U-600323, Submits Info Re Status of Design Const & Preoperational Testing Per FSAR & NRC Regulations.Fuel Loading Between Late Feb & Mar 1986 Anticipated.Const Approx 98.5% Complete as of 851130.All Sys Turned Over to Util for Testing

Submits Info Re Status of Design Const & Preoperational Testing Per FSAR & NRC Regulations.Fuel Loading Between Late Feb & Mar 1986 Anticipated.Const Approx 98.5% Complete as of 851130.All Sys Turned Over to Util for Testing

ML20137Y522
Person / Time
Site:	Clinton
Issue date:	12/09/1985
From:	Hall D ILLINOIS POWER CO.
To:	Harold Denton Office of Nuclear Reactor Regulation
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-1.G.1, TASK-2.F.2, TASK-3.D.1.1, TASK-TM U-600323, NUDOCS 8512110068
Download: ML20137Y522 (11)

Text

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U-600323 L30-85(12-09)-L 1A.120 ILLINDIS POWER COMPANY CLINTON POWER STATION, P.O. 80X 678. CLINTON, ILLINOIS 61727 December 9, 1985 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation United States Nuclear Regulatory Commission Washington, DC 20555

Subject:

Clinton Power Station Readiness to Load Fuel

Dear Mr. Denton:

Illinois Power Company (IP) is submitting this letter to provide you with a current status of the design, construction, and pre-operational testing of the Clinton Power Station (CPS) in accordance with the CPS Final Safety Analysis Report (FSAR) and NRC regulations. IP anticipates that fuel loading will occur between late February and late March 1986. IP beli..ves that submitting this letter at least three months before fuel load, with monthly revisions up to the month before the actual fuel lead readiness date, should serve our mutual interests in identifying areas warranting management attention. This will assure the efficient allocation of our respective resources, the prompt resolution of all outstanding issues, and the orderly conclusion of the CPS Licensing process. The status of each major activity needed to support fuel load is described below.

A. Construction As of November 30, 1985, construction of the CPS is estimated at 98.5% complete. All systems have been turned over from construction to Illinois Power for testing. As of this date, all project milestones scheduled through October 1985, have been achieved with the exception of the Integrated Leak Rate Test, which was scheduled to start on October 27, 1985. Daily monitoring of this milestone is underway to ensure timely completion.

At present, IP's planning does not anticipate deferring completion (until after fuel load) of any construction activities necessary for issuance of an Operating License authorizing fuel load and operation less than 5% power until after fuel load . IP is, however, conducting an intensive review of these matters.

Subsequent revisions of this letter will provide an identification of, and justification for, any deferred items in advance of any request for authorization to load fuel. ## f Int /, jp 8512110068 851209 d d'8d6

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U-600323 L30-85(12-09)-L 1A.120 B. Preoperational Testing The reactor cold hydrostatic test was completed on January 26, 1985, and hot operational testing commenced on July 3, 1985, and was completed on July 29, 1985.

The NRC Caseload Forecast Panel observed that "[t]he preoperational tests that have been recently performed (i.e. hot operations test, component cooling water system test) have proceeded with minimum problems indicating the schedule for the turnover of systems from startup to operations personnel, although ambitious, may be achievable." At present, IP's planning does not anticipate deferral beyond fuel load of any required preoperational tests. Subsequent revisions of this letter will provide identification of and justification for any deferred items in advance of any request for authorization to load fuel.

C. Personnel The NRC Staff's Supplemental Safety Evaluation Report (draft SSER #5), Section 13.1.1, found the organization for management and technical support of the CPS staff during operation to be acceptable. The organization, staff levels, qualifications, and experience of the CPS plant staff were likewise found to be acceptable in Section 13.1.2 of draft SSER #5. Any future organizational changes that might materially affect these findings will be submitted to the Staff in a timely manner.

Draft SSER f5, Section 13.1.2.l(3) found that prospective Clinton Senior Reactor Operators (SR0s) who complete IP's Supervisory Operating Plant Experience (SOPE) program will also satisfy the requirements of Generic Letter 84-16, and stated that the Staff will condition the license to require SR0s on shift to meet Generic Letter 84-16 guidelines for hot operating experience. Prior to fuel load, the number of licensed SR0s and R0s will be sufficient to support the shift complement levels set forth in the CPS Technical Specifications.

