ML17174A950
| ML17174A950 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 11/04/1991 |
| From: | Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Reed C COMMONWEALTH EDISON CO. |
| Shared Package | |
| ML17174A951 | List: |
| References | |
| NUDOCS 9111110298 | |
| Download: ML17174A950 (3) | |
Text
.._~!>-~ REG(/.
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. ~o Docket No. 50-237 Docket No~ 50-249 Commonwealth Edison Company ATTN:
Mr. Cordell Reed Senior Vice President Opus West II I 1400 Opus Place Downers Grove, IL 60515
Dear Mr. Reed:
REGION Ill 799 ROOSEVELT ROAD GLEN ELLYN, ILLINOIS 60137 NOV 4 19g1.
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\\) l(Z,Y He have rev.ie_wed your letters dated October 31, 1991, and November 1, 199.1,
- documenting your oral reque~t for a one-time regional Waiver of Compliance from Dresden Unit_ 2, Technical Specifications, Section 3.9.B. This Technical Specification requires that ~xcept when the reactor is in Cold Shutdown, or Refueling with the reactor head off, the 250 volt batteries are required to be operable.
- Copies of you~ letters are attached.
The circumstances leading to this request were that th~ 250 volt batteries were inoperable and Control Rod Drive (CRO) R-10 needed replacement.
R~placement of CRD.R-10 necessitated placing the mode switch in Refuel, which is not allowed by your Technical Specifications unless the reactor head is off.
You determined that placing the reactor in the Refueling mode with the reactor head on would not involve a significant increase *in the probabi llty or consequences of an accident.
Therefore, yoµ requested relief be granted from having to remove the reactor head in order to place the reactor in the Refueling mode to facilitate the replacement of CRD R-10~
CRD R-10 was taken out-bf-service and elettrically disarmed because it would not latch at any position except 00 (fully inserted).
Replacement would eliminate drift concerns and allow.the reacto~ core to be
. operated in a symmetrical pattern.
Withdrawal of.additional control rods would*
be prevented by the One Rod Permissive interlock which is enabled in the Refueling mode.
In order to allevi.ate a potential radioactive water inventory storage problem,,
- avoid a potential generating capacity shortage projected for Monday, rfovember *4, 1991, and avoid an extension of the current forced outage by approximately three days, you requested the waiver b~ granted for five days from 5:00 p.m.
on October 31, 1991, to 5:00 p.m. on November 5, 1991.
This would allow the.
replatement of CRD R-10 to begin immediately, rather th~n ~aiting until the 250.
volt batteries are declared operable~
1*understand that during the period of time that this Waiver of Compliance is in effeCt, Dresden Station will take the following compensatory actions to ensure that Unit 2 will be maintained in a safe and stable condition.
9111110298 911104 PDR ADOCK 05000237 P
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Commonwea 1th Ed i_son Company 2
NOV 4 1901
- a.
The Unit 3 250 volt loads will continue to remain isolated from the Unit 2 battery until the Unit 3 battery is returned to Service.
- b.
The Unit 2 and 2/3 250 volt battery chargers will not be ma.de inoperable during the duration of the waiver.
(Note only one battery charger is required by Technical Specifications.)
- c.
Activities which have the potential to degrade the Unit 2 250 volt DC p6wer distribution system will be minimized during the duration of the waiver.
- d.
- e.
- f.
- g.
- h.
Access to the Unit 2 and 2/3 250 volt battery chargers will continue to ~e limited to authorized personriel~
Survei.llances will.be per.formed on those Unit 2 systems -having *DC loads (Reactor Water Cl~anup, Shutdown Codling, Isolatipn Condenser, High Pressure Coolant Injection) only as authorized by the Operating
- Engiheer.
Pre~entiv~ mainten~nc~ activities*will be suspended on the Unit 2 and 2/3 250 volt battery chargers, and equipment associated with the 24-1 to 34 714160 volt emergency bus cross-tie.*
In the event a DC ground. is found to exist on the 250 volt DC distribution system, ground checking will only be performed by a team consisting of at least Oper~tions, Electrical Maintenance, and Technical Staff (cog~izant
- electrical engineer) personnel.
This activity will be preceded by a*
Heightened Level of Awareness briefing.
Equipment associated with the 24-1 to 34-1 4160 voit emergency bus cross-tie, and either the Unit 2 or the Unit 2/3 Diesel Generator 0ill be dperable for Unit 2 for the duration of the waiver.
Tci minimize loads on the Unit 2 250 volt battery, the Unit 2 HPCI system.
will be put in a configuration that will not draw power fr6m the 250 volt DC power system in the event of a spurious initiation or isolation signal for the duration of the waiver.
The Reactor Coolant System will be vented to preclude the possibility of system pressurization for the duration of the waiver.
Currently, all six (6) low pressure Emergency Core Coolant System (ECCS) pumps are operable.
Technical Specifications require only two pumps to be operabl~.
No ECCS pumps will be made inoperabl~ for the duration on the waiver.
Commonwealth Edison Company 3
NOV. 4 19Q1 I agree that your r.equest for a Waiver of Compliance meets the eligibility
_criteria in 10 CFR 51~22 (c) (9) and that pursuant to 10 CFR 51.22 (b), no*
environmental impact need be prepare~~
I granted the requested relief as of 5:00 p.m. on October 31, 1991, based on the minimal increase in the probability or consequences of an accident that could occur by placing the reactor iri the Refueling mode until the availability of the 250 volt battery is restored.
I agree that the margins of safety are not s*ignificantly reducecj by allowing the reactor to be in the*
Refueling mode with the h~ad on the reactor vessel versus requiring that the head be off the reactor vessel~ This approval is contingent on meeting the compensatory measures descr.ibed above.
cc w/attachme~ts:
- D. Galle, Vice President~ BWR Operations T.
Kovac~, Nuclear
~icensing Managef E. D. Eenigenburg, Station Manager DCD/DCB (RIDS")
OC/LFDCB Resident Inspectors LaSalle, Dresden, Quad Cities Richard.. Hubba rd
- . J. W. Mccaffrey, Chief, Public Utilities Division
.Robert Newmann, Office of Public Counsel, State of Illinois Center Licensing Project Manager, NRR R. J. Barrett, NRR T. E. Murley, NRR B. A. Boger, NRR J. Lieberman, OE E. J. Leeds, NRR PDR Sincerely,
~~~~%-~~
A, Bert Davi$
Regional Administrator