ML20087F353
| ML20087F353 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 03/07/1984 |
| From: | Rybak B COMMONWEALTH EDISON CO. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| 8209N, IEB-80-17, NUDOCS 8403190075 | |
| Download: ML20087F353 (3) | |
Text
. - _ _ _ _ _ _ _ _ _.
[N Commonwealth Edison
~
{ ;,) one First NT,tional Ptszt. Chicago. Illinois Address Reply to. Post Offico Box 767 s
ChtCago. Ilknois 60690 March 7, 1984 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S.
Nuclear Regulatory Commission Washington, DC 20555
Subject:
Quad Cities Station Unit 1 Request that Confirmatory Orders Related to I.E.Bulletin 80-17 Be Rescinded, and Removal and Deletion of I.E.Bulletin 80-17 Actions NRC Docket No. 50-254 References (a):
I.E.Bulletin 80-17 and Supplements 1, 2, 3 and 4.
J. G. Keppler letters to Cordell Reed dated July 3, July 16, July 22, August 22 and December 19, 1980.
(b):
V. Stello, Jr. letter to Cordell Reed dated October 2, 1980.
(Confirmatory Orders)
(c)!
T.
A.
Ippolito letter to J.
S. Abel dated Jane'ry 9, 1981.
(d):
D. G. Eisenhut letter to All BWR Licensees dateo December 9, 1980.
(e):
R.
Janecek to letter to J.
G. Keppler dated September 2, 1980.
(f):
D. B. Vassallo letter to D. L. Farrar dated June 24, 1983.
Dear Mr. Denton:
Reference (f) transmitted Orders requiring installation of the long-term BWR scram discharge modification for each unit at Quad Cities in conformance with the Staff's Generic SER before startup
.after the first refueling commencing after September 1, 1984.
These modifications are being implement?J during the current refueling outage at Quad Cities Unit 1.
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0403190075 840307 PDR ADOCK 05000254 1
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H. R. Denton March 7, 1984 Generally, the modifications include two Scram Discharge Instrument Volume (SDIVs), impreved 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 of the foremen-tioned NRC Generic SER.
Because the modified Quad Cities Unit 1 scram discharge system satisfies the Long Term Program Criteria of the Generic SER, and because this modified system now reliably provides to the control room ooerators all information concerning system operation necessary to ensure safe operation of 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 thru 4 and the Confirmatory Order, Reference (b), will be removed from Quad Cities Unit 1 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.
The system which initiates control rod insertion on low pressure in the control rod drive control air header.
The Order, Reference (c), describes this automatic air header dump system as a short term provision which provides protection against water accumulation in the Scram Discharge Volume (SDV) headers in the event of degraded air conditions in BWR control air supply systems.
As acknowledged in the Generic SER, improved _ hydraulic coupling resulting from permanent modifications such a those to be completed by Quad Cities Unit 1 will obviate the need for an automatic air header dump system.
In fact, certain licensees identified in Table 1 of the SER were excluded from the air dump requirements because they already have adequate SDV - instrument volume hydraulic coupling.
3.
Testing of the SDIV level switches after each scram event as required by I.E.Bulletin 80-17 Supplement 3 will no longer be performed.
Supplement 3 specifi-cally acknowledges that this testing is not required subsequent to the long term modifications.
e H. R. Denton 3-March 7, 1984 4.
Purging the SDV vent after each scram event as committed in Reference (e) will no longer be performed.
We believe that I.E.Bulletin 80-17 (including supplements) and the References (b) and (c) Confirmatory Orders are implicity applicaule only until modifications satisfying the Long Term Program Criteria of the Generic SER are implemented.
Furthermore, we believe that these modifications at Quad Cities Unit 1 provide equivalent information to the operator, with a greater level of safety and reliability than the Continuous Mor>itoring System required by the Confirmatory Order dated October 2, 1980 and that these modifications ensure adequate hydraulic coupling to allow removal of the automatic air header dump system.
Considering the above, we hereby request that the October 2, 1980 and January 9, 1981 Orders as they pertain to Quad Cities Unit 1 be rescinded.
I Please direct any questions you may have concerning this matter to this office.
One signed original and sixty (60) copies of this letter is provided for your use.
Very truly yours, B. Rybak Nuclear Licensing Administrator 1m cc:
R. Bevan - NRR NRC Resident Inspector - Quad Cities l
8209N l
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