ML20236Q943

Forwards Revised Restart Action Plan.Action Plan Includes Summary of Major Activities That Have Taken Place Since July 1997,current Membership of Site Performance Improvement & Restart Oversight Panel & Case Specific Checklist

ML20236Q943
Person / Time
Site:	Clinton
Issue date:	07/14/1998
From:	Grobe J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Walter MacFarland ILLINOIS POWER CO.
References
NUDOCS 9807210142
Download: ML20236Q943 (9)

Text

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e e UNITED STATES

1. p5 %g~ o, NUCLEAR REGULATORY COMMISSION 8 n REGION 111

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2 801 WARRENVILLE ROAD LISLE, ILLINOIS 60532-4351 July 14, 1998 k ..... f 1

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Mr. Walter G. MacFarland IV Senior Vice President Clinton Power Station Illinois Power Company Mail Code V-275 P. O. Box 678 Clinton,IL 61727

Dear Mr. MacFarland:

On March 13,1997, NRC forwarded a Restart Action Plan to Illinois Power (IP), which was developed in accordance with NRC Inspection Manual Chapter (MC) 0350, " Staff Guidelines for Restart Approval," and included a list of specific items that were to be reviewed prior to restart of Clinton Power Station. The results of our review of those items was documented in a letter and inspection report that was forwarded to IP on July 15,1997. Since then, several activities have transpired which necessitated a revision to the NRC's oversight process and Restart Action Plan.

Included in these activities was the docketing by IP of a simmary of the Clinton Plan For Excellence on February 19,1997, which included new co.;mitments that will be completed prior to plant startup.

This letter forwards our revised Restart Action Plan. The Action Plan includes a summary of the major activities that have taken place since July 1997, the cu6 rent membership of our Site Performance improvement and Restart Oversight Panel, and a Case Specific Checklist specifying the items that the NRC considers as necessary to be addressed prior to plant restart.

The items listed in the Case Specific Checklist will be reviewed prior to plant restart during our scheduled inspections as described to you in our May 28,1998, letter conceming the latest Plant Performance Review of CPS.

The routine, public Restart Oversight Panel Meetings between NRC and IP will be focussed on the progress made by IP to address the specific restart commitments listed in the summary for the Plan For Excellence as well as the items in the Case Specific Checklist. Similar to our July 15,1997, letter, we will forward a letter to IP to close out the revised Restart Action Plan once the items listed in the Case Specific Checklist have been adequately resolved. Our Case Specific Checklist may be modified as necessary if other items requiring resolution prior to plant restart are identified or if a change to IP's commitments is requested.

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- W. MacFarland IV In accordance with 10 CFR 2.7g0 of the NRC's " Rules of Practice," a copy of this letter and its enclosure will be placed in the NRC Public Document Room.

Sincerely,

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hn A. Grobe, Director Division of Reactor Safety Docket No.: 50-461 License No.: NPF-62 '

Enclosure:

Startup Readiness Action Plan

.c w/ encl: G. Hunger, Station Manager R. Phares, Manager, Nuclear Safety and Performance improvement J. Sipek, Director- Licensing N. Schloss, Economist Offics of the Attomey General G. Stramback, Regulatory Licensing Services Project Manager .

General Electric Company Chairman, DeWitt County Board State Liaison Officer Chairman, lilinois Commerce Commission i

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- W. MacFarland IV In accordance with 10 CFR 2.790 of the NRC's

• Rules of Practice," a copy of this letter and its enclosure will be placed in the NRC Public Document Room.

Sincerely, f

/s/ John A. Grobe John A. Grobe, Director Division of Reactor Safety Docket No.: 50-461 License No.: NPF-62

Enclosure:

Startup Readiness Action Plan cc w/ encl: G. Hunger, Station Manager R. Phares, Manager, Nuclear Safety -

and Performance Improvement J. Sipek, Director- Licensing 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 Chtirman, Illinois Commerce Commission i

DOCUMENT NAME: G:\ clin \insppin6.ec2

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OFFICE Rlli 16 Rill ldf Rlli . _ ; l l -l NAME Kozak:co% Bellamy 4f-[a Grobe Q@ [

l DATE 06/Ji/98 09/11/98 R&1lA**r 07//4g8 l

) OFFICIAL RECORD COPY.

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1 Enclosure Startup Readiness Action Plan for Clinton Power Station A. PURPOSE To establish guidelines for approving restart of Clinton Power Station which has been shutdown since September 1996.

B. BACKGROUND NRC Inspection Report 50-461/97012, "Clinton Startup Readiness Action Plan Close-out," dated July 15,1997, documented the completion of the original startup readines.= action plan with the exception of recirculation pump seal performance, feedwater check valve performance, and monitoring of control room activities during restart of the facility. Since then, several activities have transpired which necessitated a revision to the NRC's oversight process.

