ML17188A055

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Discusses Info Pertaining to Commonwealth Edison Co Implementation of Mods Associated W/Gl 96-06, Assurance of Equipment Operability & Containment Integrity During Design Basis Accident Conditions, Issued on 960930
ML17188A055
Person / Time
Site: Dresden, Byron, Braidwood, Quad Cities, Zion, LaSalle  
Issue date: 02/06/1998
From: Stewart Bailey
NRC (Affiliation Not Assigned)
To: Kingsley O
COMMONWEALTH EDISON CO.
References
GL-96-06, GL-96-6, TAC-M96782, TAC-M96783, TAC-M96789, TAC-M96790, TAC-M96806, TAC-M96807, TAC-M96825, TAC-M96826, TAC-M96856, TAC-M96857, TAC-M96888, TAC-M96889, NUDOCS 9802270180
Download: ML17188A055 (6)


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION Mr. Oliver D. Kingsley, President Nuclear Generation Group Commonwealth Edison Company Executive Towers West Ill 1400 Opus Place, Suite 500 Downers Grove, IL 60515 WASHINGTON, D.C. 20555--0001 February 6, 1998

SUBJECT:

INFORMATION PERTAINING TO COMMONWEALTH EDISON COMPANY (COMED) IMPLEMENTATION OF MODIFICATIONS ASSOCIATED WITH GENERIC LETTER 96-06 (TAC NOS. M96782, M96783/M96789/M96790, M96806, M96807, M96825, M96826, M96856, M96857, M96888 AND M96889)

Dear Mr. Kingsley:

The staff issued Generic Letter (GL) 96-06, "Assurance of Equipment Operability and Containment Integrity During Design-Basis Accident Conditions" on September 30, 1996. The generic letter requested licensees to determine (1) if containment air cooler cooling water systems are susceptible to either waterhammer or two-phase flow conditions during postulated accident conditions, and (2) if piping systems that penetrate the containment are susceptible to thermal expansion of fluid so that overpressurization of piping could occur. By letter dated January 28, 1997, as supplemented by letters dated March 28, May 2, May 30 and June 4, 1997, you submitted your 120-day responses to GL 96-06 for the ComEd sites. The staff is currently performing a detailed review of your responses.

The staff issued Supplement 1 to GL 96-06 on November 13, 1997. The supplement was issued to inform addressees about the ongoing efforts and developments associated with GL 96-06 and to provide additional guidance for completing corrective actions. Implementing corrective actions to resolve the GL 96-06 issues can have a significant impact on outage schedules and resources. Some licensees have indicated that it would be prudent to take more time to better understand the specific concerns that have been identified in order to optimize whatever actions are needed and to assure that they do not ultimately result in a detriment to safety. Current issues and ongoing efforts that could influence a licensee's decision in planning corrective actions include (1) risk implications of installing relief valves to deal with the thermal overpressurization issue, (2) feasibility of using the acceptance criteria contained in Appendix F to Section Ill of the American SoCiety of Mechanical Engineers Boiler and Pressure Vessel Code (ASME.Code) for the permanent resolution of the GL 96-06 issues, (3) ongoing tests by the Electric Power Research Institute to support a generic resolution of the overpressurization of piping issue, and (4) questions regarding the staff's closure of Generic Safety Issue 150, "Overpressurization of Containment Penetrations." Risk insights and industry initiatives that are being considered or that may be proposed could also influence the course of action that licensees take to resolve the GL 96-06 issues. Although a number of issues have arisen that could affect licensees' schedules for resolving GL 96-06 issues, all licensees of operating plants have responded to the generic letter and determined that systems and components susceptible to the conditions discussed in GL 96-06 remain operable. Therefore, the staff is receptive to licensees revising their sch~duler commitments for resolving the GL 96-06 issues, if justified.

