ML20049J917

Requests Confirmatory Order Re IE Bulletin 80-17, Failure of Control Rods to Insert During Scram at BWR, Be Rescinded

ML20049J917
Person / Time
Site:	Dresden
Issue date:	03/24/1982
From:	Rausch T COMMONWEALTH EDISON CO.
To:	Deyoung R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
References
REF-SSINS-6820 IEB-80-17, NUDOCS 8203290214
Download: ML20049J917 (3)

Text

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- Commonw3cith Edison y/ 7 Address Reply to Post Office Box 767 one Orst National _P1ata. CNeago. Ilhnois y Chicago, Illinois 60690 l

March 24, 1982 l

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s Mr. Richard C. DeYoung, Director p/

Of fice o f Inspection and Enforcement ff ' MW;g

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9 U.S. Nuclear Regulatory Commission E

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Washington, D.C.

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Subject:

Dresden Station Unit 3 Request that Confirmatory Oroers

.y Related to I.E.Bulletin 80-17 Be Rescinded, and Removal and Deletion o f I.E.Bulletin 80-17 Actions NRC Docket No. 50-249 References (a):

1.E.Bulletin 80-17 and Supplements

[

1, 2, 3 and 4.

J.

G. Keppler letters to Cordell Reed dated July 3, July 18, July 22, August 22 and December 19, 1980.

(b):

D. G. Eisenhut letter to All BWR Licensees dated October 1, 1980.

3 (c):

R. Janecek letter to D. G. Eisenhut dated January 15, 1981.

(d):

D. G. Eisenhut letter to All BWR Licensees dated December 9, 1980.

4 i

(Generic SER Transmittal)

(e):

V. Stello, Jr. letter to Cordell Reed dated October 2, 1980.

(Confirmatory Orders)

(f):

R. Janecek to letter to J. G. Keppler dated September 2, 1980.

i Dea r Mr. DeYoung:

i j

In response to the NRC Reference (b) request, Commonwealth Edison indicated in Reference (c) that long term design modifica-tions would be made to the Dresden and Quad Cities Scram Discharge 3

2 Volume (SDV) systems.

These modifications are being implemented at Dresden Unit 3 in the current refueling outage, and are expected to be completed a t that unit no later than the week o f March 29, 1982.

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R. C. DeYoung March 24, 1982 Generally, the codifications include two Scram Discharge Instrument Volume (SDIVs), improved communications between the SDV headers and the SDIVs, diverse and redundant scram sensor instrumen-tation, dedicated and positive vents with two air-operated isolation valves, two air-operated isolation valves on the drain lines, and diverse power supplies for the instrumentation and controls.

This installation completely satisfies the requirements o f the NRC Generic SER of BWR SDV systems transmitted by Reference (d).

Fo r a complete discussion o f how the modified SOV system meets the NRC SER Sa fety, Operational, and Design criteria, see the enclosed Dresden Unit 3 amendment request dated March 18, 1982.

Because the modified Dresden Unit 3 scram discharge system satisfies the Long Term Program Criteria o f the Generic SER, and because this modified system now reliably provides to the control room operators all information concerning system operation necessary to ensure safe operation o f the unit, the following equipment and actions previously required are clearly no longer applicable, and will be removed and/or deleted:

1 The SDV Continuous Monitoring System (CMS) required by I.E.Bulletin 80-17 Supplements 1 and 4 and the Confirmatory Order o f Re ference (e) will be removed from Dresden 3 and all associated surveillances will be deleted.

All operator actions associated with the CMS (i.e. manual scram on SDV hi-hi water level alarm) will no longer be required.

2.

Testing o f the SDIV level switches af ter each scram event as required by I.E.Bulletin 80-17 Supplement 3 will no longer be performed.

Supplemen t 3 specifi-cally acknowledges that this testing is not required subsequent to the long term modifications.

3.

Purging the SDV vent a f ter each scram event as committed in Reference (f) will no longer be performed.

We believe that I.E.Bulletin 80-17 (including supplements) and the Reference (e) Confirmatory Order are implicity applicable only until modifications satisfying the Long Term Program Criteria o f the Generic SER are implemented.

Furthermore, we believe that these modifications at Dresden Unit 3 provide equivalent information to the operator, with a greater level o f safety and reliability than the Continuous Monitoring System required by the Confirmatory Order.

Considering the above, we hereby request that the October 2, 198D, Dresden Station Unit 3 Confirmatory Order be rescinded.

Because (1) the long term modifications necessitated the removal and i

R.

C. DeYoung March 24, 1982 partial destruction of the interim CMS from this unit and (2)

Dresden Unit 3 will be concluding the current refueling outage as early as April 26, 1982, your expeditious a ttention to this matter is imperative.

This subject was discussed with Mr. R.

Spessard o f Region III in a March 24, 1982, telepone conversation.

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

Very truly yours, W

Then.a s J.

Rausch Nuclea r Licensing Aaministrator im Enclosure cc:

H.

R. Denton (s/ enc.)

J.

G.

Keppler ( w / enc. )

R.

L.

Spessard (w/ enc.)

Region III Inspecto r - Dresden ( w / enc. )

3708N