ML20126F304

Responds to SA Varga to Dl Farrar Requesting Addl Info Re Items 2.1,2.2.2,4.5.2 & 4.5.3 of Generic Ltr 83-28, Required Actions Based on Generic Implications of Salem ATWS Events

ML20126F304
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	06/12/1985
From:	George Alexander COMMONWEALTH EDISON CO.
To:	Harold Denton Office of Nuclear Reactor Regulation
References
0255K, 255K, GL-83-28, NUDOCS 8506170430
Download: ML20126F304 (4)

Text

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Common'vealth Edison i

O one First Nrtional Plaza, Chicago, litinois Address Roply to: Post Office Box 767 Chicago. Ilinois 60690 June 12, 1985 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555

Subject:

Zion Stations. Supplement Response to Generic Letter No. 83-28, " Required Actions Based on Generic Implications of Salem ATWS Events" NRC Docket Nos. 50-295/304 References (a): Generic Letter No. 83-28 D. G. Eisenhut letter to all OLS and CPS dated July 8, 1983 (NL-83-0003)

(b): S. A. Varga to D. L. Farrar letter dated March 15, 1985.

(c): R. N. Cascarano letter to H. R. Denton dated August 31, 1984.

Dear Mr. Denton:

Reference (b) contained a request for additional information pertaining to Items 2.1, 2.2.2, 4.5.2 and 4.5.3 o f Generic Letter 83-28. Attached are the responses to those questions for Zion Station.

Please address any questions that you or your staff may have concerning our response to Generic Letter No. 83-28 to this office.

Respectfully, G. L. Alexander Nuclear Licensing Administrator bs Attachment cc: US NRC, Document Control Desk Washington DC 20555 B

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Licensee needs ' to isubmit: deta'iled information - describing ' his vendor .

" interface l program,forl reactor? trip system components. Information supplied should: state _how:the program assuresothat. vendor technical.

Linformation is kept complete, current and controlled throughaut'the-lifeLof.the' plant and should also indicate how the program will be

. implemented at': Zion-l' &L2.

' Response

The reactor trip system components are tr'eated as Safety-Related

. equipment and;as-'such are within the scope of ZAP 6-52-5 under

. General' Paragraph fA. New ETI,will be forwarded to the ETI

' Coordinator for review;. existing ETI will be reviewed in accordance'

-with section 2.0 of: ZAP 6-52-5. Enclosed is a copy of the ZAP.

' Item 2.2.2

-Licensee.needs to present his evaluation of the.NUTAC program and describe how it:will-be_ implemented at Zion 1 & 2. The staff ~found the NUTAC. program fails'to address-the concern about establishing and_ maintaining an interface between all vendors of safety-related

-equioment-and the' utility. Accordingly the-licensee will need to-

supplement his response to address this concern. This additional

informationJshould1 describe how current procedures will be mcdified

,- and new onestinitiated to meet _'each element of item 2.2.2 cor cern.

Response

+

-CECO:has--been' informed-through'INPO that the-March,-1984 NUTAC 1documentfis acceptable to the NRC. Therefore, this letter does not

. expand on prev'ious responses. CECO used the NUTAC report in ideveloping the Nuclear Stations Division Directive and the Zion

, Station procedures.

Item 4.5.2.

Licensee'needs to submit additional information on design

, modification,to permit 'on-line testing of the RTS.

' Response y

--CurrentlyLZion is designed to permit on-line. testing, so a

modification for.on-line-testing is.not: anticipated.

The following described modification to provide for? the automatic shunt trip is r ' installed ort Unit 1 and anticipated.to be installed by the end of i

1985 on Unit 2. This modification is different than the WOG's

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proposalfas discussed in Reference c.~ _The independent testing of

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, Jthe shunt trip and undervoltage. devices for Zion Station will be

~ integrated into the_ existing reactor protection test procedures.- A

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'E ,44 typicaltexample -of 'the independent testing o f the shunt trip iand UV f,- -devices-is explained with -the use of Figure 1 as follows:

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A. Test the UV Coil J) ~ start from reset condition with breakers closed

-2) engage "TC Logic Test" selector switch P12 (disables

' automatic : shunt trip) . Annuciator lights indicating switch in non-normal position

-3) Esimulate automatic trip signal

, 4) verify reactor trip breaker opens (by UV coil), white light L10 stays off, red light goes of f, and green light goes on 18.- Test'the Shunt Trip Coil

1) . start lfrom reset condition with breaker closed

2) press the "TC Test" pushbutton Pll-(simulating automatic

.shu'nt coil trip) 3)- verify reactor trip breaker opens, light L10 energizes, red 111ght goes-off,-and green light goes on.

