U-602690, Responds to Confirmatory Action Ltr Dtd 970109.List of Specific Actions Re Util Restart Plan,Provided

Responds to Confirmatory Action Ltr Dtd 970109.List of Specific Actions Re Util Restart Plan,Provided

ML20137J874
Person / Time
Site:	Clinton
Issue date:	02/07/1997
From:	Connell W ILLINOIS POWER CO.
To:	Beach A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
CAL, U-602690, NUDOCS 9704040164
Download: ML20137J874 (3)

Text

Imnots Power Company Clinton Power Station

- PRIORfTY ROUTING P.O. Box 678 cisr. ton. it c1727 h[h i gg g Tel 217 935-5623 Fax 217 935 4632

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p40 ir.i20 DRMA February 7, 1997 FILE -- A w Docket No. 50-461 Mr. A. Bill Beach Regional Administrator Regian III U. S. Nuclear Regulatory Commission 801 Warrenville Road Lisle, Illinois 60532-4351

Subject:

Response to Cpnfirmatory Action Letter dated January 9.1997

Dear Mr. Beach:

We have received your Confirmatory Action Letter dated January 9,1997. This letter is a confirmation of previously communicated plans and actions intended to be complete prior to the restart of Clinton Power Station following the sixth refueling outage currently in progress. As discussed in the letter, the results of these actions will be discussed in a management meeting prior to restart.

In accordance with the requirements of the letter, we are informing you of minor differences in understanding specific actions in our restart plan. Details of those differences follows:

CAL Item 3. " ..IP will review all surveillance procedures prior to use, with special emphasis on preconditioning, completeness, and fidelity with the technical specifications and the Updated Final Safety Analysis Report (UFSAR)."

Illinois Power's Startup Readiness Action Plan Item I.1I states, "The operating i crew personnel will review scheduled surveillances prior to their performance to identify and correct inadequacies that prohibit successful completion of the surveillance activities. This review will be conducted in accordance with 0S0-92, Performance of Outage and Operational Activity Reviews." The OSO-92 reviews look at the ,

surveillance procedures for adequacy, completeness, preconditioning and to ensure the j technical specification acceptance criteria are satisfied. The reviews of Operations 4 0) surveillances has been expanded to include all surveillance procedures.  !

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.. U 602690 Page 2 of 3 i The OSO-92 review, however, does not include a review of the surveillance  ;

procedure against the UFSAR. - During the development ofinitial technical specifications, i cach technical specification was reviewed against the design bases documents and the ' l Final Safety' Analysis Report (FSAR). The surveillance procedures were written to satisfy . -l the acceptance criteria of the technical specifications. l On January 1,1995, Illinois Power implemented Improved Technical  ;

Specifications (ITS). During the development'and review the ITS prior to j implementation, a thorough review of each technical specification and the Updated Safety - ,

Analysis Report (USAR) was performed to ensure correct and valid information was j contained or incorporated in the ITS, USAR, and the Operational Requirements Manual (ORM). A multi-disciplined team reviewed each technical specification in the proposed j; ITS to ensure that the numerical values were correct and the ITS Bases were consistent l with plant design and the USAR. The Bases section for each technical specification ,

references the applicable USAR sections. In most cases the existing technical specification j was transferred to the ITS. Any changes to technical specifications in converting to the l ITS were reviewed to ensure that they were correct and that the Bases were in compliance 'j with the USAR. All the USAR references in the Bases section for each technical l specification were reviewed. Changes to the USAR identified during the review process - l were incorporated under the 10CFR50.59 process. This overall process has provided a i high degree of confidence that the existing technical specifications are consistent with the  !

USAR.

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In addition, prior to implementation of the ITS, a review was performed to  ;

determine if a procedure existed for each technical specification surveillance requirement.  !

Each of these surveillance procedures was reviewed to determine ifit fully met the ITS l requirements. If the procedure did not fulfill the requirements of the ITS or a new j procedure was required, these procedures were revised / created prior to implementation of l the ITS on January 1,1995. This has provided a high degree of confidence that the j existing surveillance procedures properly implement the technical specifications. Per the procedure change control and safety evaluation programs at CPS, each procedme chnge requires completion of a safety evaluation or screening. Performance of a safety  !

evaluation or screening requires verification that the procedure is consistent with the USAR. This has provided a high degree of confidence that the existing surveillance procedures are consistent with the USAR.

During our continuing review of surveillances as part of our Startup Readiness Action Plan, as a sample, all subsequent surveillances to be performed prior to plant startup will be reviewed against the USAR prior to performance. Following startup, the results of these reviews will be used to determine if additional surveillance-to-USAR reviews are warranted.

CAL Item 4. "...In addition, during the plant startup and until stable power operation is achieved, senior managers will monitor operations crews and provide written documentation of their observations."

• ,, U-602690 Page 3 of 3 Illinois Power's Startup Readiness Action Plan Item IIL3 states, "During restart .

activities and until stable power operation is achieved, experienced plant personnel will be  !

assigned to monitor major control room activities. They will be charged with assessing  !

the proper oversight functions by line management." The experienced plant personnel - ~t assigned this function will not necessarily be senior managers. The people assigned to j monitor main control room activities are all licensed or previously licensed Senior Reactor  ;

Operators (SROs) and includes supervisors, team leaders, and directors. l Please call me ifyou should have any additional questions. l 1

Sincerely, i t

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Wil dell Vice President MDS/krk l

cc: NRC Clinton Licensing Project Manager i NRC Resident Office, V-690 l Document Control Desk I Illinois Department of Nuclear Safety l l

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