ML20150B606

Ack Receipt of 880525 Response to Noncompliance Noted in NRC .Proposed Time Tables for Addressing Procedures to Encompass safety-related Fire Barriers,Emergency Lighting & NFPA Code Review Unsatisfactory

ML20150B606
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	07/06/1988
From:	Miller H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Reed C COMMONWEALTH EDISON CO.
Shared Package
ML20150B607	List: ML20150B606 ML20150B621 ML20150B627
References
NUDOCS 8807120087
Download: ML20150B606 (2)

Text

• '~

y- . .,

,- , , o

.. g ...

JUL 6 1988 r

Docket No. 50-295 Docket No. 50-304 f

Comonwealth Edison Company

-ATTN:' Mr. Cordell Reed-Senior Vice President t Post Office Box 767 i Chicago, IL 60690  !

Gentlemen:  !

Thank you for your letter dated May 25, 1988, in which you responded to the -

four items of noncompliance which we brought to your attention in our letter ,

dated April 8, 1988. In view of the discussions we had-with your staff in February, we were disappointed in your proposed time tables for addressing.

several of the items identified in the NRC report, specifically the items concerning procedures to encompass safety-related fire barriers, emergency lighting, NFPA code review, update of fire hazard analysis and Technical -

Specification changes. While your letter acknowledged two items as  ;

violations of NRC requirements, you requested that the other two-items be  !

withdrawn. We have reviewed your response carefully and have discussed the violations and your response with NRR. After due-consideration, the NRC has  ;

reached the following conclusions: j

1. Noncompliance 295/87034-08; 304/87035-08 documented a failure on your~  !

part to perform visual inspections on safety-related fire walls which  !

separate the auxiliary building from the turbine building. We have i reviewed the information in your response and still believe this is an l example of noncompliance. ,

Your response states that those portions of the G-Wall not currently  !

addressed by surveillance procedures are not the "barriers protecting l safety-related areas" specified in Technical Specification 4.21.6. l This appears to be contrary to the Zion 1984 Safe Shutdown Capability  !

Reassessment which identified the G-Wall as a fire wall protecting  ;

safety-related areas. It appears that you have utilized the 1977 Fire <

Hazards Analysis and not incorporated the 1984 Safe Shutdown Capability  ;

assessment in your surveillance procedures. You should be aware of the i NRC letter tc Commonwealth Edison Company (CECO), dated December 21, 1983,  !

which responded to the CECO letter (November 21, 1983) requesting a ,

schedule exemption for certain Appendix R requirements. This NRC letter  !

stated that both Zion units would be in violation of 10 CFR 50.48(c) l requirements for the period of time extending from expiration of the  ;

existing deadline until NRC approval was granted for a revised Appendix R  !

schedule. This letter further stated that the MRC expected that, during this period, CECO would take all possible interim measures to compensate l

8807120087 080706 ~

4 DR ADOCK 05000295  ;

g PNU I t l WN

, . v Commonwealth Edison Company 2 JUL 6 1988 for the lack of' compliance with Appendix R er enforcement action could

, be taken. It is the NRC's position that these interim measures included the upgrading of fire protection procedures to meet the required goals of.

your 1984 Safe Shutdown Capability Reassessment, Therefore, we request.

that you provide a written response within ' thirty days of receipt of this letter describing the measures that you have taken or plan to take to revise your surveillance procedures to include the safety-related fire walls which separate the auxiliary building from the turbine building.

Your response should also include the interim compensatej measures you will take until the revisions to the surveillance procedures are completed.

2. Violation 295/87034-17; 304/87035-17 documented a failure of the licensee to complete a license condition that required an approved electric motor driven pump controller which conformed to the requirements of NFPA 20. Your response acknowledged this item as a noncompliance but requested the NRC to withdraw the item since it was licensee -identified. We have reviewed your response and have concluded that the noncompliance will not be retracted.

The basis for this conclusion is the amount of time this condition existed and the number of opportunities that were available for this item to be identified and corrected. However, the corrective actions identified in your response are acceptable and no further response to this noncompliance is required.

, Your cooperation with us in addressing these issues is appreciated.

Sincerely, Cri;;r.a1 Sigacd by J. J. Ibrri:en i t.}

H. J. Miller, Director Division of Reactor Safety cc: T. J. Maiman, Vice President,

PWR Operations H. Bliss, Nuclear Licensing Manager G. J. Pliml, Station Manager 4

cc w/1tr dtd 5/25/88:

Jan Norris, LPM, NRR DCD/DCB (RIDS)

Licensing Fee Management Branch Resident Inspector, RIII Richard Hubbard J. W. McCaffrey, Chief, Public .

Utilities Division l Nayor, City of Zion RIII R II RIII RIII III R11 RI v H)1mes/j k G r ner nds F Gr e Ku H rison MTller 07/05/88 07/ f/88 07/0S/88 07hl/88 07/(o/88 07/ 7 /88 07/db/88 07/oW88'

W4%

i

_ _ _ _ _ . _ _ _ _ _ _ _ . _ . _ _ . _ _ _ _ _ _ _ _ _ . _ . . _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ . _ _ _ . _ .