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Transcript of 870410 Public Meeting,Discussion/Possible Vote in Washington,Dc Re Full Power OL for Plant.Pp 1-73. Supporting Documentation Encl
ML20206J213
Person / Time
Site: Clinton Constellation icon.png
Issue date: 04/10/1987
From:
NRC COMMISSION (OCM)
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References
REF-10CFR9.7 NUDOCS 8704160044
Download: ML20206J213 (94)


Text

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

Title:

Discussion /Possible Vote on Full Power Operating License for Clinton (Public Meeting)

Location: Washington, D. C. l J

Date: Friday, April'10, 1987 Pages: 1 - 73 I

Ann Riley & Associates Court Reporters 1625 I Street, N.W., Suite 921

( Washington, D.C. 20006 (202) 293-3950 D

870410 j 0 FR j PT9.7 PDR I . _ _ _ - _. ._ - .. .- _ - _ _ . - __

l t

1 D I SCLA 1 MER 2

3 4

5 6 This is an unofficial transcript of a meeting of the 7 United States Nuclear Regulatory Commission held on

, S 4/10/87 .. In the Commission's office at 1717 H Street, 9 ' N . tJ . , (Jash i ng t on , D.C. The meeting was open to 'public 10 attendance and observation. This transcript has not been 11 reviewed, corrected, or edited, and it may contain

(.

-s 12 inaccuracies.

13 The transcript is intended solely for general 14 informational purposes. As provided by 10 CFR 9.103, it is 15 not part of the formal or informal record of decision of the 16 matters discussed. Expressions of opinion in this transcript 17 do not necessarily reflect final determination or beliefs. No ,

18 pleading or other paper may be filed with the Commission in 19 any proceeding as the result of or addressed to any statement 20 or argument contained herein, except as the Commission may 21 authori=e. l 22 l

23 24 25 l

t 1

1 UNITED STATES OF AMERICA l

2 NUCLEAR REGULATORY COMMISSION 3

4 l DISCUSSION /POSSIBLE VOTE ON FULL POWER 5 OPERATING LICENSE FOR CLINTON 6 ---

7 PUBLIC MEETING 8 ---

9 Nuclear Regulatory Commission 10 Room 1130 11 1717 "H" Street, N.W.

12 Washington, D.C.

1 13 i

14 Friday, April 10, 1987 15

16 The Commission met in open session, pursuant to 17 notice, at 2:02 o' clock p.m., LANDO W. ZECH, Chairman of i

18 the Commission, presiding.

19 20 COMMISSIONERS PRESENT:

21 LANDO W. ZECH, Chairman of the Commission 22 THOMAS M. ROBERTS, Member of the Commission 23 JAMES K. ASSELSTINE, Member of the Commission 24 FREDERICK M. BERNTHAL, Member of the Commission 25 KENNETH M. CARR, Member of the Commission

,t s'

1 STAFF AND PRESENTERS SEATED AT COMMISSION TABLE:

2 J. Hoyle 1

3 W. Parler 4 W. Kelley 5 W. Gerstner 6 D. Hall 7 V. Stello .

8 B. Bernero 9 J. Sniezek 10 B. Siegel 11 B. Davis 12 C. Norelius 13 P. Hiland 14 15 16 17 18 19 20 21 I 22 23 24 25 l

i

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l 3

1 PROCEEDINGS 2 CHAIRMAN ZECH: Good afternoon, ladies and 3 gentlemen. The purpose of this afternoon's meeting is for the 4 Commission to conduct a review of the Clinton plant and 5 possibly to vote to authorize the director of NRR after making 6 the appropriate findings to issue a full power operating 7 license for Clinton.

8 The Commission will be briefed by the Illinois Power 9 Company and the NRC staff. I understand that copies of slides 10 to be used during the briefing are available in the rear of 11 the room. Do any of my fellow Commissioners have opening 12 comments to make?

13 [No response.]

\

i 14 CHAIRMAN ZECH: If not, Mr. Kelley, you pay proceed, 1

15 sir.

16 MR. KELLEY: Thank you, Chairman Zech and members of 17 the Commission. My name is Wendell Kelley, I am Chairman and 18 President of Illinois Power and I appreciate this opportunity 19 this afternoon to meet with you. With me today is Mr. William 20 Gerstner on my right who is executive vice president of the 21 company. Mr. Gerstner reports to me. He has been responsible 22 for the company's Clinton nuclear plant from its very 23 beginning.

24 Also with me is Mr. Don Hall who is the vice s

25 president of the company. He joined us in 1982. He is the

[ __ -

4 4

1 line manager who is responsible for the nuclear program for 2 the site at Clinton.

3 I would like to first of all emphasize our corporate 4 commitment to the safe operation of the Clinton station. My 5 board of directors emphasized to the management of this 6 company that our primary concern in the construction of that 7 plant was to be that all currently available technology and 8 quality control measures be followed to ensure safe and 9 reliable operation of the plant when placed in service.

10 Accordingly, we have dedicated the resources and the 11 management involvement to design and test and build this plant 12 correctly and I want to assure you that we intend to continue 13 to dedicate the resources and the personnel needed to ensure 14 that this plant is operated safely and reliably.

15 our commitment to safe operation is and will be 16 backed by a continuing high level of direct senior management 17 involvement in this plant. I make frequent visits to the 18 site. Mr. Gerstner spends about 60 percent of the time at his 19 office at the site and Mr. Hall is at the site essentially 20 full time.

21 This level of senior management involvement is ,

l 22 expected to continue and we are fully prepared to do that.

23 We see Clinton as a unique opportunity for successful 24 operation. We are a relatively small utility and Clinton is 25 our first nuclear plant. In early 1982 we encountered some

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5 1 difficulties during construction and we experienced a loss of

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2 NRC confidence in the quality of construction that placed the 3 co'pletion m and licensing of Clinton somewhat in jeopardy.

4 The decisions that followed that event fell squarely 5 on my shoulders. I moved quickly to realign Mr. Gerstner's 6 responsibilities to make him solely responsible for Clinton 7 and I insisted that we build a non-adversarial rel,ationship at 8 the NRC interface.

9 We brought in Stone and Webster to provide increased 10 nuclear construction experience in the project management 11 role. We hired Mr. Hall and his responsibilities evolved to 12 include all matters related to Clinton.

N 13 Clinton might well be the only plant in Region III i

14 to surmount construction difficulties and to proceed to 15 successful completion. But out of these difficulties, we i

16 think, have emerged four basic foundation elements for a

~

17 successful operation.

18 (SLIDE.]

19 MR. KELLEY: First of all is a sound design that 20 reflects the latest technology and the features to meet i

21 today's regulatory requirements. The integrity of our design 22 is born out by the independent design review that was conducted i 23 by Bechtel and was accepted by the NRC.

  • 24 Secondly, we have an as-built plant that conforms to i ~_ 25 design documents. The integrity of the as-built plant is

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1 supported by our quality assurance program and is augmented by 2 a successful NRC CAT inspection and an extensive 3 over-inspection program that was conducted by the company.

4 Third, a plant test program that successfully met i 5 our licensing commitments and in this regard, I would like to

}

6 note that we did receive an outstanding rating for i

7 pre-operational testing in the NRC SALP-6 report.

! 8 Fourthly, we believe we have an organization with l

9 the skill and the experience and the dedication and the 10 resources to safely operate this plant. We think this is born

11 out by the NRC's extensive inspections at our site and Mr. Hall 1 12 will address this matter in greater detail in just a moment.

i 13 Certainly the designing and construction and testing l 14 and operation of a power plant, a nuclear plant, in today's 3 15 environment is at the very least a very challenging task. I l 16 think we have met this challenge but more importantly, I think t

17 we have been able to search within ourselves and to profit i

18 from those difficulties that we have encountered along the

19 way.
20 We are not perfect. We will never claim to be so
21 but we do pledge a willingness to interact openly and to
22 interact professionally with the Nuclear Regulatory Commission

! 23 and to confront our problems and to act on them forthrightly.

l

! 24 We believe we have met all of the applicable l

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25 regulatory requirements. We have passed a stringent i I

1

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l 1 examination of our management there at Clinton and we believe

! 2 we are ready for a full power license and, of course, request 1

3 that this Commission act favorably on our application.

4 I would like to ask Don Hall to perhaps go into 5 greater detail on some of these matters, Mr. Chairman, and 6 then, of course, we will be available to answer any questions I 7 that you may have.

8 CHAIRMAN ZECH: Fine. Thank you very much. You may 9 proceed.

10 MR. HALL: Good afternoon, Chairman Zach and members ,

11 of the commission. As Wendell said, I am Donald Hall, vice j 12 president of Illinois Power Company and I appreciate the j , n 13 opportunity to co'me here today to talk to you about the 14 Clinton plant.

15 At some time or other in the last few years I 16 briefed each one of you on some occasion regarding Clinton's 17 status and each of you at some time has visited the site also 18 so I will avoid the detail that we have covered in the past 19 and concentrate on our basis for feeling that we are ready to j 20 be licensed.

1 2

21 First, as Wendell said, Clinton does meet the 22

) objective regulatory requirements that apply to the design, i l

l 23 construction, testing and operation including those i

24 requirements that are set forth in the standards for personnel 1

25 training and qualifications.

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4 8

1 The safety evaluation report and its supplements 2 reflect the staff's conclusions that we do meet those object l 3 requirements. They are matters of record and I won't dwell on 4 them at great length.

4 5 Second though, Illinois Power has undertaken other I

6 programs on our own initiatives to address issues that reside 7 really at the fringes of direct regulatory requirements. We 8 know just as you do that they are no less important in the i

9 success of a day-to-day operation of a nuclear plant.

10 Some of those allegations in 1982, Bill Gerstner 11 established an executive vice president quality report system.

j 12 In 1983, we established Hot Line, a telephone call-in system

^ , 13 and from 1984 until 1986 Safeteam operated on the site.

14 All are or were a means by which any individual 15 could report quality concerns to upper managemont and he could i 16 do that under identify protection methods. Our system has 17 generated enough confidence such that allegations have been 18 referred to us for investigation by the NRC and have been 19 successfully closed.

1 20 Fitness-for-duty, our program meets all the industry 21 commitments. It includes random urinalysis testing and a 22 recent evaluation by an independent agent characterized the 23 program as a model.

J 24 We are most prcud probably of the fact that of 11 1

25 cases that went into a follow-up mode wherein they accepted i

9 1 treatment and corrective action, six of those have completed 2 successfully; four are still in progress and there has been 3 only one failure and we feel very proud of that.

4 operational monitoring, this is a quality assurance f

5 program that our workers, craft persons, operators and

! 6 supervisors believe in because it helps them. Simply stated 7 it works and it does this by providing performance feedback at 8 the peer level without acrimony.

9 As those of you who have been to the site recently 10 know, we have a site specific simulator and we are maintaining 11 the configuration in parallel with the plant itself.

4 12 Third and probably the most important, we have

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13 closely examined our own performance and we have been closely

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14 examined by the NRC not only the, technical things we have 15 discussed but on how we manage the Clinton activities'on a 16 day-to-day basis.

i i 17 We were not satisfied with our fuel load performance 18 in October of 1986. We, Illinois Power, slowed the progress 19 on that test schedule significantly in November and December 20 to correct the performance problems that we saw ourselves.

! 21 Recently a team of senior NRC resident inspectors I

l 22 and I would like to say they were an impressive group, there l

l 23 were seven of them each time, their knowledge and their I

24 demeanor was most impressive have made two visits, one in ,

l 25 early March and one at the close of March.

l i

l -

4 10 1 Those team findings are still under review but we 2 can say with one possible exception, there were no violations 3 of regulatory requirements. Rather they found some weaknesses, i

4 they found some strengths and in the second inspection, they 5 found positive trends.

6 This indicates that our management and our 7 individuals at the site are on the correct path to achieve 8 excellence in operating that plant which is what we fully

-t 9 intend to do.

10 The findings of those visits are revealing when we 11 review them as a set and of course, we have the value of 12 hindsight because we have both of them in hand.

~N 13 I would like to address, first, the weakness and if (G

14 you would excuse me, I would prefer to class it as an area for l

15 improvement for the purposes of our people and second, positive l 16 trends and last the strengths. is 17 In the areas for improvement, the adherence to 18 administrative procedures. We agree we must improve that. We 19 must be persistent in the effort. There isn't any magic 20 answer to it. It is just going to be long hard work and we 21 are committed to that through the life of the plant. I 22 Quality assurance role in findings role, the NRC 23 team said on the second visit that it was too early to tell

. 24 for sure but they noted a positive trend in coordination 25 particularly with maintenance and quality assurance.

