U-600455, Submits Current Status of Design,Const & Preoperational Phase Testing.Progress Continues to Support Goal for Fuel Load During First Quarter 1986.Activities Needed to Support Fuel Load & Preparations for Testing Listed

Submits Current Status of Design,Const & Preoperational Phase Testing.Progress Continues to Support Goal for Fuel Load During First Quarter 1986.Activities Needed to Support Fuel Load & Preparations for Testing Listed

ML20214C571
Person / Time
Site:	Clinton
Issue date:	02/17/1986
From:	Hall D ILLINOIS POWER CO.
To:	Harold Denton Office of Nuclear Reactor Regulation
References
U-600455, NUDOCS 8602210180
Download: ML20214C571 (15)

Text

I U-600455 L30-86(02-17)-L 1A.120 ILLINOIS POWER DOMPANY IP CLINTON POMR STATION. P.O. BOX 678. CLINTON. ILLINCIS 61727 Docket No. 50-461 February 17, 1986 Mr. Harold R. Denton, Director Ori " of Nuclear Reactor Regulation United States Nuclear Regulatory Commission Washington, DC 20555

Subject:

Clinton Power Station Readiness to Lcad Fuel

Dear Mr. Denton:

Illinois Power Company (IP) is submitting this letter to provide you with the current status of the design, construction, and preoperational phase testing of the Clinton Power Station (CPS) in accordance with the CPS Final Safety Analysis Report (FSAR) and NRC regulations. Our analysis indicates that progress through January 1986 continues to support IP's goal of commencing Fuel Load during the first quarter of 1986. As noted in paragraph D., IP is proposing to defer some preoperational testing beyond Fuel Load, however, construction activities on systems related to these test deferrals will be essentially complete at Fuel Load. This letter describes the p'roject status as revised from the January 10, 1986, letter on Readiness to Load Fuel." The status of each major activity needed to support Fuel Load and preparations for startup/ power ascension testing is described below.

A. Project Readiness Initiatives Several project management initiatives have been taken to ensure a rigorous approach to management commitment and involvement in the control of plant activities in preparation for initial CPS licensing, Fuel Load, and subsequent startup/ power ascension testing. This section describes those key elements of IP's programmatic approach to CPS operational readiness.

(1) Management and Organization Illinois Power recognized the need for a major shift in emphasis during the transition from construction to operation. This has been emphasized in monthly management meetings by the Vice President down through the third level of supervision. Organizational changes have been initiated to meet changing conditions of responsibility and to emphasize the shift to plant operations. The following areas have been changed in the last three months:

The manager of Nuclear Program Coordination, the principal assistant to the Vice President, has been placed in charge of the day-to-day processing of all tests and work.

86022101B0 e60217 Qff PDR ADOCK 05000461 g A PDR

To coordinate smooth accomplishment of all test, construction, maintenance and operations functions, the Project Control Center (PCC) has been established. The PCC structure and functions are discussed in item (2) below.

A department of Scheduling and Outage Management has been established.

Planning and scheduling functions have been separated and scheduling is now under the control of the Plant Manager and the Outage Manager.

A Director of Operations Monitoring has been established in the Quality Assurance organization.

A new Supervisor of Plant Operations Support has been established to expedite and prepare procedures.

A consolidated and expanded central procurement organization has been established.

In addition, individual personal counselling has been initiated where problems have arisen in completing the transition to operation.

(2) Project Control Center (PCC)

The PCC is a new organization, implemented on January 8, 1986, headed by the Manager of Nuclear Program Coordination, to coordinate CPS day-to-day completion activities (as noted in item (1) above). The primary functions of the PCC are to provide continuous display and tracking of construction work, maintenance, engineering and testing associated with systems and areas required for Fuel Load, and to coordinate the various support efforts required to resolve restraints to work and test activities. One or more representatives from each of the Construction, Startup, Plant Operations, Plant Maintenance, Engineering, Outage Management, Purchasing, Scheduling, and Licensing and Safety organizations are assigned to the PCC to coordinate their respective activities. The PCC is manned for two shifts, Monday through Saturday.

The PCC has worked effectively to date, most notably in expediting critical work restraints to startup testing activities.