The. variations of logic matrices will be tested as they presently are for the UV coil and procedures will be expanded to include the effects of the automatic shunt trip feature. This testing can be done on-line with the use of bypass breakers.

' Item 4.5.3 Licensee needs to submit description of the specific implementation plan for Zion-1 and 2 after NRC reviews the WCAP-10271 and supplement 1.

Response

In regard to the modifcation, the intervals for on-line testing will beLas currently-identified in the Technical Specification, monthly.

'In regard to the main question contained in 4.5.3, CECO feels that WCAP-10271 dated January 1983 and Supplement 1 to WCAP-10271 dated July-1983 adequately address the concerns of the NRC as they apply i to Zion Station without any further changes.

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4 ZIO'N STATION VENDOR EQUIPMENT TECHNICAL INFORMATION CONTROL PROGRAM ZAP 6-52-5 TABLE OF CONTENTS SECTION T TJTM PAGE DATE REVISION Table of Contents 1 APR 27 585 0 Purpose 2 APR 2 7 585 0 Scope References Definitions General Procedure 3 APR 27 585 0 1.0 Incoming ET: Documents 2.0 ETI Currently in Station Possession 4 APR 2 71985 0 3.0 Revisions to Controlled ETI 5 APR 2 71585 0 4.0 Lost or Destroyed Controlled ETI 6 APR 2 71985 0 5.0 ETI Temporary Checkout 6.0 ETI Permanent Checkout 7 APR 2 7 585 0

' 7.0 Responsibilities of the ETICC B APR 2 7 585 0 Attachment A 9 APR 2 71985 0 Attachment 8 10 APR 2 7 585 0 g

Attachment C 11 APR 271985 0 g# Q Attachment D 12 APR 2 71985 0 8:

Attachment E 13 APR 2 71985 0 k

- J h ua Attachment F 14 APR 2 71985 0 @

Attachment G 15 APR 2 71985 0 E Z$

Attachment H 16 APR 2 7 585 0 88o E yo Attachment I 17 APR 27 585 0 $

Attachment J 18 APR 2 7 585 0 Attachment K 19 APR 2 71985 o Attachment L 20 APR 2 71885 0 ne me n a antr m 04 WJ M W)uT U This procedure contains 20 pages / 2_Ogg, APPROVID [ [ M 0497Z 1 pgg (f ty-gf

. ZAP 6-52-5 Rev. 0

/JR 271S85 ZION STATION EQUIPMENT TECHNICAL INFORMATION

" CONTROL PROGRAM PURPOSE The purpose of this procedure is to establish control for the use, distribution and revision of Safety Related and designated significant Non-Safety Related Vendor Equipment Technical Information.

E.9.P.E This procedure applies to the following Vendor Equipment Technical Information:

Safety Related Vendor Equipment Technical Information Significant Non-Safety Related vendor Equipment Technical Information as designated by Station Department Heads or their designees.

REFERENCES NS00-M02 Control of Vendor Equipment Technical Information.

Vendor Equipment Technical Information Program, March 1984, INPO 84-010 (NUTAC)

INPO Good Practice, MA-304, Control of Vendor Manuals, INPO 84-028, September, 1984. :me USNQC,, .A & W $3'!.1 (NUMG1000) $

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DEFINITIONS VETIP: Vendor Equipment Technical Information Program ETI: Equipment Technical Information h

9 us w ETICC: Equipment Technical Information Control Center Controlled ETI: ETI whose contents cannot be changed without a specific hDy review and approval procedure. H Ez"o <2g R

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GENERAL U g, A. Safety related and designated significant non safety related ETI, within the scope of this procedure, shall be issued from and controlled by the ETICC. One copy of each ETI shall be maintained as the Master Copy and shall .NQT be made available for checkout by plant personnel. Controlled satellite files may be established.

8. ETI documents and applicable revisions shall be requested on purchase requisitions when ordering new components. The receipt inspection l should include verification of receipt of manuals.

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c ZAP b.b3-5 Rev. 0 APR 2 71985 C. Any Individual using a controlled ETI document shall verify that it

, is the latest revised copy. Verification shall consist of ensuring that the ETI has a station assigned copy number and revision date.

If the ETI will be used for the preparation of plant procedures, the user shall enter the procedure number and title on a Procedure Reference Sheet (Attachment A) and forward the reference sheet to the E11CC.