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0. Kingsley Licensees are responsible for assessing equipment operability, determining actions, and
  • establishing schedules that are appropriate for resolving the specific conditions that have been identified. In determining the appropriate actions and schedules for resolving GL 96-06 issues, licensees should consider, for example, the continued validity of existing operability determinations, compensatory actions required to maintain operability, the safety significance associated with the specific nonconformances or degraded conditions that have been identified, risk insights, and the time required to complete any generic initiatives and/or plant-specific actions (e.g., engineering evaluations, design change packages, material procurement, and equipment modification and installation). Also, analytical solutions employing the permanent use of the acceptance criteria contained in the ASME Code, Section Ill, Appendix F (or other acceptance criteria) may present viable alternatives to plant modifications and can be used where appropriate, justified, and evaluated in accordance with NRC requirements such as 10 CFR 50.59, as appropriate. Licensees may find the revised guidance contained in GL 91-18, "Information to Licensees Regarding Two NRC Inspection Manual Sections on Resolution of Degraded and Nonconforming Conditions and on Operability," Revision 1, dated October 8, 1997, helpful in determining appropriate actions and schedules. Although adjustments in schedules may be warranted on the basis of these (and other) considerations, specific actions that have been defined and are clearly needed should not be delayed without suitable justification.

It is the staffs current position that licensees can use the ASME Code, Section Ill, Appendix F; criteria for interim operability determinations for degraded and nonconforming piping and pipe supports until permanent actions have been identified and approved by the NRC (as applicable) for resolving the GL 96-06 issues. This guidance supplements the guidance provided by GL 91-18 for resolution of the GL 96-06 issues.

If you choose to revise your commitments for resolving the GL 96-06 issues, you should submit a revised response to the generic letter. Your revised response should include appropriate discussion of the considerations discussed above, the current resolution status, and actions remaining to be completed, and plans being considered for final resolution of the GL 96-06 issues.

If you have any questions, please contact me at (301) 415-1321.

Docket Nos. STN 50-456, STN 50-457,...

STN 50-454, STN 50-455; 50-237, 50-249, 50-373, 50-374, 50-254/50-265, 50-295,150-304.

cc: See next page

    • 0. Kingsley Fe11ary 6, 1998 Licensees are responsible for assessing equipment operability, determining actions, and establishing schedules that are appropriate for resolving the specific conditions that have been identified. In determining the appropriate actions and schedules for resolving GL 96-06 issues, licensees should consider, for example,' the continued validity of existing operability determinations, compensatory actions required to maintain operability, the safety significance.

associated with the specific nonconformances or degraded conditions that have been identified, risk insights, and the time required to complete any generic initiatives and/or plant-specific actions (e.g., engineering evaluations, design change packages, material procurement, and equipment modification and installation). Also, analytical solutions employing the permanent use of the acceptance criteria contained in the ASME Code, Section Ill, Appendix F (or other

  • acceptance criteria) may present viable alternatives to plant modifications and can be used where appropriate, justified, and evaluated in accordance with N_RC requirements such as 10 CFR 50.59, as appropriate. Licensees may find the revised guidance contained in GL 91-18, "Information to Licensees Regarding Two NRC Inspection Manual Sections on Resolution of Degraded and Nonconforming Conditions and on Operability," Revision 1, dated October 8, 1997, helpful in determining appropriate actions and schedules. Although adjustments in schedules may be warranted on the basis of these (and other) considerations, specific actions that have been defined and are clearly needed should not be delayed without suitable justification.

It is the staffs current position that licensees can use the ASME Code, Section Ill, Appendix F, criteria for interim operability determinations for degraded and nonconforming piping and pipe supports until permanent actions have been identified and approved by the NRC (as applicable) for resolving the GL 96-06 issues. This guidance supplements the guidance provided by GL 91-18 for resolution of the GL 96~06 issues..

  • If you choose to revise your commitments for resolving the GL 96-06 issues, you should submit a revised response to the generic letter. Your revised response-should include appropriate discussion of the considerations discussed above, the current resolution status, and actions remaining to be completed, and plans being considered for final resolution of the GL 96-06 issues.