(3) Site-Wide Statusing System (SWSS)

The SWSS provides a consolidated listing to track the status of site-wide activities relative to various work-related documents. For exampic, the SWSS identifies the status of open Construction Work Requests, Nonconformance Reports, Field Problem Reports, Maintenance Work Requests, NRC open items, plant modifications and startup testing punchlist items. Efforts are currently underway to assign completion milestones to each one of these open items. Currently, milestones have been assigned to approximately 90% of all open items. This will allow identification of all work remaining for Fuel Load and subsequent milestones and will provide a common framework, relative to required plant systems and areas, needed to support timely planning and scheduling of these activities. This consolidated activity list has been crucial in assisting the PCC in tracking overall project completion.

(4) Operational Readiness Assessment IP management continues to assess the progress, performance and readiness of CPS as we approach the Fuel Load milestone.

These assessments will continue beyond Fuel Load and throughout the power ascension test program at each significant project milestone. Currently, as part of IP's commitment to a safe and reliable Fuel Load readiness program, an internal review of CPS operational readiness is being conducted. The scope of this review encompasses each major project performance indicator, including evaluations of plant hardware, software, programs, project controls, staffing, procedures, design, testing, and construction status.

i This review is similar in scope to efforts conducted by other utilities on their nuclear projects arior to licensing. This internal assessment will ';e complete in February and is expected to provide knowledge needed to prepare for operation of CPS.

(5) Systems Required for Fuel Load IP has identified those systems which will be required to support Fuel Load. The system requirements for Fuel Load are consistent with NRC Staff review criteria and support the Limiting conditions for Operation (LCOs) defined by the CPS Technical Specifications. In addition to LCO requirements, the following general criteria are used:

System / equipment is not required by the regulations (e.g., 10CFR50, Appendix A, General Design Criteria):

System / equipment is not needed due to plant physical conditions prior to the completion milestone (e.g., no equipment area heat loads, no fission product activity, or decay heat):

System operability not required to prevent safety hazards to plant personnel or other equipment; System operability does not impact plant operating procedures and System operability does not affect other system tests or operations.

Detailed evaluations of various startup preoperational test deferrals (beyond Fuel Load) are currently underway using similar criteria applied to system test requirements. The detailed results of these test deferral evaluations will be provided to the Staff by the end of February 1986.

(Preliminary information from these reviews has already been provided to the NRC Clinton Licensing Project Manager.)

As a result of our system evaluations using the above criteria, a CPS System Status Report has been prepared to provide information relative to systems required for Fuel Load, the applicable completion milestone (i.e., Initial Criticality, Heatup, 5% Power, or Commercial Operations) for systems not needed until after Fuel Load, current system completion status, and associated startup test deferrals, as applicable. This report was provided to the CPS Region III Resident Inspector and was included in the NRC meeting notes from the IP/NRC Staff meeting on CPS licensing status held on January 13, 1986. The following identifies the breakdown of systems required for Fuel Load from the CPS System Status Report, as of January 31, 1986:

Systems Required for Fuel Load = 70 Full (entire system) 14 Partial (portion of system)

Currently Ready - 29 Full 1 Partial Total Remaining - 41 Full 13 Partial

- Total Number CPS Plant Systems = 133 Construction on all required systems will be completed and these systems will be operable prior to Fuel Load.

With the above major project readiness management initiatives now in place, prior to loading fuel IP will have declared all of the required systems and areas operable, following management review and approval. Activities that remain to be completed after Fuel Load will be carefully reviewed and strictly controlled to ensure that their completion does not compromise the operability of the systems required, cause undue disruption to the startup testing program, nor result in adverse impacts on the safe operation of the plant. The management controls necessary to provide this assurance will be provided to the NRC by the end of February 1986.

B. Critical Path Analysis As of December 31, 1985, the CPS critical path analysis indicates the most limiting systems restraining fuel load are Fire Protection, Control Room Ventilation, Control Rod Drive, Reactor Recirculation, Reactor Water Cleanup, and Leak Detection.

Restraints to completion of these systems include startup test activities, design modifications, and ASME punchlist items. With the formation of the PCC and the other initiatives noted above in paragraph A, these restraints are expected to be resolved in a timely manner.

On January 2, 1986, an important milestone was achieved with the completion of the Containment Structural Integrity / Integrated Leak Rate Tests. The test data demonstrated that the integrated leak rate was less than 50% of the allowable leakage. The only remaining major project milestone required prior to Fuel Load is the Integrated Emergency Core Cooling System / Loss of Offsite Power (ECCS/ LOOP) Test. Delays in completion of the Control Room Ventilation System preoperational test have resulted in delays to the ECCS/ LOOP Test, which is now scheduled to start on March 1, 1986, and be completed by March 21, 1986.

