ML20058L991

Forwards SERs of Responses & Associated Science Application Intl Corp 900614 Technical Evaluation Rept SAIC-89/1640 Re Station Blackout.Revised Response Addressing Areas of Nonconformance Should Be Submitted within 60 Days

ML20058L991
Person / Time
Site:	Byron, Braidwood
Issue date:	08/06/1990
From:	Sands S Office of Nuclear Reactor Regulation
To:	Kovach T COMMONWEALTH EDISON CO.
Shared Package
ML20058K167	List: ML20058K165 ML20058K225 ML20058L991 ML20058L996 ML20058M000
References
TAC-68515, TAC-68516, TAC-68522, TAC-68523, NUDOCS 9008090162
Download: ML20058L991 (5)

Text

7 x c o August 6,1990 Docket Nos. STN 50-454, 50-455 DISTRIBUTI N: '

and STN 50-456, 1 0-457 Q PDIII-2 r/f

. e- NRC & Local PDRs JZwolinski l JWechselberger SSands CMoore OGC-WF1 <

Mr. Thomas J. Kovach EJordan ACRS(10)

Nuclear Licensing Manager PDIII-2 Gray TBoyce ,

Connonwealth Edison Company - Suite 300 DCrutchfield FRosa l OPUS West III  ;

1400 OPUS Place Downers Grove, Illinois 60515

Dear Mr. Kovach:

1 I

SUBJECT:

SAFETY E WLUATIONS OF THE BYRON STATION AND BRAIDWOOD STATION l RESPONSES TO THE STATION BLACK 0UT (SB0) RULE (TAC NOS. 68522, I 68523 AND 68515, 68516)

By letters dated April 17, 1989, March 29, 1990, and March 30, 1990, i Commonwealth Edison Company (Ceco) submitted responses to the Station Blackout (SBO) rule for Byron Station, Unit Nos.1 and 2 and Braidwood Siation, Unit Nos. I and 2. The responses-were reviewed by the NRC staff and by an NRC contractor, Science Applications International Corporation  :

(SAIC). Attached as' Enclosures 1 and 2 are the NRC staff Safety Evaluation l Reports (SER)ofthelicensee'sresponsesandtheassociatedSAICTechnical  ;

Evaluation Reports (TER), SAIC-89/1640 for B  ;

for Braidwood Station, dated June 14,1990 (yron Station and SAIC-90/1043 Attachment _

Ceco has-proposed using existing Emergency Diesel Generators (EDG) as an R alternate AC (AAC) power source for Byron and Braidwood Stations and has '

submitted its response in the SB0 generic response format. Based on that response, the NRC staff has concluded that the Byron and Braidwood Stations l do not conform with the SB0 rule, the guidance.of Regulatory Guide 1.155, 4 Nuclear Management and Resources Council (NUMARC)-document NUMARC 87-00, and NUMARC 87-00, " Supplemental Questions / Answers and Major Assumptions," dated December 27,1989 (issued to the industry by NUMARC on January 4,1990). The areas of non-conformance are identified in the enclosed SERs. .

.In conjunction with the above mentioned documents related to the SB0 rule, and the guidance provided to the industry by both the NRC and NUMARC, the enclosed letter. (Enclosure 3) from Mr. William T. Russell, NRC, to Mr. William Rasin,  !

NUMARC, dated June 6,1990, provides further guidance regarding the issue of load shedding in the non-blackout (NB0) unit to meet the SB0 requirements for AAC.

In addition, the following areas may require follow-up inspection by the NRC staff to verify that the implementation of any modifications, and the supporting documentation which CECO may propose as a result of this evaluation, are adequate to meet the SB0 Rule:

a. Hardware and procedural modifications.

b. SB0 procedures in accordance with R.G.1.155, Position 3.4, and NUMARC 87-00, Section 4.

9008090162 900806 PDR ADOCK 05000454 p PDC

] {

m

\\\

l .

i Mr. Thomas J. Kovach August 6,1990-m c. Operator staffing and training to follow the identified actions y in the SB0 procedures,

d. EDG reliability program meeting, as a minimum, the guidelines of RG 1.155.

e. ' Equipment and components required to cope with an SB0 are incorporated'in a QA program that meets the guidance of -

RG 1.155, Appendix A.

j

f. Actions taken pertaining to the specific recommendations noted in the SER. '

V TheguidanceprovidedonTechnicalSpecifications(TS)forSB0statesthatthe TS should be consistent.with the Interim Commission Policy Statement on Technical Specifications. The NRC staff has-taken the position that TS are required for SB0 response equipment. However, the question of how Specifi-cations for the SB0 equipment will be applied is currently being considered V generically by the NRC in the context of the Technical Specification Improve-ment Program (TSIP) and remains an open item at this time. In the interim,

.the NRC staff expects-plant procedures to refloct the appropriate testing and surveillance requirements to ensure the operability of the necessary SB0 equipment. If the staff later determines that TS regarding the SB0 equipment

-is warranted, licensees will be notified of the implementation requirements.

