ML20209F694

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Provides Addl Comments on Revised Insp Procedures 50095, Spent Fuel Storage Racks & 37700, Design,Design Changes & Mods, Per 860813 Request & 860828 Initial Response
ML20209F694
Person / Time
Issue date: 09/05/1986
From: Norelius C
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To: Partlow J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
References
NUDOCS 8609120232
Download: ML20209F694 (2)


Text

O su 6 at MEMORANDUM FOR: James G. Partlow, Director, Division of Inspection Programs, Office of Inspection and Enforcement FROM:

Charles E. Norelius, Director, Division of Reactor Projects, Region III

SUBJECT:

COMMENTS ON MC 2515 INSPECTION PROCEDURES 50095 AND 37700 By memorandum dated August 13, 1986 you requested Region III to review and comment on 2 revised inspection procedures (IP), 50095, " Spent Fuel Storage Racks", and 37700, " Design, Design Changes, and Modifications". Region III initially responded by memorandum dated August 28, 1986. Since that time, however, we have conducted additional reviews of these IP's and offer the following additional comments:

1.

IP 37700:

a.

The list of systems in section 2.01a should be expanded to include non-safety related mechanical systems whose failure could result in adverse environmental conditions (eg HELB, flooding) and non-safety related electrical / instrumentation systems whose failures could compromise safety related electrical systems due to a lack of physical separation, lack of isolation, or the imposition of excessive loads, b.

An inspection requirement should be added to assess the licensee's mechanism for controlling multiple modifications to the same system / component.

Recently, a Region III licensee failed to do this adequately with the result that a second modification made to a diesel generator control circuit invalidated a prior modification due, in part, to the fact that the drawings used to design the second modification did not reflect the first modification.

In this case, the second modification package was prepared before the first modification was implemented.

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2.

IP 50095:

a.

A requirement should be added to. ensure that the licensee has implemented any vendor-recommended preventive maintenance and/or periodic tests and inspections.

As always, Region III appreciates the opportunity to participate in inspection program enhancements. We apologize for any inconvenience our multiple responses may have caused you in this instance.

If you have any questions regarding the comments enumerated above, please contact W. Guldemand (FTS 388-5574) of my staff.

" Original Sfgned by E.G. Grcer.:un" Charles E. Norelius, Director Division of Reactor Projects cc:

D. Cooper, IE C. W. Hehl, RIII RIII RIII fjf Guife'mond/as Noreli s 09/r/86 09/ Y86

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