On August 4,1997, the NRC closed Confirmatory Action Letters (CALs) 50-461/ Rill-96013, 97001, and 97006. CAL Rill-96013 concemed the September 5,1996, event, CAL Rlll-97001 concerned the Clinton Startup Readiness Action Plan, and CAL Rill-97006 involved degraded containment coatings. Additionalissues regarding degraded voltage, breaker reliability, and temperature qualification of emergency diesel generator components remained open pending resolution prior to startup of the facility.

Between August 5 and 15,1997, the NRC performed an Augmented Inspection Team review of a July 22 and August 5,1997, failure of two 4.16 KV circuit breakers. The results of the inspection were documented in NRC Inspection Report 50-461/97018, dated November 24,1997. The NRC determined that the circuit breaker failures were caused by inadequate and ; appropriate maintenance activities, and deficiencies in the corrective action program. The circuit breaker deficiencies resulted in a potential common mode failure being introduced into at least all 4.16KV j Westinghouse Corporation circuit breakers.

On August 6,1997, the NRC issued CAL 50-461/ Rill-97009. The actions that were agreed to be taken in the letter included the preservation of the August 5 failed circuit breaker, the formation of an independent review team to establish the breaker failure mechanism, and the documentation j in a letter to the NRC that reasonable assurance existed that all safety-related circuit breakers 1 will function when called upon. A meeting to discuss the circuit breaker determinations with the NRC is required prior to restart of the facility.

Between August and October 1997, a licensee initiated integrated Safety Assessment (ISA) team identified significant weaknesses in operations, engineering, maintenance, and plant support.

Identified weaknesses included the overall conduct of operations, management and supervision of operations, performance of system engineers, control and understanding of the design basis, maintenance work scheduling, work processes, and radiation protection performance. In addition, the ISA identified weaknesses in barriers to prevent safety problems that were not typical of facilities with a strong nuclear safety culture. These weak barriers were identified at all levels of management associated with CPS and were dispersed throughout CPS' processes.

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On September 26,1997, the NRC issued a Demand For Information (DFI) regarding inadequacies in the corrective actic,n program. The DFl required that, prior to restart, information be provided regarding improvements in the corrective action program and the basis for why I safety-related structures, systems, and components will function as designed if called upon.

Following submittal of the DFI, and prior to the NRC mt2 king a decision on CPS' readiness to restart, NRC intends to meet with Illinois Power management to discuss the response and the basis for confidence that the corrective action pogram is effective. q On January 2,1998, the NRC documented the results of an NRC Special Evaluation Team (SET) which evaluated activities at CPS and validated the findings of the ISA. The SET determined that the ISA conducted an effective diagnostic assessment of the station's performance and reached substantive conclusions. The SET determined, based on an assessment of CPS performance from June 1995 through October 1997, that the following were the root causes of the licensee's problems conceming management and leadership; programs, processes, and procedures; and human performance: (1) management generally did not establish and implement effective performance standards; (2) CPS programs, processes, and procedures did not consistently provide defense in depth to assure plant activities were conducted in a safe manner; (3) problem identification was inconsistent and evaluation and corrective actions were generally ineffective; and (4) management did not ensure that the infrastructure was suitable to support major changes.

On January 15,1998, a letter was forwarded to Illinois Power which documented that NRC senior managers had placed Clinton on the NRC Watch List as a Category 2 plant and that increased NRC attention was warranted until a period of demonstrated improved performance was obtained. NRC letter dated January 21,1998, documented that the NRC Site Performance improvement Oversight Panel activities had been re-initiated.

On February 3,1998, CPS announced several management changes following the January 5, 1998, announcement that PECO Energy Company would provide management services at CPS.

On February 19,1998, CPS docketed a summary of the Plan For Excellence (PFE) including restart commitments. The PFE summary identified actions to achieve broad goals, including strategies for management oversight, personnel development, communications, safety culture, training of personnel, conduct of operations, corrective action program, work management program, procedures, preventive maintenance, plant equipment performance, system engineer effectiveness, backlogs of maintenance and surveillance tests, hardware / design readiness, organization readiness, and program readiness.

Meetings were held between the NRC and CPS on September 26 and November 14,1997, and January 18, February 5, March 17, and May 5,1998, to discuss activities involving circuit breakers, the corrective action program, preventive maintenance, work control, quality assurance, design reviews, plant material condition, the conduct of operations, and the development and implementation of the PFE.

C. SITE PERFORMANCE IMPRO$ MENT AND RESTART OVERSIGHT PANEL MEMBERSHIP An NRC Site Performance Improvement And Restart Oversight Panel has been established and is composed of the members listed below. The panel has the responsibility for developing and l maintaining this Action Plan and reviewing all available information related to CPS' current 2

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I performance and emerging issues, the actions taken by the licensee to address performance weaknesses, and the effectiveness of the licensee's corrective actions. Once the panel has completed the actions listed in the Case Specific Checklist (CSC) below and has determined that the licensee has effectively completed the activities committed to prior to plant restart, the panel will provide a written recommendation for approval of plant restart to the Region ill Regional Administrator. Once licensee performance has improved to a level where this additional NRC attention is no longer necessary, the panel will provide a written recommendation to the Region til Regional Administrator for approval to close this plan.