If you have any questions, plE!ase contact me at (301) 415-1321.

Sincerely, Orig.. signed by Stewart N. Bailey, Project Manager Project Directorate 111-2 Division of Reactor Projects - Ill/IV Office of Nuclear Reactor Regulation Docket Nos. STN 50-456, STN 50-457, STN 50-454, STN 50-455, 50-237, 50-249, 50-373, 50-374, 50-254, 50-265, 50-295, 50-304

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0. Kingsley cc:

Michael I. Miller, Esquire Sidley and Austin One First National Plaza Chicago, Illinois 60603 Regional Administrator, Region Ill U.S. Nuclear Regulatory Commission 801 Warrenville Road Lisle, Illinois 60532-4351 Illinois Department of Nuclear Safety Office of Nuclear Facility Safety 1035 Outer Park Drive Springfield, Illinois 62704 Document Control Desk-Licensing Commonwealth Edison Company 1400 Opus Place, Suite 400 Downers Grove, Illinois 60515 Mr. William P. Poirier, Director Westinghouse Electric Corporation Energy Systems Business Unit Post Office Box 355, Bay 236 W.

Pittsburgh, Pennsylvania 15230 Joseph Gallo Gallo & Ross 1250 Eye St., N.W., Suite 302 Washington, DC 20005 Howard A. Learner Environmental law and Policy Center of the Midwest 203 N. LaSalle Street Suite 1390 Chicago, Illinois 60601 U.S. Nuclear Regulatory Commission Byron Resident Inspectors Office 4448 N. German Church Road Byron, Illinois 61010-9750 Ms. Lorraine Creek RR 1, Box 182 Manteno, Illinois 60950 Chairman, Ogle County Board Post Office Box 357 Oregon, Illinois 61061 Commonwealth Edison Company Mrs. Phillip B. Johnson 1907 Stratford Lane Rockford, Illinois 61107 George L. Edgar Morgan, Lewis and Bochius 1800 M Street, N.W.

Washington, DC 20036 Attorney General 500 S. Second Street Springfield, Illinois 62701 Commonwealth Edison Company Byron Station Manager 4450 N. German Church Road Byron, Illinois 61010-9794 Commonwealth Edison Company Site Vice President-Byron 4450 N. German Church Road Byron, Illinois 61010-9794 U.S. Nuclear Regulatory Commission Braidwood Resident Inspectors Office RR 1, Box79 Braceville, Illinois 60407 Mr. Ron Stephens Illinois Emergency Services and Disaster Agency 110 E. Adams Street Springfield, Illinois 62706 Chairman Will County Board of Supervisors Will County Board Courthouse Joliet, Illinois 60434 Commonwealth Edison Company Braidwood Station Manager RR 1, Box84 Braceville, Illinois 60407 Ms. Bridget Little Rorem Appleseed Coordinator 117 N. Linden Street Essex, Illinois 60935

0. Kingsley Commonwealth Edison Company Site Vice Preside.nt - Braidwood RR 1, Box 84 Bracemille, IL 60407 Commonwealth Edison Company Site Vice President - Dresden 6500 N. Dresden Road Morris, Illinois 60450-9765.

Commonwealth Edison Company Dresden* Station Manager 2605 N. 21st Road Marseilles, Illinois 61341-9756 U.S. Nuclear Regulatory Commission Dresden Resident Inspectors Office 6500 N. Dresden Road Morris, Illinois 60450-9766 William D. Leach Manager - Nuclear MidAmerican Energy Company 907 Walnut Street P.O. Box657 Des Moines, Iowa 50303 Vice President - Law and MidAmerican Energy Company Regulatory Affairs One River Center Place 106 E. Second Street P.0. Box 4350 Davenport, Iowa 52808 Chairman Rock Island County Board of Supervisors 1504 3rd Avenue Rock Island County Office Bldg.

