ML17193A092
| ML17193A092 | |
| Person / Time | |
|---|---|
| Site: | Dresden, Byron, Braidwood, Quad Cities, Zion, LaSalle, 05000599, 05000600  |
| Issue date: | 10/01/1980 |
| From: | Reed C COMMONWEALTH EDISON CO. |
| To: | Eisenhut D Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8010070430 | |
| Download: ML17193A092 (5) | |
Text
Commonwealth Edison
- a...
One First National. Plaza, Chicago, Illinois.
M Address Reply to: Post Office Box 767
- Chicago, Illinois, 60690 DarrellG. Eisenhut, Director Division. of Licensing
, Office. bf Nu~lear ~eact6r. Regulation U. S. N u cl e a r R e g u 1 at o r y C om m i s s i on
-. Washington, D.C.
20555 *
Dear.Mr. Eisenhut:
October 1, *.1980 Pursuant to your letter of*Sept~mber ~' 1980 regar~ing "Preliminary Clarification of TMI Action Plan* Requirements" representatives of*Co~moriwealth Edi so~ attended.the regional meeting at Arlington Park on Septembei 23, 1980. *We ~nderstand that comments made a t t h e m e e t i n g w i 11 b e c o n s i d e re _d i n f i n a 1 i z i n g t h e c 1 a r i f i c a t.i o n document.
Written comments were also ~olicited at th~ meeting.
This. is to respond to that requ~st for written co~ments and to request an opportunity f6r further clarification.
- B a s e d up on t h e Sep t em b er 5, 19 8 0 1 e t te r an d t h e re g i on a 1. me e t i n g
- it is apparent that the. NRt-is not-~imply clarifying the requirements for TMI Action Plan items.
Although completion dates are in some cases being extended revised requirements are being issued at a very late date.
Many of the changes contemplated do not appear to.be substantial from a safety standpoint and appear' to *bE;! made-without cpnsideration for committments.*
made and equipment already installed by-licens.ees in.pursuit of the original requirem~~ts.
Imposition of revisecl.requir*ements at this late date will impose an uridue burden upon our e~gineering and field fGrces as well_ as the financial burden.to redesign and.replace equipment *already ordered or installed.
W~ feel that we ~a~e acted in good faith up~n the requirements issu~d previously.
In order to.meet the Janu~ry 1, 1981 implementation date we have transferred large work.forc~s from other efforts, long-lead-tim~ equipment such a~ computers and electrical cable have been d.iv.erted from other projects, and eqtiipmen't has been ordered from single sourc~s~ bypassing normal competJtive ~i~ pro~edures.
It is encouraging that the NRC *is attempting to revise the implementation schedules set up last F*all to accommodate the realities of design, procurement and installation.
. It seems,' however, that th.ese proposed revisions w9uld have major impact upon_ implementation sched~les and cost~ *We urge that each of the_proposed revisions to TMI Action.Plan requirem~nts be weighed against the benefit of.having plant changes.implemented promptly.
-I-
- Comments regarding specific items address.ed in the "Preliminary Clarification are ~ontained on the attached.
It ~ppear~ that additional work with industr~ ~s needed before these and oiher$ b~come -final as requtreme~ts.
I am willing to ~eet with you and your staff to discuss.
this clarification p~ior to its final i~sue.
GPW/sb 7094A*
.Sincerely, C. Reed*
Comments on D.G. Eisenhut Letter of Septe~ber 5, 1980 II.B.l RCS Vents II.B.2 Plant Shielding I I. B. 3 Post A*c c id en t Sampling II.D~l Valve Testing
- . Requi.rements II.E.1.2 Aux. Feed Syst~m Initiation and Flow II.E.4.1 Dedicated Penetrations Ad~itional requirements have been added regarding testability and failure probability and an ahalysis of. venting inside vs. outside containment is now requi~ed.
Although an additional yea~
has been provided, designs already installed or purchased ar~ penalized.
We have ~pent over $160,000 ~t Zion Unit Two to install a reactor vent system on a prioritj bases, the.de~ign of this installed system should be reviewed for adequacy independent of new clarifications.
The clarified position seems to add items to be considered as. requiring 'access.
