ML20063M957
| ML20063M957 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 06/14/1982 |
| From: | Gerstner W ILLINOIS POWER CO. |
| To: | Hind J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20063M934 | List: |
| References | |
| U-0502, U-502, NUDOCS 8209160404 | |
| Download: ML20063M957 (3) | |
Text
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0982-L ILLIN0/S POWER 00MPANY U-0502 CLINTON PCWER STATION, P.O. 80X 678. CLINTON, ILLINOIS 61727 June 14, 1982
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OT:OTPM, STAFF bR kNf.ISI Mr. J.A. Hind l
[MO Director, Division of Emergency Preparedness and Operational Support ktm I
- t n U.S. Nuclear Regulatory Commission
- 7 l
Region III 799 Roosevelt Road os&T:
Glen Ellyn, Illinois 61037
, fpg pg g
Dear Mr. Hind:
-This is in response to your report covering the Systematic Assessment of Licensee Performance (SALP) for the Clinton Nuclear Generating Station.
Illinois Power Company's comments concerning your evaluation of our facility are as follows:
With reference to paragraph IV.l.c, Board Recommendations, you stated, "The licensee should also consider a reassessment of their overall philosophy and approach to QA in both the con-struction and future operation of the station".
Illinois Power Company has reassessed its overall philosophy and approach to QA and have made significant changes in both philosophy and approach.
These changes included:
a.
QA Department reorganized to be more functional.
b.
Executive Vice President given overall responsibility for QA.
c.
Director-QA reports to Executive Vice President, with direct communication channel to President.
d.
Entire QA Department relocated to Nuclear Plant site.
e.
Composition and size of QA Department significantly changed to ensure adequate number of personnel and experience levels.
f.
Developed a Quality Report Program which allows site personnel to report quality problems directly to the Executive Vice President for resolution.
g.
Increased involvement by Illinois Power Coupany QA and Construction management in the contractor's construction management and QA/QC program.
This includes review and approval of contractor's procedures by IP QA; a strengthened QA surveillance program; an in-line review of nonconformance reports by IP QA; a stronger training program within IP; and the IP Executive Vice President SES%I8ToS50h J0N 211982 O
m J.A.- Hind June 14, 1982
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'NRC Page 2 now provides project direction to the Baldwin Associates Manager of Quality and Technical Services.
Illinois Power Company management philosophy for the Clinton project is to "do it right the first time".
This philosophy, and the Company's commitment to build a quality plant, has been communicated to all. employees at all levels, both company and contractor.
With reference to paragraph IV.2.c, Board Recommendations, you stated concerns in the area of " ineffectiveness of QA/QC personnel as a result of possible intimidation".
Illinois Power management has taken significant steps to ensure that personnel performing QA/QC functions are allowed free and unchallenged access in performing their activities.
Two policy statements were issued, one by the IP Executive Vice President and one by the IP Vice President-Project Manager, to all site personnel discussing intimidation.
The IP Executive Vice President's letter stated that any personnel subjected to possible intimidation have direct access to the IP Executive Vice President or the IP Director-QA.
Furthermore, it states that any such intimidation reported will be fully investigated and, if proven, strong and immediate disciplin-ary action will be taken.
We have also established a Quality Report Program which allows QA/QC personnel to report any possible intimidation to the Executive Vice President in confidence.
We are confident, after taking these actions, that the intimidation of QA/QC personnel at Clinton Power Station has been minimized to the maximum possible degree.
In paragraph IV.3.b, Conclusion, Clinton Power Station was not rated in the Electrical Power and Distribution area because
" performance level did not meet the minimally satisfactory crite-ria for a category 3 rating...".
In-the June 8, 1982, meeting it was explained to us that-in reaching a "not rated" grade the Board had gone beyond the appraisal period to events that took place in December, 1981 and January, 1982.
While some of these events undoubtedly had their roots in the appraisal period, some af them did not.
In paragraph IV.3.c, the Board recognizes action Illinois Power Company has taken with the following words:
"The Board notes that there have been indications of improved licensee attitude towards the above programmatic weaknesses and that the outlook for comprehensive and effective remedial action has improved?
While we fully agree that the action we have taken will
- need to be observed over a period of time before final judgements can be made, we do feel that the Board's recognition of those actions should be sufficient grounds for a category 3 rating in this area (Electrical Power and Distribution).
While we would not be in any way satisfied with a category 3 rating, we do feel that the definition of category 3 as it appears in Section II of the report more nearly describes the present situation in the Electrical Power and Distribution area than a "not rated".
6 u
'I
J. A. Hind June 14, 1982 C
'NRC Page 3 As a general comment to paragraph IV.3.c, Board Recommendations, we feel the Board s comment on " indication of improved licensee attitude..." could also be made in the Board Recommendation paragraphs for the Quality Assurance and Piping Systems and Supports sections (paragraphs IV.I.c and IV.2.c.).
With reference to paragraph IV.9.c, Board Recommendations, concerning the final report for 10 CFR 50.55(e), No. 80-02 on incorrect ~-soil modulus value in the seismic analysis, the evaluations and analyses were completed in early June, 1982.
A final report, dated June 14, 1982, has been submfited to the NRC.
The results of these analyses show that the Clinton Power Station design is adequate to withstand the seismic and hydrodynamic loads combination specified.
Furthermore, no design changes were made as a result of the analysis.
Therefore, we concluded that this condition is not reportable per the requirements of 10 CFR 50.55(e).
We hope that these comments provide you an indication of the improvements made to our Quality Assurance program and will be useful to you in subsequent SALP Reports.
Sincerely, h%
W.C. Gerstner Executive Vice President cc:
H.H. Livermore, NRC Resident Inspector Director-Quality Assurance Illinois Department of Nuclear Safety Director-Office of I&E, USNRC, Washington, DC 20555