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e T s 11 1 We are going to continue to expand an aggressive 2 quality effort.

3 The control room activity, high levels will subside 4 but this is also going to be a constant area of emphasis for 5 us. For example, we have taken the telephone out of the 6 reactor control panel area.

e 7 We shvald note that this is probably the period of 8 highest operational tempo that that site and that plant will 9 ever see right now. In this regard though the team also 10 commented that our pre-shift briefings were good. In one case s

11 the plant man ger at the pre-shift briefing covered a serious 12 lessons learned control room operator performance prcblem at

~} 13 another site on the same day that the Commission order on that 14 subject was is, sued.

15 We will have to keep pressing on the control room i

16 and make sure that the decorum remains where we want'it to be.

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17 '

Communication of management philosophy down to the 18 r'ahks , some problems remained in the control room but 19 improvement was noted. A continuing effort over the life of 20 the plant will be required on this also. It is something we 21 will have to continue to work on becau,se we are talking about ,. .

i 22 people and communications.

, i 23 k)

We have done two major new things, implementation of '$

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, 24 plant managers memoranda and a site-wide daily newsletter A 25 which we' feel will aid a great deal in this communication 4

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12 1 issue.

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2 Use of non-mandatory site instructions for safety 3 related activities. I emphasize the word " safety related."

4 This is a new item and we will look at it in depth. Some

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5 caution is required. We require verbatim compliance with 6 procedures, no deviations.

- 7 We must remember that management decisions that are 8 made in an administrative area that covers a wide range of 9 subjects really are most efficient and practical when you 10 prevfde the manager with a commensurate degree of flexibility 11 in his decision process.

12 We don't think this concept is in conflict with 13 verbatim compliance of safety related procedures. We think it

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14 is in direct support and we will satisfy both issues. We 15 don't feel there is any conflict there at all. '

16 Backlog of maintenance work items, in March the 17 trend was very good and all outstanding work items have been 18 reviewed for their impact on system and successful operation.

19 We continue to believe that this backlog is manageable and 20 that we are in control.

21 The team urged us to use a risk and system appraisal l

22 basis for determining our priorities. We have agreed with 23 that and are working on it right now. We have-seen a slight 24 rise in the number of maintenance work requests this month due 25 to new systems that are entering service. It was a rise which w

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13 1 was expected by us. It was predicted by the inspection team.

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2 For example, there were 35 minor steam leaks when we 1

3 cut in some of the steam piping and we are working on fixing l

4 those now.

5 All of these work requests have been categorized and 6 we are scheduling all of the equipment oriented ones.

7 This is a slight digression from the team but I 8 think a special word on maintenance is appropriate. Last 9 summer when four of you visited the site, I did not and could 10 not tell you at that time that our maintenance program was 11 where we wanted it to be.

12 In September we implemented some major changes to

{ 13 upgrade maintenance. We installed a new manager, elevated the 14 position of that individual to assistant plant manager of 15 maintenance, consolidated all of our maintenance planning 16 under one individual rather than having it in two or three 17 spots and to coordinate it.

18 We introduced more sophisticated scheduling of our 19 maintenance and we are still in the process of trying to 20 improve that. We expanded training in several areas affecting 21 maintenance and the results are evident.

22 The NRC inspectors were satisfied with the program 23 and the bulk of the impending action items have been cleared.

24 We can do timaly effective maintenance now on the first try.

25 As an example in 1985 we initiated efforts to

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14 1 improve motor operated valve maintenance at our site. Now the

(~S i 2 industry has taken this up as an industry-wide effort. We l

3 will continue to take the same aggressive approach trying to 4 improve things and we intend to do so by addressing issues 5 without hesitation and to solve them.

l 6 Now to look at the positive trends, the good thi.ngs 7 that the team found. These were on the second visit. They 8 saw increased team work in the plant and by all the 9 organizations and that was evidenced particularly in the 10 meetings that they attended.

11 There was evident increased quality assurance 12 involvement, increased management involvement in preventive 13 maintenance, better coordination and an evident reduction in

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14 the backlog of work, better use and control of daily activity I

15 schedule, better coordination of maintenance, surveillance 16 testing and operations.

17 We still need to improve on the assignment of 18 priority to do work and we are going to continue to work on 19 this.

i 20 Training of our radiation protection and contractor 21 people was satisfactory and good progress had been made on our 22 program for fixing out-of-service annunciators, instruments 23 and recorders.

24 The team presented a new item. Our licensing event l

V 25 report evaluation program was well ahead of those that they l

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1 had seen at other plants at this stage. -

, y 2 Now the last thing and to us, the most important, 3 the strengths, these were strengths at the first visit and 4 they remained strengths today; operator performance, operator 5 adherence to procedures, operator response to off-normal 6 events.

7 We believe these are vital in any well run plant and

! 8 are of such importance that they should take priority and 9 management emphasis. We were pleased that the team recognized 10 the performance of our licensed and unlicensed operators. We 11 agree that the areas for improvement should be addressed but 12 we believe our management emphasis was correct and we can now N 13 logically turn more attention to items which we consider to be 14 supportive of these-three essentials to safe operation.

l 15 In essence, we have concentrated on assuring our 16 operators made a direct contribution to safety by demonstrating 17 strong performance. This says we have done the right 18 fundamental things.

19 It also says we are doing and I think it implies 20 that we will do the right things to support fundamental safe i

21 operation in the future.

22 Now a final note on how we would propose to proceed 1

1 23 with power asceasion testing. We propose to complete test 24 condition two which confirms proper plant operation through 55

~- 25 percent power. Then we would do an assessment of the plant

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16 1 condition and if necessary schedule a maintenance outage.

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k. 2 We will not move ahead unless we are satisfied. We 3 will implement a schedule operator training period using 4 written performance evaluation standards. There will be 5 ' consultation with the NRC throughout this. The acceptability
6 of the training during that period will be established prior 7 to a decision to proceed to condition three.

8 It is our intention that our operators actually '

4 9 maneuver the plant to become familiar with the feed pumps, 10 the reactor water clean-up pumps and all the other evolutions 11 that they have not had a chance as this is our first plant to i 12 perform on their own. We believe this will provide a

T 13 quantified deliberate and measurable basis for safe power 14 ascension testing.

15 In conclusion, we, Illinois Power Company and our 16 employees, are ready. Our readiness is demonstrated by 17 objective regulatory standards and evaluation of management 18 readiness and we can and we will continue to try to achieve l 19 excellence at this plant, Mr. Chairman.

l r

1 20 CHAIRMAN ZECH: Thank you very much. Does that l

^

21 conclude your presentati n, Mr. Kelley?

22 MR. KELLEY: Yes, sir.

23 CHAIRMAN ZECH
Thank you very much. Questions from 4

i 24 my fellow Commissioners. Commissioner Roberts.

i 25 COMMISSIONER ROBERTS: No questions.

l

17 4

1 CHAIRMAN ZECH: Commissioner Asselstine.

2 COMMISSIONER ASSELSTINE: Maybe just one, I think 3 most of my questions you covered pretty well in the 4 presentation. The one question I have really has to do with 5 your maintenance program and your current views of that

! 6 program. The signals that we were getting from the staff, I 7 think, over about the past month or so were that your 8 maintenance program wasn't in too good a shape. I want to 9 explore that in more detail with the staff when we hear from I

I 10 that.

j 11 It may have been a result of the first team visit j 12 but do I take it from what you have said that you are really

') 13 pretty satisfied now that you have a good control of the

, 14 maintenance situation and that the backlog is in reasonable 15 shape, that your people are being able to do maintenance 16 activities in an effective manner and that you are in ,

17 reasonable shape on the maintenance program now?

18 MR. HALL: Yes, we do without any question. We

19 do. We would like the backlog to be less also but we feel it 20 is in control. We feel that the trends on the curves that we 21 keep track of are explainable, that we will reach a steady 22 state somewhere by the trends on the curves which include'the 23 new items entering plus the items we are closing out, that we 1

l 24 will achieve a steady state sometime late this year, sometime i

i 25 in the late summer or early fall which is perfectly acceptable.

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18 1 We may have to stop to do this to make some 2 adjustments here and there but there is nothing in there. We 3 have reviewed all of the items not once but several times.

4 They have been categorized by system, by priority and at the 5 present time, we are trying to schedule those that are 6 equipment oriented with emphasis on the safety related items 7 in specifics.

8 But we feel comfortable that we have control of the 9 maintenance backlog now and we have management procedures that 10 if we see something emerge from there that we will recognize 11 it and do something to handle it.

12 COMMISSIONER ASSELSTINE: How large is the backlog 13 right now?

14 MR. HALL: It is right now about 2,400 items. It s

15 has risen a little bit in this week. Of that, 99 of those are 16 equipment associated safety related and there are about 750 17 safety related items but 660 of them are in the desirable 18 category, things that we will do when we can get to them and I 4

19 think that is the measure of where we see it.

20 COMMISSIONER ASSELSTINE: All right. Maybe one last 21 quick question, we received a preliminary notification, I 22 guess, today on surveillance testing.

23 MR. HALL: YEs.

24 COMMISSIONER ASSELSTINE: Could you sort of highlight 25 that one and whether you 'e-1 that that is an isolated problem i

1

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19 l

1 as opposed to indicative of some broader problem in

/' t 2 surveillance testing?

3 MR. HALL: We have completed an audit of the 4 instruments. By the way, Illinois Power reported the incident.

5 COMMISSIONER ASSELSTINE: Right.

6 MR. HALL: There was a containment pressure 7 instrument that was not properly in the surveillance program.

8 We completed an audit of all of the instrumentation in the 4

9 surveillance program last night and we are in the process now, I

10 my assistant is signing out a letter reporting the situation.

l 11 We did not find a widespread problem. We found a 12 problem with one surveillance procedure that is associated 4

(

. 'T 13 with the daily surveillances, the watch-to-watch surveillances, 2 14 12-hour surveillances.

I i 15 There were four mode two items and one mode one item 16 that were in there. The four mode two items are obviously, we l 17 were operating outside the technical specifications at that ,

l 18 time because we were not reading the correct instrumentation.

! l 19 That procedure, those errors were isolated to one procedure. l I

20 We have found the individual who reviewed the 21 procedure and we are attempting to follow-up on it. We are l 22 looking back through the rest of the items to make,sure that i

23 there is not any other but right now it appears there are no

! 24 other breakdowns in that system.

1 25 We have completed an evaluation to see whether thera l

20

)

1 was a safety issue or not and the preliminary report from my 2 independent safety evaluation group is there was not.

3 COMMISSIONER ASSELSTINE: Maybe one last question 4 that had occurred to me, you mentioned earlier that you 5 weren't satisfied with your fuel loading performance. I very 6 much agree with that. We talked about that on the phone at 7 the time.

8 MR. HALL: Yes. .

9 COMMISSIONER ASSELSTINE: Could you give me a sense 10 for what you think the problem was and how you have satisfied 11 yourself that you really have taken care of that problem as 12 you have gone through the low power testing program for the

(.

'"3-13 plant?

14 MR. HALL: The problem was it was the first plant 15 for a utility. We had tried to do too much with our people 16 who had not performed it before. The overtime grew too high.

17 They got tired doing things they were not familiar with and we 18 profited from that because we slowed down and, I think, that 19 the difference in the initial approach to criticality was 20 almost breathtaking in that the number of personnel errors at 21 that evolution, there weren't any.

22 The adherence to procedures was precise. The 23 communications were crisp and that is what we fixed. We moved )

24 some offices around. We spelled out in great detail the 25 responsibility chains between the test engineers, the fuel l

l

21 1 engineers, the operational people and we prescribed that

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\-- 2 communication flow in such a fashion that it was crisp and 3 controlled.

i i

4 It was there before but we had not exercised it with '

5 enough vigor on the first attempt and that became obvious. I f

6 have agonized quite a bit about it because if we had contracted 7 the fuel load out as some utilities do perhaps we would not l

4 8 have seen that and it would have been later before we realized 9 our problem.

10 I think that I tracked certain things, your second 11 part of the question, I tracked certain things to see how we 12 are doing and we are well below the curve of unplanned scrams a

We are very

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13 during power ascension. We have had only one.

14 early on but the curve on the average of six other BWR's is 15 about twice the level above us for this point two-thirds of t

16 the way through the heat-up process.

17 For total LER's initiated, we are well below the 18 curves of four other BWR's that I plot to keep track of and 19 because I slowed the process, I expanded the horizontal axis.

20 We do another check and de went back and we normalized that 21 for the time between initial criticality and heat up and we i

22 are still very, very good and just a little bit above the best 23 that we know of.

