A98056, Forwards List of Revised Various Commitments Originally Contained in Util to Nrc.Changes in Commitments Were Satisfactorily Evaluated Using NEI Commitment Change Methodology

Forwards List of Revised Various Commitments Originally Contained in Util to Nrc.Changes in Commitments Were Satisfactorily Evaluated Using NEI Commitment Change Methodology

ML20198D575
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	12/11/1998
From:	Starkey R COMMONWEALTH EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
ZRA98056, NUDOCS 9812230125
Download: ML20198D575 (7)

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, Zion Generating 5tation 101 $hiloh Iksolemd Zion, IL (o F19 2797 Tel m 7442081 -

ZRA98056 December 11,1998 U. S. Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555 Zion Nuclear Power Station, Units 1 and 2 Facility Operating License Nos. DPR 39 and DPR-48 NRC Docket Nos. 50-295 and 50-304

Subject:

Change to Regulatory Commitments

Reference:

(1) Letter from J. C. Brons (Comed) to A. B. Beach (U.S. NRC), " Applicable Regulations, Disposition of Commitments, and Systems Required Following Permanent Shutdown And Defueling Of Zion Units 1 and 2," dated March 30, 1998.

(2) Nuclear Energy Institute guidance document, " Guidelines For Managing NRC Commitments," revision 2, dated December 19,1995.

Reference 1 identified that due to the permanent shutdown and defueling of Zion Station Units 1 and 2 we would evaluate open regulatory commitments and notify the NRC of changes to commitments using the methodology described by the Nuclear Energy Institute (Reference 2). This letter is to revise various commitments as identified in Attachment A.

Attachment A identifies:

1. The reference which created the regulatory commitment

2. The original commitment

3. The revised commitment These changes in commitments were satisfactorily evaluated using the Nuclear Energy Institute commitment change methodology as committed to in Reference 1.

Should you have any questions concerning this letter, please contact Mr. Robert Godley at (847) 746-2084, extension 2900.

Respectfully, PrSF =

R. Starkey DecommissioningPlant Manager Zion Nuclear Power Station as

• Attachment b /

9812230125 981211 ,L,9 PDR ADOCK 05000295 P PW A L nicom Compan)

December 11,1998 U.S.' Nuclear Regulatory Commission

. Attachment A to ZRA98056 Page 1 of 6 l

Change to Regulatory Commitments The following table identifies changes to previous Comed commitments.

Please notify Mr. Robert Godley, Zion Station Regulatory Assurance Manager, of any questions regarding this document or any associated regulatory commitments.

1 l Reference Which Created The Commitment Letter from J. H. Mueller (Comed) to U.S. NRC, " Request For Exemption To 10CFR50, Appendix J Option B, Type B Leak Rate Testing Requirements For Penetration P-16,* dated August 26,1996.

Original Commitment Comed plans to perform a plant modification during the next unit i refueling outage, Z1R15, such that Type B testing will not be required for P-16. The five tubing lines which pass through P-16 are pan of the Reactor Vessel leak Detection System. Comed plans to decommission this system, and to close and deactivate the containment isolation valves fram P 16. During Z1RIS, the five tubing lines which pass through P 16 will be cut, capped, and leak tested in accordance with the applicable standards. Z1Rt 5 is currently projected to complete in April,1997.

Revised Commitment None, this commitment has been deleted. The containment isolation and integrity systems along with Appendix J testing are not longer required with both units permanently defueled. The modification to l

penetration P-16 will not be pursued.  ;

i 2 l Reference Which Created The Commitment Letter from T.J. Maiman (Comed) to U. S. NRC , " Request For Information Pursuant to 10CFR 50.54(f) Regarding Adequacy And Availability Of Design Basis Information," dated February 6,1997.

Original Commitment 100% inspection of safety related cable trays were performed. This effort resulted in several potential deficiencies (hardware, housekeeping, and separation issues). Evaluation at the time of identification indicated there were no operability concerns. Deficiencies in fourteen of twenty <me areas have been resolved and a plan for the remaining areas is in place. Evaluations for the cases of reduced separation have been prepared. The remaining hardware and housekeeping deficiencies are being systematically addressed in accordance with their relative priority. ,

Revised Commitment )

None,this commitment has been deleted. Remaining deficiencies in seven of twenty one areas will not be resolved. Operability Assessment ER9700013 (1/2/97) and Safety Evaluation 97-011 (Rev 1,4/21/97) concluded that the deficiencies do not constitute an operability concern with the pl:nt operating. The deficiencies do not constitute an operability concern with both units permanently defueled.

