View source for U-600506, Submits Current Status of Plant Design,Const & Preoperational Phase Testing.Util in Final Process of Testing Plant in Preparation for Fuel Load.Fuel Load Anticipated in Late June or Early Jul 1986

{{Adams
| number = ML20203B254
| issue date = 04/16/1986
| title = Submits Current Status of Plant Design,Const & Preoperational Phase Testing.Util in Final Process of Testing Plant in Preparation for Fuel Load.Fuel Load Anticipated in Late June or Early Jul 1986
| author name = Hall D
| author affiliation = ILLINOIS POWER CO.
| addressee name = Denton H
| addressee affiliation = NRC OFFICE OF NUCLEAR REACTOR REGULATION (NRR)
| docket = 05000461
| license number = 
| contact person = 
| document report number = U-600506, NUDOCS 8604180097
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC
| page count = 11
}}

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  .'                                                         U-600506 L30-86 (04 - 16) -L 1A.120 ILLINDIS POWER COMPANY CLINTON POWER STATION. P.O. BOX 678, CLINTON, ILLINOIS 61727 April 16, 1986 Docket No. 50-461 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U. S. 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 the current status of the design, construction, and preoperational phasq testing of the Clinton Power Station (CPS) in                                                       i accordance with the TPS Final Safety Analysis Report- (FSAR) and NRC regulations. This letter describes the project status as revised from                                                    ,
the {{letter dated|date=February 17, 1986|text=February 17, 1986, letter}} on " Readiness to Load Fuel" (IP letter U-600455). The status of each major activity needed to support Fuel                                                      :
Load and subsequent startup/ power ascension testing is described below.
On March 18, 1986, Illinois Power announced that Fuel Load at CPS                                                   l would be later than expected. The target previously established for                                                      l the milestone event was the end of March. Two major factors are contributing to the delay. Because of experiences at other nuclear power plants in about the same stage of completion as Clinton, more tests are being required by the Nuclear Regulatory Commission than previously anticipated. Also, Illinois Power Company management has determined that the completion of testing and preparing the plant for                                                    i operation is more difficult and requires more time than was scheduled.
Illinois Power management, which includes the Board of Directors, has made an absolute commitment to the building of a safe operating plant at Clinton. IP is in the final process of testing the plant in preparation for Fuel Load. IP will seek to load fuel when management is satisfied all conditions are properly met to the satisfaction of                                                      l the NRC. It is anticipated that Fuel Load at CPS will occur in the                                                       l late June to early July timeframe.
A. Project Readiness Initiatives L __
In the last update of the " Readiness to Load Fuel" letter, as referenced above, several management initiatives were described which have been taken to ensure a rigorous ap roach to management commitment and involvement in the control of lant activities.
                                                                                                                         \
8604180097 860416 PDR   ADOCK 05000461                                                                                           q A                PDR                                                                                               g i

l The particular initiatives described in theclast uadate of this letter included various changes in organization, the formation-of a Project Control Center (PCC), the. Site-Wide Statusing System-(SWSS), an Operational Readiness Assessment (ORA) and the process of-identifying systems required operable for Fuel Load.           The' details of.these program initiatives-are not repeated herein             the status of key results in-these'and other areas is discussed below.
(1)   Project Control Center (PCC)
The PCC continues.to focus on the resolution of restraints-              1 to system preoperational phase testing activities.'         The involvement of.the PCC in resolving these restraints has improved.this area. In February, ten system releases were made from Startup to Plant Staff.- In March, one system 9!>           release was made to Plant Staff. System. releases in March               -
decreased due to management's decision that open system punchlist items will be cleared prior to release.          The PCC is also focusing more attention on the readiness of systems to support operation.
I                                                                                                ;
(2)   Site-Wide Statusing System (SWSS)
The SWSS provides the consolidated-listing of.all open work documents at CPS. The-assignment of completion. milestones to all open work items is essentially complete.          This effort has and will continue to provide a common framework, relative to required plant systems and areas, needed to                  t support timely planning and scheduling of these activities.
The SWSS is updated daily _and charts are maintained in the PCC and in other site-wide locations.-
(3)   Operational Readiness Assessment-(ORA)
The~ internal assessment of CPS conducted _by IP was completed in February, 1986. The_results of this OPA were provided by.
the assessment team to management in a' report.         This report has been reviewed by each' department manager, and responses have been provided to the ORA team for final assessment.