24 So we think that statistically the data shows that I i' 25 our corrective action has been effective. It means also

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22 1 though that we have to keep at it because I don't think that 2 this is something as we discussed before or during your visit 3 that is intuitively normal to people to behave in this fashion.

4 It is just something you have to continue to work on 5 to get that crisp communication flow in that control room and f

6 that will control that equipment.

7 COMMISSIONER ASSELSTINE: Thank you. That is all I 4

8 have.

9 CHAIRMAN ZECH: Commissioner Bernthal.

10 COMMISSIONER BERNTHAL: I have a question or two in 11 the same vein. You are a first time utility. You are one of 12 the smaller utilities and we have had some in the same

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13 circumstance that have done very well and others that haven't 14 done so well to say the least.

15 Could you give me some sense of the number of staff, 16 the total number that you have and have you at some point 17 along the line, I am sure you have done this, had an outside 18 consultant in to do a comparison with other utilities in a 19 similar situation, very broadly speaking, number of staff, 20 upper management to lower personnel ratios, that sort of 21 thing?

22 MR. HALL: We have 1,085 on the site of Illinois 23 Power employees right now. There are about 800 consultants 24 and contract people. That includes craft and technical

  • 25 consultant people so we are gradually drawing that down to

1 23 I where we want it. Most of those are craft people.

2 We have had two studies. We have an ongoing effort 3 right now to help us match with the other utilities. There is 4 a recent effort out if I can find the curve in here that shows 5 that we are right at about the median for our company employees 6 with a large group of other BWR's including new and old ones.

1 7 . We use that as the normalization.

8 In addition, every month we track the attrition and 9 a term that I call " motion factor" and we calculate this 10 motion factor for certain positions and we have 123 key 11 positions that a man can only be assigned to that with my 12 personal approval.

l . ' '- 13 If someone leaves and we put another person in

\

14 there, then we have a two motion factor and we keep track of 15 this to control not only the attrition. The attrition has l

16 been steadily dropping for the last year. We plot that every i 17 mohth and -- would somebody hand me by blue book -- and we

! 18 also plot motion factor and we can control motion factor 19 because if you have and we have a case right now.

20 We have one manager's position open. We have chosen l 21 to leave that open because we want to promote from within l

i 22 Illinois Power. We want to grow our own replacement managers l 23 in our system of performance.

24 To do that would cause a chain reaction rippling 25 down through these key positions such that would make the i

24 1 motion factor go very high and I liken it to the case of an 2 organization, a production organization, and I may have used 3 this when you were out there who decides they are going to put 4 a second shift of welders on so they take their best welder 5 and promote him to the leading man welder and all of a sudden, 6 they have a case where they are trying to teach someone to 7 manage the shift and they can't make the weld in the first 8 shift because the best welder is over there trying to learn 9 how to manage the shift.

10 To avoid that we try to control both of these 11 factors and that is one reason we have left that one manager's 12 position vacant right now. We will wait until we finish this

'} 13 very trying period right now and we will fill it. It is a 14 non-direct plant position. It is the nuclear support manager.

15 But you can see, this is motion factor in key 16 positions and it has been dropping steadily, also. That is l

17 manning in key position and it shows that we are almost right 1

18 up on it. This is overtime for IP and it has been dropping.

19 It came up last month and we took action to level it off.

20 This is attrition. You can see the factors. It 21 spikes up and down but the trend is down as we level out and 22 we start to build and grow our own people.

I 23 COMMISSIONER BERNTHAL: Every other month, uh? That i 4

24 is an interesting trend.

25 MR. HALL: It is. One of these days we will

-,+---- ,-- -.-,------r - - - - - - -- -r---__----------,,c..- -

. - .= . _ . _ . . .- - - . . -_ . . . _ . . _ . - . _ . - - . . - . _ _ _ - . _ _ _ _ _ -

25 1

1 investigate why that happens.

2 COMMISSIONER BERNTHAL: It is very interesting 3 there. You are showing some of these analyses thah you just

, i 4 have because that brings me to my next question. From time to 5 time I have referred in visits to other plants since I Was at 6 Clinton some time ago, I have referred to your -- and I am not 7 sure what you call it -- but I have called it a kind of l

, \

8 performance indicators program on management. j I

9 I thought that was an innovative program. it f 10 probably was too early then to make a call on the success of i

j 11 it. It may still be too early but could you give us some I 1

J 12 update on how that is working, any significant findings that ,

I l i' ,

13 you have made from your analytical process there on management 1

1 14 performance?

15 MR. HALL: You are talking about our effort --

16 COMMISSIONER BERNTHAL
I think you are showing me 17 some of it right there, yes.

l 18 MR. HALL: This is the monthly program performance '

! i

! 19 monitoring, that's right. It is too early although we have  !

.f 20 matured to the point now where this year we have prepared our t

i 21 executive plan and for the first time, it had more than one

! 22 year in it.

j 23 So we started out the year this year with an l

l 24 executive plan that is starting to get to the point where it t i

25 will reach the five year projection and then we will use the i I

i  !

i i

i i

26 l 1 first year to produce our budget request in April.

2 This year we are going to do that. We had a very 3 fine effort by the managers this time, not by outside l

4 consultants or people at my level with instruction, but the 5 managers generated the strategic plan this year themselves 6 working on it because of their knowledge of the system and f 7 because they knew how to analyze and prepara goals and 8 objectives in a fashion that we could track them in a monthly 9 report and show how well they were achieving them.

1 j 10 Interestingly enough, this month this year we have 4 11 far better success with what we are doing with regard to what 12 we had intended to do and you will remember the big chart that i

13 I had with the top level goals that we wanted to achieve and j {'

14 that we plotted each month, in the first three years we ran 15 that. I have to say that we were always short.

16 This year, the curves show that for the total

{

i j 17 program we are very, very close to our goals in what we wanted i

18 to achieve. This is the power station itself and it is very 19 close almost right on it. The quality assurance is above.

20 He is ahead of his yearly projection objectives.

21 The engineers are a little bit behind. Licensing 22 and safety is a little bit behind. The training department is 23 a little bit behind. We are going to have to catch up on

]

24 the accreditation process between now and mid-summer. We have i

j' 25 to put some more people in there because we can recognize what ,

j i

l

, 27 4

4 1 the problem was via this thing. l

! rm 2 So the first things are starting to emerge that will 3 allow us to predict where our problems are going to be rather 4 than all of a sudden, bang, it is on us. I believe that is 1

! 5 what you are referring to.

6 COMMISSIONER BERNTHAL: Yes, in fact, there was one l

I 7 other element of this that.I found especially interesting. I 8 think, if I am remembering correctly, that you had a -- i i

! 9 MR. HALL: A special group.

1

) 10 COMMISSIONER BERNTHAL: Well, you had a system for i 11 trying to quantify the management, performance in the sense of j 12 how many times do we ask something to be done and we don't get

{i 13 follow-through. <

j 14 MR. HALL: Yes. We have been able to analyze and 15 compare that now. We had two systems running in parallel. We 16 had the normal corrective action system run by the quality

17 assurance program and to pick out two or three examples to i

18 cite, if there was a failure to follow a procedure and it was j 19 written down in a formal report, we logged that and in the  !

) 20 corrective action process. If there is an error in a l l 21 procedure, we logged that.

22 COMMISSIONER BERNTHAL: Right. l I

i 23 MR. HALL: We have taken the trends in those now and l 24 normalized those and compared them with what we were getting 1

I

25 in the subjective operational monitoring program which I have 1 i

~

28 m

1 referred to in my talk and the answer is they are comparing

. 2 almost exactly and we are at the point now where in the next 3 two or three months, it is our intention to merge those into a 4 more complex and formal corrective action program with a top 5 level statement on how it works.

6 But that was a very successful program and the 7 reason I think it is is because the workers and I say the 8 workers, not just the workers, the managers and supervisors I

9 also see that as a peer level evaluation and they take it 4

10 without any acrimony ~.

11 They take it because it is coming from someone with 12 credentials.

13 COMMISSIONER BERNTHAL: I will continue to follow

{N 14 that program with some interest. Others may know of cases but 15 I don't think I have ever heard of a case where anyone has 16 tried to quantify a human factors element quite to the extent  ;

i 17 as you are trying to out there and I applaud you for that. I 18 hope it works. I will be very interested in seeing how it j 19 develops further.

j 20 I had one rather specific question and that was f 21 about the indication that you made that you plan to proceed to 22 ascend in power up to -- did you say 35 or 55 percent?

l 23 MR. HALL: To the completion of test condition two i

24 which is 55 percent power and the reason for that is that that t

i 25 proves the operation of all the plant equipment and it allows

29 1 us to establish the control parameters to prove the design, to 2 make sure that the plant itself running in its full power mode 3 does not become stable until about 60 percent really.

4 So what we are trying to do is to check the 5 performance characteristics of each of the feed pumps running 6 singly and together to make sure that they do match the 7 performance characteristics before we try to have our operators

) 8 exercise at running them.

9 COMMISSIONER BERNTHAL: I guess that I would like i

} 10 cur staff maybe to comment on that. If this is a better way 11 to do things, then we should wonder why we don't do this at 12 other plants as well. Maybe we have in some cases but I am

~

/' '13 not sure it is standard procedure at least but we will let our

!t, 14 staff handle that.

l 15 I think that is all I have right now. Thank you.

16 CHAIRMAN ZECH: All right. Commissioner Carr.

17 COMMISSIONER CARR: Yes. It looks like you are f

18 going to have five shifts of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for the operators. How 19 do you have that set up?

20 MR. HALL: Five shifts with regular shift rotation.

I 21 They are not 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

i 22 COMMISSIONER CARR: Eight hour shifts?

23 MR. HALL: Eight hour shifts.

I 24 COMMISSIONER CARR: Are you intending to go to six 25 shifts some time?

t

30 1 MR. HALL: We will. We have the sixth shift in

_3 2 training now and we hope to have them licensed this fall and 3 we having another licensing class that will start before that 4 one finishes and it is our intention to work to seven and 5 eight shifts because we are going to need those for vacation 6 and for training time in addition to the six.

7 We see a more heavy load here and we are going to 8 try to. We have put in, for example, some engineers into 9 licensing training, also. It is our goal to go to a full six 1

10 shifts sometime this fall and to get more in right after that.

11 COMMISSIONER CARR: All right. What is your operator 12 turnover rate?

S 13 MR. HALL: The operator turnover rate, we have only ,

14 lost two licensed operators since we started of the six shifts 15 and one of those, we terminated and one resigned.

16 COMMISSIONER CARR: All right. That is all I have.

17 CHAIRMAN ZECH: Thank you. You mentioned the 18 maintenance backlog and you are working on it. I am sure you 19 are going to keep working on it and keep working it down.

20 Could you talk just a little bit more about when you expect to 21 get that number down and what you think is a sufficient 22 level? What are you aiming for?

23 MR. HALL: We are looking at something that is  ;

24 stable with no equipment oriented problems in it that aren't 25 being actively worked. That is what we would like to get to.

i

31

~

, 1 In other words, have desirable maintenance the only thing that 2 is the backlog.

3 CHAIRMAN ZECH: But you have looked at it carefully 4 enough now to know that you don't have any safety problems 5 before you proceed?

6 MR. HALL: That's right and we have taken 7 compensatory action. For example, if we have a gauge, a meter 8 or if we have an annunciator that is down, we have taken t

9 compensatory action with operators to compensate for that.

l 10 But is our goal to reach that stable condition before the end i

11 of the year.

12 Now in talking to other utilities, we hear the

^

13 figures four weeks of work. I don't know what that will be

{'T i 14 for us yet. I would like to see it not just four weeks of 15 work but some amount of work that is desirable work. We have 16 to paint the so-and-so. We have so much preventive maintenance 17 that we know we have to do every month and that type of thing f

18 rather than have equipment maintenance facing me in the l

19 backlog.

I 20 We have reviewed all of the equipment maintenance we 21 have right now and it is not an impediment to operation but we 22 want to get all of that out of there.

23 CHAIRMAN ZECH: All right. Fine. I would like 24 Region III to monitor this and follow-up with the Clinton

'- 25 people and watch that very closely. You mentioned the l

32 1 annunciators. As I recall at one time anyway, there were

.m 2 quite a few annunciators that were out of service. How do you 3 stand on that area now?

4 MR. HALL: There are 35 annunciators, I believe was 5 the number, this morning. It is coming down. It is continuing 6 to come down. We had a flat spot there early this week because 7 we had a failure in a control and instrumentation device and we 8 had to stop work on that with the experts who were working on 9 the annunciators. But they are back on the annunciators and we 10 feel that we are going to be able to continue that process of 11 reducing those out-of-service instruments and annunciators.