C. Construction Status As of January 31, 1986, construction of CPS is essentially complete based on all commodities except as noted below:

Piping Insulation = 88.12%

Conduit = 93.98%

Conduit Hangers = 95.16%

Penetration Seals - 89.55%

Painting = 80.45%

All systems have been turned over from Construction to IP Startup for testing. Completion of remaining plant areas required for Fuel Load is proceeding on a schedule consistent with IP's goals.

All required areas will be completed by mid-March in support of the issuance of the Operating License. The following provides the current (as of January 31, 1986) and projected area status required for Fuel Load at CPS:

Total Physical Plant Areas = 658 Plant Areas Completed = 535 i

Plant Areas Remaining = 123

! (Required for Fuel Load = 57)

(Required Post Fuel Load = 66)

The 57 required areas remaining will be completed prior to Fuel

Load. Trends for completion of Construction Work Requests, system and non-system travelers, Nonconformance Reports, and area

punchlist items continue to support the project Fuel Load goal j for the first quarter of 1986.

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D. Preoperational Testing Through January 31, 1986, several key events occurred in the Preoperational Test Program. Reliability testing (35 starts each) of the Division I and II Diesel Generators was completed.

Preoperational Test Procedure (PTP) and Acceptance Test Procedure .

(ATP) performance status is as follows: 1 Total PTPs/ATPs = 158 PTPs/ATPs Required for Fuel Load = 136 PTPs/ATPs Completed = 97 (approx. 71% of total required for Fuel Load).

Startup testing activities required for Fuel Load were completed on nine (9) full systems and five (5) partial systems during January and these systems were srbsequently released to Plant Staff for operation and required surveillances. Currently, Plant Staff has jurisdictional control of 53% of the plant systems and 47% of the plant systems remain under Startup jurisdictional control for further testing. The systems released to Plant Staff during January represent 7.7% of the total plant systems. At the time of Fuel Load, Plant Staff will control all plant system testing and operations.

Through the end of January, over 96% of all Checkout and Initial Operation (C&IO) phase testing has been completed. Finally, over 97% of the test procedures required for C&IO, Preoperational, and Startup phase testing are approved for use.

As noted in item A.(1) above, a detailed evaluation of various preoperational phase testing which may require completion deferral past Fuel Load is currently underway. The technical justification for these test deferrals will be addressed in a separate letter to the Staff by the end of February 1986. In addition to the technical reviews being performed, IP is establishing measures for management control of activities deferred past Fuel Load. This will ensure that the deferred activities are performed at the proper time and in the proper sequence to support the safe startup and power ascension operation of CPS with no undue burden on startup test personnel or plant operators. In addition, on December 12, 1985, the NRC published an amendment to 10CFR50.12 related to specific exemptions and the standards to be used by the Staff in granting such exemptions from 10CFR50 requirements. Completion of the above technical, )lanning/ scheduling and 10CFR50.12 reviews is expected before the end of February.

E. Personnel and Staffing The NRC Staff's Safety Evaluation Report, Supplement #5 (SSER

1. 5), Section 13.1.1, found the organization for management and technical support of CPS during operation to be acceptable. The organization, staff levels, qualifications and exaerience of the CPS Plant Staff were likewise found to be acceptable in Section 13.1.2 of SSER #5.

As of January 31, 1986, there are 36 personnel licensed at CPS (26 Senior Reactor Operators (SRos) and 9 Reactor Operators (R0s)). An additional 16 candidates took the NRC SR0/R0 licensing examination in January. NRC verbal notification of the results is anticipated in February 1986. The current number of licensed operators is sufficient to fulfill the s'aift complement levels in the CPS Technical Specifications. To ensure the guidelines of NRC Generic Letter 84-16 are met until the CPS operators have accumulated the required hot operating time at CPS, SSER f5 notes that the Staff will condition the Operating License to require a licensed senior operator on each shift who has had at least 6 months of hot operating experience on a same type plant, including at least 6 weeks at power levels greater than 20% of full power, and who has had BWR startup and shutdown experience. This License Condition shall be effective for a period of one year #com Fuel Load or until the attainment of a nominal 100% poner .evel, whichever occurs later.

