U-600405, Discusses Status of Design,Const & Preoperational Testing of Facility Per FSAR in Support of Fuel Load.Fuel Loading Will Occur Between Late Feb & Early Mar 1986

Discusses Status of Design,Const & Preoperational Testing of Facility Per FSAR in Support of Fuel Load.Fuel Loading Will Occur Between Late Feb & Early Mar 1986

ML20137A321
Person / Time
Site:	Clinton
Issue date:	01/10/1986
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.1, TASK-3.D.1.1, TASK-TM GL-82-22, U-600405, NUDOCS 8601140299
Download: ML20137A321 (13)

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U- 600405 L30 86(01-10)-t 1A.120

, ILLINDIS POWER 00MPANY CLINTON POWER STATION. P.O. BOX 678. CLINTON. ILLINOIS 61727 Docket No. 50-461 January 10, 1986 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. This letter describes the current status as revised from the status in our December 9, 1985, letter on this subject. The status of each major activity needed to support fuel load is described below.

A. Construction As of December 31, 1985, construction of CPS is estimated to be over 99% complete Lased on commodities.

All systems have been turned over from construction to Illinois Power for testing. Based on the substantial construction completion of CPS, the percent complete figure will no longer be referenced in subsequent revisions to this letter. As of this date, all project milestones scheduled through December, 1985, have been achieved. The Integrated Leak Rate Test was completed on January 2, 1986. The only major project milestone remaining prior to fuel load is the Integrated Emergency Core Cooling System / Loss of Offsite Power Test, scheduled for February, 1986.

B. Preoperational Testing IP project management has identified those systems which will be required to support fuel load. The system requirements for fuel load are consistent with current NRC review criteria and support the conditions of operation defined by the CPS Technical Specifications. Current planning and scheduling does project that some system test deferrals beyond fuel load will be required. A tentative list of these \

system test deferral items is provided in Attachment 1

& 2. The next revision to this letter will provide detailed justifications for each deferral item. l\

8601140299 860110 PDR ADOCM 05000461 E PDR

U-600405 L30- 86(01- 10 )-t 1A.120 C. Personnel The NRC Staff's Supplemental Safety Evaluation Report (draft SSER 15), 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 f5. Any future organizational changes that might materially affect these findings will be submitted to the Staff in a timely manner.

Draft SSER f5, Section 13.1.2.1(3) found that prospective Clinton Senior Reactor Operators (SR0s) who comalete IP's Supervisory Operating Plant Experience (S0?E) 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. As of January 7, 1986, there are 36 personnel licensed at CPS (27 SR0s and 9 Ros). The current number of licensed SR0s and R0s is 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:

(1) Hydrogen Management (SER License Condition #5)

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. IP met with the Staff on November 6, 1985, to present an overview of the CPS preliminary hydrogen analysis.

As a result of this meeting the Staff agreed to address this issue in SSER #6 (prior to fuel load).

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U-600405 L30- 86 (01- 10 )-L 1A.120 (2) Mark III Containment Issues (SER Outstanding Licensing Issue 19 and Confirmatory Licensing Issue #71)

This item includes Suppression Pool hydrodynamic loads during a Loss cf 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 Supplement

1. 5 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 # 7)

IP has developed plans and actions to close open items resulting from an NRC audit performed during November 19-21, 1985. IP commits to resolve all open items in a manner acceptable to the Staff prior to issuance of the Operating License (OL).

Only 2 items remain open: (1) a system walkdown on safety-related active pumps and valves and (2) an NRC concern using analysis versus test results for valves.

(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 its response to all audit concerns by the end of February 1986. NRC Staff closure of these issues in SSER 16 is anticipated.

(5) Inservice Inspection (ISI) Program (SER Licensing Condition #12)

The final ISI Program is required to be submitted within six months after fuel load.

Illinois Power anticipates that requirements related to the ISI Program will become a License Condition in the OL.

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, U- 600405 l L30- 86 (01- 10)-L 1A.120

! (6) Safeguards and Security I 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 late January 1986. Illinois Power does not expect any impact from the resolution of these remaining items on issuance of the OL.

1 (7) Fire Protection IP's Safe Shutdown Analysis-(SSA) and Fire Protection Evaluation Report (FPER) have been i

completed and submitted to the NRC Staff for i review and closure of remaining licensing issues on this item. Resaonses to seven specific issues

noted by NRR have 3een submitted by IP and are currently under Staff review. IP action to

resolve open items identified during the September l NRC pre-audit.will be completed in February 1986.

l All essential hardware installation is expected to ,

i be completed prior to fuel load. A final NRC audit is expected after completion of fire protection systems.