D. Nuclear Reactor Regulation (NRR) Licensing Issues IP has maintained active communications with NRR to assure expeditious and satisfactory resolution of open licensing issues. As indicated in the NRC Staff's September 3, 1985, briefing to the NRC Commissioners, the NRC Staff does not expect any FSAR issues to impact fuel load. The major issues requiring continued management attention to assure timely closure are as follows:

U-600323 L30-85(12-09)-L 1A.120 (1) Hydrogen Management (SER License Condition f5)

Pursuant to 10CFR50.44, IP has submitted a preliminary hydrogen analysis to the Staff. It is understood that Staff approval of this analysis is not required for fuel load, but must be received prior to authorization to exceed 5% power.

(2) Mark III Containment Issues (SER Outstanding Licensing Issue #9 and Confirmatory Licensing Issue #71)

This item includes Suppression Pool hydrodynamic loads during a Loss of Coolant Accident (LOCA) and during Safety Relief Valve (SRV) discharges, as well as Humphrey-related issues. Currently, IP anticipates NRC Staff closure of that portion related to SRV hydrodynamic loads in Sup31ement f5 to the Clinton SER. IP anticipates that the remaining issues will be resolved in SSER #6 to be issued prior to fuel load.

(3) Pump and Valve Operability Review (PVOR]

(Portion of SER Outstanding Licensing Issue f 7)

An August 1985 NRC Staff audit at CPS of the PVOR Program determined that several items remain for resolution. As a result of this audit, IP has developed plans and actions to resolve all concerns as required to support fuel load. An additional NRC audit was performed during November 19-21, 1985. IP believes'that all open items can be resolved in a manner acceptable to the Staff prior to issuance of the Operating License (OL).

(4) Equipment Seismic and Environmental Qualification (SER Outstanding Licensing Issue #7)

Items related to electrical equipment environmental-qualification are expected to be resolved in SSER #5. IP does not anticipate the need for any exemptions to 10CFR50.49. The CPS mechanical equipment environmental qualification program is still under review by the Staff. Open items from recent NRC Staff audits (July and August 1985) of these programs are being addressed and the remaining FSAR revisions will be submitted in FSAR Amendment #36. Illinois Power will have completed i its response to all audit concerns by the end of t

December 1985. NRC Staff closure of these issues in.SSER #6 is anticipated.-

t

U-600323 l L30-85(12-09)-L 1A.120 (5) Inservice Inspection (ISI) Program (SER Licensing Condition #12)

The final ISI Program is not required to be submitted until after fuel load (submittal scheduled for July 1, 1986). Illinois Power anticipates that requirements related to the ISI Program will become a License Condition in the OL.

(6) Safeguards and Security It is anticipated that these issues will be resolved in SSER #5. An NRC confirmatory implementation audit is expected following security lock-down, which is scheduled for December 1985. Illinois Power does not expect any impact from the resolution of these remaining items on issuance of the OL.

(7) Fire Protection IP's Safe Shutdown Analysis (SSA) and Fire Protection Evaluation Report (FPER) have been completed and submitted to the NRC Staff for review and closure of remaining licensing issues on this item. Responses to five specific issues noted by NRR have been submitted by IP and are currently under Staff review. An NRC pre-audit of the fire protection program was conducted in September; and IP is currently evaluating the open items identified. All essential hardware installation is expected to be completed prior to fuel load. A final NRC audit is expected after completion of fire protection systems.

(8) Technical Specifications All CPS Technical Specifications have received substantial internal review and the applicable Grand Gulf Nuclear Station experience has been incorp' orated at CPS.

The NRC Staff issued the Proof and Review" copy of the CPS Technical Specifications in a September 4, 1985, letter to IP. Technical Specifications, FSAR, and SER conformance reviews will be completed and all necessary certifications will be provided to the Staff by December 20, 1985.

l U-600323 L30-85 (12-09 1A.120 (9) Implementation of TMI Requirements (NUREG-0737) .