F. Nuclear Reactor Regulation (NRR) Licensing Issues IP has maintained active communications with the NRR Clinton Licensing Project Manager to assure expeditious and satisfactory resolution of open licensing issues. Several issues were recently resolved in SSER #5, which was issued in January 1986.

The status (as of January 31, 1986) of the CPS Closure of Licensing Issues Program (" CLIP"), which is a comprehensive tracking system for all SER and other NRR related issues, is as follows:

Total Number of " CLIP" Issues Open = 35 Require NRC Action to Close = 28 Require IP Action to Resolve = 7.

The major issues requiring continued management attention to ensure timely closure are as follows:

(1) Hydrogen Management (SER License Condition f5)

Pursuant to 10CFR50.44, IP has submitted, via letter dated November 5, 1985, a preliminary hydrogen analysis to the Staff. Pending NRC Staff acceptance of the Hydrogen Control Owner's Groua (HCOG) generic Emergency Procedures Guidelines (EPGs), IP has committed to implement an interim hydrogen control guideline prior to 5% power operation. A final hydrogen control EPG for CPS will be submitted to the Staff following NRC approval of the generic EPG. Finally, as a result of recent meetings with the NRC Staff, the NRC's review and aaproval of the CPS preliminary analysis is expected to le addressed in SSER 16 (prior to Fuel Load).

(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 Humphrey-related issues. Additional information was provided to the Staff for review in a letter dated January 16, 1986. These issues are now under Staff review for closure. IP antici-pates that the remaining issues will be resolved in SSER #6 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 issues resulting from NRC PVOR audits performed during the week of August 26, and November 19-21, 1985. As of February 7, 1986, 109 out of 121 PVOR packages have been reviewed and vaulted as complete by IP. The remaining 12 packages are related to currently inaccessible or not installed components and are not considered Fuel Load restraints. These packages are scheduled to be completed prior to Fuel Load. Only 2 items remain open which require IP action to closes (1) a system walkdown on safety-related pumps and valves and (2) use of analysis versus test results for pumps and valves. IP will provide the Staff with the required information by early March to close these two items.

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

Electrical eculpment environmental qualification issues were addressed anc essentially resolved in SSER f5. 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 NRC Staff. SSER #5 identifies the need to resolve inconsistencies between FSAR Tables 3.11-1, -2, -3, and -4. Revisions to these tables were provided to the Staff in FSAR Amendment #36.

Environmental and seismic qualification packages are now essentially complete. About 200 items remain to be installed. The remaining installation work is forecasted to be complete by mid-March. A completion letter to the Staff, as required by SSER #5, will be provided by IP after all work has been completed. NRC Staff closure of the remaining issues is anticipated in SSER f6. No impact on Fuel Load from these issues is expected.

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

As noted in SSER #5, Sections 5.2.4 and 6.6.1, the Staff has accepted the non-destructive examination portion of the CPS Preservice Inspection Program (including the ultrasonic examination of corrosion-resistant clad welds in the CPS recirculation system piping and the specific relief requests from ASME code requirements). The CPS initial ISI program has not yet been evaluated by the Staff. The ISI program will be submitted within six months after Fuel Load, as previously committed. As noted in SSER #5, this action will remain as License Condition #12, and thus will have no impact on Fuel Load.

(6) Safeguards and Security SSER #5, Section 13.7, concludes that the CPS Safeguards and Security Plan meets the requirements of 10CFR73. Security screening of personnel requiring unescorted access remains on the critical path for CPS Fuel Load. The CPS security screening program is based on accepted industry standards and includes a background investigation, psychological evaluation, and a continuing observation program. A second security screening contractor has been hired to provide additional capacity and screening ariorities have been established in order to complete tais effort prior to Fuel Load. Security perimeter lockdown was implemented on February 8, 1986.

(7) Fire Protection SSER #5, Section 9.5, addressed certain aspects of the updated CPS Fire Protection Evaluation Report (FPER) and Safe Shutdown Analysis (SSA) report submitted by letter dated September 6, 1985. Some CPS deviation requests (to 10CFR50, Appendix R requirements) relative to Automatic Fire Detection in certain fire zones were not accepted by the Staff. Additional construction work on these areas to satisfy the Staff's position will br completed prior to Fuel Load. In addition, the Staff is sti41 reviewing various other issues, including alternate shutdown ca, ability.

