ML19332A134

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Responds to NRC 800623 Ltr Re Violations Noted in IE Insp Rept 50-461/80-10.Clarifies 800723 Reply Re Authorization for Drilling Operation
ML19332A134
Person / Time
Site: Clinton Constellation icon.png
Issue date: 08/13/1980
From: Gerstner W
ILLINOIS POWER CO.
To: Fiorelli G
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML19332A132 List:
References
U-0165, U-165, NUDOCS 8009100833
Download: ML19332A134 (2)


Text

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(~~ 037-80(08-13)-6 V; U-0165

. ILLINDIS POWER COMPANY (~,"

L;._ , I 500 SOUTH 27TH STREET DECATUR. ILLINOIS 62525 August 13, 1980 Mr. Gaston Fiorelli, Chief Reactor Construction and Engineering Support Branch U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, Illinois G0137

Dear Mr. Fiorelli:

Clinton Power Station Notice of Violation and Inspect. 7 Report Docket No. 50-461/80-10 As a result of discussions with representatives of NRC Region III, we have concluded that the Company's response dated July 23, 1980 to the subject Notice transmitted with your letter of June 23, 1980 requires clarification. In particular, we wish to clarify the meaning of the following sentence contained in our reply:

"The drilling operation had been verbally authorized by responsible engineering personnel based upon a technical evaluation and was being performed in a controlled manner identical with approved procedures."

1) The operation was verbally authorized by the IP Director of Design Engineering. He is authorized to approve such actions. We did not intend to imply that the work was authorized by S&L (even though the Director did discuss the matter with S&L).
2) It may have been clearer if our response had referred to I technical " judgment" rather than technical evaluation; however, a technical-judgment is preceded by some form of technical evaluation. We did not intend to imply that a j formal, documented evaluation had been made; however, we l

.did intend to emphasize that a technical judgment was made j to perform this work.

AUG i '81980 l 1800910NO d?'35:35  ;

c U-0165 Mr. Gaston Fiorelli 037-80(08-13)-6

. ' August 13, 1980 Page 2

3) The reference-to the work being performed in a controlled manner identical with approved procedures refers to the fact that holes were being drilled to remove defective CMD tubes.

This work was being performed in accordance with procedures and by qualified personnel. The " extra" hole was drilled by the same people, using the same equipment and procedures.

However, the work was not " identical" because the work involved a new hole rather~than rework of an existing hole. Therefore, it would have been more correct to.use the term "similar" rather than identical In retrospect, it is clear that in our effort to be succinct, we were too brief and the statements in our letter could be mis-interpreted. We trust-that this amplification will clarify these statements as well as the meaning and intent of our letter.

Sincerely, i .:

W. C. Gerstner Executive Vice President cc: CPS /DRC "icrofilm, T-29 Director-IP Quality Assurance H. H. Livermore, NRC Resident Inspector