ML20128B821

Confirms Granting Temporary Waiver of Compliance from TS LCO Requirement Contained in Plant TS Section 3.3.2.G.1.a, Low Temp Overpressure Protection, Requiring LTOP Porvs to Be Set at 435 Psig

ML20128B821
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	01/29/1993
From:	Zwolinski J Office of Nuclear Reactor Regulation
To:	Kovach T COMMONWEALTH EDISON CO.
References
TAC-M85645, TAC-M85646, NUDOCS 9302030184
Download: ML20128B821 (4)

Text

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% / January 29, 1993 Docket Nos. 50-245 and 50-304 s

Mr. Thomas J. Kovach Nut. lear Licensing Manager Commonwealth Edison Company-5uite 300 OPUS West III 1400 OPUS Place Downers Grove, Illinois 60515

SUBJECT:

ZION STATION, UNITS 1 AND 2 - TEMPORARY WAlVER OF COMPLIANCE FROM TECHNICAL SPEClf! CATIONS SECTION 3.3.2.G.I.a (TAC NOS. M85645 AND M85646)

This letter confirms the granting of a Temporary Waiver of Compliance from the Technical Specifications (TS) Limiting Condition for Operation (LCO) requirement contained in the Zion Station, Units 1 and 2, TS Section 3.3.2.G.I.a, " Low Temperature Overpressure Protection,' which requires the low temperature overpressure protection (LTOP) power operated relief valves (PORVs) to be set at 435 psig.

Licensee Event Report (LER) 92-19 from the Houston Lighting & Power Company dated December 31, 1992, indicated that some facilities may be setting their LTOP PORVs without considering the pressure drop due to the location of the PORV pressure sensor instrument taps. Based on this information, you commenced an investigation into the operability of your LTOP PORVs. On January 15, 1993, you completed a preliminary operability assessment that concluded'that the reactor coolant pump (RCP) and residual heat removal (RHR) pump correction factors could not be accommodated within the current TS setpoint of 435 psig without imposing significant restrictions on RCP operation. On January 26, 1993, after reviewing the means available to raise and raintain reactor coolant system (RCS) temperature, your staff concluded that RHR pump heat and reactor decay heat were inadequate and opened dialogue with the NRC staff to obtain relief from the existing TS setpoint to allow heatup of Unit 2 from the current refueling outage utilizing the RCPs.

In a telephone call on January 28, 1993, the need for this TWOC was discussed-with the NRC staff. This conversation was followed by a letter dated January 28, 1993, in which you formally requested that you be allowed to set the LTOP system below the currently specified 435 psig, at 402 and 407 psig, and gave the basis for the reduced setpoints of the valves. The different setpoints are due to the different locations of the )ressure sensor instrument taps on the hot leg piping. Your staff determined t1ese more conservative LTOP setpoints, using correction factors appropriate for the number of pumps I in operation and the RCS pressure sensor instrument tap location, to ensure l

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Mr. Thomas J. Kovach a compliance with the fracture toughness requirements specified by 10 CFR Part 50, Appendix G, in the event of an analyzed low temperature overpressure event. Since this action ensures the LTOP systems safety function is preserved, no further compensatory actions are required.

In a telephone conversation at 5:00 PM (EST) on January 28, 1993, the NRC staff granted the requested relief to Dave Wozniak of your Zion Station staff.

By copy of this letter, the NRC is confirming the granting of your request for a Temporary Waiver of Compliance to set the LTOP system at less than or equal to 435 psig, setting one PORV at 402 psig, and the other at 407 psig, effective 5:00 PM (EST) on January 28, 1993, to expire at 11:59 PM on February 22, 1993. The duration of the TWOC is intended to allow you to start reactor coolant pumps, heatup to normal operating temperature, determine if there is any need to cooldown for repairs, perform any required cooldown, and heat back up.

The NRC's basis for granting this Temporary Waiver of Compliance is our agreement with your staff's determination that lowering the PORV setpoints by the specified amounts accounts for the pressure drop due to the location of the PORV pressure sensor instrument taps. In addition, you committed to submit a TS amendment request prior to the expiration of this TWOC that will resolve this issue for the long-term by relocating the LTOP setpoint to an owner controlle'i Pressure and Temperature Limits Report.

The NRC staff agrees that your request for a Temporary Waiver of Compliance meets the eligibility criteria of 10 CFR 51.22(c)(9) and that, pursuant to 10 CFR 51.22(b), no environmental impact statement need be prepared.