                                                              ~
For the following significant items identified ~by the' ORA team, corrective action has been taken,.as noted below:
Criteria for System Release from Startup-to Plant Staff
                              - more definitive criteria have been established and are now in use. As noted in the above PCC discussion, efforts to make each system as operational ~as possible, prior to the release to Plant Staff, are underway.
Housekeeping - Daily supervisory inspections of plant areas are being conducted. Designated eating and smoking areas have been established.
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t 1
d Post Maintenance Testing - Procedures'are being revised
                                  -to provide. clearer. guidelines to the-Shift Supervisor-2                                 -in the areasHof ASME repair / replacement, Inservice.
Testing, Pump and Valve Operability requirements, equipment qualification.and leak testing requirements of 10CFR50, Appendix J.                                     ,
Technical Specification. Surveillance Procedures - a
;                                  cross-reference is being actively pursued.to ensure all.    '
requirements will be met.
Area / Process Radiation Monitoring (AR/PR)' System -
several actions-are being taken to. ensure the AR/PR system will be ready for Fuel Load. .These actions
;                                  include the establishment of.an.AR/PR' manager to i                                  coordinate all activities, the preparation of-
;                                  procedures and the performance of radiation monitor i                                  calibrations. All open work documents.are being reviewed and scheduled for completion.
]
Closure Rate of Open NRC Inspection &, Enforcement (I&E)
{                                  Items - increased management attention has been given to this area to support timely and complete I&E closure packages and the increased Region III inspection
     .                             activities as Fuel Load at CPS approaches.
                   . (4)     Systems Completion Status Work on all plant systems, with the exception'of those
'r                           systems related to the test deferrals identified in IP' Letter U-600469, dated March 12,.1986, will be completed
;                            prior to Fuel Load. As of-the end of March, there were a 1                            total of 38. full systems and 3 partial systems' declared j                            operable (out of 133). As required by CPS Technical'
;                            Specifications, surveillances will-be performed on'affected i-                           systems, up to and including, Operational-Condition l             ,
4 requirements, prior to Fuel Load, except.for those systems in which testing is deferred ~(March- 12, 1986' letter),'or
               .             where plant conditions ~ preclude such surveillances.
This area is receiving a high level.of management attention.
)!
An action plan has been established including ~the_
implementation of'a plant procedure which establishes a
                                                                     ~
rigorous system readiness checklist requiring. departmental ~
 ;                           managers / directors to~ sign-off on the' completion of all-necessary work prior to declaring the system operable and
                             " cleaning up" of systems prior-to release _to Plant-Staff-p '
from Startup. Systems which have been previously released-are being reevaluated on a case-by-case basis using these-checklists. All work documents, modifications, and punchlist items are being examined, prioritized and scheduled for completion cn1 a total system basis.-
1 i

                       =-B.                   Critical Path' Analysis
:                                            As of March 21, 1986, the CPS critical path analysis indicates the most limiting systems restraining Fuel Load are'the Control Room Ventilation, Fuel Handling,-Fire Protection, Off Gas, Diesel Generator, Standby Gas Treatment,'High Pressure. Core Spray, and Combustible. Gas Control-Systems.
Restraints to completion of these systems include startup test activities, equipment repairs, p                                             design. modifications,-preparation of procedures.and surveillance procedure performance.
The PCC is resolving-these restraints so'as to complete the required work'in-a safe and timely manner.
The only remaining major-project milestone requiring completion                                                                            1
                                             -prior to Fuel Load is the Integrated Emergency. Core Cooling System / Loss of.0ffsite Power-(ECCS/ LOOP) Test.. The ECCS/ LOOP-
:                                             Test is currently scheduled.to be started in May'1986.
C.           Construction Status l
As of March 25,.1986, construction of CPS is essentially complete based on all commodities except as noted below:
)
i                                                          Piping Insulation = 95.05%
Conduit = 98.47%                                                                                                              .
