NRC-95-0080, Comment on Proposed Generic Communication Re Testing of safety-related Logic Circuits

Comment on Proposed Generic Communication Re Testing of safety-related Logic Circuits

ML20086T378
Person / Time
Site:	Fermi
Issue date:	07/21/1995
From:	Goodman L DETROIT EDISON CO.
To:	NRC
References
CON-NRC-95-0080, CON-NRC-95-80, FRN-60FR27141 60FR27141-00002, 60FR27141-2, NUDOCS 9508030002
Download: ML20086T378 (2)

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July 21,1995

• NRC-95-0080 l Chief,  ;

Rules Review and Directives Branch U. S. Nuclear Regulatory Commission l

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Washington, D. C. 20555

References:

1) Fermi 2 NRC Docket No. 50-341 i NRC License No. NPF-43

2) Proposed Generic Communication; Testing of Safety-Related Logic Circuits,60 FR 27141, dated May 22,1995

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Subject:

Detroit Edison Comments on the Proposed Generic -

Communication on Testine of Safety-Related Logic Circuits The purpose of this letter is to provide Detroit Edison's comments on Reference 2, as given below:

The following modifications are suggested under " Description of Circumstances" '

to clarify the examples of details associated with this issue at Fermi 2:

e 2nd paragraph,1 Ith line, after ".. RHR pump start logic.", add a new sentence .,

"The conductors which connect the I&C and electrical portion of the circuit -

were not tested."

e 4th paragraph,10th line, at the end of the sentence "...(ECCS) logic were not being tested.", add the word " separately"

. In the beginning of the 5th paragraph replace "on November 30,1994" by "In October and November 1994"

. In the 6th paragraph delete the wording "To address.. .. deficiencies.",

appearingin the first 8 lines.

t

. 6th paragraph,14th line, change " created electrical" to "is creating electrical";

and in the 15th line change " trained" to "is training" 9508030002 950721 PDR p

ADOCK 05000341 PDR ll0 ,

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u USNRC July 21,1995 NRC-95-0080 Page 2 The review required by the " Requested Actions" section can be very extensive.

The timing can also create a large burden at a time licensees are preparing for their refueling ontage and can lead to less than comprehensive review. A 180 day time frame after the issuance of this generic letter is suggested.

In performing a review to determine adequacy oflogic circuit testing, judgments are made since criteria is not always clear. A workshop would be beneficial to share experience and practical examples gained from performing the reviews about 60-90 days after the generic letter is issued. There are a variety of acceptable ways to perform the testing, these should be shared, as well as identified unacceptable methods.

It is good that the NRC is allowing the licensees to take credit for the reviews already performed and actions already taken for addressing this issue.

If you have any questions, please contact Mr. Girija S. Shukla at (313) 586-4270.

Sincerely, W

Lynne S. Goodman Director, Nuclear Licensing cc: T. G. Colburn A. Marion(NEI)

H. J. Miller M. P. Phillips A. Vegel