A99001, Forwards Zion 1998 Annual Rept of Revised Regulatory Commitments

Forwards Zion 1998 Annual Rept of Revised Regulatory Commitments

ML20202B073
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	01/19/1999
From:	Starkey R COMMONWEALTH EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
ZRA99001, NUDOCS 9901280366
Download: ML20202B073 (3)

Text

I. ~~

Commonweahh Idison Lompany - I

,k

• zion Generating station e 101 hhdoh Itoulnard Zion. II.<nen r97  !

Tel Ri7-76 2084 i

i I

ZRA99001 January 19,1999 U. S. Nuclear Regulatory Commission Document Control Desk i Washington, D.C. 20555  !

i 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 i

Subject:

Annual Report Of Changes 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. l (2) Nudcar Energy Institute Guidance Document, " Guidelines For Managing; NRC Commitments," revision 2, dated December 19,1995.

Rne. v:e 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  ;

desenbed by the Nuclear Energy Institute (Reference 2). Reference 2 indicates that the NRC should be informed  !

of these changed regulatory commitments on an annual basis. This letter is to provide the Zion 1998 annual report (Attaclunent A) of revised regulatory conunitments.

Attachment A identifies;

1. The referem e which created the regulatory commitment

2. The original commitment

3. The revised commitment These changes in commitments were satisfactorily evaluated using the Nucleu 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, l (1-1SV R. Starkey Decommissioning Plant Manager

{

Zion Nudear Power Station

{

L Attachment cc: Regional Adniaistrator, U.S. NRC- Region III

\

k '

~ 1 9901200366 990119 PDR #

P ADOCK 05000295 PDR,

,e N NIN$ mIfEanf

january 19,1999 U.S, Nuclea,r Regulatory Commission

. Attachment A to ZRA99001 Page 1 of 1 Annual Report of Changes 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 R. Starkey (Comed) to U.S. NRC, transmitting I scensee Event Report Number 197-026, Docket No. 50400295, dated January 8,1998.

odginal Commitment Complete thc Technical Inspecion Improvement Program review of Modes of Applicability of Technical Specification required surveillances and verify the electronic data base is properly updated prior to unit 2 startup from 22R14.

Revised Commitment None, this commitment has been deleted. Comed has submitted its written certification of permanent cessation of operations at Zion Station Units 1 and 2. Comed has also provided the NRC written certification that all fuel has been removed from the Zion Station Units 1 and 2 reactor venets and that the two units will remain permanently defueled. The Improved Technical Specifications will not be implemented due to the units being permanently defueled. A Technical Specification change proposing new Defueled Technical Specifications for Zion station L u been submitted to the NRC.

2 l Reference Which Created The Commitment Letter from J. H. Mueller (Comed) to U.S. NRC, Reply To A Notice Of Violation, NRC Inspection Report Nos. 50-295/304-97019, dated November 3,1997, original Commitment ZAP 100 07 will be revised to reflect what actions are required when N/As are uwd in procedures; i.e.,

concurrence of two cognizant individuals that a step can be marked N/A. The two will each initial the step and provide a reason or justification for marking the sep N/A.

Revised Commitment Zion Administrative Procedure (ZAP) 100 07 will be revised to reflea the required actions for msrking steps without conditional statements as Not Applicable (N/A) . The appropriate supervisor will initial the step or series of steps and ensure the reason or justification for them being marked as Not Applicable is provided. The supervisor will explain to the person performing the procedure the reasons why the steps are marked Not Applicable and resolve any questions before proceeding. The revised commitment maintains the requirement for annotating the steps marked Net Applicable, continues to provide for a second knowledgable person in the process to mark steps as Not Applicable, and providcs for the appropriate supervisor to be the single point of accountability for marking steps Not Applicable iu a procedure. The change will ensure the control of marking steps Not Applicable rests with the proper experience and leadership level.

l .

. _ - . . _ . _ .