Conduit Hangers = 99.45%
Penetration Seals = 96.05%
!                                                           Painting = 98.39%
1 i                                             All systems have been turned over from Construction to Startup I
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 April-1986. ' The j                                              following provides the status of remaining. plant areas, as of 4                                             March.26, 1986:
4 i                                                           Total Physical Plant Areas = 659 i                                                           Plant Areas Completed = 586 1
4 Plant Areas Remaining = 73 i
i                                                           Remaining Areas Required for Fuel Load = 26 i
Remaining Areas After Fuel Load = 47 i                                              The 26 required plant areas remaining.will be completed prior to Fuel Load.-               The data reported'above represents an increase of 51.
1.
I
:                                                                                                         i
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                                                                                   ~
    , , - - . -        =,-r-        ,,1---y.,%     - - - -,    .,-,-~yw.   -ew cw.   ,. -- , +~ c--  ,-       .m -r   -    -- e-m.- ~- . ~ .    ,~,e5 ---mri--,.- -, -. .-.-,-r-  --r areas completed since the last update of this letter.      Final commodity turnovers will be based on building completion Trends for completion of Construction Work Requests, Field Chan e Requests, Area Punchlist Items, Travelers and Plant Modi ications continue to support timely plant completion.
Several other key construction completion activities warrant mention. During the month of February 1986, construction work on the Control Room elevation of the Control Building was completed.
All fire wrapping and fire damper modifications were completed in March. The piping department completed the construction portion of IE Bulletin 79-14 and the balance of plant hanger arograms in March. Finally, additional management attention has been directed towards removing restraints, such as testing related work, from the completion of remaining area commodities (e.g.,
insulation and painting).
D. Preoperational Testing A total of six (6) Preoperational Tests, all of which are required for Fuel Load, were completed in February, 1986. Eight (8) Preoperational Tests were completed in March. As of March 31, 1986, Preoperational Test Procedure (PTP) and Acceptance Test Procedure (ATP) performance status is as follows:
Total PTPs/ATPs = 157 PTPs/ATPs Required for Fuel Load = 148 PTPs/ATP Completed = 109 (approximately 74% of the total required for Fuel Load)
Through the beginning of March, approximately 98% of all Checkout and Initial Operation (C&IO) phase testing has been completed.
In addition, over 98% of the test procedures required for C&IO, Preoperational, and Startup phase testing are approved for use.
On March 12, 1986, IP Letter U-600469 was submitted to the NRC which provided detailed technical evaluations of several preoperational phase tests being deferred until after Fuel Load.
The referenced letter identifies a total of 17 PTPs/ATPs (9 full     :
PTPs/ATPs and 8 partial PTPs/ATPs) affected by these test deferral requests. The technical evaluations performed indicate that the affected test activities can be deferred until after Fuel Load with no undue risk to the health and safety of the public and no impact on the safe and reliable operation of CPS during the low power phase of the plant startup program.
Preliminary discussions with the Staff in,dicate that the NRC will l            approve these test deferrals. IP has established measures for controlling the deferred test activities in a manner that will i            minimize the impact on power ascension activities and result in l            no unwarranted burden on plant operations and testing 1
personnel. IP Letter U-600510, dated March 27, 1986, submitted five (5) specific exemption requests to the requirements of 10CFR50, Appendix A, General Design Criteria, in accordance with 10CFR50.12, rela *ive to the safety-related systems affected by the test deferraio.
E. Personnel and Staffing Currently, there are 46 personnel licensed to operate CPS [34 Senior Reactor Operators (SR0s) and 12 Reactor Operators (R0s)].
This includes the 10 candidates that passed the NRC examinations in February, 1986. The current number of licensed operators exceeds that required to fulfill the shift complement levels of the CPS Technical Specifications.
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. The status (as of April 4, 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 = 13 Require NRC Action to Close = 5 Require IP Action to Resolve = 8 Since the last update of this letter, 22 " CLIP" issues have been resolved by the Staff.
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|date=November 4, 1985|text=letter dated November 4, 1985}}, a preliminary hydrogen analysis to the Staff. The NRC's review and approval of the CPS preliminary analysis is expected to be addressed in SSER #6 (prior to
!                  Fuel Load).
(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 of Coolant Accident (LOCA) and Humphrey-related issues. Recent discussions with the NRC reviewer indicate no further information will be required to close these issues. IP anticipates that the remaining issues will                   i
,                  be resolved in SSER f6 prior to Fuel Load.                                       i a
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_.                                             ~. .                _                                . , . _.-             .                  . _ _ _ . .