(8) Technical Specifications All CPS Technical Specificationa 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 Specification conformance reviews will be completed and all necessary certifications will be provided to the Staff by the'end of February, 1986.

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

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U- 600405 L30 86(01-10)-L 1A.120

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 recuirements have been requested in IP letters c ated December 3 and 26,1985.

4. III.D.l.1 " Primary Coolant Outside Containment" (leaka'ge control program) - the program will be performed after fuel load.

(10) NUREG-0737, Supplement #1 " Requirements for Emergency Response Capability" 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 Implementstion Program (ERCIP) Plan.

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

(a) Safety Parameter Display System (SPDS)

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 #5. Results of additional testing of the analog optical isolators were also submitted in September 1985. Startup testing of the SPDS is scheduled for completion in February 1986 and the IP Verification and Validation program should be completed by late February. 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. This review is complete and an IP DCRDR Summary Report has been reviewed by the NRC Staff. The Staff also completed an audit of the DCRDR program and results on November 1, 1985.

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U-600405 L30 86(01-10)-L 1A.120 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. As a result of the NRC audit, several open items were identified by the Staff which require further reviews by IP to resolve. 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 NRC audit open items and the Control Room environmental survey.

The Staff has indicated this issue will be resolved in SSER #5 and a License Condition will be imposed relative to the open audit items.

(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 date for performing this appraisal has been scheduled for May 15,'1986.

(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 f5. . All required E0Ps have1been 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 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.)

Specifically, in an IP letter dated November 4, 1985, IP committed to provide an operating instruction for hydrogen control prior to exceeding 5% power (pending final NRC approval of-the generic hydrogen control EPG).

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U-600405 L30-86(01-10)-L  :

1A.120 (e) Post-Accident Monitoring Instrumentation Requirements of Regulatory Guide (RG)l.97,

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Rev. 3 IP has satisfactorily resolved (draft SSER

1. 5) all. Staff technical concerns relative to

, R.G. 1.97. In a letter, dated December 3, 1985, IP requested a variance to the R.G. l 1.97 requirements related to sample line loss I correction factors. This matter is currently under NRC Staff review. Equipment installation and field verification is .

scheduled for completion in early February 1986. As of January 3, 1986, equipment '

installation and verification is over 99.5%

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 o 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 approved the CPS Emergen'cy

,. Planning Zone (EPZ). The State of Illinois l Radiological-Emergency Plan and CPS Annex have been prepared-and submitted to FEMA and to the NRC L Staff. Illinois Power has completed the FEMA-43 Reaort-regarding the Alert'& Notification System (ANS). T ae NRR/RIII Emergency Preparedness Implementation Appraisal (EPIA) was performed during November 12-21, 1985.- IP responses to all oaen items from this

- appraisal will be submitted 3y February, 1986.

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U-600405 L30-86(01-10)-L 1A.120 IP anticipates that the NRC Staff will require a License Condition to complete the Emergency Response Facilities Appraisal, required by NUREG-0737, Supplement fl, after fuel load (see E.(10)(c) above).

IP does not anticipate resolution of the remaining audit open items will impact fuel load.

F. Atomic Safety Licensing Board (ASLB) Proceedings On January 28, 1985, the parties to the CPS ASLB proceedings entered into a Joint Stipulation that recuested and led to dismissal of the proceedings. As inc icated 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 (draft SSER 15 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 equipment identification under R.G. 1.97, SPDS color coding, color consistency between SPDS and Area Radiation and Process Radiation Monitoring (ARM /PRM) displays, ani inclusion of ARM /PRM parameter (s) on the SPDS display in SSER #5. The Staff intends to document its review and resolution of test results fer isolators installed to isolate computer signals from safety-related signals in SSER

1. 6.

G. Exemptions The FSAR documents CPS conformance to the NRC rules and regulations set forth in 10CFR50 including Appendix A (General Design Criteria). At present, the only request for exemption from NRC rules and regulations pertains to Appendix J 1eak testing requirements submitted by IP :bi a letter dated December 9,1985.

These exemptions relate to the Main Steam Isolation Valves and the Containment Air Lock.

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:

(1) Independent Design Review (IDR)

To 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.

U-600405

{ L30-86(01-10)-L '

1A.120 I L Bechtel' concluded from this independent I assessment that the CPS design basis is i t

generally adequate and meets the applicable NRC-rules and regulations. Several i

" 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 i SSER #5. All items currently remaining open will be resolved with the Staff. Bechtel has l, issued a separate report on the.high energy /

moderate energy line break analyses, which concludes that the design of CPS is adequate for

, these considerations. This supplemental report ,

was submitted to the NRC via.IP Letter U-600266, dated September 30, 1985. The NRC Staff's September 3, 1985, briefing to the Commissioners l indicated that none of the IDR issues are expected l to impact CPS fuel loading.

