ML17201L002
| ML17201L002 | |
| Person / Time | |
|---|---|
| Site: | Dresden, Byron, Braidwood, Quad Cities, Zion, LaSalle, 05000000 |
| Issue date: | 09/15/1988 |
| From: | Greenman E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Reed C COMMONWEALTH EDISON CO. |
| References | |
| NUDOCS 8809260172 | |
| Download: ML17201L002 (4) | |
Text
Docket No. 50-456, 50-457 Docket No. 50-237, 50-249 Docket No. 50-295, 50-304 Docket No. 50-373, 50-374 Docket No. 50-454, 50-455 Docket No. 50-254, 50-265 Commonwealth Edison Company ATTN:
Mr. Cordell Reed Senior Vice President Post Office Box 767 Chicago, IL. 60690 Gentlemen:
SEP 1 5 *1988 The purpose of this letter is to advise you of a generic inservice testing
( IST) concern identified by the NRC as a result of inspection activities conducted during the period August 22 - 26, 1988, at the LaSalle County and Zion Nuclear Generating Stations~ Details of the inspections will be forwarded to you under separate cover; however, you are requested to provide additional information regarding our concern as it applies to all Conunonwealth Edison (CECo) nuclear stations.
- 10 CFR 5rr.55a of the Code of Federal Regulations requires that certain nuclear power plant components be periodically tested in accordance with specified editions of Section XI *of the American Society of Mechanical Engineers (ASME)
Boiler and.Pressure Vessel Code.
Generally, this te~ting program is defined as the IST program for pumps and valves.
During our inspections at both the LaSalle County and Zion Nuclear Generating Stations, inspectors noted that periodic observations of remote position indicators (RPI) for valves were not being performed as specified in Subsection IWV-3300 of.Section XI of the ASME code.
Subsection IWV-3300 Valve Position Indicator Verification states that:
Valves with remote position indicators sha 11 be observed at 1 east once every 2 years to verify that valve operation is accurately indicated.
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Commonwealth Edison Company 2
SEP t 5 1988 Discussions with members of your staff during our inspections indicated.that Commonwealth Edison Company had implemented the requirements of IWV-3300 for only those indicators located in the control room at each of your licensed facilities. The NRC staff believes that the requirements of IWV-3300 apply to all valve RPis and do not ekempt RPis located outside the control room from periodic observation requirements.
No evidence of verification of accurate RPI indications for locations other than the control room was found.
While lb CFR 50.55a provides a mechanism for obtaining relief from requirements of Section XI, relief requests associated with IWV-3300 have not beeri submitted for either the LaSalle County or Zion Stations.
Since the *practice of restricting verification to only those RPis located in the control room appears to be a corporate practice, you are asked to submit for our review the following information for each of your stations:
(1) information as to whether or not RPis other than those located in the control room are in fact ~eriodically verified to accurately reflect valve position, (2) a description of the remote positi6n verification test method employed, (3) whether a relief request from the requirements of IWV-3300 has been submitted, (4) a copy of the relief request, if any, and (5) a description of all valves with RPis that do not have their positiori verified.
For those stations which do -not currently perform periodic verification of RP Is not located in the control room, please provide an estimated date by which the RPI verification procedures will be in place and an estimate of when the associated testing will be completed for each unit.. If you do not plan to include periodic verification of RPis*not located in the control room in your testing program, please provide your justification and rationale along with a relief request for this approach.
Please submit this information within 45 days of the date of this letter.
We will gladly discuss any questions you have concerning this matter.
See Attached Distribution Riil Eng/j p RI II Ring Riil Hinds RIII Forney Sincerely, Edward G. Greenman,*Oirector Division of Reactor Projects Rill RI II RIII Miller Virgilio Greenman
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Corrnnonwealth Edison Company 2
SEP 2 S 1999 Discussions with members of your staff d~ring our inspections indicated that Corrnnonwealth Edison Company had implemented the requirements of IWV-3300 for only those indicators located in the control room at each of your licensed facilities.
We believe that the requirements of IWV-3300 apply to all valve RPis and do not exempt RPis located outside the control room from periodic observation requirements.
We have discussed this issue with NRR and they are in agreement with this position.
No evidence of verification of accurate RPI indications for locations other than the control room was found.
While 10 CFR 50.55a provides a mechanism for obtaining relief from requirements of Section XI, relief requests associated with IWV-3JOO have not beeri submitted for either the LaSalle County or Zion Stations.
Since the practice of restricting verification to only those RPis located in the control room appears to be a corporate practice, you are asked to submit
.for our review the following information for each of your stations:
(1) information as to whether or not RPis other* than those located in the control room are in fact periodically verified to accurately reflect valve position, (2) a description of the remote position verification test method employed, (3) whether a relief request from the requirements of IWV-3300 has been submitted, ( 4) a copy of the re 1 i ef request, if ~ny, and ( 5) a description of all valves with RPis that do not have their position verified.
For thos~ stationi which do not currently perform periodic verification of RPis not located in the control roorn, please provide an estimated date by which the RPI verification procedures will be in place and an estimat~ of when the associated testing will be completed for each unit.
If.you do not plan to include periodic verification of RPis not located in the control room in your testing program, please provide ybur justification and rationale along with a relief request for this approach.
Please submit this information
- within 45_days of the date of this letter. '
We will gladly discuss any questions you have concerning this matter.
See Attached Distribution
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Sincerely, Edward G. Greenman, Director Division of Reactor Projects
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Commonwealth Edison Company 3
SEP IS 1911 Distribution cc:
H. J. Miller, RIII RI Byron RI Braidwood RI Dresden RI Quad Cities RI LaSa 11 e RI Zion M. J. Virgilio, NRR
. D~ R. Muller, NRR T. J. Maiman, Vice President, PWR Operations D. Galle, Vice President, BWR Operations H. Bliss, Nuclear Licensing Manager R. Pleniewicz, Station Manager, Byron G. J. Diederich, Station Manager, LaSalle J. Eenigenburg, Plant Manager, Dresden R. L. Bax, Station Manager, Quad Cities G. J. Pliml, Station Manager, Zion Jan Norris, Project Manager, NRR, Zion S. Hunsader, Nuclear Licensing Administrator, Braidwood M. Lohmann, Project Construction and Startup Superintendent R. E. Querio, Station Manager, Braidwood P. L. Barnes, Regulatory Assurance Supervisor, Braidwood DCD/DCB (RIDS)
Licensing Fee Management Branch D. W! Cassel, Jr., Esq.
Richard Hubbard
. J. W. Mccaffrey, Chief, Public Utilities Division H~ S. Taylor, Quality Assurance Division E. Chan, OGC G. Berry, OGC Stephen P. Sands, NRR, Braidwood Diane Chavez, DAARE/SAFE L. Olshan, NRR PM, Byron David Rosenblatt, Governor's Office of Consumer Services Mayor, City of Zion
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