ML20217G747

Forwards Insp Rept 50-461/97-07 on 970313-0522 & Nov.Insp Identified Addl Issues Re Findings from Insp Rept 50-461/96-15 Re Deficiencies in CPS Administrative Procedure Governing Procedure Adherence

ML20217G747
Person / Time
Site:	Clinton
Issue date:	09/29/1997
From:	Grobe J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Jackie Cook ILLINOIS POWER CO.
Shared Package
ML20217G749	List: IR 05000461/1997007 ML20217G747 ML20217G752
References
50-461-96-15, 50-461-97-07, 50-461-97-7, EA-97-133, NUDOCS 9710140187
Download: ML20217G747 (3)

See also: IR 05000461/1997007

Text

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ig~ REGloN ill tii ' g 601 WARALNvlLLE ROAD " LISLE, ILLINOIS rM32 4%1 ..... Septmunr 29, 1997 , . EA 97133 Mr. John G. Cook Senior Vice President Clinton Power Station

lilinois Power Company

Mall Code V 275 , i P. O. Box 678 Clinton,IL 61727 SUBJECT: NRC INSPECTION REPORT No. 50 461/97007(DRP) Dear Mr. Cook: On August 11,1997, the NRC completed a special safety inspection of the c!rcumstances surrounding an event on March 9,1997. The event involved operator actions that deviated from Clinton Power Station (CPS) procedures during surveillance testing. The enclosed report presents the results of that inspection. This inspection identified additionalissues relative to the findings from inspection Report 50-461/96015 regarding deficiencies in CPS' administrative procedure goveming procedure adherence. This inspection also identified additional examples where the deficiencies led directly to operators falling to follow procedures. NRC regulations and CPS' Technical Specifications require activities affecting quality be prescribed by procedures which are implemented as written, or are changed following appropriate review and approval. CPS' administrative procedure goveming procedure adherence was not consistent with these requirements. Specifically the CPS procedure allowed nonperformance of procedure steps without the necessary reviews and approvals, inspection Report 50-461/96015 identified two apparent violations. The apparent violation identified in this inspection is considered a further example of the originalissue. The apparent violations are of significant regulatory concem because performance of work in accordance with procedures provides the mechanism by which activities are planned and controlled to achieve _ expected and desired results This report identified two additional examples of work not perfomied as planned because of CPS' procedure adherence policy; five examples were identified in Inspection Report 50-461/96015, 9710140187 970929 PDH ADOCK 05000461 0 N l

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. J. Cook 2- The circumstances surrounding the a pparent violations for this and the 96015 inspection, were discussed with you and members of your staff at exit meetings on May 22 and August 11,1997. During these discussions, you acknowledged the circumstances surrounding the apparent i violations and described corrective actions taken to address them. These actions included: (1) development and implementation of a more appropriate procedure Goveming procedure adherence on April 1,1997; (2) training sessions on the new procedure adherence policy for all plant staff who perform activities important to safety; and (3) initiation of an ongoing program to munitor procedure adherence at your facility These corrective actions are documented in NRC inspection Reports 50-461/97000,97011, and 97012. The apparent */lotation in this report,in combination with the apparent violations from inspection Report 50 '81/96015, are being considered for escalated enforcement action in accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions"(Enforcement Policy), NUREG 1600. During the August 11,1997, telephone conversation with Mr. Frederick Brown, NRC Project Engineer, you indicated that a predecisional enforcement conference would not be necessary for the apparent violations identified in inspection Report 50-461/96015 and this report because of our common understanding of the facts and corrective actions taken rogarding the apparent

! violations. You will be advised by separate correspondence of the results of our deliberations on this matter. No responso regardir g the current examples of the apparent violation is required at this time, in addition to the apparent violations discussed above, an additional violation of NRC requirements was identified. The NRC inspectors identified that the fuel pool cooling system t operating procedure was inadequate. Specifically, performance of the procedure led to overfilling the spent fuel pool, significantly distracting the operating crew attention from an in-progress surveillance test. The disruption resulted in sufficient time passing that the operators thought they a needed to violate a CPS procedure in order to maintain safety related systems in an operable condition. The violation associated with the spent fuel pool activity is cited in the enclosed Notice of Violation (Notice), and the circumstances surrounding the violation are described in detailin the enclosed report. In addition, a second violation regarding an inadequate high pressure core spray system surveillance procedure, described in inspection Report 50-461/96015, is also cited in the enclosed Notice. Please note that you are required to respond to this letter for the two violations and should follow the instructions specified in the enclosed Notice when preparing your response. The NRC will use your response, in part, to determine whether further enforcement actions are necessary to ensure compliance with regulatory requirements. ! 1 -

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J. Cook 4 In accordance wilh 10 CFR 2.790 of the NRC's * Rules of Practice," a copy of tHs letter and its enclosures will be placed in the NRC Public Docunwnt Room. Sincerely, /s/ J. A. urobo John A. Grobe, Act!ng Director

Division of Reactor Safety l Docket No.: 50-461 l License No: NPF 62 Enclosures: 1. Notice of Violation 2. Inspection Report No. 50-461/97007(DRP) cc w/encis: W. D. Romberg, Assistant Vice President P. Yocum, Plant Manager Clinton Power Station R. Phares, Manager Nuclear Assessment J. Sipok, Director. Licensing Nathan Schloss, Economist Office of the Attorney General G. Stramback, Regulatory Licensing Services Project Manager General Electric Company Chairman, DeWitt County Board < State Liaison Officer Chairman, lilinois Commerce Commission Distribution: Docket File w/encls DRP w/encls OC/LFDCB w/encls PUBLIC IE 01 w/encls SRI Clinton w/encls Rlll PRR w/encls Project Manager, NRR w/encls CAA1 w/encls (E mail) Rlli Enf. Coordinator w/encls A. B. Beach w/encls TSS w/oncis Deputy RA w/encls DOCDESK (E mail) DRS (2) w/encls J. ' .eberman, OE w/encls J. Goldberg, OGC w/encls R. Zimmerman, NRR w/encls DOCUMENT NAME: R:\\lNSPRPTS\\ POWERS \\ CLIN \\CLl97007.DRP To receive a copy of this document, Indicate in the box "C" = Copy without attach / encl 'E" = Copy with attach /enci "N" = No copy OFFICE Rljl Rlli / OE / Rlli J NAME [ Clayt[ Liebe Grob DATE 9/8/97 97 J/f97 9/1.h ' OFFICIAL RECORD COPY \\\\ }}