IP has participated in the Boiling Water Reactor Owner's Group (BWROG) in connection with TMI issues. Currently, nearly all TMI Action Plan Items have been technically resolved with the Staff. Also, most hardware modifications required of NUREG-0737 have been installed or will be installed prior to fuel loading at CPS. The remaining actions are scheduled for implementation as follows:

1. NUREG-0737, Supplement #1 " Requirements for Emergency Response Capability". See NRR Item (10) for discussion of this program (various actions remain for completion after fuel load):

2. I.G.1 " Training During Low Power Testing" -

the program will be performed after fuel load:

3. II.F.1 " Additional Post-Accident Instrumentation" - specific variances to these requirements have been requested on the Noble Gas and Effluent Sample monitors and the Drywell High Range Radiation Monitors; and

4. III.D.l.1 " Primary Coolant Outside Containment" (leakage control program) - the program will be peric med after fuel load.

(10) #1 "Re NUREG-0737, SupplementEmergency Response Capability" quiremen These requirements were finalized by the Staff in Generic Letter 82-22. IP's response was submitted to the Staff'in an April 1983 letter which provided the CPS Emergency Response Capability Implementation Program (ERCIP) Plan.

Implementation of these NRC requirements at CPS is nearing completion as follows:

(a) Safety Parameter Display System (SPDS) '

i The SPDS Dynamic Simulation Test was conducted in August 1985, and a detailed results and analysis report was submitted in September. Based upon this report, the Staff has indicated that this issue will be closed in SSER f5. Results of additional testing of the analog optical isolators were also submitted in September 1985. Startup testing

]

U-600323 L30- $ (12-09 )-L 1A.120 of the SPDS is scheduled for completion in December and the IP Verification and Validation program should be completed in January 1986. Therefore, the SPDS will be operable prior to fuel load, based on current planning and scheduling activities.

(b) Detailed Control Room Design Review (DCRDR)

The DCRDR was performed by IP personnel assisted by human factors consultants from Torrey Pines Technology, Inc. The majority of this review is complete, and a DCRDR Summary Report has been issued for the Staff to review the results achieved. The Staff completed an audit of the DCRDR program and results on November 1, 1985. Category A Human Engineering Discrepancies (HEDs) will be implemented prior to fuel load. Category B HEDs shall be implemented within 180 days after fuel load. Category C HEDs shall be completed before startup following the first refueling outage. A supplement to the DCRDR Summary Report shall be submitted to the Staff within six (6) months after fuel load.

This Supplement will address the results of the Control Room NRC audit and environmental survey. This issue is not expected to have any impact on fuel load.

(c) Emergency Response Facilities (ERFs)

All ERFs were completed and operational, with personnel training complete, in support of the December 4, 1985, Integrated Emergency Exercise.. The ERFs appraisal will be performed by the Staff after fuel load. A firm date for performing this appraisal will  ;

be mutually agreed to with the Staff prior to fuel load.

(d) Upgrading Emergency Operating Procedures (EOPs)

This item relates-to Confirmatory Licensing Issue #41, which has been reviewed and closed by-the Staff in draft SSER #5. All required E0Ps have been upgraded to symptomatic-based procedures. Emergency Procedure Guidelines (EPGs) for hydrogen control (under development by the Hydrogen Control Owner's Group in which IP participates) and some l  !

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U-600323 L30-$ (12-09 )-L 1A.120 Staff generic concerns associated with post-accident containment venting for decay heat removal will be implemented after fuel load (this is considered acceptable since the generic issues related to these items are still under industry-wide resolution).

(e) Post-Accident Monitoring Instrumentation Requirements of Regulatory Guide (RG)l.97, Rev. 3 IP has satisfactorily resolved (SSER #5) all Staff technical concerns relative to R.G.

1.97. Equipment installation and field verification is scheduled for completion in December 1985. As of November 30, 1985, equipment installation and verification is over 99% complete. Equipment upgrading for the Reactor Vessel Fuel Zone water level instruments and the Neutron Monitoring System will be completed prior to restart following the first refueling outage.