Rock Island, Illinois 61201 Chairman Grundy County Board Administration Building 1320 Union Street Morris, Illinois 60450 Commonwealth Edison Company Quad Cities Station Manager 22710 206th Avenue N.

Cordova, Illinois 61242-9740 Commonwealth Edison Company Commonwealth Edison Company Site Vice President - Quad Cities 2271 O 206th Avenue N.

Cordova, Illinois 61242-9740 U.S. Nuclear Regulatory Commission Quad Cities Resident Inspectors Office 22712 206th Avenue N.

Cordova, Illinois 61242 Phillip P. Steptoe, Esquire Sidley and Austin One First National Plaza Chicago, Illinois 60603 Assistant Attorney General 100 W. Randolph Street, Suite 12 Chicago, Illinois 60601 U.S. Nuclear Regulatory Commission LaSalle Resident Inspectors Office.

2605 N. 21st Road Marseilles, Illinois 61341-9756 Chairman LaSalle County Board of Supervisors LaSalle County Courthouse Ottawa, Illinois 61350 Chairman Illinois Commerce Commission Leland Building 527 E. Capitol Avenue Springfield, Illinois 62706 Commonwealth Edison Company LaSalle Station Manager 2601 N. 21st Road Marseilles, Illinois 61341-9757 Commonwealth Edison Company Site Vice President-LaSalle 2601 N. 21st Road Marseilles, Illinois 61341-9757 Robert Cushing Chief, Public Utilities Division Illinois Attorney General's Office 100 W. Randolph Street Chicago, Illinois 60601

0. Kingsley Dr. Cecil Lue-Hing Director of Research and Development Metropolitan Sanitary District of Greater Chicago 100 E. Erie Street Chicago, Illinois 60611 Mayor of Zion Zion, Illinois 60099 U.S. Nuclear Regulatory Commission Zion Resident Inspectors Office 105 Shiloh Blvd.

Zion, Illinois 60099 Commonwealth Edison Company Site Vice President - Zion 101 Shiloh Blvd.

Zion, Illinois 60099-2797 Commonwealth Edison Company Zion Station Manager 101 Shiloh Blvd.

Zion, Illinois 60099-2797 Mr. David Helwig Nuclear Services Senior Vice President Commonwealth Edison Company Executive Towers West Ill 1400 Opus Place, Suite 900 Downers Grove, IL 60515 Mr. Gene H. Stanley PWR's Vice President Commonwealth Edison Company Executive Towers West Ill 1400 Opus Place, Suite 900 Downers Grove, IL 60515 Mr. Steve Perry BWR's Vice President Commonwealth Edison Company Executive Towers West Ill 1400 Opus Place, Suite 900 Downers Grove, IL 60515 Mr. Dennis L. Farrar Regulatory Services Manager Commonwealth* Edison Company Executive Towers West Ill 1400 Opus Place, Suite 500 Downers Grove, IL 60515 Commonwealth Edison Company Ms. Irene Johnson, Licensing Director Nuclear Regulatory Services Commonwealth Edison Company Executive Towers West Ill 1400 Opus Place, Suite 500 Downers Grove, IL 60515 Commonwealth Edison Company Reg. Assurance Supervisor - Byron 4450 N. German Church Road Byron, Illinois 61010-9794 Commonwealth Edison Company Reg. Assurance Supervisor - Braidwood RR 1, Box84 Braceville, Illinois 60407 Commonwealth Edison Company Reg. Assurance Supervisor - Dresden 2605 N. 21st Road Marseilles, Illinois 61341-9765 Commonwealth Edison Company Reg. Assurance Supervisor - Quad Cities 22710 206th Avenue N.

Cordova, Illinois. 61242-97 40 Commonwealth Edison Company Reg. Assurance Supervisor-LaSalle 2601 N. 21st Road Marseilles, Illinois 61341-9757 Commonwealth Edison Company Reg. Assurance Supervisor-Zion 101 Shiloh Blvd.

Zion, Illinois 60099-2797