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i December 11,1998

- U.S. Nuclear Regulatory Commission Attachment A to 2RA98056 Page 2 of 6 Change to Regulatory Commitments 3 l Reference which Created The Commitment Letter from T.J. Maiman (Comed) to U. S. NRC, " Request For Information Pursuant to 10CFR 50.54(f)

Regarding Adequacy And Availability Of Design Basis Information," dated February 6,1997.

l Orighial Commitment Several initiatives are being undertaken and planned at Zion to assure continuation of consistency with j the design bases. These initiatives are intended to enhance the programs that currently provide reasonable assurance of consistency between the plant and its design bases. These initiatives are:

Improvements in the quality of and access to design basis information, including:

Review of the UFSAR, Technical Specifications, station procedures, and supporting design basis calculations and documentation to ensure consistency Deter. ination of the need for and generation of up to seven additional topical design basis documents hlapping and improvement of the process and procedures to ensure the traceability and retrievability of design basis information meets the needs of Zion Station.

htapping and improvement of the process and procedures to ensure the integrity and consistency of the design basis calculations, technical specifications, UFSAR and station procedures is maintained in real time.

l -Ensuring understanding of the maintenance and control of the design basis program through

< communication and training l -Resolving design basis discrepancies

. Conducting periodic self assessments to demonstrate that process and procedure changes are achieving I the desired results.

, Revised Commitm:nt l None, this commitment has been deleted. This commitment was to be implemented through the " Design Basis Initiative" (DBI) projecc. This project has been cancelled because of the permanent shutdown of both Zion units. The station has submitted a revision to the Updated Final Safety Analysis Repon called l the Defueled Safety Analysis Report that was written to reflect the permanent defueled condition of the l plant. The validation process used during the preparation of the DSAR should ensure that the DSAR i

adequately reflects the licensing basis of the Zion units with both units permanently defueled.

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Reference Which Created The Commitment j Letter from L. E. Holden (Comed) to U.S. NRC, " Inservice Testing Program (IST) for Pumps and Valves Third Ten Year Interval, Revision 1,* dated November 10,1995.

l Original Commitment Diesel Driven Containment Spray Pump cooling Water Solenoid Valve 1(2) SOV-SWO153 will be permanently disconnected.

Revised Commitment None,this commitment has been deleted. The design change was completed on Unit 2 and was scheduled for installation on Unit 1 prior to reactor startup. The Containment Spray system is classified as not required with both units permanently defuelled and the design change will not be performed on Unit 1.

December 11,1998 U.S. Nuclear Regulatory Commission Attachment A to 2RA98056 Page 3 of 6 Change to Regulatory Commitments s I Reference Which Created The Commitment Letter from J. H. Mueller (Comed) to U.S. NRC, " Commitment Regarding Pressure Temperature Limits Report Methodology," dated December 17,1996.

Original Commitment Comed will revise the Pressure Temperature Limits Report methodology such that a margin of I degree Fahrenheit per degree Fahrenheit of difference will be applied to account for the difference between the irradiation temperature of the Point Beach Unit 2 capsule and the irradiation temperature of the Zion reactors.

Revised Commitment

, None, this commitment has been deleted. Comed will not revise the Pressure Temperature Limits Report methodology. The Reactor Coolant System is no longer required to be operable with both units permanently defueled. The Prenure Temperature Limits Report (PTLR) requirements are no longer applicable because the reactor will no longer be operated.

6 l Reference Which Created The Commitment Letter from C. Y. Shiraki (U.S. NRC), to D. L. Farrar (Comed), " Safety Evaluation of Steam Generator Girth Weld Inspection Results Zion Nuc! car power Station, Units 1 and 2," dated October 6,1994.

Original Commitment For Unit 1, the licensee has conunitted to inspect l A and ID steam generators as required by Section XI of the ASME Code during next inspection period (Third Interval, First period), which is tentatively scheduled to end around spring 1997. Steam generators 1B and IC, which had no recordable indications resulting from the 1993 inspection, will be inspened if the results of the 1 A and ID steam generators require the inspection as specified by the ASME code.

Revised Commitment None,this commitment has been deleted. The Steam Generators are no longer required to be operable with both units permanently defueled. The inspection cited in the commitment was scheduled for the Unit 1 Fall 1998 refuel outage which has been cancelled due to the permanent defuel of Unit 1.