(11) Financial Protection The NRC requires proof of financial protection in terms of $160,000,000 of insurance to be complete prior to CPS fuel load. An amendment to the Special Nuclear Materials (SNM) Indemnity Agreement (between NRC and Illinois Power, Soyland, and Western Illinois Power Cooperative) will be executed in connection with the OL. This indemnity agreement shall be signed by the CPS owners shortly after receipt of the OL. The CPS owners shall have and maintain financial protection of the type and amounts required by the Commission in accordance with Section 170 of the Atomic Energy Act of 1954, as amended, to cover public liability claims.

E. Emergency Planning And Preparedness On-site Emergency Plan issues were resolved by the Staff in SSER #4. With respect to off-site issues, several important milestones have been reached. The Federal Emergency Management Agency (FEMA) has recently approved the CPS Emergency Planning Zone (EPZ). The State of Illinois Radiological Emergency Plan and CPG Annex have been prepared and submitted to TEMA and to the NRC Staff. Illinois Power has recently completed the FEMA-43 Report regarding the Alert & Notification System (ANS). The NRR/ Rill Emergency Preparedness

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U-600323 L30-85 (12-09 )-L 1A.120 Implementation Appraisal (EPIA) was performed during November 12-21, 1985. IP responses to all open items from this appraisal will be submitted by the end of January 1986. The full-ccale integrated Emergency Exercise was held on December 4, 1985. In accordance with 10CFR50 Appendix E.IV.F, NRC and FEMA evaluations of the Exercise results must be completed prior to operation of the plant above 5% power. IP anticipates that the NRC Staff will require a License Condition to complete the Emergency Response Facilities Appraisal, required by NUREG-0737, Supplement #1, prior to operation above 5% power.

F. Atomic Safety Licensing Board (ASLB) Proceedings On January 28, 1985, the parties to the CPS ASLB proceedings entered into a Joint Stipulation that requested and led to dismissal of the proceedings. As indicated in the Stipulation, certain issues relating to Contention III remained for NRC Staff review and resolution. At present, the Staff has documented its review and resolution of CPS Regulatory Guide (R.G.)

1.97 compliance (SSER #5 Section, Section 7.5.3), and the CPS Reactor Vessel Water Level Measurement System and plant improvements therein (SSER #4, Section 4.4.2). The Staff intends to document its review and resolution of SPDS color coding, color consistency between SPDS and Area Radiation and Process Radiation Monitoring (ARM /PRM) displays, and inclusion of ARM /PRM parameter (s) on the SPDS display in SSER #5. The Staff intends to document its review and resolution of equipment identification under R.G. 1.97 and test results for isolators installed to isolate computer signals from safety-related signals in SSER #6.

G. Exemptions The FSAR documents CPS conformance to the NRC rules and regulations set forth in 10CFR50 including Appendix A (General Design Criteria). IP is currently completing the FSAR Certification Program. Any requests for exemptions from NRC rules and regulations will be submitted in advance of any request for authorization to load fuel.

H. Design and Construction Assurance Reviews CPS has undergone a series of reviews beyond the normal Quality Assurance Program to assure that CPS design and construction conforms to applicable requirements. The current status of each of the major reviews is as follows:

U-600323 L30- 8512-09 )-L i

1A.120 i '(1) Independant Design Review (IDR) 4 iTo', provide additional assurance of the design adequacy of CPS design, IP contracted with Bechtel Power Corporation to perform an IDR.

This review was completed with the issuance of the Bechtel IDR Report in January 1985.

Bechtel concluded from this independent assessment that the CPS design basis is generally adequate and meets the applicable NRC rules and regulations. Several

" observation reports" were issued following IDR completion. Most of the required actions from these observation reports are currently resolved with the Staff as identified in draft SSER f5. All items currently remaining open will be resolved with the Staff. Bechtel has issued a separate report on the high energy /

moderate energy line break analyses, which con'cludes that the design of CPS is adequate for these considerations. This supplemental report was submitted to the NRC via IP Letter U-600266, 3

P dated September 30, 1985. The NRC Staff's September 3, 1985, briefing to the Commissioners indicated that none ofs the IDR issues are expected to impact CPS fuel load;ing.