12 our goal is to have them all working.

4 13 CHAIRMAN 5ECH: One last question, as I recall your

{'

14 control room is a relatively small control room and you

! 15 mentioned earlier the activity and I agree with you, this is i

16 probably the highest activity period you would expect in the 17 control room, certainly one of the highest.

18 Do you foresee in the future, could you talk just a 19 little bit about your efforts since you do have a little bit 20 smaller control room than most, it seems to me it is awfully ,

1 21 important to have a system of discipline and formality and you l

l 22 mention crispness of communications and I certainly agree with 23 that.

24 It seems to me though that it might take a bit of a

'- 25 special management effort on the part of your senior operators

_.~ - . - . - - - . - - ~ -.---. - _ ._ - ._. .- - _ - _

I j 33 4

1 and operator management people to make sure that that control d

S,.

2 room perhaps because of its size maintains a rather strict

]

j 3 decorum.

4 could you talk about that a little bit? Do you have l 5 any efforts to make any special efforts'in that regard?

I f 6 MR. HALL: Yes. I talked a little bit about what we 7 did between fuel load and initial criticality. Since initial i

8 criticality pointed out by the first time that we needed to do F

i 9 other things and what we did was we moved the test directors l

j 10 out of the control room area.

i  !

11 They were not in the horseshoe in the control panel

! 12 area proper but they were right next to it and the exchanges I

t I

I

/ N 13 across were just not conducive to crisp performance of the

(

l 14 watches. We moved them out of there. We moved the maintenance

, 15 control people out into offices away from the control room. t l  !

16 In addition, now we have gotten down to the point i

17 where our monitors are capable of picking up the individual 18 shifts and we have just gotten to this point this week and we I  !

i 19 are able now to detect individual shift performance and '

l 20 individual shift supervisor performance.

21 We have seen a very interesting and what I think a 22 very responsive note from our people bscause when we were able '

23 to do this for the first time to challenge the shift supervisor l 24 or his assistant shift supervisor to why did that performance j -

25 deteriorate that the next time we were able to observe that 1

L '

34

]*

1 shift, the performance was vastly improved.

,^.

( 2 So we have gotten it down to the point now where we

, 3 can call on the management skills of those individuals and 4 that is what our goal was and what we will continue to press 5 for.

6 CHAIRMAN ZECH: All right. Thank you very much.

]

i 7 Unless there are other questions from my fellow commissioners, 4

8 at this time we will call for the staff to come forward and i

j 9 thank you very much for your presentation.  ;

) l I 10 Mr. stello, you may proceed.

l l 'll MR. STELLO: Thank you, Mr. Chairman. In a few 12 minutes I will turn it over to Mr. Bernero who will introduce

, ~S 13 the people at the table. I thought it was appropriate first j \.

l i 14 to make two points. First, we are at a point where we are l

}.

15 prepared and do recommend that the Commission vote to allow us

]

j 16 to issue a license to full power license when ready. There 1

j 17 are still some things as we will get into that are not finished l j 18 but hopefully will be in a few more days.

l 19 I think this project has gone slowly and you do  ;

l l 20 recall I asked to have it moved off the commission calendar i

{ 21 one time when we were not satisfied. The progress had gotten 22 to the point where we were content with recommending to the i

23 Commission to move forward.

I 24 It has been a difficult start-up process but we 1

1

{

25 think a great deal has been learned from it and we are now

! l

35 1 satisfied that we are comfortable with the process that is s .

2 ongoing and are prepared this afternoon to go into a number of 3 those issues which we will.

4 With that, let me ask Mr. Bernero to begin.

5 CHAIRMAN ZECH: Please proceed.

6 MR. BERNERO: Thank you, Mr. Stallo. Mr. Chairman 7 and Commissioners, for the staff briefing today on the Clinton 8 full power license meeting what we are going to do is Byron 9 Siegel, the project manager on my right, will gi.ve the initial 10 briefing on the safety review process and how we got to this 11 point here and then Charles Norelius, the reactor projects 12 division director from Region III who is down toward the other 13 and of the table, will cover the NRC inspection and oversight 14 activities and the status of the plant.

15 Also at the table we have Jim sniezek, deputy 16 director of NRR; Bert Davis, our Region III Administrator'and 17 at the far and of the table we have Pat Hiland, our senior 18 resident inspector from Clinton.

19 Also in the audience in support and should any 20 question arise, we have Walt Butler, our licensing project 21 director. We have Bob Warnick from Region III and one of our 22 specialist inspectors from Region III, Zelig Falevits.

1 23 I would just like to say a few things to start to 24 just set a perspective before Byron Siegel starts his 25 briefing. Clinton is the fourth of a set of four boiling

A 36 l

i 1 water reactors, the model "6" product line, BWR-6, and they

! g 1

2 are the ones with the MARK III containment. They are the set

{i i

j 3 of four in the United States. There are two of these in i 4 Taiwan. There is one in Switzerland, also and all of those l 5 three overseas units are operating I

! 6 The units in the United States started with Grand 7 Gulf and then River Band was licensed, then Perry and now we i

) 8 are facing the full power license for Clinton.

I

{ 9 The Grand Gulf and the Perry plants are the i

10 relatively large size. They are on the order of 1,300 megawatt 11 electric output. The River Band and Clinton are just below l

] 12 1,000 megawatt electric output. People sometimes forget i

! 13 that but there is a distinct size difference available in that j ((' ;'

14 product line.

15 All of the U.S. plants of this type are first i

16 reactors of utilities. In other words, it is the only plant l 17 they own and we have been very conscious of that and I think i

! 18 the owners have, too.

19 Last year in particular we encouraged the owners To ,

j 20 get together. All the late model BWR owners were encouraged

21 to get together for a lessons learned exchange and I must say
I i 22 that from the perspective I have as licensing director for l

! 23 boiling water reactors, I think they have treated each other

}

l 24 as brothers, so-to-speak, exchanging information.

l 25 I have frequently found that when I talk to one II

37

, 1 about a problem that another has that they have already 2 communicated to each other and, in fact, much of the technical y

j 3 detail that we are aware of, we get that'way, we see what'they 1

4 are exchanging. So I think we have a good thing in that j 5 regard.

6 I would like to turn now and ask Byron Siegel to

! 7 start the formal presentation.

8 MR. SIEGEL: Thank you, Mr. Bernero. Chairman Zach 9 and Commissioners, may I have slide two please?

i 10 (SLIDE.]

4 i 11 MR. SIEGEL: My name is Byron Siegel and I am the i 12 licensing project manager for Clinton. I have been on the 13 Clinton project for almost three years when it was about 85 i 14 percent through the construction phase and probably about 50 p 15 percent through the licensing phase.

16 This afternoon on our presentation, I will discuss 17 the licensee and the plant background, the licensing milestones i 18 and events, the plant design features, the NRC requirements l 19 implemented, the shift staffing and then Mr. Norelius will f 20 address the inspection program, construction, preoperational i

21 testing, startup testing, operational readiness and then 22 provide the staff's conclusion.

23 Slide three, please?

?

24 (SLIDE.]

j

' 25 MR. SIEGEL: The owners of Clinton are Illinois

38 3

1 i Power Company.who ls the operator and agent for the other two 2 owners that are Soyland Power Cooperative and Western Illin'ois 3 Power Cooperative. The total cost of the plant will probably I 4 be somewhere around $4.2 billion. Soyland Power Cooperative j 5 and Western Illinois have a fixed amount, $450 million dollars 1

! 6 they put into this project, so their percentage would vary 1

7 depending on the plant costs.

8 The nuclear staan supply vendor is General Electric.

l I 9 The reactor type is a GE-BWR-6. As Mr. Bernero mentioned thera l 10 are three other plants like that and it has a MARK kII l

-l 11 containment.

)

i 12 The architect / engineer is Sargent and Lundy. The

~

< 13 constructor was a consortium called Baldwin Associates. It is 4 (

14 locaced in Dewitt County in Illinois and the nearest city'is 15 Clinton, Illinois which is about six miles west of the site i

16 and has a population of about 8,000. 1

1

! 17 Clinton is located if you form a triangle between j 18 Decatur, Bloomington and Champaign or Urbana. It is

, 19 approximately.in the center of the triangle formed by those

20 three cities and they have populations of, I think, well over l Y I '

21 100,000 in each one of them. -

22 Slide four, please?

23 (SLIDE.]

24 MR. SIEGEL: With regard to Clinton plant licensing 25 milestones, I am just going to touch upon a few of them. The i

l

39 1 original CP application was docketed for units 1 and 2 back cn m

2/ October 30, 1973. Since then unit 2 has been cancelled.

3 A construction permit was issued in February 1976.

4 The OL application was docketed September 8, 1980. The low 5 power license was issued on September 29, 1986. Initial 6 criticality occurred on February 27, 1987 and the fuel load

7. license is projected to be sometime this month.

8 Slide five, please.

i i  !

4 9 ,. (SLIDE.]

10 MR. SIEGELP y This is the Clinton organizational ,

11 chart. Mr. Hall dincussed this in some detail so I am not k12 going to spend much time on it. Essentially Mr. Kelley and

^\ 13 Mr. Gerstner are off site and Mr. Gerstner as Mr. Hall 14 mentioned is on site probably about half of;his time.

15. J Everybody below that horizontal line from Mr. Hall

! 26 down through all the plant managers are all on site, all the i

17 engineering, the quality assurance, the licensing and safety, 18 nuc'a ear station engineering, nuclear planning and suppo'rt and 4 adnager for scheduling outage.

19 N 4

, t 20 As Mr. Hall mentioned there is one manager opening  %

21 that is vacant and he explained that one to you.

22 3 May I have slide six, please?

t 23 (SLIDE.] e '. r ,

24 MR. SIEGEL: Clinton has a rated thermal power of

'- 25 2,894 megawatts thermal and an electribal power,ot'933 x

A.., _. - . - - - -,c-, . .- ,,,- e

40 1 ,' megawatts. It has a containment volume of over one and a half

,N y 2 ( 31111on cubic feet and even though it is the smallest of the 3 MARK III designs, it has the largest MARK III containment.

4 I think Grand Gulf has about 1.4 million cubic feet 5 and it has a power of over 3,800 megawatts, about a thousand

\x- r 6 megawatts higher.

7 The containment differential pressure, the drywell 8 differential pressure is 30 psi differential and the 9 containment design pressure is 15 psig., The containment 10 ultimate strength is 63 psig.

11 The safety systems are typical of a BWR-6 and some 12 of the 5's. It has'three diesel generators. One of the

('T

\_/

13 diesel generators is dedicated to the high pressure core spray 14 system and the remaining two diesel generators, the safety 15 systems are divided amongst them, the low pressure core spray 16 is on division and the low pressure coolant injection is 17 divided between divisions 1 and 2.

18 The ADS automatic depressurization valves are split 19 between divisions one and two and the shutdown service water 20 system is divided L:'"seen the two divisions. In addition, it 21 has a reactor core installation coolant system which is steam 22 driven.

~

23 The unique feature of Clinton is probably the 24 control room. It has a GE Nuclenet control room. It is a 25 one-of-a-kind. It has what is called a nuclear system i

l 41 l 1 protection system which utilizes solid state logic circuitry

, <~.

2 totally and it has a self-test system which is for automatic 3 test and surveillance and what happens is that in the self-test 4 system, you inject a small pulse, a millisecond pulse, which is 5 fast enough so that it doesn't actuate the safety devices.

6 COMMISSIONER BERNTHAL: Excuse me. Would somebody 7 just tell me quickly how many years elapsed basically between 8 the marketing of the MARK I, MARK II and MARK III designs? Do 9 you have the approximate dates when each of those were first 10 brought on the market?

11 MR. BERNERO: Order of magnitude at least, the MARK 12 I designs were marked in the 1950's.

'] 13 COMMISSIONER BERNTHAL: That long ago?

14 MR. BERNERO: YEs, that long ago and the MARK II's, 15 I would say in the early 1960's and MARK III's were being 16 marketed in the very late 1960's/early 1970's and that design 17 was still developing then as you know.

18 COMMISSIONER BERNTHAL: Thank you.

19 MR. SIEGEL: The self-test system essentially in 20 essence, it injects a very short pulse into the system, in the 21 nuclear system protection system and it continuously and 22 automatically tests the operability of that system.

23 The self-test system is capable of testing the 24 entire nuclear system protection system once per hour when the 25 self-test system is used in its automatic mode.

