ML20212H498
| ML20212H498 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 03/03/1987 |
| From: | Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Gerstner W ILLINOIS POWER CO. |
| Shared Package | |
| ML20212H502 | List: |
| References | |
| EA-87-011, EA-87-11, NUDOCS 8703060127 | |
| Download: ML20212H498 (5) | |
See also: IR 05000461/1986048
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3 1987
Docket No. 50-461
License No. CPPR-137
EA 87-11
Illinois Power Company
ATTN:
Mr. W. C. Gerstner
Executive Vice President
500 South 27th Street
Decatur, IL 62525
Gentlemen:
SUBJECT:
NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY
(NRC INSPECTION REPORTS NO. 50-461/86048(DRP); N0. 50-461/86053(DRS);
AND NO. 50-461/86054(DRP))
This refers to three NRC safety inspections conducted by the NRC Region III
-staff during the period July 1 through October 10, 1986, of activities at
Clinton Power Station authorized by NRC Construction Permit No. CPPR-137.
During these three inspections, numerous violations of NRC requirements
were identified. ThesubjectInspectionReportsNo. 50-461/86048(DRP),
No. 50-461/86053(DRS), and No. 50-461/86054(DRP) were sent to you on
and September 26, 1986, respectively.
Enforcement
August 22, November 28,ith you and members of your staff on August
conferences were held w
29, 1986,
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and again on December 18, 1986, and a management meeting was held with your
staff on September 19, 1986, to discuss these violations, their causes and
your corrective actions.
Based on the information you provided in those meetings and our inspection of
the actions taken, including the correction of material deficiencies, we
believe Illinois Power Company has made adequate progress in resolving the
identified problems.
However, the weakness described herein should not have
occurred.
The inspections conducted at the Clinton Power Station during the period
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July 1 through October 10, 1986, disclosed numerous examples which demonstrated
that the checks and balances of the quality assurance program did not work
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effectively in the areas of facility design, maintenance, and modifications.
The inspection findings indicated an apparent lack of awareness, by all levels
of management, of the extent of the significant deficiencies in these areas and
a failure to effectively implement a program to assure that modifications to
the plant were properly designed and implemented and that testing adequately
CERTIFIED MAIL
REIURN RECEIPI REQUESTED
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8703060127 870303
ADOCK 0500
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verified that the maintenance and modifications were performed as intended.
Tne inspections identified numerous instances wherein Illinois Power Company
failed to comply with NRC regulatory requirements.
The violations included
the failure of engineering personnel to ensure that valve operators and motors
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would Mrform as designed and to properly document. safety evaluations.
In
addition, personnel failed to ensure that modification packages were complete
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and that maintenance procedures for valve lubrication would assure proper valve
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performance.
The post-modification and maintenance testing programs failed to
demonstrate that work activities were accomplished satisfactorily.
Further,
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corrective actions failed to ensure that identified deficiencies were effectively
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and completely resolved.
The violations in the maintenance and modification
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area were of particular concern to the NRC because these work activities were
performed by the same organization that.is performing these activities during
plant operations.
A key _ factor in many of the problems leading to these
violations was the lack of adequate corrective action.
The licensee's staff
-the necessary corrective action; problems identified, knew the root cause, andthe pr
was already aware of many of the
however
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not raised to the management level necess,ary to obtain action, or, when raised
.to that level, were not addressed. Additional management attention was necessary
to (1) ensure that the maintenance and modification programs provide sufficient
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controls to preclude conditions that could adversely affect the operation of
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plant systems and equipment and (2) ensure that identified conditions adverse
to quality are adequately corrected and preventative actions implemented.
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Violations A-D set forth multiple examples of problems related to design-
control; instructions and procedures; test control; and corrective action.
Violation C.1 illustrates many of these concerns.
During the modification and
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testing of motor o)erated valves, ap?roximately 17 valves were modified under
work requests whic1 improperly set tie limit switches.
This had no effect on
valve operation when they were operated with the associated TEST / NORMAL switch
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in the test position; however, in the normal position, valve closure would cause
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the valve motor to stay energized at the end of valve travel.
This would result
in locked rotor current, damage to the motor, and possible damage to the valve
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and valve operator. The problem was inadvertently discovered during a valve
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lineup on March 6, 1986, when main steam system containment isolation valves
were found closed so tightly that they could not be opened by the handwheel and
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would not work electrically.
Post-maintenance or post-modification testing was
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inadequate to discover the problem since it was done with the TEST / NORMAL switch
in the test position.
In addition, operational surveillance testing, also done
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in the test mode, would not have detected the faulty switch setting.
If the
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problem had gone undetected until the valves were needed, the associated systems
could have been rendered inoperable.