(3)             Pump and-Valve Operability Review (PVOR)
                                       '(Portion of SER Outstanding Licensing Issue #7) l                                        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 March 31,_1986, 120.out of
!-                                       121 PVOR packages have been reviewed and. vaulted as complete by IP. 1Rie remaining package will be completed and vaulted
:                                        in April. A PVOR completion letter will be submitted to the                                                                                     ,
                                       'NRC after all of the packages are completed.                                                                                                      ;
(4)             Equipment Seismic and Environmental Qualification l                                        (SER Outstanding Licensing Issue f-7)
Electrical ecuipment environmental qualification issues were l                                       addressed anc essentially resolved in SSER #5. The CPS i                .                      mechanical equipment environmental qualification program is i                                        expected to be closed by the NRC Staff in SSER f6.                                                                                               ,
    ~I                                  Environmental and seismic qualification packages are now complete. As of April 4, 1986, 20 items remain to be installed. The installation work-for 10 of the items is forecasted to be complete in April, 151e remaining 10_ items
  ,                                      relate to installation of high efficiency particulate air filters and reactor vessel head spray components (which will i                                       be installed-following reactor vessel head set). A
:                                        completion letter to the Staff, as required by SSER f5, will i                                        be provided by IP after all work has been completed. NRC Staff closure of the remaining issues is anticipated in SSER
                                         #6. No' impact on Fuel Load from these issues is expected.
]                        (5)             Safeguards and Security j                                        SSER f5, Section 13.7, concludes that the CPS Safeguards and Security Plan meets the requirements of 10CFR73. Security screening of personnel requiring unescorted access for Fuel
 ;                                       Load is underway.. The CPS security screening program is i
based on accepted industry standards and includes a
;                                        background investigation, psychological evaluation,: and a i                                        continuing observation program. A-second security screening
.                                        contractor has been hired to provide additional capacity and j                                        screening priorities have been established in order to i                                       complete.this effort prior to Fuel Load. As of March 7,
;                                        1986, access authorization had been granted for over 76% of i                                        the personnel required for Fuel Load.
4 (6)             Fire Protection
,                                        SSER #5, Section 9.5, addressed certain aspects of the l                                        updated CPS Fire Protection Evaluation Report (FPER) and
{                                        Safe Shutdown Analysis:(SSA) report submitted by' letter i                                        dated September 6, 1985. These matters were identified as l                                        Outstanding Licensing Issue #21 in SSER #5. IP Letter i-i 4

U-600448, dated March 4, 1986, provided Amendment #1 to the SSA/FPER. Resolutions to five of eight " CLIP" fire protection issues have been achieved. As of April 4, 1986, IP has completed a:tions to resolve 19 of the 24 Region III open items from the September 1985 NRC audit. IP Letter U-600461, dated March 7, 1986, provided responses to NRR's audit concerns. IP actions on the remaining audit items will be completed in April 1986.
(7)   Technical Specifications All CPS Technical Specifications have received substantial internal review 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 Technical Specifications in a {{letter dated|date=September 4, 1985|text=September 4, 1985, letter}} to IP. Upon Staff issuance of the final copy of CPS Technical Specifications, conformance reviews will be completed and all necessary certifications will be provided to support Fuel Load.
(8)   Remote Shutdown System (RSS)
In the letter U-600460, dated March 10, 1986, IP agreed to implement, prior to restart from the first refueling outage, plant design modifications to eliminate the use of jumpers, rewiring, or disconnecting circuits such that Division II equipment can be locally operated in accordance with NUREG-0800, the Standard Review Plan (SRP), Section 7.4.
All Division II controls and equipment are being included in the CPS Technical Specifications, Section 3/4.3.7.4 and the associated Limiting Conditions for Operation / Surveillance Requirements will be implemented coincident with the design modifications. Plant operators will be trained on the procedures for remote shutdown using Division II controls and equipment prior to plant operation above 5% of rated reactor power. In addition, IP will provide a followup submittal committing to perform a one-time test, prior to Fuel Load, of the affected Division II equipment noted above.