I

42 1 COMMISSIONER ASSELSTINE: Is that similar to some of s,-

2 the European systems where they have those self-test systems 3 in the control room sort of bouncing around?

4 MR. SIEGEL: I am not familiar if it is or isn't.

5 COMMISSIONER ASSELSTINE: Do you know, Bob?

6 MR. BERNERO: No. I haven't seen one that I would 7 compare to this. The technology was used in aerospace, you 8 know, the whole idea of getting a little pul'se to go through.

j 9 COMMISSIONER BERNTHAL: Are you saying this is 10 unique to Clinton, it is unique to the MARK III's?

11 MR. BERNERO: It is unique to Clinton.

t 12 COMMISSIONER BERNTHAL: I see.

13 MR. BERNERO: The other plants use a relay circuitry

{

14 and it is not on line testable. In other words, you have to 15 pulse it or lift leads or open test circuits or something to 16 test it.

17 COMMISSIONER BERNTHAL: Was this the last one to go 18 through complete design? Is that the reason?

19 MR. BERNERO: This was to be the first of a class 20 really.

21 COMMISSIONER BERNTHAL: It was?

22 MR. BERNERO: Or something like a first of the 23 class, you know, the Black Fox and all of the cancelled 24 BWR-6's as a practical matter were these.

'- 25 COMMISSIONER BERNTHAL: So the other BWR-6's, in

, - - . . - . - - - - - . . - , ,,-_m,- - , , -

43 1 fact, sort of pre-dated this one.

2 MR. BERNERO: Yes, they were the early versions and 3 that design was developing as they were being developed and 4 marketed.

5 MR. SIEGEL: May I have slide seven, please, or 6 viewgraph seven?

7 [ SLIDE.]

8 MR. SIEGEL: With regard to significant post TMI NRC 9 requirements implemented, all the TMI action plan items have 10 been implemented and all the NUREG-737 and Supplement One 11 iters. There are two license conditions in the license, one 12 related to the detailed control room design review and one

['N qi 13 related to Reg Guide 197 requirements that remain to be 14 implemented but they are only small parts of those two items.

15 With regard to fire protection, there was a fire 4

16 protection audit done, Appendix R audit done in May of 1986.

17 Illinois Power complies with the requirements of our branch l 18 technical position 9.5.1 and the fire protection has been  !

l 19 removed from the tech specs and it has been put in their plant )

l 20 administrative procedures. I l 21 With regard to ATWS, Clinton satisfies the ATWS 22 rule. It has alternate rod injection. It has reactor pump 23 trip and it has a manual stand-by liquid control system, 24 manually actuated stand-by liquid control system.

25 With regard to equipment qualification, it meets

. 44 1 both the environmental and seismic requirements and the pump m

s 2 and valve operability requirements.

3 Two additional items I would like to mention are 4 Salem ATWS, it satisfies the requirements in generic letter 5 83-28 and the staff has reviewed it against that with the 6 exception of four parts.

7 With regard to emergency planning, it has approved 8 on site and off site plans. They have successfully completed.

9 two full participation exercises, one in December of 1985 and 10 one only as recently as January 13, 1987 and in both of those, 11 there was a positive finding that the exercise was successful.

12 There are two items that remain to be carry-over 13 items as a result of the 1987 drill, the January drill, that 14 have to be examined during the next full scale exercise but 15 they are rather minor.

16 May I have the next viewgraph, please?

17 [ SLIDE.]

18 MR. SIEGEL: With regard to staffing as Mr. Hall 19 mentioned, they are on a five shift rotation. They do not 20 have any advisors or don't need them. One of their operators, 21 SRO's, on each shift has at least six months hot operational 22 experience and six weeks at power levels greater than 20 23 percent power.

24 The shift is comprised of one shift supervisor, one

\ 25 line assistant shift supervisor both of which have SRO

45 1 licenses, one shift technical advisor, two control room

,m 2 operators, two auxiliary operators and a rad physics person, a 3 rad protective technician and one rad waste operator which 4 aren't shown on this slide.

5 Their operators are, the SRO's are non-degreed and

! 6 operators are non-degreed. The SCA is degreed. Illinois 7 Power is implementing a program. They are starting a program 4

8 for their operators to get a B.S. in nuclear engineering on 9 site in conjunction with the University of Illinois for those 10 operators that completed two years of college. This is sort 11 of a continuation of a program that was required for degreed 12 STA's and I understand they are starting a junior college N, 13 program in addition.

14 COMMISSIONER ASSELSTINE: Where did their operators 15 get their hot operating experience? .

16 MR. SIEGEL: I think most of them got it at 17 La Salle.

18 COMMISSIONER ASSELSTINE: What kind of pass / fail 19 rates did we see on the operator licensing exams?

20 MR. SIEGEL: Around 80 percent.

21 COMMISSIONER ASSELSTINE: Eighty percent?

22 MR. SIEGEL: Yes.

23 COMMISSIONER ASSELSTINE: Good.

24 MR. SIEGEL: With regard to conclusions from a l

'- 25 licensing standpoint, I would like to point out that we found

.I l

. - , -- ,. - - , . . . , , - , - . . - , , .- ----,--.-,.a . . . -

46 1 a high degree of consistency between the as-built design, the

,m.

2 FSAR, the tech specs and the SER and the licensee, in fact, 3 has certified the plant as-built design against all three of 4 those.

5 In conclusion, I would like to say from a licensing 6 standpoint that we feel that Clinton meets all of the license 7 requirements for issuance of a full power license.

8 CHAIRMAN ZECH: All right.

9 MR. SIEGEL: If there are no questions, I will turn 10 it over to Mr. Norelius.

11 CHAIRMAN ZECH: Thank you. Proceed.

12 MR. NORELIUS: Next slide, please?

13 [ SLIDE.]

14 MR. NORELIUS: The company has already given you a 15 preview of some of the things that I had intended to say so I 16 will try not to be excessively duplicative.

17 CHAIRMAN ZECH: We have two other events this 18 afternoon, so that will be fine.

19 MR. NORELIUS: But I will try to hit the highlights.

20 COMMISSIONER ASSELSTINE: Don't give short shrift to 1

21 maintenance though. l 22 MR. NORELIUS: I will try to address the questions 23 that you raised.

24 COMMISSIONER ASSELSTINE: All right.

25 CHAIRMAN ZECH: Fine.

1

47 1 MR. NORELIUS: Slide nine.

(~h 2 (SLIDE.]

3 MR. NORELIUS: They did have some significant 4 problems in construction in the early years and they described 5 for you the actions that they took in 1982 to change 6 management, change programs. They developed a rather extensive 7 over inspection program which we reviewed and found 8 satisfactory and the major inspections, independent design 9 review and CAT inspections, turned out satisfactory.

10 I did put one item on here on a hearing issue 11 because I thought it was somewhat unique. The Illinois 12 Attorney General and Prairie Alliance had filed certain

('5 13 contentions and these were reduced down to three, a basic one

\. '

- 14 being QA and through discussions between NRC, the state and 15 the utility, we entered into a joint stipulation which provided 16 for a large involvement by the state in on-going activities 17 that we had.

18 They were involved in commenting on over inspection 19 program changes and were very much involved in day-to-day 20 activities and were satisfied with that arrangement so I ,

l 21 thought it was unique and worked very well in resolving the l 22 issues.

23 Next slide, please. I l

24 (SLIDE.]

\ 25 MR. NORELIUS: The preoperational testing program l

. 48 1 went quite well at Clinton. We did give them a category one 2 rating in our last SALP period in this area because of the 3 good staff, effective results review and very few violations 4 compared with other plants in this stage. So they received a 5 category 1.

6 There were some problems that came up during hat 7 time that were not specifically related to the testing but had 8 to do with their control of systems when they were turned over 9 from construction to testing to operations.

10 Once the systems had been turned over, we found that 11 the maintenance program was not ready to accept them and do 12 the necessary thing including post maintenance testing to

(\, 13 assure the validity of the testing that had been done.

(.

14 So that was a problem that we found during that

15 period and that led to a lower rating in some other areas in 16 our SALP which I will address later.

17 Next slide, please?

18 [ SLIDE.]

19 ,

MR. NORELIUS: We have already discussed, I believe, 20 that the fuel loading had substantial problems. They did make 21 changes right after that time and they showed good 22 improvement. I will show you a slide a little later on on 23 LER's which I think will demonstrate that graphically. l 24 It also showed up when they went to initial 25 criticality that they had corrected their early problems and

! l

.l

49 i

1 the initial criticality went quite smoothly.

2 The testing.that is required, I believe, they have 3 about six days of testing left now to complete before the 4 plant is ready to go above the five percent limit.

5 Next slide.

6 (SLIDE.]

7 . MR. NORELIUS: There are a numb 9r of things that we 8 did to assess their readiness for operation. I will focus 9 more of my comments on this area.

10 Next slide, please.

11 [ SLIDE.]

12 MR. NORELIUS: During the last SALP evaluation which 13 ended on August 31st, basically they got category 2 ratings in 14 most areas and I have already talked about preoperational 15 testing were they got a 1. They had category 3 ratings in two 16 areas, one of those was maintenance.

l 17 The problems there I have already alluded to some of 1 18 those but they had problems with motor operated valves, the 19 wiring of those, post maintenance testing was not completed 20 properly, procedures were not changed after deficiencies were 21 identified and those were some of the things that led to the 22 category 3. Training of Stone and Webster people was not l

23 proper so that led to that rating.

24 In the quality assurance area, we again felt that 25 they should have taken actions to identify a number of these

\ -

50 1 problems themselves and so while there were a lot of aspects 2 to that, I think that was one of the major items that led to a 3 down rating in that area.  !

4 Since this rating was given just before we issued 5 the low power license, we assured ourselves before recommending I

6 issuance of that license that they had programs in place to 7 correct those and subsequently we went back to addres's those 8 areas and found that they had taken corrective action in both 9 of those areas and again, I believe the company has given you 10 the basis of those so I will not repeat those items that they 11 did to improve it unless you have a question.

12 COMMISSIONER BERNTHAL: Well, let me ask one

^

13 question. It has been asked a time or two already but I am

, ]

14 still a bit troubled by the maintenance backlog and the whole 15 question of maintenance. In fact, that was part of the reason 16 for my question about personnel and how many and at what 17 level.

18 MR. NORELIUS: Let me try to sort out the 19 differences. In the earlier problems, we were concerned with 20 the maintenance program itself, the adequacy of procedures, 21 how good the maintenance work requests were written, the 22 training of the people to do maintenance and so the problems 23 were mostly oriented toward the actual conduct of the 24 maintenance activity.

25 During our early operational readiness inspections

51 1 in December, we went back to focus on corrections to the i

2 maintenance program by itself, how good did they do the 3 maintenance,.how well was it defined and how well the training 4 was and how well did they do it.

5 In the later operational readiness inspection we 6 focused on that subject more in terms of how it related to 7 supporting the operation.of the plant and the concerns we had 8 were not so much in the adequacy of doing maintenance, but it 9 was were they defining the proper maintenance to do to support 10 the plant.

11 COMMISSIONER BERNTHAL: That is precisely the point, 12 not so much did you do it correctly but is it getting done, I t N. 13 think is the question and there is this huge backlog.

(;. '

14 MR. NORELIUS: That's right and when we went out 15 early in March to do the first operational readiness inspection 16 after they had gone critical, we thought that they had a fairly 17 high number of maintenance items, the backlog, they had a high 18 number of late preventive maintenance items. They had a high l

19 number of out-of-service annunciators in the control room and 20 we did not see these things going in the right direction.

21 So it was more when you put all of these things 22 together, we didn't think they were addressing it to support 23 the plant operations.

24 COMMISSIONER BERNTHAL: So we both understand the 25 problem. Now, why?

S l

I j

i

  • l 52 1 MR. NORELIUS: Why?

, N, 2 COMMISSIONER BERNTHAL: Yes. The question is why is 3 there still this large backlog? I realize it is being whittled 4 down and I trust based on the fact that you are here today that 5 those are not safety significant items but it seems like a lot 6 of nits yet to be cleaned up.

7 MR. DAVIS: Let me.through in a comment because I 8 have also pursued this a little bit and looked at it with 9 respect to some other plants. I think Mr. Hall said earlier 10 that the number was about 2,300 or 2,400.

11 We looked typically at some plants in the region 12 that have been operating for a while and they have backlogs

^'-

13 in the order of 1,000 to 1,500 so Clinton is higher than that.