D. E11 drawings may not lend themselves to updating due to inconsistencies with plant drawings. Therefore ETI drawings will be stamped "FOR INFORMATION ONLY".

E. Spare and renewal parts lists of ETI documents will not be controlled and will be marked appropriately.

F. lhis procedures applies only to the printed body of ETI documents supplied to Zion Station by the vendor and any content changes provided by either the vendor or by station personnel. Work aids, such as user notes which do not affect the content of the ETI, should not be controlled.

ER0cr0VRE 1.0 incomina ETI Documents 1.1 All incoming ETI which are addressed to Zion Station, shall be forwarded to the Tech Staff ETI Coordinator who will determine if the document requires control.

1.2 lhe lech Staff ETI Coordinator shall promptly notify appropriate 2 personnel and Nuclear Network if such ETI identifies a concern 2 which could contribute to a degration of safety. Nuclear Network notifications are made through the Office of Nuclear W[

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Safety. gz 1.3 If control is not required, the document should be forwarded to DNw the addressee, hN Wo 1.4 88ocz If control is required:

1.4.1 lhe lech Staff ETI Coordinator shall attach to the document a Routing / Approval Sheet. (Attachment B).

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c6 1.4.2 The ETI, with attachment, shall be routed to a cognizant system engineer and one person knowledgeable on the equipment involved (the dept. head or his designee) for review.

1.4.2.a. The Routing / Approval Sheet serves as the record of comments for the ETI. Reviewers should note any comments on Attachment B.

When a comment is resolved, the person making the comment initials the comment to indicate his concurrence.

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ZAP 6-52-5 Rev. 0 APR 2 71985 1.4.2.b. Unresolved reviewer comments shall be resolved by a committee consisting of the Tech Staff ETI Coordinator, the system engineer, and the cognizant Department Head or his designee.

1.4.3 When the review is complete and all discrepancies resolved, the ETI Coordinator shall sign Attachment B and forward the ETI with-attachments to the ETICC. ,

2.0 ETI Current 1v in Station Possession 2.1 If, during the performance of a procedure or work request on a safety related or designated significant non-safety related piece of equipment, ETI is used to perform the task, that ETI shall be controlled per this procedure.

2.2 Establishing control of safety related or designated significant non-safety related ETI.

2.2.1 When ET! is identified as meeting the control requirements, immediately place the ETI on the Departmental ETI Control Identification List (Attachment C).

2.2.1.a. Fill out the title of the ETI and the date of identification.

2.2.1.b. Indicate using a Y or N if a procedure change will be required (if the ETI is referenced in the reference section of the procedure, no 2 procedure change is necessary; if the ETI is 2 not referenced, a procedure change will be required to add the ETI as reference g;::::

material). gg 2.2.1.c. Sign Attachment C. h 2.2.2 Proceed with procedure or work request.

2.2.3 Within 90 days of the ETI's identification date on 8 9, .

Attachment C, the Department Head or his designee shall 7 $

review the ETI for applicability to station procedures '

A and equipment, any known errors or omissions, and to determine if the ETI reflects the "As Built" condition of the equipment. The reviewer shall complete and attach a Procedure Reference Sheet (Attachment A) and an ETI Routing / Approval Sheet (Attachment B).

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,i IFIC ATION FOR iOmAiit suuMT ConL TRIP K;y: TC - Shunt Trip Coi5 (Energizes to Trip Breaker)

UV - Undervoltage Coil (De-energizes to Trip Breaker)

G - Green Light (Breaker Open) Shows in Control Room R - Red Light (Breaker Closed) Shows in Control Room W - White Light for testing H,H(other Train) - Shown for bypass breaker in test position.

This prevents both bypass breakers from stayinn

! simultaneously closed in the connect cosition. The breaker can be in the following positions: racked in (connect, or operate) , test and racked out.

Reactor Protection Logic - Provides Automatic Trip

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Rev. 0 APR 2 7 545 2.2.4 If the reviewer finds that the ETI is not applicable, contains errors or omissions or no longer reflects the equipments "As Built" condition, he shall note the discrepancy on Attachment B and forward the ETI with attachments to the Tech Staff ETI Coordinator.

2.2.5 If the Tech Staff ETI Coordinator deems necessary, he may convene a meeting of appropriate personnel to rectify the discrepancies. He shall also solicit the concurrence of the equipment supplier in order to resolve or confirm significant issues regarding technical content and warranties.

