ML20203L446

Forwards Rev 1 to Interim Compensatory Measures,Reflecting Revs to Request for Schedular Exemption from 10CFR50.48 Requirements,To Ensure Compliance w/10CFR50.12 Requirements, Per Generic Ltr 83-33

ML20203L446
Person / Time
Site:	Quad Cities
Issue date:	08/19/1986
From:	Wojnarowski J COMMONWEALTH EDISON CO.
To:	Harold Denton Office of Nuclear Reactor Regulation
Shared Package
ML20203L449	List: ML20203L446 ML20203L454
References
1996K, GL-83-33, NUDOCS 8608260266
Download: ML20203L446 (2)

Text

'

P ,

- Commonwealth' Edison A.

One First National Plaza, Chicago, Cnois Address Reply t2 Post Omco Box 767 Chicago, Illinois 60690 0767

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• l August 19, 1986  !

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Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation i U.S. Nuclear Regulatory Commission Wasnington, DC 20555 -

Subject:

Quad Cities Station Units 1 and 2 10 CFR 50.48 and Appendix R Schedular Exemption Request -

Compliance with Revised 10 CPR 50.12 NRC Docket Nos. 50-254 and 50-265 1

References (a): Letter from B. Rybak to H. R. Denton dated December 18, 1984.

(b): Letter from B. Rybak to H. R. Denton

. dated March 1, 1985.

(c): Letter from J. R. Wojnarowski to H. R.

Denten dated December 4, 1985.

Dear Mr. Denton:

This letter is provided to document compliance of our previously submitted 10 CPR 50.48 schedular exemption request for Quad Cities Station with the criteria in 10 CFR 50.12. In addition, updated Interim Compensatory Measures (Enclosure 1) and an updated Appendix R modification schedule (Enclosure 2) are provided.

In the reference (b) letter, Commonwealth Edison requested schedular exemption to the requirements of 10 CPR 50.48 for specific Appendix R modifi-

, cations. The reference (c) letter supplemented our request by providing an updated schedule. These schedules reflect the original modifications for which we had previously requested schedular exemptions as well as new modifications resulting from our re-verification effort. Both old and new modifications were described in Enclosure II to reference (a), which also documented compensatory measures instituted until the modifications are complete.

Since the issuance of Appendix R, Commonwealth Edison has maintained an aggressive program to ensure that compliance with the applicable require-ments is achieved in a thorough and expeditious manner. As described in Enclosure I to refere1ce (a), we made a series of submittals documenting our efforts to comply with the rule which culminated in the issuance of the NRC Safety Evaluation Report in late 1982. However, as a result of industry-wide l~ concerns regarding the proper interpretation of Appendix R requirements, j Generic Letter 83-33 was issued to provide clarification. Commonwealth t Edison participated in a number of meetings and workshops and in late 1983, initiated a major re-verification effort to assure compliance with the O(

I B608260266 860819 PDR l j ADOCK 05000254 j PDR :,

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H. R. Denton August 19, 1986 rece-' clarified intent of Appendix R. This effort resulted in additional modifs . ions and exemption requests, both technical and schedular. It is j large* his situation which, in spite of our best efforts, prevented Common-

! wealt' .dison, as well as many other utilities, from achieving compliance with tne schedular requirements of 10 CFR 50.48.

We believe the circumstances described above resulted from an industry-wide misunderstanding of the NRC's intent regarding Appendix R and were therefore beyond our direct control. As additional guidance became available, we reacted promptly to re-evaluate our compliance and initiate additional modifications as needed. Our current schedule represents our best effort to complete all required work as soon as possible considering the extensive scope of work involved. Our commitment to expeditiously achieve compliance is demonstrated by our track record of completing the modifications on schedule and, in some cases, ahead of schedule.  ;

As previously stated, Enclosure 2 of reference (a) identified the Interim Compensatory Measures instituted for incomplete modifications.

Enclosure 1 to this letter provides revised and updated Interim Compensatory Measures currently in effect. As requested by your staff, references to complete modifications or modifications where no interim measures are required have been deleted. In addition, an updated modification schedule is provided in Enclosure 2.

Based on the above discussion, Commonwealth Edison believes our schedular exemption request for Quad Cities Station complies with the criterion in 10 CFR 50.12(a)(2)(v).

Please address any questions you may have regarding this transmittal to this office.

One signed original and five (5) copies of this letter and the enclosures are provided for your use.

Very truly yours, J. R. Wo narowski Nuclear Licensing Administrator Im Enclosures cc: R. Bevan - NRR NRC Resident Inspector - Quad Cities 1996K

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