In closing, a revised response to the SB0 rule, which addresses the areas of-non-conformance, should be submitted for staff review within 60 days from receipt of this letter. Subject-to an acceptable resolution of the identified L non-conformances, the issue of conformance to the SB0 rule remains open at H Byron Station, Unit Nos. I and 2 and Braidwood. Station, Unit Nos. I and 2.

l

[ Sincerely, p OriginalSigned By:

L Stephen P. Sands, Project Manager Project Directorate III-2 Division of Reactor Projects - III, IV, Y and Special Projects i Office of Nuclear Reactor Regulation

Enclosures:

1. Byron Station Safety Evaluation Report w/ Attachment

'm 2. Braidwood Station Safety Evaluation Report

'a w/ Attachment

3. Letter dated 6/6/90 cc w/ enclosures:

See next page DOCUMENT TAC 68515/16 SB0 Office: 1-2 PM7PDIII;2 PM/PDIII-2 9 j (A)PD/PDI Surname: e SSands/tg TBoyce M'J JWechselberger Date:

} \ /90 f /d( /90 ()1/Jt /90 g/L/90 n;

_ . . u

P h

' ^

. #* ""8

%'9,, UNITED STATES .j k5 -n

[

NUCLEAR REGULATORY COMMISSION WASHINGTON D.C.20566 I

"***C August 6,1990 Docket 30s. STN 50-454. 50-455 ,

and STN 50-456, 50-457 l

Mr. Thcmas J. Kovach- f Nuclear Licensing Manager  !

Commonwealth Edison Company - Suite 300 l OPUS West III i 1400 OPUS Place l Downers Greve, Illinois 60515  !

SUBJECT:

SAFETY EVALUATIONS OF THE BYRON STATION AND BRAIDWOOD STATION  ;

RESPONSES TO THE STATION BLACK 0UT (SBO) RULE (TAC NOS. 68522,  ;

68523AND68515,6B516) J By letters dated April 17, 1989, March 29, 1990, and March 30, 1990, Commonwealth Edison Company (CECO) submitted responses to the Station Blackout (SBO) rule for Byron Station, Unit Nos. I and 2 and Braidwood Station, Unit Nos. I and 2. The responses were reviewed by the NRC staff and by an NRC contractor, Science Applications International Corporation l (SAIC). Attached as Enclosures 1 and 2 are the NRC-staff ",afety Evaluation Reports (SER)ofthelicensee'sresponsesandtheassociatedSAICTechnical EvaluationReports(TER),SAIC-89/1640 for Byron Station and SAIC-90/1043  !

for Braidwood Station, dated June 14,1990(AttachmentstoEnclosures1and2).

l CECohasproposedusingexistingEmergencyDieselGenerators(EDG)asan alternate AC (AAC) power source for Byron and Braidwood Stations and has submitted-its response in the SB0 generic response format. Based on that i response, the NRC staff has concluded that the Byron and Braidwood Stations do not conform with the SB0 rule, the guidance of Regulatory Guide 1.155, NuclearManagementandResourcesCouncil(NUMARC)documentNUMARC87-00,and l NUMARC 87-00, " Supplemental Questions / Answers and Major Assumptions," dated l December 27,1989 (issued to the industry by NUMARC on January 4,1990). The '

areas of non-conformance are identified in the enclosed SERs.

In conjunction with the above mentioned documents related to the SB0 rule, and )

the guidance provided to the industry by both the NRC and NUMARC, the enclosed letter (Enclosure 3) from Mr. William T. Russell, NRC, to Mr. William Rasin NUMARC,datedJune6,1990,providesfurtherguidanceregardingtheissueof load shedding in the non-blackout (NBO) unit to meet the SB0 requirements for AAC.

