A980025, Discusses Applicable Regulations,Disposition of Commitments & Sys Required Following Permanent Shutdown & Defueling of Plant.Listing of Commitments Encl

Discusses Applicable Regulations,Disposition of Commitments & Sys Required Following Permanent Shutdown & Defueling of Plant.Listing of Commitments Encl

ML20217Q550
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	03/30/1998
From:	Brons J COMMONWEALTH EDISON CO.
To:	Beach A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
ZRA980025, NUDOCS 9804130012
Download: ML20217Q550 (5)

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U. S. Nuclear Regulatory Commission Region 111 DNMS PAO 801 Warrenville Road ORMA  ;

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Subject:

Applicable Regulations, Disposition of Commitments, and Systems Required Following Permanent Shutdown and Defueling of Zion Units 1 and 2 Zion Station Units 1 and 2 Facility Operating Licenses DPR-39 and DPR-40 NRC Docket Nos. 50-295 and 50-304

References:

1) Letter from O. D. Kingsley, Comed, to U.S. NRC, dated February 13, 1998, Certincation of Permanent Cessation of Operations

2) Letter from O. D. Kingsley, Comed, to U.S. NRC, dated March 9, 1998, Certi6 cation of Permanent Fuel Removal

3) Nuclear Energy Institute guidance document dated December 19, 1995," Guidelines for Managing NRC Commitments," Revision 2

4) SECY-95-300, from J. M. Taylor, NRC Executive Director for Operations, to the NRC Commissioners, dated December 20,1995, concerning Nuclear Energy Institute guidance document " Guidelines for Managing NRC Commitments" l

5) Letter from D. M. Crutchneld, NRC to J. F. Colvin, Nuclear Energy i Institute, dated January 24,1996, Endorsement of NEl's " Guidelines for Managing NRC Commitrnents," Revision 2 9

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This letter addresses three issues related to the permanent shutdown and defueling of I

/ l Zion Station Units 1 and 2. These issues concern changes in the applicability of certain j regulations, the disposition of previous commitments, and identincation of systems that

[ j are clearly not needed to support the long term storage ofirradiated fuel in the spent fuel j pool. $

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- ,' ZRA980025 Page 2 of 4 Chances in the Annlicability of Certain Reculations As specified by 10 CFR 50.82(a)(1), Comed has provided ;'eferences 1 and 2) certification of permanent cessation of operation and certification of permanent fuel removal at Zion Station. In accordance with rule changes published by 61 FR 39278, dated July 29,1996, certain sections and appendices of 10 CFR 50 are not applicable to plants that have submitted these certifications. Accordingly, Comed considers that compliance with the 10 CFR 50 sections and appendices tabulated below is no longer required for Zion Station.

Non-applicable Portion of Rendered Non-10 CFR 50 Title applicable by:

50.44 Standards for Combustible Gas Control Systems in 50.44(a)(3)

Light-Water-Cooled Power Reactors i 50.46 Acceptance Criteria For Emergency Core Cooling 50.46(a)(1)(i)

Systems For Light-Water Nuclear Power Reactors 50.49 Environmental Qualification of Electric Equipment 50.49(a)  ;

important to Safety for Nuclear Power Plants 50.61 Fracture Toughness Requirements For Protection 50.61(b)(1)

Against Pressurized Thermal Shock Events 50.62 Requirements for Reduction of Risk from 50.62(a)

Anticipated Transients Without Scram (ATWS)

Events for Light-Water-Cooled Nuclear Power Plants Appendix G Fracture Toughness Requirements 50.60(a)

Appendix 11 Reactor Vessel Material Surveillance Program 50.60(a)

Requirements Appendix J Primary Reactor Containment Leakage Testing for 50.54(o)

Water-Cooled Power Reactors Appendix K ECCS Evaluation Models 50.46(a)(1)(i)

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, ZRA980025 Page 3 of 4 i

The rule changes published by 61 FR 39278 also allow licensees of permanently shutdown and defueled plants to significantly reduce the scope of two programs required by 10 CFR 50. These are the Fire Protection program required by 10 CFR 50.48 and the Maintenance Rule program required by 10 CRFR 50.65. Comed is evaluating the

, existing Zion Station programs and may initiate changes in accordance with the l requirements of 10 CFR 50.48(f) and 10 CRFR 50.65(a)(1).

Disposition of Previous Commitments l

l The Zion Station commitment tracking system contains approximately 400 commitments made by Comed to the NRC in previous correspondence. Many of these commitments may no longer be relevant with both units permanently shutdown and defueled. Comed intends to evaluate these commitments and notify the NRC of changes to commitments in accordance with the methodology and criteria developed by the Nuclear Energy Institute, as described in Reference 3. This methodology has been determined to be acceptable by the NRC Staff as documented in References 4 and 5.

Structures. Systems. and Comnonents Not Needed for Lone Term Storace of Fuel Comed has begun identifying those systems that directly affect the safe storage and handling of nuclear fuel. Although this process has not been completed, Comed has j identified certain systems that are clearly not needed for the safe storage and handling of nuclear fuel and are not needed to support planned operation'of the main generators as synchronous condensers. These systems are listed below for information. Comed is using this list for guidance in determining work priorities and allocation of resources.

t BD Steam Generator Blowdown CD Condensate (except for the Condensate Storage Tank)

CR Control Rod Motor Generators, Switchgear, and Reactor Trip Breakers CR Control Rods and Drives CS Containment Spray DT Reactor Coolant Drain Eli Turbine EllC ES Extraction Steam FS Feedwater Turbine Supervisory FW Auxiliary Feedwater i FW Main Feedwater llD lleater Drain l

j llM Miscellaneous IIcater Drains l

lIR Moisture Separator / Reheaters j IC Incore Systems  !

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L.L Loose Parts Monitoring MS Main Steam ,

NR Nuclear Instrumentation PP Penetration Pressurization RC Reactor Coolant Ril Residual lleat Removal RP Reactor Protection RV liydrogen Monitors SI Safety Injection TC Thermocouples (Reactor)

Attached is a listing of the commitments contained in this submittal. Please direct any questions you may have concerning this submittal to this office.

Respectfully, m -

ohn C Brons ite Vice President Zion Nuclear Station Attachments cc: NRC Document Control Desk - Washington DC Zion Station Project Manager - NRR L Senior Resident Inspector - Zion Station Office of Nuclear Facility Safety - IDNS IDNS Resident Inspector k Niegroup\ shut-dw n\ reg-info \R3-info l . doc c

l..o Attachment to ZRA980025 Page1of1 l List of Commitments Identified in ZRA980025 t

The following table identifies those actions committed to by Comed in this document. Any other actions discussed in this submittal represent intended or planned actions by Comed. They l are described to the NRC for the NRC's information and are not regulatory commitments. Please notify Mr. Robert Godley, Zion Station Regulatory Assurance Manager, of any questions regarding this document or any associated regulatory commitments.

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Commitment Committed Date l

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! Comed will comply with the provisions of 10 CFR 50.48(f) and No specific date.

10 CRFR 50.65(a)(1) for changes to the Fire Protection program and the l Maintenance Rule program to reflect the permanently shutdown and defueled condition of the plant.

l Comed will evaluate commitments made to the NRC in previous No specific date.

correspondence and notify the NRC of changes in accordance with the l

j l methodology and criteria described in Nuclear Energy Institute '

l, document " Guidelines for Managing NRC Commitments," Revision 2, l dated December 19,1995.

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