ML20203D374

Highlights Items from Confirmatory Order Forwarded by HR Denton Which Are Completed & Closed Out or Superseded by Addl Regulatory Action.Summary of Info Presented & List of Refs Also Encl

ML20203D374
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	04/18/1986
From:	Leblond P COMMONWEALTH EDISON CO.
To:	Harold Denton Office of Nuclear Reactor Regulation
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-3.A.2.1, TASK-3.A.2.2, TASK-TM 1515K, NUDOCS 8604220092
Download: ML20203D374 (13)

Text

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^xOCommonwealth Edison

,) One First National Plaza. Chicago. Ilknots

( O 7 Addr:ss Reply to: Post Office Box 767 (j Chicago lilinois 60690 April 18, 1986 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Comission Washington, DC 20555

Subject:

Zion Nuclear Power Station Units 1 and 2 Zion Confirmatory Order dated Feb. 29, 1980

, NRC Docket Nos. 50-295 and 50-304 References (a): November 18, 1985 letter from Cordell Reed to H. R. Denton.

(b): February 29, 1980 letter from H. R. Denton to D. L. Peoples.

Dear Mr. Denton:

Reference (a) contained Commonwealth Edison's request to delete the Zion Confirmatory Order which was transmitted with Referenc.e (b). Subsequent discussions with members of your staff have resulted in the need to highlight Order items with two distinct characteristics.

The first set of Order items are those issues that have been completed and are closed out. The status of these items is discussed in Attachment 1. The second group consists of order items that have been superseded by additional regulatory action since the issuance of Reference (b). These items are discussed in Attachment 2.

Attach.nent 3 contains a summary of the information presented in Attachments 1 and 2. Attachment 4 transmits a listing of the references utilized in this letter.

If any further questions arise regarding this matter, please contact this office.

Very truly yours, P. C. LeBlond Nuclear Licensing Administrator cc: Region III Inspector - Zion J. A. Norris - NRR II 1515K B604220092 860410 PDR ADOCK 05000295 F PDR

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ATTACHMMrr 1 CLOSED ORDER ITEMS A.1 " Maintain reactor power level as necessary such that calculated fuel peak clad temperature does not exceed 20500F under large break LOCA conditions per the 10 CFR 50 Appendix K analysis submitted on October 22, 1979."

Status: This order item was deleted with the issuance of License Amendments No. 91 and 81. These amendments were transmitted with Reference (1).

A.2 " Revise plant operating procedures as necessary to require a base load mode type of operation only, without load following except for power reductions required to maintain system load for grid stability, required for maintenance (e.g., containment entry, main feed pump repairs, etc.) or as required by Technical Specifications."

Status: This order item was deleted with the issuance of License Amendments No. 91 and 81. These amendments were transmitted with Reference (1).

A.6 " Submit not later than March 1, 1980, the results of a review of possible permanent plant modifications and procedures to further reduce the potential of a severe reactor accident and resultent radiation releases."

Status: Commonwealth Edison provided this study within the time frame requested. This information was transmitted in References (2) and (3). It was later supplanted by the Zion Probabilistic Safety Study which was supplied in Reference (4) and reviewed by the NRC in Reference (5).

A.7 " Require that all reactor operators and senior reactor operators conduct simulator training and in-plant walk-through of the following emergency procedures. (Proceduros listed)."

Status: The specified training was completed within the time frame required as described in Reference (2).

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f B.2 "To ensure control room habitability under accident conditions, the licensee shall reexamine ventilation intakes, location of potential plant leakage (ingress and egress), and control room filter capabilities, and submit the results of this review to the NRC."

Status: The required reviews were provided to the NRC in Reference (6) and later under the subject of NUREG-0737 Item III.D.3.4. The NRC closed this order item out in Reference (7).

B.4 "The licensee shall comply with the NRC's " INTERIM POSITION FOR CONTAINMENT PURGE AND VENT VALVE OPERATION PENDING RESOLUTION OF ISOLATION VALVE OPERABILITY", as contained in the October 1979 letter to the licensee. The licensee committed to this position in its December 14, 1979 letter to the NRC."

Status: Reference (8) stated that this order item should be followed until the issuance of an SER and tech specs pertaining to this issue. Reference (9) transmitted the NRC's SER and Reference (10) contained Commonwealth Edison's submittal of tech specs governing this issue.

B.7 "R2quirements regarding reactor operator qualifications shall be revised to incorporate the following for applications submitted af ter June 1, 1980 except for training classes in session at the time of issuance of this Order: (Requirements listed)."

Status: Commonwealth Edison documented the revision of the requirements in Reference (6). The NRC characterized Commonwealth Edison's response to this issue as acceptable in Reference (11). In addition, Zion Station received INPO accreditation for the reactor operations area on September 25, 1985. This will further ensure the high quality training at Zion Station in the future.