John A. Grobe, Chairman CPS Oversight Panel Ronald R. Bellamy, Vice Chairman, CPS Oversight Panel Thomas J. Kozak, Chief, Reactor Projects Branch 4 Jon B. Hopkins, Project Manager Troy W. Pruett, Senior Resident inspector Karia K. Stoedter, Resident inspector Carey E. Brown, Resident inspector D. CASE SPECIFIC CHECKLIST The Case Specific Checklist for CPS specifies the items that the NRC considers as necessary to be addressed prior plant restart. These items were derived from the NRC's review of inspection activities including the ISA and SET inspections, other NRC inspections, the PFE, CALs, the DFI, and Licensee Event Reports. The corrective actior:s for these items will be reviewed during the planned inspection activities. The results of the inspections will be evaluated by the NRC's Oversight Panel. The checklist will periodically be revised to reflect changes in plant performance noted by the NRC's Oversight Panel.

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CASE SPECIFIC CHECKLIST REM NUMBER SOURCE DOCUMENT STATUS I Management and Supervision 1.1 Estabhsh and Implement Root cause from the NRC Safety Evaluaton Open Management Expectations Team (SET) Report. CPS Plan For Excellence (PFE) Summary Secton 2.1.

Il Conduct of Operations

11. 1 Estabhsh and implement NRC Inspection Reports 97022,97025, and Open Continuing Operator Training 98003 PFE Summary Sections 2.2 and 2.4.

Emphasizing TS Adherence / Knowledge and Recognition of Degraded Conditions

11. 2 Estabhsh and implement an NRC Inspection Report 97019. Open Effectrve Equipment Clearance Program 11 3 Review and Revise Abnormal NRC Letter dated June 9,1997," imposition of Open Operations Sections of CMI Penalty." NRC Inspecton Report 98003.

Operatons Procedures PFE Summary Secton 2.2.

11 4 Estabhsh and implement an NRC Inspecton Report 97022. PFE Summary Open Effective Risk Assessment Sectons 2.2 and 2.4.

Program lli Corrective Actions 111. 1 Estabhsh and implement Demand For Informaton (DFI) ttem 1. SET Open Actons to Achieve and Report. PFE Summary 2.3.

Sustain improvement in the Correctve Acton Program til 2 Establish and Implement DFlitem 1. SET Report. PFE Summary 2.3. Open Performance Measures To q Assess Performance IV Structures, Systems, and Components (SSCs) Operational Readiness IV.1 Estabbsh Program to Reduce Confirmatory Acton Letter Rill-97-001. NRC Open and Maintain Main Control Inspecton Report 98003. PFE Summary Room Deficiencies. Secton 2.4.

IV.2 Provide Reasonable DFlitem 2. PFE Summary Secton 2.3. Open Assurance that Deficiencies Affectng Safety Related SSCs Have Been Identified and Cortacted.

IV.3 Resolve issues Associated Confirmatory Acton Letter Rill-97-009. PFE Open With Circuit Breaker Failures. Summary Secton 2.4.

N.4 Resolve Degraded Voltage NRC inspecton Report 97012. PFE Summary Open and Electncal Distributor Secton 2.4.

Concems.

IV.5 Resolve Fire Protecton Safe SET Report. PFE Summary Section 2.4. Open Shutdown Concems i

ITEM NUMBER SOURCE DOCUMENT STATUS IV.6 Complete Root Cause PFE Section 2.4. NRC inspection Report 97012. Open Analysis of Recirculation Pump Seal Failures and Develop Field Performance Measures IV.7 Resolve EDG Concerns SET Report. Open V Maintenance V.1 Develop Process to Review SET Report. PFE Summary Section 2.4. Open Deferrais of Preventive Maintenance items.

V.2 Provide Reasonable LERs 98001 and 98004, NRC inspection Report Open Assurance that Quairfied 97020.

Materials and Parts are Installed in Plant Systems V.3 Establish Maintenance Rule PFE Summary Section 2.4. Open Program VI Design and Configuration Control VL1 Provide Reasonable SET Report. PFE Summary Section 2.4. Open Assurance That Safety System Design and Functional Validation Related SSCs Will Perform (SDFV) Program.

Their Intended Safety Functions as Described in the Design and Licensing Basis.

VI.2 Validate the Adequacy and SET Report. SDFV Program. Open Control of Calculations VI.3 Validate the Adequacy and SET Report. SDFV Program. Open Control of the Setpoint Program.

Vil Emergency Preparedness Program Vll.1 Develop and Implement EP NRC inspection Report 98003,97022 Open improvement initiatives Vill Licensing Actions Vill.1 Develop a List and Schedule General Open for Anticipated Licensing Action Submittals Affecting Plant Restart 1

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