14 COMMISSIONER BERNTHAL: That's right.

15 MR. DAVIS: Perry, on the other hand, has somewhat 16 more than Clinton, probably up around 3,000. Davis-Besse 17 which we addressed here a few months ago has a higher backlog 18 than Clinton has.

l 19 So putting it all together at least from my 20 perspective, the number is higher than what I would like to 21 see it but it is not out of line with some of the other plants 22 in Region III and I think some of the other plants in then 23 nation.

24 Now one of the things that Mr. Hall discussed with 25 you earlier was that he is planning after test condition two l

53 1 to look at the material condition of the plant and also to 2 look at how well the operators performed during that period of 3 time and he intends to meet with us and discuss that. i 4 We have also discussed that if the maintenance

! 5 request backlog is not going in the right direction and I 6 won't put words in his mouth but I think he will agree with 7 this that he will consider at that time taking an outage to 8 reduce the maintenance backlog.

9 We addressed maintenance back in December when we 10 found a number of problems similar to what Chuck Norelius was i

! 11 telling you. We had problems with wiring. We had problems i

12 with motor operated valves that probably would not operate j,  ; 13 properly under low voltage conditions.

L 14 We had problems with post modification testing and 15 not finding 17 valves with limit switches wired backwards, a 16 myriad of things like that.

17 Since that time we have sent maintenance people down 18 to look again. We have covered maintenance in both of the 19 operational readiness inspections that we have done in the i

20 last couple of months and our maintenance inspector, a 21 specialist from the regional office, when I asked him the 22 other day, "Do they have enough maintenance people?" His 23 answer was "Yes."

24 How is the quality of those maintenance people? He 25 felt the quality was good. I asked, "How about the re-work?

_w - - - - - - - - , - ., . . _ , , , , _ _ , , . - - , --- --

54 1 How much re-work?" "Not much re-work."

l A.

2 COMMISSIONER BERNTHAL: I am willing to concede the 4

3 quality of the people and the quality of the work but if this l 4 plant is typical and maybe it has something to do with BWR's, 5 if it does, tell me but I do recall, I believe, that we have 6 had licensees here at this stage with numbers that I think are l

i t

7 well below 1,000 at least if not in the hundreds and going.

8 down but maybe I am wrong.

j 9 Nevertheless, that doesn't change the question of l 10 why are there so many little things that take so long to get 1

11 whittled down that are maintenance items? The answer to that l

12 kind of problem would normally seem fairly straight forward.

l 1 ( ~ ', 13 You get more good maintenance people than you have and whittle 1 (.

j 14 the number down.

15 COMNISSIONER ASSELSTINE: Or you get the things 3

I 16 fixed before you start to run the plant.

17 COMMISSIONER BERNTHAL: Preventive maintenance 18 perhaps, too.

19 MR. STELLO: I think the right answer, what I would 20 like to see is that there is a maintenance backlog equal to i

j 21 zero but you will never achieve it.

i

, 22 COMMISSIONER BERNTHAL: Well, that is not possible.

1 a

l 23 We all understand that. l 1 \

24 MR. STELLO: Everyone understands that there needs 5  :

i 25 to be a backlog simply because a. lot of things can't be done  !

l  !

i

  • l 55 1 until the plant is out-of-service and you have equipment, you ,

<m.  :

2 have to shut the plant down, clear voltage on panels and what 3 have you, do a lot of things.

4 So there is a number that is going to be there in 5 the mean. When you look at how you count these things and 6 what you see in one plant $n: what you see in another plant, we 7 have tried to look at this a long time'ago and this is one of 8 the issues we want to work very hard on, performance 9 indicators. It is all over the map and you can't get any real 10 correlations in terms of how well people are doing by how 11 large the number is.

12 COMMISSIONER BERNTHAL: Are people logging different (N. 13 things?

( '

i 14 MR. STELLO: They definitely log them differently.

15 You can go to two different plants and you can get a list in l

16 one plant that is a thousand and it will be exactly the same I

17 number of issues that literally have to be done that somebody 18 else will log in at 2,000. So it is all over the map and it i

19 is very, very difficult --

I 20 COMMISSIONER ROBERTS: That is why you have to be 21 very careful.

I 22 MR. STELLO: -- because every utility does it 23 differently. There is no easy answer. I wish I could answer i

24 the question. It is a good question. It is one we have to 25 work on. Is this plant too high? I think the issue was I

o 56 1 wasn't prepared to come and tell the Commission I was 'atisfied s

/,

2 until I was convinced that one thing for sure, it would not go 3 up, it was coming down and have that trend reversed so we know 4 it is decreasing. That is the first point that had to be made.

5 Now is it as large as I would like it to see, no, I 6 would like to see it smaller. Can they really do more to make 7 it a smaller number in the next several weeks? I think they 8 will. How small should it get to where we are all happy? We 9 don't have that answer. You are not going to get that answer 10 today.

11 We are struggling very hard to deal with that. It 12 is a very important question, I think, probably very

, r' 13 fundamental to the performance of some plants. They just

(

14 don't know how to do it yet.

15 CHAIRMAN ZECH: But what you are saying though is 16 you think the number is at such a level that there is no 17 concern as far as safety of operations is concerned?

18 MR. STELLO: Right now we are satisfied. In fact, I i

19 don't think he could have made that case before but we are 20 satisfied that that is okay. In addition, we are persuaded i

21 that they now are managing it and it is moving in the right l 22 direction. l l

23 CHAIRMAN ZECH: All right.

24 MR. SNIEZEK: Let me add on that. When the last 25 team went out they picked 11 of the major systems and looked

57 1 at the maintenance work requests and they identified about 350 2 or so maintenance work requests associated with those 11 3 systems of which we thought 100 or so may have safety 4 significance.

, 5 The utility is still verifying all 350 to ensure 6 that they don't have any safety significance. Our team went 7 out and looked.

8 COMMISSIONER BERNTHAL: Can you give me an example 9 of, let's say, three from that visit, three items? I assume 10 maintenance items outstanding is equivalent to somebody having 11 a work order out somewhere, a piece of paper that says 12 something needs to be fixed.

(5 13 Can you give me three items that you would call the 14 most significant from that visit?

15 MR. SNIEZEK: Let me ask Pat Hiland, the resident, 16 to address that.

17 MR. HILAND: Yes, sir. One item that they identified 18 on that list was their air compressors on the emergency diesel l l

19 generator air start system. As you might know, each diesel 20 generator has its own air start system which involves two air 21 compressors, a redundant system.

22 One air compressor had been taken out of service 23 because it cycled when it was running so they had a maintenance 24 work request out to repair that.

25 In their review, when they went back out and reviewed

58 1 it, they agreed with the team. Of the 105 that the team 2 thought had a potential to impact safety, that was one of 3 the 105 that they agreed and they prioritized a higher 4 maintenance activity on that item.

5 Another item that we looked at --

6 . COMMISSIONER ASSELSTINE: How long had that item 7 been out of service by the way?

8 MR. HILAND: I don't know the exact time. I believe 9 it had been out for about three weeks, two to three weeks.

10 That is based on my plant tours.

11 COMMISSIONER ASSELSTINE: All right.

12 MR. HILAND: Another item they identified was a

. (" t 13 sticky rocker arm on a diesel generator. They had an 14 outstanding maintenance work request on it and the utility 15 went and discussed with the team and the plant manager himself

16 had gone out to the diesel engine to determine just how sticky 17 the rocker arm was.

18 Based on his own evaluation, that was done before 19 the team brought that up, he decided that that engine was 20 still operable and he had additional maintenance people out 21 there with him. So one concern that they had actually 22 evaluated, the outstanding maintenance work item could still 23 declare that system operable or leave that work item as a 24 lower priority.

25 Some other items would include some leaks on valves,

59 1 stem packing leaks. There is a RCI steam supply valve to

- 3 2 their RHR heat exchanger for the steam condensing mode where 3 the packing leak has been leaking for a long period of time 4 and on that item, they decided that that did not deserve a 5 higher priority maintenance because of their not planning to 6 run that system.

7 Those are three examples. I can give you some 8 breakdowns further but those are the three types of things and 9 they have completed that walkdown. We said 105 and they went 10 out and did a hands-on walkdown of all 350 of the maintenance 11 work request items and they completed that earlier in the week 12 and of that 350, two of those they decided to increase its

.I

! 13 maintenance already.

14 CHAIRMAN ZECH: All right. Thank you. Proceed.

15 MR. NORELIUS: Unless you have other specific 4

16 questions on that inspection, then I think I will just move on 17 to the next chart which shows a picture of LER's.

18 We did say earlier that they had substantial problems 19 during fuel load and that is graphically represented there and '

i 20 in the November / December time frame we met with them and they 4

21 took actions to slow down activities, reduce overtime, 22 instituted controls and I think all that showed a much 23 favorable trend in the number of LER's that have been issued, 24 I would just add to this graph that in April you d

25 will see that jump up again. Right now, I believe, I know of e

I.

60 1 about 11 LER's that we anticipate in April. The primary p

2 reason for that, I believe, is that they went critical in i

3 February and March was their initial period of operating the 4 plant and that resulted in bringing systems in under different 5 plant conditions. I 6 They did have one scram which we mentioned. That 7 has been the only scram they have had. That was a manual 8 scram which was positive in that they recognized that rods 9 were drifting in and they scrammed the plant manually so I 4

10 think that was a plus.

11 But that chart will go up next month and right now, 12 I think, we know the reason why and yet we want to maintain ,

r~

, (X 13 diligence in overseeing that and try to get it'back down as 14 they move on up again.

15 COMMISSIONER BERNTHAL: I am coming back again, I 16 want to ask one more brief question on maintenance. How many 17 people actually do the work in the plant on maintenance? I

] 18 don't mean the people who track it or analyze it or put it in i

19 the computer or keep the files. How many people actually get 20 out and put the hands on and do the work?

21 MR. HILAND: They have a maintenance contractor on 22 site, Stone and Webster, that has been supporting their own 23 maintenance staff. The exact numbers to date, I think we 24 could ask the licensee for that, but I believe they had about 4 x 25 200 contracted craft and they have about 60 in their own 4

61 1 maintenance staff.

, 2 COMMISSIONER BERNTHAL: So 260 that actually do the 3 work?

4 MR. HILAND: That is correct.

5 COMMISSIONER BERNTHAL: All right.

6 COMMISSIONER ASSELSTINE: A question on LER's, how 7 do these numbers relate and this experience relate to some 8 other plants say in Region III that have started up in the 9 last year or so?

l 10 MR. NORELIUS: We have compared them to the large 11 BWR's, not only in Region III, and they are a little better at

12 this point than most of the others.

3 13 COMMISSIONER ASSELSTINE: All right.

, \

14 MR. NORELIUS: If we could go to the next slide, 15 please?

16 (SLIDE.] l 4

17 MR. NORELIUS: We conclude that they have satisfied 18 all of the basic requirements. We still have a couple of open

! 19 items that we need to close but we are satisfied that they are l

20 to the point where we would recommend a vote for a full power I

21 license.

1 I

22 I did one item to this slide which I believe, l 1

1 23 Commissioner Bernthal, you asked about, the fact that we plan )

24 to do somewhat of a formal review of their performance midway 25 through the start-up program, power ascension program.

l

. - . - - - . - = - - - _ _ - _ _ _ - . _ - . . -

62

{ l I think we have tried to learn from our experiences 2 from some other utilities recognizing that all utilities go

! 3 through a learning curve and recognizing that this is a 4 utility that is bringing their first and only plant up, we

! 5 would like to do whatever we can to try to shorten that 6 learning curve.

7 We thought it prudent to work out an agreement with

! 8 the utility that we would sit down about midway up in this t 9 program and assess the performance. Mr. Hall has provided us 10 a program which he described that includes both some steady j 11 state operation and some training evolutions that they plan to i

12 go through.

l

~

l /^ 13 They also plan to assess the maintenance situation i (.

14 at that point with us. We are planning to do another team i

15 inspection with some NRR and possible AEOD people to assess-

16 licensee event reports, deviation reports, to see what have 17 been the root causes, to see if they have looked at those and i

18 learned in terms of corrective actions at that point.

19 So we have agreed to sit down after they have gone l 20 through test condition two and assess the performance to that l 21 point and see if there needs to be any correction. So that is i

! 22 the nature of that program.

c 23 CHAIRMAN ZECH: Then you tend to perhaps use this f

i 24 procedure in this future on other plants, is that correct?

25 MR. NORELIUS: I think it might depend on the l .

l

63 1 plant. They have had some problems in the past. We talked 2 about the fuel handling problem. We talked about the problems 3 in maintenance, some of the other areas. So I think it may

.i 4 depend on the plant where you would use this but we thought it 5 prudent for this utility to do this.