B.8 " Requirements regarding reactor operator qualifications shall be revised such that all operator licensees shall participate in periodic retraining and recertification on a full scope simulatory representative of Zion Units 1 and 2. The frequency of training will be on an annual basis."

Status: Commonwealth Edison provided these commitments in Reference (6). The NRC stated that our response was acceptable in Reference (11). In addition, the INPO accreditation discussed above also addresses these elements. Commonwealth Edison has recently revised its program for Operator Requalification under NUREG-0737 Item I.A.2. Reference (12) documented the NRC's approval of this continuing Corporate program.

C.1 " Review the steady state steam generator operating level to determine the optimum steady state level for the purpose of maximizing dryout time with due consideration for overfilling. The results of this study shall be provided to the NRC."

Status: The results of this review were supplied in Reference (13).

Reference (14) accepted these results and informed Commonwealth Edison that the NRC considered this issue to be completed.

C.2 " Evaluate possible co-impregnation of the charcoal in the plant's air effluent filtration systems with KI and I2 and an amine such as TEDA (triethylene-diamine) to improve the iodine removal capability of these systems. The results of this review shall be submitted to the NRC."

Status: The results of Commonwealth Edison's review was reported to the NRC in reference (13). Reference (15) documented the NRC's acceptance of these results and closed this Order Item out.

C.3 " Evaluate effects on plant systems stability if power is reduced as much as 50%, treating power as a parameter. (For example, the effects on the feedwater flow automatic control)."

Status: Commonwealth Edison provided this evaluation in Reference (13).

D.2 "The licensee shall establish.a temporary on-site inter-dicciplinary review group consisting of, as a minimum, representatives from the architect-engineer and the plant maintenance and operations staffs.

This group shall review and concur in all existing plant emergency procedures. Emergency changes may be approved in accordance with current licensee requirements, but shall be subsequently submitted for approval by the review group."

Status: Reference (16) provided Commonwealth Edison's commitment to establish this temporary group. Reference (17) provided Commonwealth Edison's procedure generation package to the NRC. Zion Station's revised emergency operating procedures became effective on December 31, 1985.

E.1 "The licensee shall examine key plant system vulnerability areas and possible operator dependent areas with the intent of maximizing the reliability in the subject areas. Specifically, the licensee shall:

a. Verify that the sump for ESF recirculation is free of debris and determine if flow test verification was initially performed. If not performed, explore means to verify. Review existing proce-dures and training on recirculation alignment and RWST refill.

b. Review administrative check and verification procedures for assuring that the two single failure points (manual) valves in AFWS supply line are in the correct position.

c. Impose an administrative order requiring expeditious shutdown whenever an independent train of the auxiliary feedwater system and any one of the following are inoperable: All backup sources of offsite power, one of the two diesel generators supplying power to the other independent train or either of the other trains of the auxiliary feedwate system.

d. Develop station blackout procedures addressing:

1. grid dispatcher actions

11. reactor operator actions 111. diesel generator repairs.

e. Assure that DC-powered lighting is available at the steam-turbine driven auxiliary feedwater pump,

f. Review causes for, and procedures and operator training required to diminish, the overall number of reactor and main feedwater trips.

g. Develop or review procedures to restore main feedwater promptly after a trip and to mitigate the consequences of an ATWS event (e.g. emergency boration and CVCS control).

h. Review administrative controls on the manual valve (s) whose misalignment could fall all ECCS."

Status: Commonwealth Edison provided the results of this review in Reference (18).

F.1 " Conduct a review of past Licensee Event Reports (LERs) at Zion Units 1 and 2. These LERs shall be reviewed to identify design inadequacies (common mode failures, systems interactions, etc.), procedural and training inadequacies, and man-machine / human factor inadaquacies.

Recommendations shall be submitted for correction of the base cause of the subject LZRs. Immediate corrections of deficiencies will be made when possible, with the required notifications to be made to the NRC."

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l t I Status: Commonwealth Edison provided the required review of past Licensee Event Reports at Zion Station within the appropriate time frame. This review was supplied in Reference (19). The NRC documented its review of this report in Reference (20).

F.3 " Conduct a study to determine and document the method by which its l plants comply with current safety rules and regulations, in particular those contained in 10 CFR Parts 20 and 50."

l Status: Commonwealth Edison provided the required study in Reference (19). The NRC documented its review of this study and closed this item out in Reference (21).

F.4 " Evaluate the reliability and failure modes of selected systems /

components as follows:

! a) Failure Mode Effects Analysis: Examine the failure modes (random failures and consequences of outages in support systems) of the active components on the reactor coolant pressure boundary.

