ML20217E218

Forwards Demand for Info Re NRC Concerns About Illinois Power Co & Effectiveness of C/A Program at Clinton Power Station.Discusses NRC Concerns Re Licensee Effectiveness in Identifying,Evaluating & Resolving Potential Safety Issues

ML20217E218
Person / Time
Site:	Clinton
Issue date:	09/26/1997
From:	Collins S NRC (Affiliation Not Assigned)
To:	Haab L ILLINOIS POWER CO.
References
EA-97-435, NUDOCS 9710060393
Download: ML20217E218 (6)

Text

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y gg t UNITED SYATES 54L#f/

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}t NUCLEAR RECULATCRY CEMMISSION WASHINGTON, D.C. 30006 4001

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September 26, 1997 EA 97-435 Mr. Larry D. Haab Chief Executive Officer Illinois Power Company 500 South 27th Street Decatur,IL 62525 1

SUBJECT:

DEMAND FOR INFORMATION PURSUANT TO 10 CFR 50.54(f) REGA9 DING CORRECTIVE ACTION PROGRAM PERFORMANCE AT CLINTON POWER STATION

Dear Mr. Haab:

Over the past year, the NRC staff has had several management meetings with Illinois Power Company (IP) to discuss the effectiveness of the corrective action program at the Clinton Power Station (CPS). This Demand for Information is being issued because of NRC concems regarding IP's effectiveness in identifying evaluating, and resolving potential safety issues.

The NRC's concems were initially raised following the September 5,1996, reactor recirculation pump seal fa!!ure event, when IP's senior management and CPS staff's initial investigation failed to identify significant procedural adherence issues. The NRC subsequently issued Confirmatory Action Letters (CAls) stemming from what the NRC perceived as a narrow focus in IP's corrective actions for a number of identified problems.

Further, several escalated enforcement actions were issued within the past several months highlighting equipment and human performance issues.

Following the Senior Management Meeting 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 included examples of nonconservative safety focus in de:ision making, poor procedural udherence and adequacy, weak engineering and maintenance support to operations, and a lack of discipline and rigor during conduct of operations. This letter was intended to provide early notification to IP management that ,

corrective measures were necessary to address the areas of concem. 01 I

Equipment problems identified subsequent to the trending letter continued to require NRC _

involvement to ensurs p oper r6 solution. As noted in the June 23,1997, Systematic Assessment of Licensee Performance report, "The inspection findings and NRC effort

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required to achieu acceptable issue resolution indicates that Illinois Power's management had not provided sufficient oversight to ens'ure the program for problem identification and corrective action was effective. Management often did not understand the significance of hardware issues and did not ensure that effective measures were taken to address the issues."

9710060393 970926 PDR ADOCK 05000461 k $ ik 0 PDR

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L.Haab .

As a result of these contiriuing NRC conoems and following the Senior Management Meeting review in June 1997 of CPS improvement initiatives, IP cor nitted to perform an Integrated Safety Assessment (ISA) similar to an NRC Diagnostic P aluation, in an August 21,1997, letter to IP, the NRC informed CPS management that ' NRC would perform a Special Evaluation Team (SET) asssssment to independen" . iuste the scrutability and thoroughness of CPS't integrated Safety Assesst.)e.. The NRC recognizes that the ISA and SET are underway. However, these efforts were not t 3ctly chartered to address findings in relation to plant restart.

Until recently, NRC had determined that, based on inspection activities during the past year, reasonable assurance existed that IP programs and processes were capable of ensuring CFO would be operated in accordance with applicable requirements. NRC inspections had noted examples of improvements in procedural adequacy, human performance, conservatism in operational decision-mak.r.g, and plant material condition. The NRC restart oversight panel assessed the results of these NRC inspections and conducted several meetings with IP management discussing improvement actions. Based on those assessments and meetings, on August 4,1997, NRC concluded that IP commitments confirmed in the CALs had been adequately accomplished, although equipment issuet, and other activities required completion prior to restart._ At that time, the NRC restart oversight panel concluded that sufficient progress had been made in the improvement of the corrective action program to support safe plant restart.

However, the NRC Augmented Inspection Team that responded to the July 22 and August 5, 1997, electrical circuit breaker failures concluded that IP corrective actions and preventive maintenance in this area were inadequate. This is particularly significant because IP thought they had effectively addressed through their special breaker inspection program weaknesses in breaker preventive maintenance activities. These findings, subsequent to the most recent NRC senior management meeting and CAL closure, callinto question the consistency of IP's implementation of an effective corrective action program.

Therefoie, prior to CPS's restart, further information is needed to determine whether the NRC can have reasonable assurance that actions taken to correct the recurring weaknesses in the corrective action program have been effective and thei reasonable assurance exists that the

. operability of safety-related structures, systems, and components has not been adversely affected.

Accordingly, pursuant to Sections 161c,161o,182, and 186 of the Atomic Energy Act of 1954, as amended, and the NRC's regulations in 10 CFR 2.204 and 10 CFR 50.54(f), in order for the NRC to determine whether the CPS operating license should be modified, suspended, or revoked, or other enforcement action taken to ensure compliance with NRC requirements, the CPS is required to submit to the Director, Office of Enforcement, U.S.

Nuclear Regulatory Commission, Washington, DC 20555, at least two weeks prior to planned rentart, the following information, in writing and under oath or affirmation:

1. The corrective actions, both taken and planned, -)ecessary to achieve and sustain improvement in the station's corrective actions programs. This response should include your views on the root cause(s) for the past deficiencies in your corrective

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cetion programs, y:ur casessment cf the current program's deficiencies, your methods to measure the effectiveness of overallimprovements in the corrective action a

programs, and a schedule for actions not yet complete. For those actions te be completed after restart, justification (s) for deferred item (s) are to be provided; and

2. The basis for your confidence, in view of recurring weaknesses with corrective action programs, that the deficiencies that affect the operability of safety-related structures, systems, and components (SSCs) have been sufficiently identified and corrected, so that SSCs will function as designed if called upon.

