ML19344B018
| ML19344B018 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 08/15/1980 |
| From: | Abel J COMMONWEALTH EDISON CO. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8008250385 | |
| Download: ML19344B018 (2) | |
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K Commonwealth Edison j one First N;tional Plata, Chicago, tthnois
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D 7 Address R; ply to: Post Ofhc3 Box 767 N
/ Chicago, !!hnois 60690 v
August 15, 1980 s
Mr. Harold R. Denton, Director Of fice of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555
Subject:
Zion Station Units 1 and 2 Clarification / Interpretation of Confirmatory Order Item A.3 NRC Docket Nos. 50-295 and 50-304 Reference (a):
February 29, 1980 letter from H. R. Denton to D.
L. Peoples containing Confirmatory Order
Dear Mr. Denton:
Item A.3 in Appendix A of Reference (a) requires Commonwealth Edison Company to conduct a low pressure gross leak test of containment prior to any start up from cold shutdown conditions.
Prior to the issuance of the Confirmatory Order, Commonwealth Edison had discussions with the NRC Staff concerning the intent of this item.
Based on these discussions, Commonwealth Edison understood the NRC Staff's intent was for the licensee to perform the actions indicated prior to any startup from cold shatdown conditions following only those outages which involved maintenance.
Commonwealth Edison believes that this understanding is consistent with the requirement of the Order, i.e. to ensure that there is no gross containment leakage.
In some cases (as occurred recently at Zion Station), after leaving cold shutdown following an outage, it becomes necessary to return to cold shutdown for a brief period of time to correct problems not related to containment isolation.
During this time, the containment isolation valves are not required to change positions from their normal operational mode.
However, without knowing the intent, a strict reading of the Order for Zion would indicate retesting of the isolation valves is required prior to startup.
Commonwealth does not believe that this was intended nor is there a technical basis for such a requirement, especially since performing such additional testing involves unwarranted personnel radiation exposure as well as extends the outage an additional two days.
Based on the above considerations and understandings, Commonwealth Edison has determined that additional leak testing will not be required prior to startup whenever the containment isolation valve ~ system is known to have remained in its normal operational mmm82 50 DT$ -
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Commonwecith Edison p
i Mr. Harold R. Denton
-August 14, 1980 Page:2 mode'during a soutdown.
NRC Staff concurrence with Commonwealth Edison's position on this matter is appreciated, as well as the basis for any disagreement.
Please address any questions concerning this ratter to this office.
One (1) signed original and thirty-nine-(39) copies of this letter are provided for-your use, Very truly yours, j
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ames S. Abel Director of Nuclear Licensing JSA:WFN: rap i
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