ML20205G787

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Forwards Request for Addl Info Re Util 831105,840202,850612, & 860603 Responses to Generic Ltr 83-28,Items 2.1,2.2,3.1, 3.2 & 4.3
ML20205G787
Person / Time
Site: Zion  File:ZionSolutions icon.png
Issue date: 03/23/1987
From: Norris J
Office of Nuclear Reactor Regulation
To: Farrar D
COMMONWEALTH EDISON CO.
References
GL-83-28, NUDOCS 8703310541
Download: ML20205G787 (6)


Text

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March 23, 1987 r

DISTRINUTION Docket Nos. 50-295 and 50-304 6

B. Grimes NRCPOR ~^"

J. Partlow Local PDR N. Thompson PD#3 Rdg.

ACRS(10)

T. Novak C. Vogan l

Mr. Dennis L. Farrar OGC J. Norris F

Director of Nuclear Licensing E. Jordan S. Varga k

Connonwealth Edison Company Post Office Box 767 Chicago, Illinois 60690

Dear Mr. Farrar:

SUBJECT:

ZION NUCLEAR POWER STATION, UNITS 1 AND 2 - REQUEST FOR ADDITIONAL INFORMATION FOR ITEMS 2.1, 2.2, 3.1, 3.2 and 4.3 0F GENERIC LETTER 83-28 The Commonwealth Edison Company responded to Items 2.1, 2.2, 3.1, 3.2, and 4.3 of Generic Letter 83-8 by letters dated November 5, 1983, February 2, 1984, June 12, 1985 and June 3, 1986. Our review of these responses indicates additional information is needed, as described in the enclosed Request for Additional Information, in order for the staff to determine that the licensee's programs acceptably meet the staff position of Generic Letter 83-28.

The reporting and/or recordkeeping requirements of this letter affect fewer than ten respondents; therefore, OMB clearance is not required under PL 96-511.

Sincerely, Jan A. Norris, Project Manager Project Directorate #3 Division of PWR Licensing-A

Enclosure:

As stated cc: See next page f

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- Mr. D. L. Farrar Commonwealth Edison Company Zion Station CC:

Robert J. Vollen, Esquire Mr. Michael C. Parker, Chief 109 North Dearborn Street Division _ of Engineering Chicago, Illinois 60602 Illinois Department of Nuclear Safety Dr. Cecil Lue-Hing 1035 Outer Park Drive, 5th Floor Director of Research and Development Springfield, Illinois 62704 Metropolitan Sanitary District of Greater Chicago 100 East Erie Street Chicago, Illinois 60611 Mr. P. Steptoe Isham, Lincoln and Reale Counselors at Law Three First National Plaza Sist Floor Chicago, Illinois 60602 Mayor of Zion Zion, Illinois 60099 Illinois Department of Nuclear Safety ATTN: Manager, Nuclear Facility Safety 1035 Outer Park Drive, 5th Floor Springfield, Illinois 62704 U.S. Nuclear Pegulatory Commission Resident Inspectors Office 105 Shiloh Blvd.

Zion, Illinois 60099 i

Regional Administrator, Region III U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137

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i I M REQUEST FOR ADDITIONAL INFORMATION ITEMS ?.1 (PART 21, 2.2 (PART 11, 3.1.3, 3.7.3 AND 4.3 T.S.

OF GENERIC LETTER 83 78 ZION NUCLEAR PLANT, UNITS 1,7 Review of the licensee's response dated November 5,1083; February ?,1984;

.1une 12, 1985; and slune 3, 1986 for items 2.1 (Part ?), 2.? (Part 1), 3.1.3, 3.2.3 and 4.3 T.S. of Generic Letter R3-28, discloses the need for additional information as follows:

A.

Iten 2.1 (Part ?) " Vendor interface (Reactor Trio System Components)"

Our review of the licensee's submittals indicates that the licensee has identified an interface with their nuclear steam supply systen vendor. However we are k

unable to determine that the licensee's vendor interface program encnnpasses a periodic and continuing feedback mechanism.

Item ?.1 (Part ?) states that the vendor interface program shall include periodic communication with vendors to assure that all applicable information has baen received. The licencee should describe how their program assures that all relevant material is received, properly evaluated, implemented and maintained during the life of the plant.

B.

Iten 2.2 (Part 1) " Equipment Classification (prooran For All Safety Related Components)"

iten ?.?.1.3 - Ilse of the Eouipment Classification Listing The licensee's responses imply that there are some activities performed on safety-related components that may not be considered safety-related.

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The licensee should clearly identify what activities on safety-related systens may not be considered safety-related and describe the controls which govern these activities.

Item 2.2.1.4 - Management Controls The licensee's responses have not clearly identified how management verifies that the procedures for preparation, validation and routine utilization of the information system have been followed.

The licensee should confirm that their program encompasses continuing man-agement control over the procedures utilized for preparation, validation and utilization of the information handling system.

C.

Items 3.1.3 and 3.2.3 " Post Maintenance Testing" Items 3.1.3 and 3.?.3 of Generic Letter 83 28 require licensees and applicants to identify, if applicable, any post-maintenance test re-quirements in existing Technical Specifications which are perceived to degrade rather than enhance safety.

Item 3.1.3 pertains to reactor trip system components, item 3.2.3 to all other safety-related components.

The licensee's November 5,1983 response states for item 3.1.3 that no present post-maintenance testing requirements are known to degrade safety.

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1 However,'the proposed shunt trip modification for the Reactor trip breakers could become a problem due to increased breaker cycling unless the test frequency is changed to quarterly.

The licensee is evidently confusing the requirements of Items 3.1.3 and 3.?.3 for an evaluation of post-maintenance testing required by the Technical Specifications with the requirements of Item 4.5.3 for evaluating intervals for on-line functional testing and with the requirements of Generic Letter 84-15 regarding surveillance and functional testing of diesel genera tors.

Items 3.1.3 and 3.2.3 of Generic Letter 83-28 are restricted to post-maintenance testing of the reactor trip system and other safety-related components required by the Technical Specifications.

For Item 3.2.3, the licensee states in their November 5,19R3, response and again in their June 3,1986, response that the present Technical Specifica-tions coupled with the Zion confirmatory order of 2/29/80 have an adverse

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effect on diesel generator reliability due to less and less time allowed to j

perform maintenance on individual engines. We find that the part of the 2/?9/80 confirmatory order pertaining to diesel generator testing, Item R.6, i

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4 is not within the scope of Item 3.2.3 of Generic Letter 83-28 because Item 3.2.3 pertains to post-maintenance testing. Therefore, the licensee may want to submit a separate request to have Item B.6 lifted from the 2/29/80 confirmatory order.

The licensee has not specifically stated whether their review of the post-maintenance test requirements contained in their Technical Specifications for the reactor trip system and other safety-related components disclosed any post-maintenance testing requirements that may degrade rather than enhance safety.

The licensee should state that they have reviewed their post-maintenance test requirements and found none that would degrade safety.

D.

Itert.4.3 T.S. Technical Specification Changes The licensee has not submitted proposed Technical Specification changes in accordance with Generic Letter 85-09 and Item 4.3 of Generic Letter 83-28.

The licensee needs to submit proposed Technical Specification changes con-sistent with Generic Letter 85-09 for the automatic trip logic and the reactor trip breakers.