Assess the acceptability of these failure modes.

b) Implement Failure Mode Effects Analysis for minor departures from operating, maintenance and emergency procedures.

c) Explore ways to inprove the reliability of those components with a particularly high failure rate as delineated in NUREG/CR-1205."

status: Commonwealth Edison provided the requested evaluation within the required time period in Reference (19). In addition, Reference (4) provided the NRC Staff with the Zion P: )babilistic Safety Study. Reference (5) documented the NRC's review of the Zion PRA.

F.5 " Attain full compliance with NRC letters concerning AFWS reliability improvements."

Status: Commonwealth Edison provided information regarding this issue in Reference (19). Reference (22) issued Zion License Amendments No. 80 and 70. In addition, Reference (22) formally closed out Item F.5.

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r ATTACIGIENT 2 ORDER ITEMS SUPERSEDED BY OTHER REGULATORY ACTION A.4 " Maintain at least two senior reactor operators (SR0s), one of whom may be shift supervisor, in the control room at all times during power operations or hot shutdown, except that the shift supervisor shall be allowed to leave the immediate vicinity of the control room as duties may require, provided he is available to respond to an emergency by returning to the control room within ten minutes. The shift or watch supervisor's office is considered part of the control room."

status: Reference (2) contained Commonwealth Edison's notification of its compliance with this issue. Subsequently 10 CFR 50.54.M.2.i. and ill have been issued which address this issue.

A.5 " Conduct testing to assure that LPI/RHR check valves are in fact installed correctly and functioning as prissure isolation barriers when the plant is at pressure and produelag power. Verification of valve operability shall be performed prior to plant restart if shutdown at the time of issuance of the Order and thereafter whenever RCS pressure has decreased to within 100 psig of RHR system design -

pressure."

Status: Reference (2) supplied Commonwealth Edison's commitment to comply with this testing requirement. Commonwealth Edison's commitment to the continued performance of these leak tests has been restated since that time. Reference (23) supplied the most recent Corporate commitment to the continued performance of these tests.

B.3 " Emergency action levels shall be revised to require notification of the NRC for all eveints in the emergency classes described in NUREG 0610, September 1979."

Status: Reference (6) supplied the NRC with notification that this requirement has been implemented. Subsequently, 10 CFR 50.47, 50.72, and 10 CFR 50 Appendix E have been issued which address this same requirement.

B5 " Plant personnel shall be trained or retrained in the following areas within thirty days, or prior to startup if required by the Lessons Learned implementation schedule. Plant personnel shall also be retrained in the following areas within thirty days of the time that there are significant changes to the procedures or requirements j applicable to these areas: (areas listed)"

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r Status: Reference (6) supplied the NRC with notification that all shift personnel had been trained. Reference (11) contained the NRC's statement that this issue is not outstanding. In addition, Reference (12) transmitted th*' NRC's approval of Commonwealth Edison's revised topical ceport governing Licensed Operator Requalification. This report contains similar requirements to those of B.5 and require that the training be completed within sixty days. Thus, this item will continue after the formal deletion of Item B.S.

C.4 " Submit a schedule to implement the ATWS instrument modification justified in accordance with the Westinghouse analytical results contained in the letter from T. N. Anderson to S. H. Hanauer in NS-TMA-2182 dated December 30, 1979."

Status: The Commission has issued 10 CFR 50.62 to address the required actions to deal with the ATWS issue. This regulation was codified subsequent to the issuance of the Confirmatory Order and will continue after the Order's deletion.

D.1 "The licensee shall establish the on-site emergency preparedness manning levels on each shift as contained in Table 1 attached to this Appendix."

Status: Reference (16) documented the establishment of the required manning levels within the time frame alloted by the Confirmatory Order. The Regulatory Requirements for Emergency Preparedness were later codified in the Federal Regulations by the issuance of Appendix E to 10 CFR 50. In addition, the issue was also addressed by NUREG-0737 Item III.A.2.1. The NRC concluded that Commonwealth Edison's Emergency Preparedness capabilities were adequate in Reference (24) and closed out Item III.A.2.1.

E.2 "A review of control room emergency procedures shall be conducted for the purpose of improving these procedures from a human factors engineering standpoint. Improvements which can be attained by modifying procedures shall be implemented within the 120 days.

Control room displays shall also be reviewed for the purpose of identifying improvements which will increase the operators' ability to assess plant conditions. A report will be submitted to the NRC to describe the improvements recommended and the schedule for their implementation."

