U-600708, Forwards Chronological Listing of Milestones Occurring During Tech Spec Review Process,Per NRC 860618 Request.Tech Specs Consistent W/Fsar,Ser (NUREG-0853) & as-built Facility

Forwards Chronological Listing of Milestones Occurring During Tech Spec Review Process,Per NRC 860618 Request.Tech Specs Consistent W/Fsar,Ser (NUREG-0853) & as-built Facility

ML20206S474
Person / Time
Site:	Clinton
Issue date:	09/18/1986
From:	Hall D ILLINOIS POWER CO.
To:	Harold Denton Office of Nuclear Reactor Regulation
References
RTR-NUREG-0853, RTR-NUREG-853 U-600708, NUDOCS 8609220237
Download: ML20206S474 (5)

Text

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/LLINDIS POWER COMPANY ,

CLINTON POWER STATION P.O. BCx 678. CLINTON, ILLINOIS 617a7 SEP 181986 '

Docket No. 50-461 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation United States Nuclear Regulatory Commission Washington, D.C. 20555

Subject:

Clinton Power Station Certification of Final Draft Technical Specifications Dec.r Mr. Denton: -

In your letter of June 18, 1986, transmitting the Final Draft of Clinton Power Station (CPS)-Technical Specifications (TS) you requested that Illinois Power Company (IP) certify that the Technical Specifications are consistent with the CPS Final Safety Analysis Report (FSAR),

the NRC's Safety Evaluation Report (SER), NUREG-0853, and the as-built facility.

IP has been cognizant of this requirement since our Technical Specification development meeting of December 5, 1984 (Letter, A. Schwencer to F. A. Spangenberg, dated January 31, 1985). A chronological listing of milestones occurring during the Technical Specification review process is provided in Attachment 1.

The Clinton Power Station (CPS) Technical Specifications (TS) were initially developed using the BWR Standard Technical Specifications (NUREG-0123). The CPS-TS have been modified by incorporating Clinton-specific values / concepts supportive of the design represented in the CPS Final Safety Analysis Report (FSAR) through Amendment

38. The FSAR has been accepted by the NRC as documented in the NRC's Safety Evaluation Report and Supplements No. 1-6 (NUREG-0853). The CPS-TS have undergone numerous and extensive reviews, including two " Draft" reviews, the " Proof and Review" phase review, and the " Final Draft" review.

The Nuclear Training Department has been kept apprised of all Technica! Specification revisions to ensure proper operator training. Operators have utilized the CPS-TS during their training on the CPS simulator.

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U-600708 L30-86 ( 09-18 )-L 1A.120 The~ CPS FSAR has undergone a complete certification review. This was conducted by IP's Licensing & Safety Department.with, representatives from other CPS. departments,

- the architect engineer.(AE),_Sargent and Lundy, and the Nuclear Steam Supply System-(NSSS) vendor, General Electric Co. The purpose of the review was to ensure that the information presented'in the FSAR was accurate and traceable

- to design documents. . To ensure consistency between the FSAR and CPS-TS, a separate review of the FSAR was. performed by the Plant _ Technical Department. The results of both reviews were compared, discrepancies identified and resolved, and the results compiled into a matrix for later reference and retrieval.

The SER and its supplements were reviewed and a detailed list of SER requirements was prepared.. IP's review was then compared to the NRC's review and again, discrepancies were identified and resolved. Each requirement was reviewed for proper implementation into the CPS-TS.

A review of the " Final Draft" copy of CPS-TS was conducted. The appropriate FSAR and SER subsections were provided to plant personnel (system engineers) and the SER and FSAR were compared with the as-built plant. The AE and NSSS vendor reviewed the Final Draft for consistency with

the design and subsequent design change recommendations. In addition, the ongoing process of conducting plant testing and performance of surveillance requirements have confirmed that the CPS-TS are consistent with the'as-built facility.