Copies also shall be sent to the Director, NRR, and the Assistant General Counsel for Hearings and Enforcement at the same address, and to ths Regional Administrator, NRC Region Ill,801 Warrenville Road, Lisle, IL 60532.

Questions concoming these actions should be addressed to A. Bill Beach, Administrator, NRC 'tegion 111, at (630) 829 9657.

Following submittal of IP's response to this Demand for Information, and prior to NRC making a decision on CPS restart, NRC iritends to meet with IP management to discuss the response and to discuss the basis for confidence that the corrective actions program is effective. After reviewing your response, the NRC will determine whether further action is necessq to ensure compliance with regulatory requirements.

In accordr. net with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter and your rest onse vill be placed in the NRC Public Document Room (PDR). To the extent i

possib' , your rs sponse should not include any personal privacy, proprietary, or safeguards informatioi so th at it can be placed in the PDR without redaction if personal privacy or proprietary .irmation is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected end a redacted copy of your response that deletes such information if you request withholding of such material, you must specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g.,

explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.790(b) to support a request for withholding confidential commercial or financialinformation). If safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21.

Sincerely.

Original signed by:

Samuel J. Collins, Director Office of Nuclear Reactor Regulation Docket No. 50-461 cc: See next page DOCUMENT NAME: 435NRR.DDFl OFFICE RA: Rill C D:OE OGC IANM EDO NAME ABeach* JLloberman" JGoldberg" S N r[s LCallan**

DATE 9/22/97 9/22/97 9/22/97 9/ 4 /97 9/24/97

'By telecon OFFICIAL RECORD COPY "See previous concurrences

. L. t b 3

,. i action programs, y:ur cssessment of the current progr:m's deficiencies, y:ur methods to measure the effectiveness of overall improvements in the corrective action

, progrhms, and a schedule for actions not yet complete. For those actions to be complet61 after restart, justification (s) for deferred item (s) are to be provided; and

2. The basis for your confidence, in view of recurring weaknesses with corrective action programs, that the deficiencies that affect the operability of safety-related structures, systems, and components (SSCs) have been sufficiently identified and corrected, so that SSCs will function as designed if called upon.

Coples also shall be sent to the Director, NRR, and the Assistant General Counsel for Hearings and Enforcement at the same address, and to the Regional Administrator, NRC Region lil, 801 Warrenville Road, Lisle, IL 60532.

Questions conceming these actions should be addressed to A. Bill Beach, Administrator, NRC Region Ill, at (630) 829 9657.

Following submittal of IP's response to this Demand for Information, and prior to NRC making a decision on CPS restart, NRC intends to meet with IP management to discuss the response and to discuss the basis for confidence tha; trio corrective actions program is effective. After reviewing your response, the NRC will detumine whether further action is necessary to ensure compliance with regulatory requirements.

In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter and your response will be placed in the NRC Public Document Room (PDR). To the extent possible, your response should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction. If personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the infermation that should be protected and a redacted copy of your response that deletes such information. If you request withholding of such material, you must specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g.,

explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.790(b) to support a request for withholding confidential commercial or financial information). If safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21.

Sincerely, Original signed by:

Samuel J. Collins, Director Office of Nuclear Reactor Regulation Docket No. 50-461 cc: See next page DOCUMENT NAME: 435NRR.DDFl OFFICE RA: Rill C D:OE OGC RNh EDO NAME ABeach* JLieberman" JGoldberg" SMs LCaiian-DATE 9/22/97 9/22/97 9/22/97 9/ 4 /97 9/24/97 By telecon OFFICIAL RECORD COPY "See previous concurrences

4 Clinton Power Station, Unit No.1 lilinois Power Company

. cc:

John G. Cook lilinois Department of Nuclear Safety Senior Vice President Omco of Nuclear Facility Safety Clinton Power Station 1035 Outer Park Drive P.O. Box 678 Springfield,IL 62704 Clinton,IL 61727 Joseph V. Sipek Larry Wgley Director - Licensing Manager Nuclear Station Clinton Power Station

Engineering Department P.O. Box 678 Clinton Power Station Mall Code V920 P.O. Box 678 Clhton,IL 61727 Clinton,IL 61727 Resident inspector U.S. Nuclear Regulatory Commission RR#3, Box 22g A Clinton,IL 61727 4

R. T. Hill 1

Licensing Services Manager 4 i General Electric Company 4

175 Curtner Avenue, M/C 481 San Jose, CA 95125 Regional Administrator, Region 111 U.S. Nuclear Regulatory Commission 801 Warrenville Road 4

Lisle, IL 60532 4351

Chairman of DeWitt County c/o County Clerk's Office DeWtt County Courthouse Clinton,IL 61727 J, W. Blattner i Project Manager Sargent & Lundy Engineers 55 East Monroe Street Chicago,IL 60603 1

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o' oe DISTRIBl> TION:

Docket File PUBLIC PDill 3 Reading SCollins/FMiraglia EAdensam (EGA1)

GMarcus JHopkins DPickett GTracy, OEDO GGrant, Region 111 JCaldwell, Region lli RZimmerman OGC ACRS CArmstrong (CAA1)

Region lll Enforcement Coordinator EDO R/F E.

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