6 COMMISSIONER BERNTHAL: Let's see. The risk to 7 public health and safety though, the difference between 55 8 percent and 60 percent, whatever it is, and 100 percent must 9 be marginal, I would think.

10 In fact, it is true, is it not, that most of these 11 plants are designed to be run at full power. If this is 12 better to stop midway like this, then why wouldn't we do it 13 routinely or is it better on BWR's and not on PWR's? If there-14 is little to be gained in risk and perhaps even something be l 15 lost, why stop here instead of at 100 percent?

16 MR. DAVIS: This is the end of one of the test j 17 plateaus during the test program.

j 18 COMMISSIONER BERNTHAL: Right.

i 19 MR. DAVIS: Of course, although it is at 55 percent j 20 power, you have not operated for a long period at that time so 21 your fission product inventory is not as great. I think 22 another point is that Fermi or a period of time operated at i

23 about 20 percent power which, of course, is better for the l 24 fission product.

25 COMMISSIONER BERNTHAL: Of course, 20 is a lot

t 64 A

E I 1 different than 100.

2 MR. DAVIS: But it also results in a lot of vibration 3 in the plant.

4 COMMISSIONER BERNTHAL: Right. ,

1 5 MR. DAVIS: I think Mr. Hall made the point that you  !

l 6 are better off --

7 COMMISSIONER BERNTHAL: That is the point.

8 MR. DAVIS: -- to get up above 55 percent.

9 COMMISSIONER BERNTHAL: That is the point. So at

10 60, you are close enough to 100 that these mechanical questions 11 don't arise. Well, I am still not sure I understand.

12 . CHAIRMAN ZECH: All right.

4 i t' 13 COMMISSIONER BERNTHAL: I take your word for it, I

\. .

14 guess.

15 CHAIRMAN ZECH: Does that conclude the presentation?

16 MR. STELLO: Well, maybe a bit more straight forward 17 than that, I think the simple point is to put pressure on the 4

18 licensee to make sure that the kinds of problems we have had l 19 in the past and the things that we have asked him to correct I

20 so he knows we are going to be back and look. I think it is 21 that simple.

22 COMMISSIONER BERNTHAL
All right. That is a 1

, 23 straight answer.

24 CHAIRMAN ZECH: All right. Other questions from my 25 fellow Commissioners. Commissioner Roberts?

i ,

, _ _ _ _ _ _ _ - - - - . ~ . , , , . , _ _ - -- - - - - - , - . _ _ . . , , . . - - - , - - - - _ - - . . _ _ , - , _ _ , _ , . - - , - _ ,. ,,--. ,., ,.,

65 1 COMMISSIONER ROBERTS: No.

f' .3 2 CHAIRMAN ZECH: Commissioner Asselstine. 4 3 COMMISSIONER ASSELSTINE: Yes. I am going to forego 3

4 some of my more detailed ones but just as you a broader one, I 5 think it follows along the same lines of the same kinds of 6 things we have been talking about all through the meeting.

7 One question, how does what the licensee is proposing 8 in terms of this more extended operation at about the 50 or 55 9 percent level relate to the recommendations the staff just made 10 in the strategic planning review that what we ought to have in i

11 new plants is a period of two or three months operation at the

.i 12 lowest power level where you can operate all the systems and 13 make sure that the utility understands what they are doing, the

14 operators know their procedures, that they are able to manage 15 the plant well and keep up with the maintenance load, those 16 kinds of things?

17 Is this along the same lines? Is it pretty much it?

18 MR. STELLO: Yes. Why not get the power level high

19 enough so that when you are doing it, but yet, plan. Now you 20 might want to change that depending on the facility as we did 21 before so you don't even bring on the other major systems but 4

22 it is part of that process. At least that it the suggestion 23 and has as its genesis the simple answer I just gave 24 Commissioner Bernthal when you have concern.

25 MR. NORELIUS: But it is for less than two months. ,

i s

66 1 COMMISSIONER ASSELSTINE: For less than two months m

- 2 though, how long a period are they talking about?

3 MR. NORELIUS: They are introducing two periods of 4 steady state operation of about three days each, I think, two 5 to three days and then a seven day period where they are going l

6 to go through training evolutions and monitor as they exercise 7 various pieces of equipment.

8 COMMISSIONER ASSELSTINE: All right. Let me tell 9 you my concern and then I will get your reaction to a I

10 question. To put it bluntly, I don't want this to be another l 11 Fermi. Bert, I know you don't want it to be another Fermi 12 either but I get a little worried when I look about at this

, 13 plant quite frankly.

14 .When I visited the plant, I came away with a pretty i

15 good feeling. I did not come away with a good feeling at all 16 with the experience on fuel loading. I was not impressed and 17 the company knows that and I don't think the staff was either. I 18 MR. STELLO: That is why I scrapped it the first l l

19 time.  !

20 COMMISSIONER ASSELSTINE: That's right. I

, 1 21 MR. STELLO: I wasn't satisfied. I am satisfied now 22 but that is why I said so plainly so that the licensee clearly 23 hears me that we will be watching him. If it is another Fermi 24 and we have a problem, we are going to find it out quickly and 25 wa are going to get it fixed. I don't think we expect that.

)

i e e

_ --- ,.__- - - . _ . _ _y .- _- , .

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) I , 67

. s 1 i' I think we have their attention but want ito do just ,

m. - ,

2 a little bit more and make sure they know it is not over.

  • We 3

\}

  • l 3 are going to be looking some more. We think this licensee has 4 ,

learned a lesson and he has listened to us. We are just gaing

.b /~

5 /to go back and make sure he, in fact, does that. k

\ ,

'I

',' 6 COMMISSIONER ASSELSTINE: Let me finish my question r

7 f ,and then get your reaction. Given the fact that it is a first ',

i  ! '

(

8 time licensee, given the problems they had in fuel loading, 9'

  • things have gone better with low power testing so far, glven l 10 the maintenance problems that we have been talking:aboud,,why 11 isn'tthisagoodcandidateforamoreextendedperiodof[ ,
s -

l 12 lower power operation even than what they are talking about.

' 13 9- That does say to them get a full power license but ,

/

k' . . 1, 14 r why isn't a good candidate for that more deliberate approach?

, 15 3 MR. STELLO: Well, we go back and look. If we are N

16 not satisfied, it may go on. But if we are really unhappy, j 17 the power level may come way back down, too.

W 18 a,

[ F COMMISSIONER ASSELSTINE: All right. *\

19 g MR. STELLO: What we need CG do is see how well it 20 is doing. If it goes okay, wt Eis '2:isfied. If it doesn't, 21 it might not only mean that we would delay them starting there 22 or staying at that power level but also the possibility that

, w 23 maybe nor severe action would be needed.

24 ,I think we want the licensees to understand that we

'- 25 are very serious especially when they are starting up these j

,, l

, i

- d

..-..4

. i 68

+ -s 1 plants that we want them to do it very carefully and start out 2 on the right foot.

3 I think all of the licensees understand that is our 4 view, that is the Commission's view, I think we made our 5 point. We are not precluded from doing that.

6 COMMISSIONER ASSELSTINE: Your feeling and Bert, 7 yours as well, is that they really are ready.

8 MR. DAVIS: I have given this a lot of thought, your 9 question.

10 COMMISSIONER ASSELSTINE: I know you have. We 11 talked about this before.

12 MR. DAVIS: There are several things that make me 13 believe that they are ready and, of course, you know that I 14 don't want another Fermi either. I look at their recovery 15 from the construction problems that they had and I have to 16 give them credit.for a good recovery. l 17 I think that they have a strong vice president on 18 site who is capable of managing the plant very well. I think 19 that is stronger than we had at Fermi. I think the licensed  !

20 and balance-of-plant operators are strong and they are good at

-21 following their procedures and I think that we have conducted 22 much stronger operational readiness inspections at Clinton 23 than we did at Fermi although we did one there and we told you 24 at the Commission meeting that we thought we had done a good 25 job and I am positive we did a much better job here so I put I

=

  • j 69 1 1 all those things together and I say, I think they are ready to 2 go up but I also feel that it is important for us to look at 3 them at 55 percent.

4 COMMISSIONER ASSELSTINE: All right.

5 MR. SNIEZEK: Commissioner Asselstine, I would like 6 to address your question also. I would second what Bert said i 7 on the construction recovery program. They took something 8 that was in shambles and they made it turn out pretty good.

9 When I was out at the site touring the plant and 10 talking to a few of the operators, talking to the managers, I 11 was very impressed by the philosophy of the managers. They at 12 least expressed a philosophy of "let's do it right." They 13 have had some problems early on but I believe the philosophy

[

14 is really there.

15 They are paying attention to their staffing, the 16 quality of their staff and the training of their people. The 17 plant manager is down there with the plant operators and new 18 evolutions doing it with him, talking to him about it, starting l

19 off a feed pump for the first time, he was down there as an 20 example, with the operator. What shall we expect when the pump 21 lights off, et cetera? l t

22 I see a philosophy as expressed after their fuel 23 loading problems of let's not rush it, let's slow down, take 24 it easy, let's correct the problems that are identified, let's 25 not just move forward.

4 70 1 I have the feeling that the management is really in 2 charge of the plant and the operations that go on, that they 3 do take an interest and besides that, looking at the overall 4 NRC licensing program we went through and the inspection 5 program, the results, the integrated results of the operational 6 readiness inspection, I wasn't very happy when I got the first 7 team report early in March but after we went out there in April 8 and saw the improvements, I said to myself, "This plant can 9 move in the right direction and get it done."

10 So I am pretty well convinced that we can have a 11 safe operation at the Clinton facility.

4 12 COMMISSIONER ASSELSTINE: All right.

^'

13 MR. STELLO: Mr. Chairman, we are through with our 14 presentation and we have told you where we come and we did 15 indicate we would watch maintenance. I hope you.are convinced 16 we intend to do so not only in this plant but across the 17 board.

18 CHAIRMAN ZECH: All right. Commissioner Bernthal, 19 do you have any questions?

20 COMMISSIONER BERNTHAL: No. I think I have finished, 21 thank you.

22 CHAIRMAN ZECH: All right. Commissioner Carr.

23 COMMISSIONER CARR: No questions. l 24 CHAIRMAN ZECH: Let me just emphasize the fact that 25 I think that maintenance should be watched and I understand

_ _ .._. _ _ i. _._ . . _ . _ _ __ _

71 1 the commitment'from the Clinton people to do that and also the 2 staff to monitor it, the region to monitor it, too.

3 I would like to say, too, that I agree with Jim 4 Sniezek as far as management of the plant is concerned and I I 5 think the attitude has been strong and competent and certainly 1

l 6 my impression has been in following this plant that it has a 7 commitment to careful constructive conservative operations 8 focused on safety.

9 I think that is important. I would agree with you, t 10 Mr. Sniezek in that evaluation.

1

! 11 I would like to thank the Illinois Power Company and 12 the staff for an excellent presentation here today. If I can

( 13 summarize, as I understand, the licensee and the staff both

\ .

14 have concluded that upon successful completion of the remaining i

15 low power testing, Clinton power station will have satisfied l

16 the requirements for issuance of a full power license and that '

17 you are going to take this intermediate step on the way up.

18 Consequently, unless there are any additional i 19 questions or comments, I will ask my fellow Commissioners if 20 they are prepared to vote.

21 COMMISSIONER BERNTHAL: If I may, I did want to make 22 one final comment that relates a little bit to what I asked 23 Mr. Bernero and maybe one or two others about earlier.

24 CHAIRMAN ZECH: Go ahead.

25 COMMISSIONER BERNTHAL: The point I want to make is

. . , . - _ , , _ , - - ,,, . , ,-- - ..-_, , _m. . . , . . . . , . . . _ _ - - _ . - . ,-,-,,--m.... . , _ . ,,,.__...,...___._v._,,

. 72 l l

1 that it is often missed by the press and others, I think, that  !

! i 2 this really is the newest generation plant of the BWR type and 3 whenever I see one of the newest generation designs on the one 4 hand, it is striking to me that the n'ewest generation design 5 tends to be vintage 1970 in our country today but on the other 6 hand, the newest generation design in this case should be 7 quite a good plant and quite a forgiving plant in many respects 8 compared to some of our other plants.

9 So I always follow this kind of plant with great 10 interest. This is a good plant design. It incorporates many 11 of the most modern features so I certainly hope that the 12 utility does the plant a survice and that the plant serves 13 them well in the same vain.

14 That is just a point and a comment that I wanted to 15 make that this is, I guess, the latest and the flagship in 16 that sense of the most modern boiling water reactor. Treat it 4

17 well.