Finally during the week of. March 3, 1986, a regional inspection team reviewed the CPS-TS against the FSAR and the

. as-built plant for selected systems (

Reference:

Inspection Report No. 50-0461/86016(DRP)). Discrepancies dealing with

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the FSAR and CPS-TS'have been satisfactorily resolved.

! Further comments and changes to the Final Draft CPS-TS i

were identified in your letters dated August 21, 1986 and September 17, 1986. We have continued to work with the NRC staff during the Final Draft review cycle to address their 4

concerns and assure the latest ac-built information was included in the CPS-TS.

In addition, IP has maintained throughout the life of the CPS project, a formal program of design control and l

verification in accordance with 10CFR50 Appendix B, which effectively control the configuration of the plant and the i

1 content of the FSAR.

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U-600708 L30-86(09-18 ) L 1A.120 t

In summary, based on all the programs described herein, the' CPS-TS are consistent in all material aspects with the FSAR as amended in letters U-600619 U-600624, U-600630, U-600633, U-600636, U-600647, U-600662, U-600667, U-600673, i . U-600674, U-600676, U-600691 andeU-600706, the SER and its Supplements No. 1-6, and the as-built plant. An affidavit relating to this certification accompanies this letter.

If ou.have any questions or. require additional '

infornation, please contact.me.,

f re yours,

. . Hall Vice President TLR/kaf '

Attachment ,

cc: Director, Office of Inspection and Enforcement, USNRC R. M. Bernero, Director, Division of BWR Licensing Dr. W. R. Butler, Director, BWR Project Directorate #4 B. L. Siegel, NRC Clinton Licensing Project Manager Regional Xdministrator, Region III, USNRC Illinois Department of Nuclear Safety 1

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U-600708 L30-86( 09-18 )-L

.1A.120 ATTACHMENT 1 Chronological Listing of CPS Technical Specification Milestones

' January 1982 IP arovided markup of Standard Tecinical Specifications to 1 NRC [R. Bottimore]  !

November 1982 NRC [R.'Bottimore] returned i markup incorporating latest NRC guidance.

4 December.1982 to IP/GE/S&L conducted an September 1984 in-depth review of CPS-TS identifying all design documents associated with each 4

CPS-TS value.

IP conducted FSAR, NUREG-0737, and SER/SSER reviews.

IP' submitted markup to reflect ,

results of above reviews.

9/28/84 (U-0739) r w

June to November 1984 IP maintained communication with NRC's D. Hoffman on

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, CPS-TS and BWR/6 issues.

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i December 1984 IP met with NRC to discuss CPS-TS review and approval process and NRC resources.

NRC reviewer assigned: C. S.

Schulten i

! April 1985 NRC provided " Draft" of CPS-TS

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incorporating NRC guidance learned over previous period.

Meetings were held to resolve NRC Technical Branches

comments.

August 1985 NRC provided " Proof & Review" CPS-TS. Meetings were held to ,

resolve NRC Technical Branches '

comments.

June 1986 NRC provided " Final Draft" of l CPS-TS for certification of

( consistency between FSAR, SER, and as-built plant.

. July - September 1986 IP met with NRC to resolve Final Draft comments.

U-600708 L30 86(09 -18 )-L 1A.120 STATE OF ILLINOIS COUNTY OF DEWITT DONALD P. HALL, Being first duly sworn, deposes and says: That he is Vice President of Illinois Power Company:

that the provided information to certify that the Clinton Power Station (CPS) Technical Specifications are consistent with the CPS - Final Safety Analysis Report, the NRC Safety Evaluation Report and the as-built facility, has been prepared under his supervision and directions that he knows the contents thereof and that to the best of his knowledge and belief said request and the facts contained therein are true and correct.

DATED: This / 8 day o ep e A , 1986.

Signed:

Donald P. Hall Subscribed and sworn to before me this /M day of September, 1986, t%t$t.) Mes)

/ Notary Public My commission expires:

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