ML20040A920

Requests Amend to Licenses DPR-19,25,29 & 30 Revising Limiting Condition for Operation Re Safety & Relief Valve Position Indication.Proposed Changes to Tables 4.2.1 & 3.2.4 Restoring Inoperable Indication Prior to Startup

ML20040A920
Person / Time
Site:	Dresden, Quad Cities, 05000000
Issue date:	01/12/1982
From:	Rausch T COMMONWEALTH EDISON CO.
To:	Harold Denton Office of Nuclear Reactor Regulation
Shared Package
ML17194A419	List: ML17194A418 ML20040A920
References
NUDOCS 8201220306
Download: ML20040A920 (3)

Text

. .

[h ?Commonwrith Edison

[ ) One First National Plaza. Chicago, Ilknois O Address Reply to: Post Office Box 767 Chicago, Illinois 60690 sn Janua ry 12, 1982 a E RECEtVED Mr. Harold R. Denton, Director Of fice of Nuclear Reactor Regulation J AN 2 8198T** -

a U.S. Nuclea r Regulato ry Commission m anim a -

Washington, DC 20555 s, h3

Subject:

Dresden Station Units 2 and 3 4 _.

Quad Cities Station Units 1 and 2 Proposed Amendments to Technical Specification of Operating Licenses DPR-19, 25, 29 and 30, Concerning Safety /Relie f Valve Position Indication NRC Docket Nos. 50-237/249-and 50-254/265 Reference (a): R. F. Janecek letter to Director of Nuclea r Reacto r Regulation dated Septembe r 18, 1980.

Dear Mr. Denton:

Pursuant to 10 CFR 50.50, Commonwealth Edison Company hereby requests a permanent change to Appendix A Technical Specifications of Provisional Operating License DPR-19 and Facility 4 Operating Licenses DPR-25, 29 and 30 for Dresden Units 2 and 3 and l Quad Cities Units 1 and 2, respectively. The purpose of this request is to revise an overly restrictive Limiting Condition for {

Operation (LCO) concerning sa fety and relief valve position j indication.

In f ulfillment o f TMI-2 lessons learned Ca tegory "A" requirements, Commonwealth Edison proposed various Technical Specification changes for Dresden Units 2 and 3 and Quad Cities Units 1 and 2 in Reference (a) . Among the changes that were subsequently approveo were changes to Table 4.2.1 and Table 3.2.4 for the respective Dresden and Quad Cities Units prohibiting plant startup from a shutdown condition unless all position indication is operable.

In discussions with your staff, it was ascertained that the NRC's only intent behind this requirement was to provide assurance that both methods of position indication (i .e. thermocouple and acoustic monitors) would be reasonably available. In fact, the requirement to shutdown following 30 days o f operation with both indication methods inoperable already provides strong incentive for Commonwealth Edison to repair and maintain these position indicators in an operable condition.

Commonwealth Edison proposes to change Tables 4.2.1 and 3.2.4 to require the restoration of all inoperable position indication prior to startup if the reactor is in a cold shutdown condition for more than seventy two hours. This provision, in 8201220306 820112 0 0 4#

PDR ADOCK 05000237 P PDR

= __ _ _ _ _ _

\

h\\\ ke

3 H. R. Denton Janua ry 12, 1982 conjunction with the 30 day requirement, will ensure that all indicators are restored whenever suf ficient outage time is avail- l aole, without requiring costly extensions o f short-term outages I associated with scram recoverys or minor maintenance.

This proposed change has been discussed with the Dresden and Quad Cities NRC project managers, and we understand that it is acceptacle to your staf f.

i We believe tnat this proposal is in closer accord with the '

original installation requirements for this instrumentation. The safe operation of the units is not adversely a ffected by this change, because these indicators provide no direct safety function, l and Decause the Technical Specification requirement to have at least i one operable indicator per valve remains unchanged. Reference (a) provides a further oiscussion o f why the availability o f safety and relief valve position indication provides only minimal benefits.

The proposed changes to the Technical Specification a re centained in the attachment to this letter. These proposed changes have received On-site ano O f f-site review and approval.  ;

In accordance with 10 CFR 170, Commonwealth Eoison has determineu that this change consists o f two Class III and two Class I amendments. Accordingly, a fee remittance in the amount o f $8,800 is enclosed.

Please direct any questions you may have concerning this matte r to this of fice.

Three (3) signeo originals and fif ty -sevta ( 5 7) copies o f this transmittal are provided for your use.

Ve ry t ruly y ours, w N Thoma s J. Rausch Nuclea r Licensing Administrator Boiling Water Reactors cc: RIII Inspecto r - Dresden RIII Inspector - Quad Cities lm SUBSCRIBED A"9 SdOHN 10 before me this ft/ g day of f, 1982 l

0WdWW

/ ~ Nota ry Public i

3212N l

A T T AC HME N T Dresden Station Unit 2, DPR-19 Dresden Station Unit 3, DPR-25 Quad Cities Station Unit 1, DPR-29 Quad Cities Station Unit 2, DPR-30 Proposed changes to Appendix A Technical Specifications:

DPR 19 - Revised page 45 DPR Revised page 45 DPR Revised page 3.2/4.2-15a DPR Revised page 3.2/4.2-15a l

l l

l l

3212N i

_- .