ML19332C408
| ML19332C408 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 11/16/1989 |
| From: | Stols R COMMONWEALTH EDISON CO. |
| To: | Murley T Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML19332C409 | List: |
| References | |
| NUDOCS 8911280089 | |
| Download: ML19332C408 (4) | |
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November 16, 1989 v
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Dr.-Thomas E. Murley, Director Office.of Nuclear Reactor Regulation-U.S. Nuclear Regulatory Commission Hashington,~DC 20555
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Subject:
Quad Cities Station Unit I Request for Halver of Compliance to
,1 Technical Specifications Requirements
-HRC_ Docket No. 50-254 References-(a):
R. Stols letter to'T. E. Murley dated June 9, 1989.
q (b):
R. Stols letter to T.E. Hurley dated l
November 15, 1989.
iDr. Murley
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Commonwealth Edison requests that _a Temporary Haiver of Compliance be granted to allow the restart of Quad Cities Unit-1. -The basis for~this request P
is delineated in
Attachment:
- 1. Commonwealth ~ Edison requests that the Haiver L
of Compliance be'in effect during the review and approval period.for-the proposed Technical Specification..The proposed changes.are delineated in L; and further discussed in Attachments 3 and 4.
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-r Members of the Commonwealth Edison and NRC Staffs'have discussed the circumstances of the event on November 14, 1989 and it was. agreed that'a -
s Temporary Halver of Compliance should be pursued to document the acceptability of. unit.startup until'the amendment can be reviewed and approved.
This t'
submittal supercedes the submittal described as Reference (b) in its entirety.
The proposed changes have been reviewed and approved by both On-site and'0ff-site review in accordance with Commonwealth Edison Company's proce--
dures.
The proposed amendment has been reviewed in accordance.with 10 CFR l50.92 (c) and it has been determined that the proposed amendment does not involve a significant hazards consideration.
The evaluation is documented in-.
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j Dr. T.E. Hurley
' November _16, 1989' i
P Commonwealth Edison is notifying the State'of Illinois by providing a copy of this letter and~the Attachments to the designated State.0fficial.
Commonwealth Edison requests a review and approval of this_ proposed Temporary Haiver of Compliance and amendment on an expedited basis.
Commonwealth Edison appreciates the. Staff's prompt attention to this matter.
Please direct any questions you may have regarding this matter to this office.
Very truly yours, R. Stols Nuclear Licensing Administrator im-Attachments cc:
T.H. Ross - Project Manager, Quad Cities R.L. Higgins - Senior Resident Inspector, Quad Cities A.B. Davis - Regional Administrator, RIII Office of Nuclear Facility Safety - IDNS l
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ATJACHMEKl_1 BASI Sl0RlEMEDRARLHMYELOLC0 HELI ANCE._R EQUISI j
Darin'g the Quad Cities Unit i Outage, two (2) modifications ~were' performed, The modifications removed the head spray and CRD Return lines as
.part.of the.Intergranular Stress Corrosion Cracking (IGSCC)' mitigation program.' Commonwealth Edison notified the NRC of the-intent to perform these modifications in the Unit 1 IGSCC Inspection Plan submitted on June 9, 1989:
however, the~ station failed to submit the associated Technical Specification amendment to~ allow for NRC issuance prior to.startup.
This was11dentified during a review of Technical Specification Improvement Program.
Commonwealth Edison is performing an investigation on the root cause of the event.
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Appropriate corrective actions will be implemented based on the investigation results.
Commonwealth Edison has identified that literal compliance to Technical Specification 3.7.D.1 cannot be achieved due to the removal of head spray valves H0-1001-60 and H0-1001-63. These valves served as primary contain-ment isolations valves. Current Technical Specification 3.7.0.1 requires that
'all isolations valves. listed on Table 3 7-1 be operable during power operation.
Valves H0-1001-60 and HO-1001-63 are included in the listing and as a result, literal compliance cannot be achieved.
Technical Specification 3.7,0.2 states thattinfthe event an isolation valve becomes inoperable, reactor power operation may continue, provided:at least one valve in each line is in the mode corresponding to the isolated condition.
The remaining piping on the head spray system (reactor side) is~ fitted with a blind flange, thereby, the intent (not the Letter) of Specification 3.7,0.2 is met.
The current configuration is thereby consistent with the philosophy of providing the
-isolation of the reactor pressure boundary to prevent an unisolable release u
pathway in the' event of an accident.
The blind flange was tested during the reactor. hydrostatic test to ensure the integrity of the installation.
In addition, the current design is not consistent with the pene-tration description contained in the Technical Specifications.
Technical Specifications 3.7.A.2 and 4.7.A.2 require that all primary containment valves and penetrations.are subject to Type B and C testing.
Table 3.7.2 of the Technical: Specification contains e listing of primary containment leakage test penetrations.
Included in this listing are pipe penetrations X-17, reactor vessel head spray and X-36, Control Rod Drive Return.
The Technical l
-Specifications, therefore, require a Type B or C test to be performed on these penetrations.
Due to the modified configuration, a Type B or C test is no longer feasible.
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The purpose'of testing the penetration is to verify the leak tightness of the bellow assembly of the penetration. The primary bellow serves as a-primary-containment boundary and the secondary bellow provides for the testable volume.
By installing a welded cap on the-interior side of contain-ment, the primary bellow no longer serves as the primary containment boundary.
.The penetration._ caps (20"on the head spray penetration and 8" on the CRD
' return-line) now serve as the primary containment boundary.
The welded cap,
-as currently designed, is not subject to a Type B or C test as described in
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-Appendix J.
The integrity of the penetration cap is verified during the Integrated Leak Rate Test which is performed at 48#.(gauge pressure) and the Ltesting is consistent with Appendix J requirements. An Integrated Leak Rate Test was performed during this outage with acceptable results achieved on both the CRD Return Line and Head Spray Line. The current configuration is therefore tested in accordance-with Appendix-J requirements, however, not as described in the Technical Specifications.
t Commonwealth Edison therefore, requests that a Temporary Walver of Compliance be_ granted to allow the restart of Unit 1.
Unit I startup is currently scheduled'for Tuesday, November 21.
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