ML20151S283
| ML20151S283 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 04/20/1988 |
| From: | Ross T Office of Nuclear Reactor Regulation |
| To: | Bliss H COMMONWEALTH EDISON CO. |
| Shared Package | |
| ML20151S287 | List: |
| References | |
| TAC-57284, TAC-57285, TAC-64493, TAC-64494, NUDOCS 8804280270 | |
| Download: ML20151S283 (3) | |
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April 20, 1988 5
l OISTRIBtlTION:
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Docket N l
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LLuther OGC-Rockville Mr. Henry Bliss Nuclear Licensing Manager Connonwealth Edison Company Post Office Box 767 Chicago, Illinois 60690
Dear Mr. Bliss:
SUBJCLT: REVISED SAFETY EVALUATION FOR EXEMPTION FROM 10 CFR 50, APPENDIX R SECTION III.G.1 (TACNOS. 57284,57285,64493,AND64494)
By letter dated December 1,1987, the NRC staff issued a Safety Evaluation Report (SER) to address exemption requests from the regulatory requirements of 10 CFR 50, Appendix R Section III.G submitted by Commonwealth Edison Company (CECO, the licensee) for the Quad Cities Nuclear Power Station (QCNPS).
Subsequently, CECO reviewed nur SER for consistency with the as-built configuration of QCNPS and provided us with their documented connents, as well as applicable justifications, on February 19, 1988. The NRC staff evaluated these connents and incorporated those that were germaine.
Consequently, in i
response to CECO comments offered on February 19, 1988, we revised our previous SER on Appendix R.Section III.G. The revised SER is enclosed herein, and shall replace the previous SER of December 1, 1987 in its entirety. However, the cover letter for this previous SER is still appropriate.
Sincerely,
/s Thierry Ross, Project Manager i
Project Directorate III-2 Division of Reactor Projects - III, IV, V and Special Projects
Enclosure:
As stated l
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Futhermore, in the letter dated November 20, 1987 CECO notified the staff that a portion of an exemption request,10.0 '"Hot Shutdown Repairs (Fuse Replacements)" in the September 30, 1987 letter, was no longer necessary due to a non-Appendix R plant modification to be accomplished during the Unit I refueling outage. Consequently, that part of the exemption request applicable to the Unit 1 Reactor Core Isolation Cooling System iriboard steam supply isolation' valve was withdrawn. of thisxletter contains the NRC staff SE, which encompasses all the aforementioned CECO submittals except for two subject requests described below.
It was the staff's conclusion that the manual actions, including hot shutdown repatrs, proposed by CECO,to resolve concerns of high impedance faults, electrical isolation deficiencies, and, spurious operations were acceptable; and applicable exemptions requests (for performing hot shutdown; repairs) should be granted.
The staff also concluded that'devia+1ons described by the July 17, 1987 letter would not compromise the safe shu,tcc,4 capability at QCNPS and therefore, are acceptable.
Furthermore, the staff recognizes that ICMs specified in of the reevaluation report dated December 18, 1984 are no longer required.
It should also be noted, CECO submitted two additional letters, not previously mentioned, dated July 23,,1987 and December 2,1987. These letters were provided to the staff for information purposes only, as such no formal evaluation was performed.
Technical exemption requests from Section III.'O of Appendix R, contained in s of the December 18, 1984 reevaluation report, related to fire s
protection features for selected plant areas will be evaluited by the staff in s
a separate SE to be issued later. ' A schedular exemption from compliance with 10 CFR 50.48 was requested by letter dated November 20h1987. This subject will also be evaluated separately and issued later. The' legal regulatory "Exemption", that exempts certain hot shutdown repairs at QCNPS from compliance with requirements of 10 CFR 50, Appendix R.Section III.G.1 will be issued to CECO and published in the Federal Register by other separate co'erespondence, which should be forthcoming.
In response to Ceco conrnents dated February 19, 1988, the NRC staff hasN revised the Appendix R Safety Evaluation enclosed a in letter dated December 1, 1987. Consequently, the SE enclosed herein shall be considered to supersede s the Decen.ber 1,1987 SE'in its ent.irety, f
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Thierry M. Ross, Project Manager
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Project Directorate III-2 Division of Reactor Projects - III, IV, V and Special Projects
Enclosures:
- 1. Safety Evaluation cc w/eaclosures:
See next page
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1 Dockets Nos. 50-254 DISTRIBUTION:
and 50.265 Docket File NRC & Local PDRs GHolahan PDIII-2 r/f LLuther PDIII-2 Plant File Mr. L.D. Butterfield, Jr.
TRoss ACRS(10)
Nuclear Licensing Manager OGC-Rockville EJordan Connonwealth Edison Company JPartlow Post Office Box 767
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Chicago, Illinois 60690
/
Dear Mr. Butterfield:
/
SUBJECT:
INTERIM COMPENSATORY MEASURES AND REQUEST FOR, EXEMPTION FROM 10 CFR PART 50, APPENDIX R, SECTION IlhG.1 REGARDING HOT SHUTDOWN REPAIRS
/
(TACNOS. 57284, 57285, 64493 AND 64494)/
/
By letter dated December 18, 1984, Connonwealth Edison Company (CECO, the licensee ) submitted a reevaluation report pertaining'to 10 CFR Part 50, Appendix R (Fire Protection Program) for Quad Cities Nuclear Power Station (QCNPS) in response to NRC staff positions prescr.ibed in Generic Letter 83 33, dated October 19, 1983.
This report identified Interim Compensatory Measures (ICMs) that were being conducted at QCNPS for,an interim period (until completion of Appendix R required hardware modifications) to ensure safe shutdown capability of Units 1 or 2 for postulated fire evants.
Based on a review of the aforementioned report, the' NRC staff has detennined that the previous staff Safety Evaluation (SE) and approval of safe and alternative shutdown capauilities at QCNPS, issued December 30, 1982, remains valid.
f However, during the staff's review, additional information was requested from CECO concerning the affect of fire, induced high impedance faults and electrical isolation deficiencies upon safe 3hutdown capability at QCNPS for certain fire events. These issues were not explicitly addressed in the reevaluation report.
Additional information was also'sou'ght on the ICMs.
CECO responded to the staff's inquiries,with letters dated December 30, 1986, March 13, 1987, July 15, 1987, and October 9, 1987.
In these submittals, Ceco proposed conducting,certain manual o'perations, including) hot shutdownre issues above, and resolve problems with fire-induced spurious operations that were subsequently self-identified.
In general,'Section III.G.1 requirements have been interpreted to prohibit hot shutdown repairs. Consequently, CECO submitted letters dated January 12, 1987, September'30, 1987, October 1, 1987, November 20, 1987, and November 30,1987, requesting approval for several exemptions from Appendix R,Section III.G.1 which would' allow such repairs in order to achieve and maintain hot shutdown.
In the March / 13, 1987 letter,CECostatedthatbecausealltherequiredsafe s
shutdown hardware modifications had been completed, their corresponding ICMs would no longer be necessary. Also, in a July 1/, 1987 letter, several deviations between the present safe shutdown program, and what was approved in the previous NRC SE (dated December 30, IM2), were described by Ceco and i
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