2.2.6 Indicate on Attachment B if vendor concurrence is f required. If yes, complete Attachment H, the Vendor Review Status Sheet.

2.2.7 When all discrepancies are resolved, or if no discrepancies existed, the reviewer shall approve the ETI by signing Attachment B.

2.2.8 When the ETI is approved, forward the ETI with attachments and all known copies to the ETICC.

3.0 Revisions to Controlled ETI 3.1 Individuals who receive ETI revision or addendum documents shall submit the information to the Tech Staff ETI Coordinator to initiate review.

NOTE 3e 3>- $2 ETI Revisions can result from vendor input, operating experience {$3 uJ ~~

b (in-house and external), ETI use or equipment modifications. ca 53$i Personnel who identify a need for an ETI change will prepare the c=1 g *C proposed revision and submit it to the Tech Staff ETI LaJ - g Coordinator, d cn])w; CD ::) c a 3.2 Revisions from in-house sources will be initiated by completing h:b and forwarding the request for ETI Revision Sheet (Attachment E) [ ;

to the Tech Staff ETI Coordinator. ((j $355c 2:

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3.3 The Tech Staff ETI Coordinator will prepare a review package to 23 8" .

include the following: i 3.3.1 Procedure Reference Sheet (Attachment A) 3.3.2 Routing / Approval Sheet (Attachment B) 3.3.3 Request for ETI Revision Sheet (Attachment D) 04972 5 e<

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ZAP 6-52-5 Rev. 0 APR 2 71985 3.4 The Tech Staff ETI Coordinator should review the ETI revision first and note any comments on Attachment B.

3.5 Routing for review will be to the system engineer and the cognizant department head or his designee who shall note all comments on Attachment B.

3.6 The ETI with attachments shall be returned to the Tech Staff ETI Coordinator who will, if necessary, convene a meeting of all ,

reviewers to resolve any discrepancies.

3.7 When all comments are resolved, the Tech Staff ETI Coordinator shall sign the bottom of Attachment B.

3.8 Final routing shall be to the ETICC.

-4.0 Lost or Destroyed Controlled ETI 4.1 In the event of lost or destroyed controlled ETI, the individual responsible for the manual shall complete and submit a Lost or Destroyed ETI Form ( Attachment E) to the ETICC.

4.2 The ETICC will update its files to reflect the loss and will f'le Attachment E.

4.3 If a manual that was reported lost is found, it shall be returned to the ETICC for disposition.

5.0 ETI Temporary Checkout 5.1 Temporary checkout of any ETI shall be accomplished by M completing a Temporary Checkout Card (Attachment F). The Master g $

Copy of any ETI shall not be checked out but may be used in the ETICC.

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Ozi 5.2 ETICC personnel shall issue the ETI requested and file the Temporary Checkout Card.

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no case should temporary checkouts exceed 30 working days. If o a cc temporary checkouts exceeds 30 working days, ETICC personnel O ca 8 should locate and reissue the ETI. y $

ca 5.4 Temporary Checkout Cards should be filed in chronological order by date of checkout. The card file should be checked weekly and an ETI Recall Slip (Attachment J) issued for overdue items.

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ZAP 6-52-5 Rev. 0 APR 2 71985 6.0 ETI Permanent Checkout 6.1 Department Heads may permanently check out a controlled copy of an ETI by submitting an ETI Request Form (Attachment G).

6.2 Upon receipt of the ETI Request Form, ETICC personnel wi,ll

-update the files to indicate date, issued to, revision date, and copy number; and transfer 1 copy to the requestor.

7.0 Responsibilities of the ETICC 7.1- When ETI is received for Control:

7.1.1 ETICC personnel will assign a copy number to each manual and mark each copy appropriately. One copy will be marked as the Master Copy.

7.1.2 When an ETI document is submitted for control, notify all department heads via Attachment L.

7.1.3 ETICC personnel will insert the following forms in the front of each ETI Master Copy.

1. Procedure Reference Sheet (Attachment A)

2. Record of Revision Sheet (Attachment I)

3. ETI Routing / Approval Sheet (Attachment B)

4. Vendor Review Status (Attachment H) (if necessary) x 7.1.4 The Record of Revision Sheet (Attachment I) shall be > N placed in the front of all controlled copies of ETI. Mj:!