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December 11,1998

. U.S. Nuclear Regulatory Commission Attachment A to ZRA98056 Page 4 of 6 Change to Regulatory Commitments 7 l Reference Which Created The Commitment Letter from M.J. Vonk (Comed) to U. S. NRC, " Comed Response to NRC Generic Letter 95-03:

Circumferential Cracking of Steam Generator Tubes," dated June 27,1995.

Or%inal Commitment Edition to Technical Specification requirements, the following will be performed:

1.100% full-length bobbin coilinspection of inservice tubes.

2. A minimum 20% of the hot leg roll transitions in all steam generators. If circumferential indications are detected, expansion will consist of 100% inspecion of the hot leg roll transitions of all steam generators.

3.100% of allinservice row 2 U-bends,(row 1 U. Bends were preventively plugged in the sixth refueling ,

outage). I 4.100% of all sleeves.

5. 20% of the dents > 3.0 volts at the lowest hot leg tube support plate. If circumferentialindications are detected, inspection will be increased to 100% of the dents > 5.0 volts at the tube support plates.

Revised Commitment None, this commitment has been deleted. The Steam Generators are no longer required to be operable j with both units permanently defueled. 1 i

8 l 1 Reference Which Created The Commitment Letter from R. P. Tuetken (Comed) to U.S.NRC, " Required 30 Day Report On Timed Rod Drop Testing," dated May 7,1996. -

Original Commitment It is believed that the elevated "Zero" and signal decay are a temperature related phenomenon that has a high probability of being corrected by an Exempt Change (E22.l(2)-94223) which is scheduled to be installed on the Unit 1 RPI system in the Spring of 1997, during refueling outage 21R15 (currently scheduled for March 8,1997 April 24,1997), and on the Unit 2 RPI system no later that Z2R15 (currently scheduled for March 21.1998 - May 7.1998).

Revised Commitment )

None,this commitment has been deleted. The Control Rod Position Indication system is part of the Control Rod and Drive System which is no longer required to be operable with both units permanently i defueled.

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+ U.S. Nuclear Regulatory Commission l Attachment A to 2RA98056 l Page 5 of 6 i

I l Change to Regulatory Commitments l

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Reference which Created The Commitment f.etter from J. H. Mueller (Comed) to U.S. NRC, " NUREG 0737, Item II.D.1, Performance Testing of Relief and Safety Valves -Status of Open Issues," dated August 29,1997.

1 Original Commitment ,

Comed intends to perform plant modifications during the next refueling outages (Z IR16 and Z2R15) j which will address PSV load combinations. In addition, the PSV modifications and associated analyses which will be completed in support of this modification will include PSV discha,;e loads in combination 1 with SSE loads. In accordance with the NRC Staff request, Comed will provide a description of the PSV )

modifications for staff review and approval prior to installation. I Revised Commitment J None, this commitment has been deleted. This issue involves completing modifications to ensure the l adequacy of the pressurizer relief piping during a pressure transient event. Since both Zion units have be-n permanently shutdown and defueled with the reactor coolant system vented, pressure transients are l not a concern. The Pressurizer System is no longer required to be operable with both units permanently  !

l defueled. I 1

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Reference which Created The Commitment Letter from L. E. Holden (Comed) to U.S.NRC, " Status Update on Generic Letter 93-W. P 1 : rol System Failure and Withdrawal of Rod Cluster Assemblies,10CFR50.54(f)," dated February 14, tot Original Commitment This letter provides the requested written notification that the current order timing moddication was installed in Zion Unit 1 during the recent outage (Z1R14). This modification will be installed on Unit 2 during the upcoming fall outage (Z2R14).

Revised Commitment None,this commitment has been deleted. The Control Rod and Drive System is no longer required to be operable with both units permanently defueled.

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December 11,1998

. U.S Nuclear Regulatory Commission Attachment A to ZRA98056 Page 6 of 6 Change to Regulatory Commitments 11 l Reference Which Created The Commitment Letter from D.J. Chrzanowski (Comed) to U.S. NRC, Response to NRC bulletin 8941, supplement 2, Failure of Westinghouse Steam Generator Tube Mechanical Plugs," dated August 9,1991.

Original Commitment (Item 2b)

The Commonwealth Edison program implemented in November,1990 will result in the implementation of remedial actions for all inconel-600 steam generator tube plugs prior to the lifetime dates estimated in WCAP-1244.

Revised Commitment None,this commitment has been deleted. The plug replacement program was partially completed and Inconel 600 plugs remain installed in the Unit I steam generators and they will not be replaced. The Steam Generators are no longer required to be operable with both units permanendy defueled

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