initial response documented IP's plans to improve its corrective action program and the planned activities to reasonably assure that safety-related SSCs will perform their intended functions. Illinois Power also described the development of an improvement plan called the Plan-for-Excellence. The June ,

1998 submittal provided information pertaining to the development of the System Design and '

Functional Validation (SDFV) initiative, verifications of corrective action effectiveness, and evaluations of maintenance practices. The final response to the DFl was provided by IP on February 8,1999, and provided information pertaining to the resolution of corrective action and root cause determination deficiencies at CPS. The final response also contained information pertaining to IP's SDFV initiative and other verification activities. Based on the results of these activities, IP stated that CPS has reasonable assurance that: (1) actions taken will correct previously recurring weaknesses in the corrective action program, and (2) safety-related SSCs will perform their intended functions.

The NRC Manual Chapter 0350 Oversight Panel met with IP management during a public meeting on March 18,1999, to discuss the content of IP's responses and the basis for IP management's confidence that the corrective action program at CPS was effective. In addition, the NRC conducted two major team inspections in February and March 1999 (the Safety System Engineering inspedon (SSEI) and the 40500 Inspection) to review the effectiveness of the corrective action program and validate the basis for IP's assertion that safety-related SSCs will perform their intended functions. The SSEl team also conducted a review of IP's SDFV project findings as well as an independent review of the reactor core isolation cooling system.

1 J. McElwain l The SSE1 team concluded that the results of the SDFV were valid and that IP had established reasonable assurance that safety-related SSCs would perform their intended safety functions as described in the design and licensing basis. The 40500 team evaluated the improvements made to the corrective action program. The NRC concluded that IP's planned and completed I

corrective actions established a basis for reasonable assurance that the corrective action program was effective.

The NRC considers IP's actions associated with the DFl to be satisfactory, and, therefore, the DFl conceming the corrective action program at CPS is considered closed. The inspection and evaluation activities outlined in the revised MC 0350 Restart Action Plan, issued on July 14, 1998, are currently under final review. Once this review is complete, a separate letter documenting the closure of the Action Plan will be forwarded to you.

Sincerely,

/s/ J. E. Dyer James E. Dyer Regional Administrator Docket No. 50-461 License No. NPF-62 cc: G. Hunger, Station Manager i

R. Phares, Manager, Nuclear Safety and Performance improvement l J. Sipek, Director- Licensing M. Aguilar, Assistant Attorney General G. Stramback, Regulatory Licensing l Services Project Manager General Electric Company Chairman, DeWitt County Board State Liaison Officer Chairman, Illinois Commerce Commission l

DOCUMENT NAME: G:\ CLIN \LTR-DFl.WPD ,f i T4 receive a copy of this document. Indicate in the bor: "C" = Copy w/o atta bnt/en ure "E" = Copy with attachment / enclosure "N" = No copy OFFICE Rill:DRP l6 Bill:ElQS,,, R HQ:OE A/ HQ:NRR _l Rlll: ORA l l NAME Dapas/kic/coef Claytort%4 C Lieberman P ' Collins 450.per Dyer d& & i DATE 04/.7//99 04/21/99 " " 04Lt/ /99 04/22/99 FfM 04/2 7/99 j OFFICIAL RECORD COPY j

'o l J. McElwain i l Distribution:

RPC (E-Mail)

J. Lieberman, OE J. Goldberg, OGC

8. Boger, NRR Project Mgr., NRR l J. Caldwell, Rill B. Clayton, Rlll SRI Clinton DRP i

DRS Rlli PRR PUBLIC IE-01 Docket File l GREENS '

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