These matters were identified as Outstanding alcensing Issue 121 in SSER f5. IP evaluations are continuing on these issues to support resolution by Fuel Lond. Resolutions to four of eight " CLIP" fire protection issues have been achieved recently. IP has completed actions to resolve 10 of the 24 open items from the September 1985 NRC audit. IP actions on the remaining audit items will be completed by the end of February 1986.

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(8) Technical Specifications All CPS Technical Specifications have received substantial internal revies and the applicable Grand Gulf Nuclear Station experience has been incorporated at CPS. The NRC Staff issued the " Proof and Review" copy of the CPS Tech-nical Specifications in a September 4, 1985, letter to IP.

Upon Staff issr.ance of the final copy of CPS Technical Specifications. conformance reviews will be completed and all ne'ressary certifications will be provided to support Fuel Load.

(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, hardware modifications required by NUREG-0737 have been installed. The remaining actions are scheduled for implementation as follows

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

2, 1.G.1 " Training During Low Power Testing" - the program will be performe<1 after Fuel Load

, 3. II.F.1 " Additional Post-Accident Instrumentation" -

specific variances to these requirements have been f recuested in IP letters dated 13ecember 3 and 26,1985 anc, in a letter dated January 27, 1986. A letter relative to the Noble Gas Monitoring calibration i

methodology proposed for the CPS Station Ventilation and Standby Gas Treatment System stacks is under preparation and should be submitted to the staff before the end of February.

4. III.D.1.1 " Primary Coolant Outside Containment" (leakage control proj; ram) - this program will be per-formed after Fuel Load.

(10) NUREG-0737, Supplement #1 " Requirements for Emergency Response Capability"

< These requirements were finalized by the Staff in Generic Letter 82-33. 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 has been completed as follows:

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t (a) Safety Parameter Display System (SPDS)

SPDS implementation issues were resolved in SSER 15, Section 7.5.3.2. Startup testing of the SPDS is scheduled for completion in February 1986 and the IP Verification and Validation will be completed prior to Fuel Load. Therefore, the SPDS will be operable prior to Fuel Load.

(b) Detailed Control Room Design Review (DCRDR)

The Staff completed an audit of the DCRDR program and results on November 1, 1985. 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. SSER

1. 5, Section 18.3 identifies the eleven audit items to be addressed in the Supplemental Summary Report. This action is identified as License Condition f20 (SER Confirmatory Issue 138 is now considered closed).

(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 ERF appraisal will be performed by the Staff after 5% power operation.

(d) Upgrading Emergency Operating Procedures (EOPs)

This item relates to Confirmatory Licensing Issue #41, which has been reviewed and closed by the Staff in GSER

1. 5 Section 13.6.3. All required E0P's have been upgraded to symptomatic-based procedures. In particular, the Staff approved IP's approach to post-accident containment venting in SSER #5.

Emergency Procedure Guidelines for hydrogen control are discussed in item F.(1) above and is no longer part of SER Confirmatory Licensing Issue f41.

(e) Post-Accident Monitoring Instrumentation Requirements of Regulatory Guide, Rev. 3 SSER #5, Section 7.5.3.1, finds the CPS design accept-able with respect to Regulatory Guide 1.97, Rev. 3 conformance. In a letter, dated December 3, 1985, IP requested a variance to the R.G. 1.97 requirements related to sample line loss correction factors. This matter is currently under NRC Staff review. Equipment installation and field verification was completed in late January 1986. Equipment upgrading (power supplies) for the Reactor Vessel Fuel Zone Water Level instruments will be completed prior to restart

following the first refueling outage in accordance with SER License Condition #15.

(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 Indemnity Agreement (between NRC and Illinois Power, Soyland, and Western Illinois Power Cooperative) will be signed coincident with the OL.

G. Emergency Planning and Preparedness On-site Emergency Plan issues were resolved by the Staff in SSER

1. 4. The Federal Emergency Management Agency (FEMA) has completed their initial review of the State of Illinois Radiological Emergency Plan and CPS Annex. By letter dated November 6, 1985, FEMA stated that some aspects of the Illinois plan were inadequate, but that extensive planning efforts and corrective action were expected to result in an acceptable plan. IP continues to work with the State of Illinois to assist in resolving FEMA's comments in a timely manner.

During the period November 12-21, 1985, NRC Region III personnel conducted a special appraisal of the state of onsite emergency preparedness at CPS. NRC Region III Inspection Report 50-461/85039, dated December 20, 1985, listed 47 open items and 32 improvement iters that were identified during the appraisal.