(2) NRC Construction Appraisal Team (CAT) Review The NRC CAT team appraised CPS construction y activities on May 20-31 and June 10-21, 1985. The CAT concluded that hardware and documentation for CPS construction activities were generally in accordance with NRC requirements and Illinois

'< Power program commitments. In addition, the Team indicated that the IP Overinspection Program has provided an effective added measure of the quality of plant construction. In the CAT Report provided

, in the Staff's-letter dated August 15, 1985, deficiencies requiring additional Illinois Power management attention were identified.

Subsequently, Region III issued, by letter dated August 30, 1985,ssix Notices of Violation. IP is continuing' to implement corrective actions for these items, as. identified in its response to Region III's August 30, 1985, letter (IP Letter U-600282, dated October 1, 1985). As indicated in the Staff's September 3, 1985, briefing to the Commissioners, none of these items are expected to impact fuel load.

U-600323 L30 JB (12-09)-L 1A.120 (3) Overinspection and Record Verification Programs In response to the 1981-1982 Stop Work Actions, IP implemented an Overinspection Program to provide additional assurance of CPS construction quality and a Record Verification Program to provide additional -

assurance of CPS construction quality records. NRC Region III's letter dated July 2, 1985, concurred with IP's request to terminate the Overinspection (01) Program for piping and mechanical supports, finding that NRC inspections and independent reviews give reasonable assurance that CPS piping and supports will perform satisfactorily in service. NRC Region III's letter dated September 13, 1985, concurred with IP's proposal to suspend, at its own risk, the OI program for electrical hangers, HVAC duct and duct supports, cable tray, conduit, cable, and cable termination, based upon favorable results of the IP Overinspection Program and NRC inspections to date. On October 14, 1985 (IP Letter U-600295), IP submitted additional information in four categories specified in NRC Region III's letter as necessary to support NRC concurrence in termination of the 01 Program for those commodities. IP intends to conclude the Overinspection Program for radwaste (Aug D), fire protection, structural steel, mechanical /

electrical equipment, instrumentation, and instrument piping and to make the results available for NRC review prior to fuel load. On November 15, 1985, IP submitted a request to terminate review for the majority of record categories within the scope of the Record Verification Program based upon results to date that have established high confidence in the quality of CPS construction records.

I. NRC I&E Items IP maintains formal systems for tracking and resolution of all NRC I&E inspection items, 10CFR50.55(e) items, and 10CFR Part 21 items. At present the status of these items is summarized as follows:

NRC 50.55(e) Part 21 , Inspection Pending NRC Action for Closure 20 10 97 Require IP Action for Closure 10 13 214 Total Open Items 30 23 311 U-600323 L30-$ G 2-09 )-L 1A.120 IP has undertaken an intensive review to establish schedules, action plans, and priorities for achieving closure of all items necessary to support fuel load. IP personnel have met with Mr. T. P. Gwynn, the CPS NRC Resident Inspector, to establish initial priorities for closure of these items. IP actions will be prioritized for completion of all items necessary for fuel load in sufficient time to support a timely NRC review, J. Allegations IP maintains three formal systems on site to address employee concerns. Mone of these systems are licensing requirements and IP does not rely upon or take credit for these systems in seeking the CPS operating license. IP will review all safety-related concerns and will take actions to assure that any concerns that are still open at the time of fuel load will not challenge the safe operation of the Clinton Power Station. NRC Region III has referred fifty-one allegations to IP for investigation. Of these, IP has completed investigations on fifty, two have been reviewed and closed by the NRC, forty-eight await NRC review and closure, and one is presently under investigation by IP.

If you have any questions or comments concerning the above information please contact me or Frank Spangenberg of my staff.

We will be prepared to discuss the above items with you at your convenience.

I rely yours,

. . Hall Vice President TLR/kaf cc: Director, Office of Inspection and Enforcement, USNRC R. Bernero, Director BWR DOL B. L. Siegel, NRC Clinton Licensing Project Manager

, NRC Resident Office Regional Administrator, Region III, USNRC Illinois Department of Nuclear Safety i

1 i

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