Status: Reference (18) provided the NRC with Commonwealth Edison's review of the Zion Station cont;ol room. In addition, Reference (25) transmitted NUREG-0737, Supplement 1 to Commonwealth Edison. Included in this document was a requirement to conduct a Detailed Control Room Design Review (DCRDR). A Zion DCRDR Summary report and implementation schedule will be transmitted by May 1, 1986 in compliance with the requirements of Reference (25). The requirements of Reference (25) will remain in effect following the deletion of Order Item E.2.

F.2 " Meet meteorological acceptance criteria for emergency preparedness contained in Annex 2 to this Appendix, pending necessary equipment deliveries and installation (including computer hardware and soft-ware modifications). During the interim period while modifications are being completed, real time forecasting will be available and provided by a consultant."

Status: Reference (19) transmitted Commonwealth Edison's Off-Site Dose Calculation Manual (ODCM). In addition, the require-ments for meteorological assessment capability were later addressed by NUREG-0737. Item III.A.2.2. This item was also included in Reference (25). Reference (25) will remain in effect following the formal deletion of Order Item F.2.

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ATTACHMENT 3

SUMMARY

OF ATTACHMENTS 1 AND 2 CLOSED ORDER ITEMS ITEM BRIEF DESCRIPTION A.1 2050*F PCT A.2 Base load A.6 Plant modification review A7 Operator walk-throughs B.2 Control Room Habitability Review B.4 Purge and Vent restrictions B.7 Reactor Operator qualifications B.8 Simulator retraining for operators C.1 Steam Cenerator level review

• C.2 Air filtration review C.3 Plant stability review D.2 On-site procedure review group E.1 Plant vulnerability review F.1 Past LER review F.3 10 CFR compliance review F.4 Failure mode evaluation t f

f F.5 Aux. Feedwater improvements

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SUPERSEDED ORDER ITENB ITEM BRIEF DESCRIPTION A.4 Two SR0s in Control Roont A.5 RHR Check Valve Testing B.3 Emergency reporting levels B.5 Plant personnel retraining C.4 ATWS modifications D.1 Emergency manning levels E.2 Human Factor procedure review F.2 Meteorological capability 1515K

ATTACHpINT 4 REFERENCE DESCRIPTION

1. 12/31/85, JA Norris to DL Farrar Transmitted license amendment Nos. 91 and 81 which deleted A.1 and A.2. l

2. 3/28/80, WF Naughton to HR Denton Ceco response to Immediate Action Order  ;

Items.

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3. 2/25/80. DL Peoples to HR Denton Submitted results of modification review as required by Item A.6.

4. 9/08/81, LO DelGeorge to HR Denton CECO transmitted Zion's PRA.

5. 8/26/85 SA Varga to DL Farrar NRC transmitted staff review of Zion's PRA.

6. 3/28/80, WF Naughton to HR Denton Ceco response to 30-day order Items.

7. 6/25/82, SA Varga to LO DelGeorge NRC closure of Order Item B.2 based upon III.D.3.4.

8. 8/14/80. TH Novak to DL Peoples NRC requests information and provides B.4 closure conditions.

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9. 4/03/84, SA Varga to DL Farrar NRC SER on containment purge valves. i

10. 2/21/86, PC LeBlond to HR Denton Ceco submittal of Technical Specifica- l tions governing purge / vent.

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11. 10/31/80, SA Varga to JS Abel NRC closure of Order Items B.7 and B.8.

12. 1/27/86, JA Zwolinski to DL Farrar NRC SER on CECO's revised Licensed j Operator Requalification Topical Report.

13. 4/25/80, DL Peoples to HR Denton Ceco response to 60-day Order Items.

14. 12/18/80, SA Varga to JS Abel NRC closure of Order Item C.l.

15. 1/15/81 SA Varga to JS Abel NRC closure of Order Item C.2.

16. 5/28/80. DL Peoples to HR Denton CECO response to 90-day Order Items.

17. 12/28/84, RN Cascarano to HR Denton CECO transmittal of Emergency Procedure Generation Package.

18. 6/25/80, WF Naughton to HR Denton Ceco response to 120-day Order Items.

19. 8/29/80 WF Naughton to HR Denton Ceco response to 6-month Order Items.

20 3/27/81, SA Varga to LO DelGeorge NRC closure of Open Item F.1.

21. 11/05/81, SA Varga to LO DelGeorge NRC closure of Open Item F.3.

22. 1/21/83, SA Varga to LO DelGeorge Transmitted license amendment Nos. 80 and 70, and closed Order Item F.5.

23. 11/19/85 G Reed to HR Denton CECO's comments on NRC staff's review of Zion's PRA.

24. 5/16/83, SA Varga to DL Farrar NRC closure of NUREG-0737. Item III.A.2.1.

25. 6/12/84, SA Varga to DL Farrar Confirmatory Order regarding NUREG-0737

- Supplement 1.

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