By letter date ' February 5,1986, IP has provided Region III with our assessment af the 32 improvement items and planned action (s) for the 47 open items. As noted in the February 5 letter, actions have been completed on 15 of the 47 items. Actions on an additional 28 open items will be completed by mid-February and 3 action items will be completed in early March. The one remaining open item relates to the installation of onsite backup meteorological sensors which are scheduled to be operational by May 1, 1986. Region III has agreed to the completion of this one audit item after Fuel Load. IP will provide documentation closure packages, to verify completion of these actions, to the CPS NRC Resident Inspector's Office as these items are completed.

The Integrated Emergency Exercise was held on December 4, 1985.

Of the six findings noted by the NRC, two were stated as required to be resolved before Fuel Load. IP actions are underway to fully resolve these findings. No major deficiencies were noted by the Staff or FEMA from the exercise. A formal report from FEMA has not yet been received.

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H. Atomic Safetv Licensing Board (ASLB) Proceedings I

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. SSER #5, Sections 7.5.3.1, 7.5.3.2.3, and 18.2, completed NRC actions relative to Regulatory Guide 1.97, SPDS, and DCRDR reviews. With these issues now resolved for Fuel Load, no additional impact on the issuance of the CPS Operating License is anticipated.

I. Exemptions The FSAR documents CPS conformance to the NRC rules and regula-tions 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 leak testing require-ments submitted by IP in a letter dated December 9, 1985. These exemptions relate to the Main Steam Isolation Valves and the Containment Air Lock. The Staff has requested that IP provide additional information relative to the December 12, 1985, revi-sion to 10CFR50.12(a) on specific exemptions. IP will provide this information prior to the end of February.

J. 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)

This review. which evaluated more than 2900 documents and expended approximately 31,000 man-hours, was completed with the issuance of the Bechtel Power Corporation 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. A separate Bechtel report on the high energy / moderate energy line break analyses, which concluded that the design of CPS is adequate, was submitted to the NRC via IP letter dated September 30, 1985. Through January 1986, IP actions have been completed on 124 of the 128 IDR action items. The Staff noted in SSER #5, Sec ion 17.5.5, that any further independent design review of CPS is considered unwarranted.

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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 CPS construction activities were generally in accordance with NRC requirements and Illinois Power program commitments. In the CAT Report provided in the Staff's letter dated August 15, 1985, 4

deficiencies requiring additional Illinois Power management attention were identified. Subsequently, Region III issued, by letter dated August 30, 1985, six Notices 6f. Violation.

IP responded to these six Notices of Violer 44 by letter dated October 1, 1985. Currently, IP actions on five of the six Notices of Violation are complete. Of these five, one has been formally closed by the NRC, three have received NRC reviews and will be closed in a future inspection report and one is under NRC review. The last item is not a Fuel Load restraint and will be completed by 5% power operation.

(3) Overinspection and Record Verification Programs

In response to the 1981-1982 Stop Work Actions, IP i implemented an Overinspection Program to provide additional assurance of CPS construction quality and a Record Verifi-cation Program to provide additional assurance of CPS construction quality records. IP intends to conclude the Overinspection Program for radwaste (Augmented D), fire pro-l tection, structural steel, mechanical / electrical equipment, instrumentation, and instrument piping and to make the results available for NRC review prior to Fuel Load. Based on the results of the Record Verification Program provided '

to NRC Region III in IP letters dated November 15, 1985, and January 22, 1986, IP suspended this program effective February 4, 1986.

K. NRC I&E Items IP maintains a formal system for tracking and resolution of all NRC I&E inspection items, 10CFR50.55(e) items, and 10CFR Part 21 items. As of February 7, 1986, the status of these items is summarized as follows:

NRC 50.55(e) Part 21 Inspection Pending NRC Action for Closure 7 12 130 Require IP Action for Closure 16 12 143 Total Open Items 23 24 273 IP has completed an intensive review to establish schedules, action plans, and priorities for achieving closure of all items necessary to support Fuel Load.

L. Allegations IP maintains three programs for addressing employee concerns. IP does not seek any credit for these programs in meeting requirements relative to issuance of the 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, and the NRC has closed, all fifty-one.

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.

S r yours, dY Gd!..$. natt Vice President TLR/ asp 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 h