ML20057D117
| ML20057D117 | |
| Person / Time | |
|---|---|
| Site: | Byron, Braidwood  |
| Issue date: | 09/27/1993 |
| From: | Bauer J COMMONWEALTH EDISON CO. |
| To: | Murley T NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), Office of Nuclear Reactor Regulation |
| References | |
| RTR-REGGD-01.093, RTR-REGGD-1.093 NUDOCS 9310010130 | |
| Download: ML20057D117 (3) | |
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t Ccmmonwscith Edison FC 1400 Opus Place 17' Downers Grove, Illinois 60515 rw September 27,1993 Dr. Thomas E. Murley, Director l
Office of Nuclear Reactor Regulation j
U.S. Nuclear Regulatory Commission j
Washington, D.C. 20555 j
1 Attn: Document Control Desk 1
Subject:
Withdrawal of Proposed Exception to Regulatory Guide 1.93 l
Byron Station Units 1 and 2 NPF-37/66; NRC Docket Nos. 50-454/455 i
Braidwood Station Units 1 and 2 NPF-72/77; NRC Docket Nos. 50-456/457 i
References:
See Attachment A i
Dear Dr. Murley:
i As documented in Reference (a), Commonwealth Edison Company (CECO).
proposed to change an Updated Final Safety Analysis Report commitment for Byron and Braidwood Stations by taking exception to a provision of Regulatory Guide 1.90, " Availability of Electrical Po.ver Sources." The proposed exception I
would allow CECO the option of performing periodic maintenance on the System Auxiliary Transformers (SAT) with the affected unit at power. Regulatory i
Guide 1.93 currently limits this preventative maintenance to periods when the affected unit is in Cold Shutdown or Refueling.
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After review of this submittal, the Staff has informed CECO that the NRC does not disagree with the proposal, however, suggested that changes to license commitments of this nature be addressed through the 10CFR50.59 process.
References (b), (c), (d) and (e) also appear to support the concept of performing preventative maintenance at power provided the licensee develops a full l
understanding of the associated impact on plant safety.' Commonwealth Edison acknowledges the Staffs concern that changes in license commitments be well documented and technicallyjustified.
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Dr. T. E. Murley September 27,1993 In light of this information, CECO is withdrawing the subject proposal (Reference (a)) for formal NRC review and approval. CECO will consider taking.
exception to Regulatory Guide 1.93 and justify performing System Auxiliary Transformer maintenance at power under the provisions of10CFR50.59. Other license commitment modifications of similar nature may also be pursued in the future utilizing the 10CFR50.59 process.
Commonwealth Edison appreciates the Staffs review of this proposal. We look forward to continued frequent, open and candid communications with the NRC.
Please address any further comments or questions regarding this matter to this office.
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Respectfully, bk<
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enf Joseph A. Bauer Nuclear Licensing Administrator JAB /gp Attachment ec:
J. B. Hickman, Byron Project Manager - NRR R. R. Assa, Braidwood Project Manager - NRR H. Peterson, Senior Resident Inspector - Byron S. G. Dupont, Senior Resident Inspector - Braidwood B. Clayton, Branch Chief-R.egion III k:nla:by: letters:10
s Attachment A References (a)
February 24,1993 Letter from T. W. Simpkin to T. E. Murley, " Proposed Exception to Regulatory Guide 1.93" i
(b)
June 17,1987 Memorandum from T. E. Murley to the Regional Administrators, " Intentional Entry Into Technical Specification Limiting Condition For Operation 3.0.3."
(c)
March 28,1991 Memorandum from J. M. Taylor to Commissioner Curtiss,
" Voluntary Entry Into Technical Specifications Action Statements For The Purpose Of Performing Preventive Maintenance" (d)
April 17,1991 Memorandum from C. I. Grimes to S. J. Collins, " Entry Into a Technical Specification (TS) Limiting Conditio'p For Operation (LCO)
During The Performance Of Surveillance Testing" (e)
May 14,1993 Letter from T. E. Murley to Diane Curran, Esquire, response to Ms. Curran's April 2,1993 letter regarding " intentional disabling of safety systems for purposes of performing at-power repairs" l
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