ML17191B331

Responds to from PD Swafford Requesting That NRC Exercise Discretion Not to Enforce Compliance with Actions Required in ST 3.6.E,Action 1,that Specifies All Reactor Coolant Sys Safety Valves Be Operable

ML17191B331
Person / Time
Site:	Dresden
Issue date:	05/06/1999
From:	Thomas C NRC (Affiliation Not Assigned)
To:	Kingsley O COMMONWEALTH EDISON CO.
References
NOED-99-6-004, NOED-99-6-4, TAC-MA5358, NUDOCS 9905110106
Download: ML17191B331 (4)

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. 2055&-<>001 May 6, 1999

SUBJECT:

NOTICE OF ENFORCEMENT DISCRETION FOR COMMONWEAL TH EDISON COMPANY REGARDING DRESDEN NUCLEAR POWER STATION, UNIT 3 (TAC NO. MA5358; NOED 99-6-004)

Dear Mr. Kingsley:

By letter dated May 4, 1999, from P.D. Swafford, Commonwealth Edison Company (ComEd) to the NRC, your staff requested that the NRC exercise discretion not to enforce compliance with

. the actions required in Technical Specification (TS) 3.6.E, Action 1, that specifies all reactor coolant system safety valves be operable. In order to complete our formal review, clarifying supplemental information was requested and was submitted on May 6, 1999. Your letters documented information previously discussed with the NRC in a telephone conference call on May 4, 1999, beginning at 1:15 a.m., Central Time. The principal NRC staff members who participated in that telephone conference included: for NRC, C. Thomas, Director, Project Directorate Ill; J. Wermiel, Chief, Reactor Systems Branch; E. lmbro, Chief, Mechanical Engineering Branch; M. Dapas, Deputy Director, Division of Reactor Projects; M. Ring, Chief, Reactor Projects Branch 1; and for ComEd, C. Crane, Vice President, Boiling Water Reactors; D. Helwig, Senior Vice President, Nuclear Service; P. Swafford, Dresden Station Manager; W. Boike, Engineering Vice President; and R. Kritch, Vice President, Regulatory Services.

Your staff stated that Dresden, Unit 3, was required to be placed in hot shutdown on May 4, 1999, at 7:51 a.m., in accordance with TS 3.6.E, Action 1, due to an inoperable Target Rock

. safety-relief valve (SRV). ComEd requested that a Notice of Enforcement Discretion (NOED) be issued pursuant to the NRC's policy regarding exercise of discretion for an operating facility, set out in Section VILc, of the "General Statement of Policy and Procedures for NRC Enforcement Actions" (Enforcement Policy), NUREG-1600, and be effective until a license amendment could be approved, obviating the need for continued discretion. This letter documents our telephone conversation at 2:15 a.m. on May 4, 1999, when we orally issued this NOED.

Com Ed declared the safety valve function inoperable for the Target Rock SRV following

.1 indication in the Dresden, Unit 3, control room at 7:51 p.m. on May 3, 1999, that the bellows on the SRV had failed. At the time of this event, the unit was operating at full power. ComEd

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• stated that the Target Rock SRV was a d.ual function valve and the relief valve function is not affected by a bellows failure and that only an actual bellows failure or a failure in the bellows

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failure detection instrumentation would cause the indication they received. The Target Rock Q:

SRV is one of nine safety valves required to be operable by TS 3.6.E. As described in the

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-,i. ;. Dresden Updated Final Safety Analysis Report (UFSAR), the Target Rock SRV is not credited M '--"""

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0. Kingsley in either the safety or relief mode in any of the overpressure analyses. The UFSAR also documents that only three safety valves are needed to meet the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (Code) overpressure protection requirements. In addition, ComEd stated that based on its analyses for the current cycle of operation for Unit 3, adequate overpressure protection existed for the most severe overpressure transient with only six operable safety valves. ComEd reasoned that if it shut down Unit 3, it would subject the unit to an unnecessary transient. This is because the UFSAR does not assume that the Target Rock SRV functions and adequate overpressure protection margins remain with the Target Rock SRV inoperable. ComEd stated that it would perform a root cause determination of the reasons for the bellows failure through their corrective action.

program and repair the valve during the next refueling outage.