>-- z 7.2 ETICC personnel will establish and maintain a cross-reference O Zj index between station procedures and the vendor ETI documents J us o they reference. o Q u'a c::: pz 7.2.1 When ETI is submitted for initial control, the Procedure yOy g Reference Sheet (Attachment A) shall be checked and the o eOc:::

information included in the cross-reference. jCg C

7.2.2 When ETI revisions are received, the Procedure Reference Sheet shall be reviewed by ETICC personnel to determine if any procedures could be affected by the revision.

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1 ZAP 6-52-5 l Rev. O  ;

APR 2 71535 )

7.2.2.a If the revision does not affect any procedures, ETICC personnel will recall all copies of the ETI by use of the ETI Recall Slip (Attachment J), make all required changes, update the Record of Revisions Sheet (Attachment I) and reissue to the holder.

7.2.2.b if the revision does affect procedures ETICC personnel shall:

7.2.2.b.1 Recall all copies of the ETI.

7.2.2.b.2 Make required change to the ETI Master Copy and all other' controlled copies.

7.2.2.3 Notify the appropriate department head of the affected procedure by the use of the ETI Reference Sheet (Attachment K).

7.2.2.4 The department head will coordinate a review of each procedure to determine the affect

. of the revision and to implement a procedure change if necessary.

. Return Attachment K to the ETICC.

7.2.2.5 Track and follow up on completion of ETI Reference Sheets.

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ZAP b-$2 b Rev. 0 APR 2 71985 ATlACHMENT A PROCEDURE REFERENCE SHEET ET1 No.

ET1 Revision No.

E11~litle This document was used as reference material for the preparation of the procedure listed below. Any revision to this ETI requires that these procedures be reviewed for possible change.

Procedure No. Procedure Title Procedure No. Procedure Title l- Procedure No. Procedure Title i

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ZAP 6-52-5 Rev. O APR 2 71985 ATTACHMENT B 1 1

ROUTING / APPROVAL SHEET

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ETI TITLE Route to: Signature: Date:

ETICC Comments M

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- ZAP 6-52-5 Rev. 0 APR 271985 ATTACHMENT E LOST OR DESTROYE0 ETI FORM

Title:

ETI No.:

The above ETI has been 0 Lost 0 Destroyed Explain:

Section Supervisor Date g N 8 w>E&

o w z <i.a ETICC: h gw cc: rz This ETI has 0 has not O been reissued. gog g 888 z a Signature Date ,

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ZAP 6-52-5 Rev. 0 APR 2 71985 ATTACHMENT F TEMPORARY CHECK 0UT CARD ETI Number:.

Title:

Checkout-Date:

Signature:

(Print Name):

Note: Return ETI by Due Date (30 working days from date of issue) s N

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ZAP 6-52-5 Rev. O ATTACHMENT G APR 2 71985 ETI RE0 VEST FORM (Permanent Issue)

To: ETICC from:

Department Head Approval:

Date:

Please issue copy (s) of the following:

ETI Number:

Title:

To:

(Holder's Name) ,

(Department) w&

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The above ETI is subject to recall by document control upon request il:g for the purpose of audit and/or revision. Do not remove or alter in z anyway any pages.

or replacement.

If damage occurs, return to the ETICC for repair ~8 w

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. ZAP 6-52-5 Rev. O ATTACHMENT H APR 2 71985 l

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EQUIPMENT TECHNICAL INFORMATION VENDOR REVIEW STATUS l

This Vendor ETI document has the following Vendor Review Status This ETI document has been scheduled for review by the equipment supplier. Date:

The equipment supplier is in the process of reviewing this ETI document.

Date:

The equipment supplier has reviewed this ETI document and concurs with its content. All appropriate changes have been incorporated into this ITI document by either a vendor issued revision or an appropriate notation by the station. Date:

The concurrence of the equipment supplier was not obtained because Oate:

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. m ZAP 6-52-5 Rev. O ATTACHMENT I APR 2 7 IS85 RECORD OF REVISION SHEET ETI No.:

Title:

Rev. Rev. Reason for No. Date Description of Chance Change Initial asc

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, ZAP 6-52-5 Rev. O ATTACHMENT J MR 2 7 US ETI RECALL SLIP To:

From:

Please return the following ETI within three working days:

ETI Number:

Title:

Reason for recall:

O Revision O Overdue O Replacement Recall date:

s:

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., ZAP 6-52-5 Rev. 0 APA 2 71985 ATTACHMENT L To:

Department Head From: ETICC The following ETI document by ETI Title has been submitted for control to the ETICC by Vendor

. If your department has a copy of this ETI, Department it must be turned over to the ETICC imediately so that it too may be controlled.

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FINAL.

04972 20 4