Proper review may require repeat of access calculations already perfofmed under the previous criteria.
The new requirement,to add passive fl ow restrictors to already small sampling li~es will provide a crud trap in the line and is inconsistent with good sampling practice.
The testing programs.underway in the.
industry are attempting to meet the p~evious requirem~nt of testing completion by July l, 1981.
The new requirement that the data be reduced, the report provided, and plant specific conclusi6ns b~*provided by the same. date is unwarranted and impossible to ~omply.
with.
The addition of PORV block valves to the program further compounds the problem.
Our December 14, 1919 submittal provided our.justification for our existing system at Zion; the NRC has not responded.
Chan~es imposed at this late d~te to* meet the criteria of IEEE 279-1971 could not be implemented.bY.1-1-81.
The requir~ments for submittal of additional design information, by October 1, 1980 imposes an unnecessary and duplicative burden upon licensees who have already provided submittals in accordance with NUREG 0578 Category "A" items.
II.E.4.2 II.F.1 II.F.2 Co.ntainment Isolation Dependability Additional Ace i.dent Monitoring
- Instrumentation Instrumentation for Detection of Inadequate Core Cooling
-2:..
This item was already addressed on an emergericy basis in response to NUREG 0578.
T~ now require f~rther moefification by Ju 1 y 1, 1'9 81 based upon yet-to-be-pfovided NRt guidance does n-0t seem appropriate nor achievable.
As a re~ult of previous requirements a tremendous effort has b~en applied to comply with a 1/1/81 dated.
In most cases.
installation is well a.dvanced or even complete.
At this late date imposition
. of previously unidentified accuracy, response time, and Reg. Guide 1.97 qualification criteria renders much of
. this effort ~seless.
In the case of cdntain~ent ~ressure, the control room indicator has now been changed to a recorder with no change in the implementation date of 1/1/81.
In the case Of *Containment level the narrow range device must now be fully qualified but the 1/1/81 date still stands.
We
~ontend thBt the ~ystems designed to the previous criteria should be acceptable.
The. new requirement proposed in the *
- Septe~ber 5, 1980 letter would place in jeopardy over $400,000 committed for in~trumentation to be delivered before 1/1/81 fo~ noble gas, and hydrogen m o n.i t o r i n g
- Although an extended date of 1/1/82 has been provided, even the NRC's own research into the ability of the various systems proposed to indeed be unambiguous will not. be completed until th~t date.
Because of the lead times involved, level system procurement ahd installation must be made now and without benefit of this.
re~earch.
Either installation should be
~elayed further, or system installed now
- should not have to be changed after the r~searc~ program *
. The requirement that subcooling monitoring system, installed by 1/1/80 in response to an emergency need, now be in accordance with R~g. Guide 1.97 Rev. 2 appears to iridicate that ~eplacement of these systems is required.
The existing system should be allowed to remain if ihey are of arlequate quality.
. ~
~. *
.Q II.K.3 I I I
- A. 1 ~.2 7094A*
Final Recommendations B&O Tack Force Many of *the individual *topics within.this item are the subject of studies or discussion with the various owner's goups.
It would appear useful for each own~r's group to.pro~ide input on the
~chedules presented.
Upgrade Emergency Considerab)e effo~t has been expanded to*
Support Facilities. install Technical S~pport Centers (TSC) based ~pon designs submi.tted by 1/1/80 in a c c o r d a n c e.w i t h p r e v i o u s r e q u i r em e n t s.
- Imposition of new and not_.ye*t-complete criteria at this late date, without apparent review of the adequacy of
- previous submittals appears to unfairly and unnecessarily penalite thos~
utilities who have been responsive~
In our effort to provide upgraded TSC's at our Dresden, Quad Cities and Zion sites we have built two new buildings and are providing new computer systems.
If all the requirements of draft NUREG_.0696 are i mp o s e d, over 3 m i 1 1 i o 'n 'do 1 1 a rs w i 1 1 h ave been expended uselessly.*
If. new requirements are indeed justified*
at the TSC and Emergency Operations Facility, and implementation schedule should be flexible and based upon.
procurement and installation beginning after*NRC approval of the design.