L In addition, the following areas may require follow-up inspection by the NRC i staff to verify that the implementation of any modifications, and the supporting documentation which CECO may propose as a result of this evaluation, are adequate to meet the SB0 Rule:

a. Hardware and procedural modifications.

b. SB0 procedures in accordance with R.G. 1.155, Position 3.4, and NUMARC 87-00, Section 4.

1 L ,

L Mr. Thomas J. Kovach August 6,1990

c. Operator staffing and training to follow the identified actions in the 580 procedures,

d. EDG reliability program meeting, as a minimum, the guidelines of RG 1.155,

e. Equipment an'd components required to cope with an SB0 are incorporated in a QA program that meets the guidance of RG 1.155, Appendix A.

f. Actions taken pertaining to the specific recommendations noted in the SER.

TheguidanceprovidedonTechnicalSpecifications(TS)forSB0statesthatthe TS should be consistent with the Interim Commission Policy Statement on Technical Specifications. The NRC staff has taken the position that TS are required for SB0 response equipment. However, the question of how Specifi-cations for the SB0 equipment will be applied is currently being considered generically by the NRC in the context of the Technical Specification Improve-ment Program (TSIP) and remains an open item at this time. In the interim, the NRC staff expects plant procedures to reflect the appropriate testing and surveillance requirements to ensure the operability of, the necessary SB0 equipment. If the staff later determines that TS regarding the SB0 equipment is warranted, licensees will be notified of the implementation requirements.

In closing, a revised response to the SB0 rule, which addresses the areas of non-conformance, should be submitted for staff review within 60 days-from receipt of this letter.- Subject to an acceptable resolution of the identified non-conformances,-the issue of conformance to the SB0 rule remains open at Byron Station, Unit Nos. I and 2 and Braidwood Station, Unit Nos.1 and 2.

Sincerely,

. kdA) ~Y Step n P. Sands, Project Manager Project Directorate 111-2 Division of Reactor Projects --III, IV, V and Special Projects Office of Nuclear Reactor Regulation

Enclosures:

1. Byron Station Safety Evaluation Report w/ Attachment

2. Braidwood Station Safety Evaluation Report

-w/ Attachment

3. Letter dated 6/6/90 cc w/ enclosures:

See next page

Mr. Thomas J. Kovach Byron /Braidwood Power Station Comonwealth Edison Company Unit Nos. 1 and 2

- CC'-

p Mr. Gabe Toth U._ S. Nuclear Regulatory Comission L Westinghouse Electric Corporation Byron / Resident Inspectors Office L Energy Systems Business Unit 4448 North German Church Road Post Office Box 355, Bay 236 West Byron, Illinois 61010 Pittsburgh, Pennsylvania 15230 Ms. Lorraine Creek Joseph Gallo, Esq. Rt. 1, Box 182  ;

L Hopkins and Sutter Manteno, Illinois 60950 '

88816th Street, N.W.

Suite 700 Mrs. Phillip B. Johnson Washington, D.C. 20006 1907 Stratford Lane Rockford, Illinois 61107 Regional Administrator U. S. NRC, Region III Douglass Cassel, Esq.

l 799 Roosevelt Road, Bldg. #4 109 N. Derarborn Street Glen Ellyn, Illinois 60137 Suite 1300 Chicago, Illinois 60602 Ms. Bridget Little Rorem Appleseed Coordinator David C. Thomas, Esq.

117' North Linden Street 77 S. Wacker Drive I: Essex, Illinois 60935 Chicago, Illinois 60601 1

Mr. Edward R. Crass Michael Miller, Esq. '

Nuclear Safeguards and Licensing Sidley and Austin Division .

One First National Plaza Sargent & Lundy Engineers Chicago, Illinois 60690 55 East Monroe Street Chicago,_ Illinois 60603 George L. Edgar Newman & Holtzinger, P.C.

U. S. Nuclear Regulatory Comission 1615 L Street, N.W.

Resident Inspectors Office Washington, D.C. 20036 RRf1, Box 79 Braceville, Illinois 60407 Comonwealth Edison Company Byron Station Manager Mr. Thomas W. Ortciger, Director 4450 North German Church Road Illinois Emergency Services Byron, Illinois 61010 and Disaster Agency l 110 East Adams Street Illinois Department of I Springfield, Illinois 62706 Nuclear Safety  ;

Office of Nuclear Facility Safety l Robert Neumann 1035 Outer Park Drive Office of Public Counsel Springfield, Illinois 62704 State of Illinois Center 100 W. Randolph l

. Suite 11-300 l Chicago, Illinois 60601 l 1

1

,