G. Emergency Planning and Preparedness During the period November 12-21, 1985, NRC Region III personnel conducted a special appraisal of the onsite emergency preparedness at CPS. NRC Region III Inspection Report 50-461/
85039, dated December 20, 1985, listed 47 open items and 32 improvement items that were identified during the appraisal.       By {{letter dated|date=February 5, 1986|text=letter dated February 5, 1986}}, IP has provided Region III with our assessment of the 32 improvement items and planned action (s)     ,
for the 47 open items.      As of March 20, 1986, actions have been   '
completed on 40 of the    47 items. Actions on the 7 remaining open   i items, with one exception, will be completed in April 1986.       IP  j will provide documentation closure packages, to verify completion      '
of these actions, to the CPS NRC Resident Inspector's Office as       ;
these items are completed.                                            !
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The Integrated Emergency Exercise was. held on December 4, 1985.
Of the six findings noted by the NRC, two were stated (NRC {{letter dated|date=December 24, 1985|text=letter dated December 24, 1985}}) as required to be resolved before Fuel Load. IP actions on these two items are complete with the exception of training on one of the two items which will be completed in April. IP actions required to resolve a third item are also complete (contamination control practices in the Emergency Operations Facility Environmental Lab). No major deficiencies were noted by the Sraff or FEMA from the exercise.
A formal report from FEMA has not yet been received.
H. Exemptions The FSAR documents CPS conformance to the NRC rules and regulations set forth in 10CFR50 including Appendix A (General Design Criteria). A request for exemption from 10CFR50, Appendix J, leak test requirements was submitted by IP in a {{letter dated|date=December 9, 1985|text=letter dated December 9, 1985}}. These exemptions relate to the Main Steam Isolation Valves and the Containment Air Lock. Additional
                        ~
information relative to this request was submitted by IP Letter U-600468, dated March 11, 1986. The Staff's notice of environmental assessment and finding of no significant impact for this request was issued il Federal Register Volume 51, No. 32, page 5816, dated February 18, 1986.
I. 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 conform to applicable requirements. The current status of each of the major reviews is as follows:
                     '1)
                      ,   Independent Design Review (IDR)
Bechtel Power Corporation completed the IDR in 1985 and concluded the CPS design is adequate. Through March 1986, IP actions have been completed on 125 of the 128 IDR action             ;
items. The Staff noted in SSER f5, Section 17.5.5, that any           l further independent design review of CPS is considered unwarranted.
  ;                   (2) NRC Construction Appraisal Team (CAT) Review                             ,
i The NRC CAT team appraised CPS construction activities on                l May 20-31 and June 10-21, 1985.       The CAT concluded that             i hardware and documentation for CPS construction activities were generally in accordance with NRC requirements and Illinois Power program commitments. In the CAT Report i                        provided in the Staff's {{letter dated|date=August 15, 1985|text=letter dated August 15, 1985}}, deficiencies requiring additional Illinois Power management attention were identified. Subsequently, Region III issued, by {{letter dated|date=August 30, 1986|text=letter dated August 30, 1986}}, six Notices of Violation.
IP responded to these six Notices of Violation by letter I
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dated October 1, 1985. Currently, IP actions on five of the six Notices of Violation are complete. Of these five, two have been formally closed by the NRC and three'have received NRC reviews and will be closed in a future inspection report. The last item will be completed in April 1986.
(3)  Overinspection Program By letter (U-600514) dated April 3, 1986, IP informed the NRC that it has concluded the Overinspection Program for all items remaining in the scope of the program [radwaste (Augmented D), fire protection, structural steel, mechanical / electrical equipment, instrumentation, and instrument piping) and will make the results available at CPS for NRC review.
J. NRC I&E Items IP maintains a formal system for tracking and resolution of all l                                                                 NRC I&E inspection items, 10CFR50.55(e) items, and 10CFR Part 21 items. As of April 4, 1986, the status of these items is summarized as follows:
NRC 50.55(e)       Part 21          Inspection Pending NRC Action for Closure       14              8               102 Require IP Abtion for Closure               2              4                91 4
Total Open Items         16             12               193 Significant progress has been achieved on closure of I&E items in
 ;                                                                 the last two months. Additional management attention has been given to this area by IP, and continued management attention by the NRC will be required.
L. Allegations IP maintains three programs for addressing employee concerns. IP
,                                                                  does not seek any credit for these programs in meeting require--
ments 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 l                                                                 Load will not challenge the safe operation.of the Clinton Power Station.
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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.
e,    yours,
                                                                          /'/
                                                           '.Vice President s   . all TLR/cke 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
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