Sincerely, Cl&nd EQnd Dy:

John A. Zwolinski, Assistant Director for Region III Reactors Division of Reactor Projects - III/IV/V Office of Nuclear Reactor Regulation cc: See next page DISTRIBUTION: Docket File NRC & Local-PDRs PDIII-2r/f T. Murley F. Miraglia J. Partlow J. Roe J. Zwolinski J. Dyer C. Moore C. Shiraki OGC D. Hagan G. Hill (4) W. Jones C. Grimes W. Forney J. Strosnider R. Jones A. Thadani J. Richardson ACRS (10) OT'A OC/LFDCB PDIII-2 p/f J. Lieberman H. Boyle B. Clayton RIII

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. Mr. Thomas J. Kovach Zion Nuclear Power Station Commonwealth Edison Company Unit Nos. I and 2 cC! j Michael 1. Miller, Esquiru Sidley and-Austin 1 One First National Plaza  !

Chicago, Illinois 60690 i Dr. Cecil Lue-Hing )

Director of.Research and Development Metropolitan Sanitary District of Greater Chicago 100 East Erie Street Chicago, Illinois 60611 Phillip Steptoe, Esquire Sidley and Austin One first National Plaza Chicago, Illinois 60603 Mayor of Zion Zion, Illinois 60099 Illinois Department of Nuclear Safety Office of Nuclear facility Safety 1035 Outer Park Drive Springfield, Illinois 62704 U. S. Nuclear Regulatory Commission Resident Inspectors Office 105 Shiloh Blvd.

Zion, Illinois 60099 Regional Administrator, Region Ill V. S. Nuclear Regulatory Commission 799 Roosevelt Road, Bldg. #4 Glen Ellyn, Illinois 60137-Robert Neumann i Office of Public Counsel l

State of Illinois Center 100 W. Randolph-l Suite 11-300 l Chicago, Illinois 60601 l

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.. . Mr. Thomas J. Kovach. compliance with the fracture' toughness requirements specified by 10 CFR Part 50, Appendix G, in the event _of an analyzed low temperature overpreWure esent. Since this action ensures the LTOP systems safety function is preserved, no further compensatory actions are required.  ;

In a telephone conversation at 5:00 PM (EST) on January 28, 1993, the NRC staff granted the requested relief to Dave Wozniak of your Zion Station staff.

By copy of this letter, the NRC is confirming the granting of-your request for a Temporary Waiver of Compliance to set the LTOP system at less'than or equal to 435 psig, setting one PORV at 402 psig, and the other at 407-psig, effective 5:00 PM (EST) on January 28, 1993, to expire at 11:59 PM on February 22, 1993. The duration of the TWOC is intended to allow you to start reactor coolant pumps, heatup to normal operating temperature, determine if there is any need to cooldown for repairs, perform any required cooldown, and heat back up.

The NRC's basis for granting this Temporary Waiver of Compliance is our agreement with your staff's determination that lowering the PORV setpoints by the specified amounts accounts for the pressure drop due to the location of the PORV pressure sensor instrument taps. In addition, you committed to ,

submit a TS amendment request prior to the expiration of this TWOC that will resolve this issue for the long-term by relocating the LTOP setpoint to an owner controlled Pressure and Temperature Limits Report. 1 The NRC staff agrees that your request for a Temporary Waiver of Compliance meets the eligibility criteria of 10 CFR 51.22(c)(9) and that, pursuant to 10 CFR 51.2?(b), no environmental impact statement need be prepared.

Sincerely, Ctyn:1 Signed 0yi John A. Zwolinski, Assistant Director for Region III Reactors Division of Reactor Projects - III/IV/V office of Nuclear Reactor _ Regulation cc: See next page DISTRIBUTION: Docket File NRC & Local PDRs PDIII-2r/f T. Murley F. Miraglia J. Partlow J. Roe J. Zwolinski J. Dyer C. Moore C. Shiraki OGC D. Hagan G. Hill (4) W. Jones C. Grimes W. Forney J. Strosnider R. Jones A. Thadani J. Richardson ACRS (10) OPA OC/LFDCB P.III-2 p/f J. Lieberman- M. Boyle B. Clayton RIII g ]oncurred by telephone OFC lL4 P III-2 PM:PDIII-2d D:PDIII-2 SC:RIII*

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