18 COMMISSIONER ASSELSTINE: Lando.

19 CHAIRMAN ZECH: Jim.

20 COMMISSIONER ASSELSTINE: Just a comment. I am 21 ready to vote as well although I have to say that in this case 22 there are still some doubts in my mind about the plant and I 23 hope that the staff will watch it very closely and that the j

, 24 company will take a very slow and careful and deliberate 25 approach as they proceed and don't rush it.

. . . , , - - _ ~ . . - . , , , - - - - _ . - - ,- , . , - - - - . , -

73 1 CHAIRMAN ZECH: Thank you. Any other comments?

2 [No response.]

3 CHAIRMAN ZECH: Are we prepared to vote? Those 4 Commissioners in favor of issuing a full power license to 5 Clinton power station, please signify by saying aye.

6 COMMISSIONER ROBERTS: Aye.

7 COMMISSIONER CARR: Aye.

8 COMMISSIONER BERNTHAL: Aye.

9 COMMISSIONER ASSELSTINE: Aye.

10 CHAIRMAN ZECH: Aye. Those opposed?

i 11 [No response.]

j 12 CHAIRMAN ZECH: The vote is five to zero in favor.

13 We stand adjourned.

s 14 [Whereupon, the meeting of the Commission was 15 adjourned at 3:47 o' clock p.m., to reconvene at the Call of i

]

16 the Chair.]

1 17 18 4

19 20 21 22 23 24 25

1 2 REPORTER'S CERTIFICATE 1 3 4 This is to certify that the attached events of a 5 meeting of the U.S. Nuclear Regulatory Commission entitled:

6 7 TITLE OF MEETING: Discussion /Possible Vote on Full Power q .

Operating License for Clinton 8 PLACE OF MEETING: Washington, D.C.

9 Friday, April 10, 1987

! DATE OF MEETING:

10 ,

i 11 j

were held as herein appears, and that this is the original 12 transcript thereof for the file of the Commission taken

[. 13 stenographically by me, thereafter reduced to typewriting by 14 me or under the direction of the court reporting company, and 15 that the transcript is a true and accurate record of the 16 foregoing events.

17 18

--- MRTITynn Nat-tens------------

19

! 20 21

  • 1 22 Ann Riley & Associates, Ltd.

23

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24

25 i

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1 OBJECTIVE REGULATORY REQUIREMENTS HIGHLIGHTS l

DESIGN

- INDEPENDENT DESIGN REVIEW l

- IMPLEMENTED TMI REQUIREMENTS CONSTRUCTION

- QA RECOVERY PROGRAMS

- OVERINSPECTION EFFORT

- RECORD VERIFICATION PROGRAM

- NRC NON-DESTRUCTIVE TEST EVALUATION TEAM

- CONSTRUCTION APPRAIS AL TEAM ATOMIC SAFETY AND LICENSING BOARD TESTING

- NRC INSPECTIONS OPERATIONS

- ON-SHIFT MANNING (IN S SHIFTS)

- TECHNIC AL SPECIFIC ATION CERTIFIC ATION (SALP SAYS HIGH CONSISTENCY BETWEEN FSAR, SER, AS-BUILT PLANT AND TECHNICAL SPECIFICATIONS). .

l

l

\

3 COMMISSION BRIEFING CLINTON POWER STATION, UNIT 1 APRIL 10, 1987 FULL POWEP OPERATING LICENSE i

BYRON L. SIEGEL i PROJECT MANAGER 492-9474 l

I l

~

2 PRESENTATION OUTLINE LICENSEE / PLANT BACKGROUND LICEt' SING MILESTONES / EVENTS PLANT DESIGN FEATURES e

NRC REQUIREMENTS IMPLEMENTED SHIFT STAFFING INSPECTION PROGRAM CONSTRUCTION PREOPERATIONAL TESTING STAP. TUP TESTING CPERATIONAL READINESS CONCLUSION

3 LICENSEE / PLANT BACKGROUND OWNERS ILLIN0IS POWER COMPANY (87%)*

S0YLAND POWER COOPERATIVE (6.5%) ,

WESTERN ILLIN0IS POWER COOPERATIVE (6.5%)

FSSS VENDOR GENERAL ELECTRIC REACTOR TYPE GE-BWR 6 CONTAINMENT TYPE ,

GE-MARK III A/E SARGENT AND LUNDY CONSTRUCTOR BALDWIN ASSOCIATES LOCATION DEWITT COUNTY, ILLIN0IS NEAREST CITY CLINTON, ILL (6 MILES WEST)

POPULATION 8,000 (1980)

NEAREST CITIES 25,000 DECATUR, ILL ( 22 MILES)

POPULATION BLOOMINGTON, ILL ( 24 MILES)

CHAMPAIGN / URBANA, ILL ( 30 MILES) l l

'ILLIN0IS POWER COMPANY: OPERATOR AND AGENT FOR OWNERS

4 CLINTON POWER PLANT LICENSING - MILESTONES OCTOBER 30, 1973 CP APPLICATION DOCKETED FOR UNITS I a 2 GCTOBER 1974 FES ISSUED MARCH 1975 SER ISSUED APRIL 8, 1975 ACRS LETTER RECEIVED FEBRUARY 1976 CONSTRUCTION PERMIT ISSUED SEPTEMBER 25, 1978 S0YLAND POWER COOPERATIVE, INC. AND WESTERN ILLIN0IS POWER COOPERATIVE, INC. BECAME APPLICANTS SEPTEMBER 8, 1980 OL APPLICATION DOCKETED DECEMBER 1981 DES ISSUED (NUREG-0854)

FEBRUARY 1982 SER ISSUED (NUREG-0853)

APRIL 1982 FES ISSUED (NUREG-0854)

MARCH 9, 1982 ACRS LETTER RECEIVED JANUARY 28, 1985 JOINT STIPULATION AGREEMENT SIGNED WITHDRAWING REf1AINING CONTENTIONS SEPTEMBER 11, 1985 CP FOR UNIT 2 REV0KED SEPTEMBER 29, 1986 LOW POWER LICENSE ISSUED OCTOBER 9, 1986 ACRS BRIEFING OCTOBER 21, 1986 FUEL LOAD COMPLETED FEBRUARY 27, 1987 INITIAL CRITICALITY APRIL 1987 PROJECTED FULL POWER LICENSE ISSUANCE ,

i l NUCLEAR P@WER PREGRAM -

I ORGANIZATION ,

l I

PRESIDENT WENDELL J.

KELLEY a

I EXECUTIVE VICE PRESfDENT g---------~~~~ W. C. GERSTMER

  • g 3 OFF - SITE ORGANIZATION
l ON - SITE ORGANIZATION

. I i

' I VICE PRESIDENT E

I S/82 D.P. HALL

' I I MANAGER NUC.

I PROG.COORD 1

l 8 10/64 J.S. PERRY

' 1

! l E

E I

I e 10/88 3/34 tres

/3/S S S/82 e MANAGER MANAGER MANAGER SCHED.

MANAGER MANAGER NUC.STA.ENG. NUC. PL. & SUP. & OUTAGE MGT.

l MANAGER CPS QUALITY ASSUR. LIC & SAFETY

! W. CONNELL * (NOTE 1) T.J. C AMILLERI J. W. WILSON R. E. CAMPSELL P. A. SPANGENBERG (NOTE 2) 1 DIRECTOR NUC.

DIRECTOR NUC. TR.

PROG. ASSESS.

I R. E. WYATT E.A. TILL l

11/a3 esas 1

2/87 l NOTES: DATES INDICATE ASSIGNMENT TO CLINTON PROJECT

1. Thee poeltlen le presently untitled.
2. Mr. Camillert le the acting Manager-Scheduling and Outege Managefnent.

l

. 1 6

PLANT DESIGN FEATURES NSSS FEATURES 2894 MWT RATED THERMAL POWER 933 MWE NET ELECTRICAL POWER 624 FUEL ASSEMBLIES 145 CONTROL RODS 218 INCH RV INSIDE DIAMETER j

  • DRYWELL VOLUME = 246,000 FT 5
  • = 1,550,000 FT CONTAINMENT VOLUME DRYWELL DESIGN DIFFERENTIAL PRESSURE = 30 PSID CONTAINMENT DESIGN PRESSURE = 15 PSIG SAFETY SYSTEMS (MULTIPLE DIVEPSE WAYS TO REMOVE DECAY HEAT)

LPCS (DIV 1) RCIC RHR/LPCI (DIV 182) ADS VALVES (DIV 182)

SSW (DIV 182) HPCS (DIV 3)

DIESEL GENERATORS (3)

UNIQUE FEATURES GE NUCLENET CONTROL ROOM NUCLEAR SYSTEM PROTECTION SYSTEM (NSPS) UTILIZES SOLID STATE LOGIC CIRCUITRY

' - SELF-TEST SYSTEM, AM AUTOMATIC TEST AND SURVEILLANCE SYSTEM DESIGNED TO CONTINUOUSLY MONITOR NSPS CIRCUITRY

. l 7

SIGNIFICANT POST TMI NRC REQUIREMENTS IMPLEMENTED TMI ACTION PLAN ITEMS FIRE PROTECTION ATWS ECUIPMENT QUALIFICATION 1

, I 7A SHIFT STAFFING 5 SHIFT ROTATION l

4 I

1 SHIFT SUPERVISOR

  • 1 LINE ASSISTANT SHIFT SUPERVISOR

1 1

2 AUXILIARY OPERATORS i

SR0 LICENSED R0 LICENSED 1-4

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l

8 RIII INSPECTION

SUMMARY

4 CLINTON I. CONSTRUCTION

. II. PRE 0PERATIONAL TESTING III. STARTUP TESTING IV. OPERATIONAL READINESS V. CONCLUSION f

i

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9

' I, CONSTRUCTION 1981 TEAM INSPECTION (PIPING SUPPORTS AND ELECTRICAL SUPPORTS) 1982 ELECTRICAL INSPECTIONS i

POST 1982 ACTIONS TO IMPROVE CONSTRUCTION 1984 IDR FINDINGS i

1985 CAT INSPECTION HEARING ISSUES IAG CONCERNS JOINT STIPULATION i

i I

- . , , - - , . - - - - - - . - - , - - . ,.m- -._,.., --, .. . . - . - . - - - . . - - - _ - - - - , ----.-,,y - __ - , - , - . - -

10 II. PRE 0PERATIONAL TESTING CATEGORY 1 RATING DURING SALP 6 PERIOD COMPETENT STARTUP STAFF EFFECTIVE TEST RESULTS REVIEW GROUP MINIMUM NUMBER OF VIOLATIONS PROBLEMS IDENTIFIED WITH POST MAINTENANCE AND POST MODIFICATION TESTING I

1

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11 III. STARTUP TESTING FUEL LOAD - PROBLEMS WITH EQUIPMENT AND PERSONNEL ERRORS.

- INITIAL CRITICALITY FEBRUARY 27, 1987.

REQUIRED' TESTING BELOW 5% POWER COMPLETED.

i

}

}

I

A- A-O l

12 IV, OPERATIONAL READINESS i

4 SALP EVALUATION OPERATIONAL READINESS INSPECTIONS i

ACTIONS TO IMPROVE PERFORMANCE REVIEh' 0F REPORTABLE EVENTS J

4 4

j i

i I

. O i

13 CLINTON SALP 6 RATINGS FUNCTIONAL AREAS

. OPERATIONAL READINESS 2

~

CONSTRUCTION 2 RADIOLOGICAL CONTROLS 2 f MAINTENANCE 3 i

SURVEILLANCE -

FIRE PROTECTIOM 2 .

1 EMERGENCY PREPAREDNESS 2 SECURITY 2 QUALITY PROGRAMS AND l CONTROLS AFFECTING QUALITY 3 l

LICENSING ACTIVITIES 2 TRAINING AND QUALIFICATION J

EFFECTIVENESS -

PREOPERATIONAL TESTING 1 1

i t

o' i

14 i

V. CONCLUSION i

i THE STAFF CONCLUDES THAT THE LICENSEE SATISFIES ALL REQUIREMENTS

> FOR ISSUANCE OF A FULL POWER LICENSE FOR CLINTON, UNIT 1.

j .

j 1

THE STAFF PLANS TO CONDUCT A FORMAL REVIEW 0F THE LICENSEE'S PERFORMANCE MID-WAY THROUGH THE POWER ASCENSION PROGRAM.

i I

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CLINTON STATION STARTUP LERs ' '

. 6 MONTHS ,

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! ADVANCED COPY T0: The Public Document Room g DATE: Y[/Y 7

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