ML20127J292

Forwards Addl Info Re Generic Ltr 83-28,Items 2.2.2 & 4.5.3 & Backup Scram Valve Testing,Per NRC 850319 Request. Implementation of Nuclear Util Task Action Committee Program Re Interface W/Vendor Described in Encl Procedures

ML20127J292
Person / Time
Site:	LaSalle
Issue date:	05/16/1985
From:	Alexander, George Alexander COMMONWEALTH EDISON CO.
To:	Harold Denton Office of Nuclear Reactor Regulation
Shared Package
ML20127J297	List: ML20127J292 ML20127J304
References
0136K-28, 136K-28, GL-83-28, NUDOCS 8505210438
Download: ML20127J292 (3)

Text

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- 1 First National Plazi, Chicago, llhnois kC 7 Address Reply to: Post Office Box 767 (j . Chicago, lilinois 60690 May 16, 1985 Mr. Harold R. Denton, Director Of fice of Nuclear Reactor Regulation U.S.-Nuclear Regulatory Commission

. Washington, DC 20555

Subject:

LaSalle County Station Units 1 and 2 Response to Request for Additional Information Generic Letter No. 83-28 NRC Docket Nos. 50-373/374 Reference (a): March 19, 1985 A. Schwencer letter to D. L. Farrar.

Dear Mr. Denton:

Reference (a) requested that we provide additional information pertaining to Generic Letter 83-28, Item 2.2.2, Item 4.5.3 and backup scram valve testing. Attached are responses to those questions.

Please address any questions that you or your staff may have concerning our response to this office.

One signed original with Attachment and fifteen copies are being provided for your use.

Respectfully, s

Greg sexande 3 Nuclear Licensing Administrator 3 0 85y5 P

r cc:: RIII Inspector - LSC hO[yr I

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_ _ gem 2.2.2 i

~ Licensee.needs to present his evaluation of the-NUTAC program and describe

how..it will be. implemented at LaSalle 1, 2. This program

needs to:be supplemented because it fails to address the

establishment-and maintenance of an interface-between the licensee and all. vendors of safety-related equipment to assure that vendor technical information is.kept current,' complete,-and is incorporated

=as' appropriate _intoiplant-procedures and maintenance instructions.

'The response should also addresseconcerns about division of ,

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responsibility between licensee and their vendors who provide.

! maintenance oritesting services'to: assure that needed control is

, maintained over-procedures and maintenance instructions. -

Response

The. evaluation and implementation of the NUTAC program has been

' described by means'of the Nuclear Stations. Division (NSD) Directive MO-2,. Control 1of-Vendor Equipment Technical Information, revision 2, March 4, 1985. This directive is the~ source document from'which the

LaSalle Nuclear Station Administrative Procedure (LAP) for Control of Vendor Equipment Technical Information was' written.

~Both the Nuclear Stations' Division Directive and the LaSalle Station AdministrativeLProcedure adequately address those conditions under which' vendor' interface must be exercised and therefore established and maintained. .:

, , The NSD Directive MO-2 meets all of the requirements of the NUTAC program regarding-vendor interface and supplements,' clarifies and

-enhances:that interface where necessary. The LAP was written'in accordance with NSD Directive MO-2 and therefore addresses those conditions under which vendor interface should be exercised.

-With regard to vendors who provideLmaintenance or testing services i on's'afety-related equipment,'the. CECO Quality Assurance Manual assures:that'needed control over procedures and maintenance

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instructions is maintained by all vendors.

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-The"NSD Directive.M0-2, LAP-100-15 are enclosed for your review.

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' Item 4.5.3

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iLicensee'needsito' describe and present.the results of studies'of

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h existing or: proposed-intervals.for on-line testing of the reactor-y"

, trip system.: -Such studies shall; consider-the concerns expressed in.

sub-items E4.5.3.1-through 4.5.3.5 of the generic letter,.show how

.the' selected intervals'results in high. reactor: trip system availability, and-presents'any resulting Technical Specification

, changes forEstaff review.

p 4 Response:

LThe:BWR 0wners~ Group response _to Item 4.5.3 is embodied in report ~

NEDC-30844.. Since this: study was based on a standard RPS~which is notridentical to the LaSalle system, we cnn not formally endorse the 1studytof this time. -We are1 proceeding with an analysis of the

, ' system' differences _to determine:that the conclusions of the generic

-studyeremain'applicableito LaSalle. Therefore, we are using NEDC-30844 as'the basis-forJour response, but do not1knowEat this stimeJwhat i further stipulations are required. We anticipate that

~results framfthe' site 1 specific review will be available by

- OctoberEl,J1985. 'In the event thatLthis date exceeds 90 days from-Ethe date of the NRC's final review of NEDC-30844,1we are requesting approval of.our schedule.

The-staff finds that-modifications are not required to' permit-on-line testing of the-backup scram valves. However, the staff-

concludes that testing-of the backup scram valves (including

' initiating circuitry) at a refueling outage frequency, in : lieu of on-line testing, is appropriate and should be included in the itechnical specification surveillance requirements. The licensee

.needs to address this conclusion.

Response

The testing 'of_ the backup scram valves including initiating circuitry on anE18 month basis will.be done in conjunction with existing surveillance requirements 4.3.1.2 in the Technical Specifications.

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