The NRC staff evaluated ComEd's submittals and stated rational for the NOED requested. The NRC staff verified that TS 3.6.E would be violated by not placing the unit in hot shutdown within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. The staff reviewed the safety basis for the request and verified that the safety valve function of this SRV is not credited in the UFSAR and it is not needed to provide adequate overpressure protection. The staff reviewed and accepted the basis for ComEd's conclusion that the noncompliance would not t:>e of potential detriment to the public health and safety and that no significant hazards consideration was involved. The staff reviewed and accepted ComEd's basis that the noncompliance would not involve adverse consequences to the environment. The staff concluded that ComEd's request met criterion B.2.1 of NRC's guidance for granting enforcement discretion (IMC Part 9900), i.e., granting of the NOED request would avoid an undesirable plant transient as a result of forcing compliance with the TS and would,

. therefore, minimize potential safety consequences.

Based on the staff's evaluation of your request, we have concluded that a NOED is warranted because we are clearly satisfied that this action involves minimal or no safety impact, is consistent with the enforcement policy and staff guidance, and has no adverse impact on*public health and safety. Therefore, it is our intention to exercise discretion not tO enforce compliance with TS 3.6.E, Action.1, due to an inoperable safety-relief valve for the period from 7:51 a.m. on May 4, 1999, until issuance of a.license amendment for which ComEd submitted an application by letter dated May 5, 1999. The staff plans to complete its review and issue the license amendment within four weeks of the date of this letter.!

0. Kingsley As stated i_n the Enforcement Policy, action will-be taken to the extent that violations were involved, for the root cause that led to the noncompliance for which this NOED was necessary.

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1 Sincerely, bri~in~l Signed By

_*'Cecil 0. Thomas,* Director Project Directorate I.II *,

Division of Licepsing ProjeC::t Management Office, of. Nuclear Reactor Regulation

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Docket No. 50-249

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• NOED (electronic copy)

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DOCUMENT NAME: NOEA5358 without enclosures "E" = Co y with enclosures "N" = No copy OFFICE PM:LPDlll NRR:RSB NRR:EMEB NAME LROSSBAC JWERMIEL tt-EIMBRO,}(,

DATE 051 (' /99 051 6 199 05/t: 199 OFFICE Riii NAME MDAPAS*.,)(...~

DATE 051 6 199

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0. Kingsley Commonwealth Edison Company cc:

Commonwealth Edison Company Site Vice President - Dresden 6500 N. Dresden Road Morris, Illinois 60450-9765 Commonwealth Edison Company Dresden.Station Manager 6500 N. Dresden Road

• Morris,. Illinois 60450.:.9755 U.S. Nuclear Regulatory Commission Dresden Resident Inspectors Office 6500 N. Dresden Road Morris, Illinois 60450-9766.

Regional Administrator U.S. NRC, Region Ill

• 801 Warrenville Road Lisle, Illinois 60532-4351 Illinois Department of Nuclear. Safety Office of Nuclear Facility Safety 1035 Outer Park Drive Springfield, Illinois 62704 Chairman Grundy County Board Administration Building 1320 Union Street Morris, Illinois 60450 Document Control Desk-Licensing Commonwealth Edison Company

. 1400 Opus Place*, Suite 400 Downers Grove, Illinois 60515 Commonwealth Edison Company Reg. Assurance Manager-. Dresden 6500 N. Dresden Road Morris, Illinois 60450-9765 Mr. David Helwig Senior Vice President Commonwealth Edison Company Executive Towers West Ill 1400 Opus Place, Suite 900 Downers Grove, Illinois 60515 Dresden Nuclear Power Station Units 2 and 3 Mr. Gene H. Stanley PWR Vice President Commonwealth Edison Company Executive Towers West Ill 1400 Opus Place, Suite 900 Downers Grove, Illinois 60515 Mr. Christopher Crane

• BWR Vice President Commonwealth Edison Company Executive Towers West 111 1400 Opus Place, Suite 900 Downers Grove, Illinois 60515 Mr. R. M. Krich Vice President -: Regulatory Services Commonwealth Edison Company Executive Towers West Ill 1400 Opus Place, Suite 500 Downers Grove, Illinois 60515 Ms. Pamela B. Stroebel Senior Vice President and.General Counsel Commonwealth Edison Company P.O. Box 767.

Chicago, Illinois 60690-0767