Additional examples of similar problems
aredocumentedinthesubjectinspectionreports.
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The violation involving the Shutdown Service Water (SSW) system piping and
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cubicles located in the Clinton Power Station Screenhouse is significant because
the area was below the elevation of the probable maximum flood and not protected
against the effects of flooding.
This condition was identified by an NRC
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WAR L 31987
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inspector on July 25, 1986. . The Clinton Power Station's quality assurance
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_ program for turnover and acceptance of plant areas did not identify this
deficiency and did not assure that the screenhouse SSW system pump cubicles
and piping tunnel were-completed in compliance with the Clinton Power Station
FSAR.
Emergency procedures for coping with a high lake level were found to
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be deficient in that they did not caution personnel to monitor those portions
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of the plant which could be affected by flooding conditions. These emergency
procedures assumed that sufficient plant equipment woulcobe available to
support plant operations even up to the maximum probable flood height.
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To emphasize the need.for you to ensure that your programs continue to have
adequate controls so that plant safety and system operability will not be
jeopardized,Ihavebeenauthorized,afterconsultationwiththeDirector,
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Office of Inspection and Enforcement, to issue the enclosed Notice of Violation
and Proposed Imposition of Civil Penalt
Seventy-FiveThousandDollars($75,000)yinthecumulativeamountof
for the violations described in the
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enclosed Notice.
In accordance with the " General Statement of Policy and
Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1986)
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(Enforcement-Policy), the violations de:;cribed in the enclosed Notice have been
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categorized as a Severity-level III problem.' The base value of a civil penalty
for a Severity Level III problem or violation is $50,000.
In determining the
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amount of the civil penalty, we have considered the safety significance of the
violations, the existence of prior notice of many of these violations, and the
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fact that many of the violations contain multiple examples.
Because of the
multiple examples of violations in these functional areas, the base civil
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penalty has been increased by 50 percent.
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In order to assure that these weaknesses do not recur in the quality assurance
program for operations, you are required to respond to the enclosed Notice and
should follow the instructions specified in the enclosed Notice when preparing
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your response.
Your response should be directed at the following three areas.
First, you should confirm the completeness of the actions you have taken to
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correct the violations cited in the Notice as well as additional examples of
similarproblemsdescribedinthesubjectinspectionreports.
Second, you
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should confirm how you have changed or strengthened the implementing procedures
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to preclude similar violations in these subject areas during future modification
or maintenance activities.
Third, you should confirm the steps you have taken
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to ensure that continuing attention by management will be provided to prevent
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recurrence of these kinds of failures.
The NRC recognizes that some corrective
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actions have already been implemented and that you may have already addressed
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some of these concerns in previous correspondence.
Therefore, in your response
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you may reference previous submittals where appropriate.
In any event, all
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corrective actions need to be resolved prior to full power licensing.
After
reviewing your response to the Notice, including your proposed corrective
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actions and the results of future inspections, the NRC will determine whether
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further enforcement action is necessary to ensure compliance with NRC regulatory
requirements.
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Clinton Power Station
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3 1987
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In accordance with 10 CFR 2.790 of the NRC's'" Rules of Practice," Part 2,~
Title 10, Code of Federal Regulations, a copy of this letter and the enclosure
will be placed in the NRC's Public Document Room.
The.responsesdirectedbythisletterandtheenclosedNoticearenotsubject
to the clearance procedures of the Office of Management and Budget as required
by the Paperwork Reduction Act of 1980, PL 96-511.
Sincerely,
c eisirvil cfsnzd tr/
A. Cert caric
A. Bert Davis
Acting Regional Administrator
Enclosures:
1.
Proposed Imposition of
Civil Penalty
2.
Inspection Report
No. 50-461/86048 (DRP)
3.
Inspection Report
No. 50-461/86053 (DRS)
4.
Inspection Report
No. 50-461/86054 (DRP)
Docket No. 50-461
cc w/ enclosure:
DCS/RSb (RIDS)
Licensing Fee Management Branch
Resident. Inspector, RIII
Richard Hubbard
Gary N. Wright, Manager
Nuclear Facility Safety
Mark Jason, Assistant
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Attorney General,
Environmental Control Division
H. S. Taylor, Quality Assurance
Division
David Rosenblatt, Governor's
Office of Consumer Services
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Clinton Power Company
3 1987
Distribution
.PDR
LPDR
SECY
CA
JMTaylor, IE
ABDavis, RIII
ABeach, IE
HWong, IE
JLieberman, 0GC
Enforcement Coordinators
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RI, RII,.RIII, RIV, RV
JSniezek, DEDROGR
HDenton, NRR
BHayes 01
SConnelly,0IA
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JCrooks, AE00
EA File
ES File
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