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

accordance with NRC requirements'and Illinois h Power program commitments. In addition,.the Team i

indicated that the IP Overinspection Program has provided an effective added measure of the quality l of plant construction. In-the CAT Report provided i; in the' Staff's letter dated August 15, 1985, l deficiencies requiring additional Illinois Power l management attention were identified.

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L Subsequently, Region III issued, by letter dated-R August. 30, 1985, six Notices of_ Violation. IP is-continuing to implement corrective actions for p these items, as identified in_its response to Region III's August 30, 1985, letter-(IP Letter l U-600282, dated October 1, 1985)..:As-indicated ~in t the Staff's September 3, 1985, briefing to the Commissioners, none of these items are expected to L impact fuel load.

! (3) Overinspection'and Record Verification Programs L In response to the.1981-1982 Stop Work l' 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 l 2,_1985, concurred with IP's request to l terminate the Overinspection (OI) Program for l-I

L' U-600405 l L30- 86(01-10)-L L 1A.120 piping and mechanical supports, finding that l NRC~insaections and independent reviews give ,

l reasonable assurance that CPS piping and l 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 Qverinspection 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 OI 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. -As of January 7, 1986, the statusoof these items is summarized as follows:

NRC 50.55(e) Part 21 Inspection Pending NRC Action for Closure 17 19 102 Require IP Action for Closure 11 14 185 Total Open Items 28 33 287 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.

U-600405 L30-86( 01-10 )-L 1A.120 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. None 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 l

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 all fifty-one, three have been closed by the NRC and forty-eight await NRC review and/or closure.

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

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

yours, T]g D. . Hall Vice President

~TLh/kaf Attachments cc: Director, Office of Inspection and Enforcement, USNRC R. M. Bernaro, Director BWR DOL Dr. W. R. Butler, BWR Project Directorate #4 B. L. Siegel, NRC Clinton Licensing Project Manager NRC Resident Office Regional Administrator, Region III, USNRC Illinois Department of Nuclear Safety i

l Attachm:nt No. 1 to U- 600405 FUEL LOAD - NUMBER IN STARTUP TESTING - 20 SYSTEMS System Projected Designator Description Completion Milestone CM Containment Monitoring Initial Criticality EH Steam Bypass Heatup (HU)

EW Electrical Welding Comm. Ops.

HG Cont. Combustible Gas Heatup HI Hydrogen Ignition System 5% Power HT Heat Tracing 5% Power IS MSIV Leakage Control Initial Criticality OG Offgas RPV Headset (HU)

RA Respirator Air Initial Criticality RI RCIC System Heatup SH Station Heating Comm. Ops.

ST Sewage Treatment Comm. Ops.

TD TG Misc. Vents & Drains 5% Power TP Transversing In-Core Probe 5% Power

-VA Aux. Bldg. HVAC 5% Power VO Offgas HVAC RPV Headset (HU)

VP Drywell Cooling Heatup WA Warehouse Auxiliaries Comm. Ops.

WO. Chilled Water Initial Criticality' TOC Solid Radwaste Processing Heatup l

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Attachmsnt No. 2 to U-600405 FUEL LOAD - NUMBER FUNCTIONAL - 32 SYSTEMS (Not Demonstrated Fully Operable)

System Projected Designator Description Completion Milestone AB SCAB Comm. Ops AS Auxiliary Steam Heatup CA Condenser Vacuum Heatup CS Feedwater Control 5% Power CW. Circulating Water Heatup DA Digital Acquisition 5% Power DL Laundry Equipment Comm. Ops. -

-DV Feedwater Heaters Heatup ES Extraction Steam 5% Power GC' Gen. Stator. Cooling 5% Power GD Cathodic Protection 5% Power GS Turbine Gland Seal 5% Power HD FW Heater Drains Heatup HY Hydrogen Cooling 5% Power Ili Loose Parts Monit. 5% Power LV Low Voltage Aux. Power 5% Power MP- Main Power 5% Power OT Turbine 011 Transfer 5% Power RN- Recirculation Control Heatup SE' Spare Breakers Comm. Ops.

SO Gen. H 9 Seal Oil 5% Power SW Screen 9 ash- Heatup-TE Various Bldg. Drains Heatup TF Various Bldg. Drains Heatup TG TG Aux. & Misc. Devices 5% Power

TS Turbine Supervisory 5% Power VH Screenhouse & MWPH HVAC 5% Power VJ Machine Shop HVAC 5% Power VS Service Bldg. HVAC Comm. Ops.

lAT EOF Bldg. HVAC 5% Power WD MWPH Potable Water Comm. Ops.