ML20212H267

Requests NRC Approval of 861205 Application for Amends to Licenses DPR-39 & DPR-48,revising Tech Spec Sections 3/4.3.2 Re Pressurization & Sys Integrity by 870305,prior to Expiration of 30-day Period Allotted for Public Comments

ML20212H267
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	02/26/1987
From:	Leblond P COMMONWEALTH EDISON CO.
To:	Harold Denton Office of Nuclear Reactor Regulation
References
2769K, NUDOCS 8703060058
Download: ML20212H267 (3)

Text

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\ / Address Reply to: Post Omco Box 767 As' Cnoa0o, tenois 60600 0767 February 26, 1987 Mr. Harold R. Denton, Director

-Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC. 20555

Subject:

Zion Nuclear Power Station Units 1 and 2 Proposed Amendment to Facility Operating License Nos. DPR-39 and DPR-43 Heatup and Cooldown Limitations NRC Docket Nos. 50-295 and 50-304

Reference:

December 5, 1986 letter from P.C. LeBlond to H.R. Denton.

Dear Mr. Denton:

The referenced letter transmitted a proposed amendment to Facility Operating License Nos. DPR-39 and DPR-48, Appendix A, Sections 3/4.3.2 -

Pressurization and System Integrity. That change provided a revised set of heatup and cooldown limitation curves for Zion Station. The referenced letter stated that Zion Unit 2 was expected to acquire 8 EFPY of exposure in mid-February of 1987. This would result in the existing heatup and cooldown curves containing outdated guidance.

The scheduled start of the upcoming Unit 2 refueling outage was expected to be on February 19, 1987. This scheduled outage start date was believed to be consistent with Zion Unit 2's accumulation.of exposure.

However, Zion Unit 2 performed exceptionally well during the period from December 5, 1986 through February 2, 1987, with an overall capacity factor of 99.3L This resulted in the accumulation of 8 EFPY of exposure sooner than was previously expected.

In addition, the Zion Unit I refueling outage that has been in progress since September of 1986 has been extended on three separate occasions. The estimated return to service date as of December 5, 1986 was January 15, 1987. The three outage extensions are discussed below.

The completion of the Unit I refueling outage was delayed from January 15, 1987 to February 15, 1987, due to the increased scope of outage related work required to repair the internals of the Zion Unit 1 main f

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'Mr. H.R. Denton February 26, 1987 generator. Subsequent to that, the completion date was revised a second time from February 15 to February 23, 1987 due to damage to a control rod guide tube contained in the upper internals package. The extensive repairs necessitated by the recent catastrophic failure of the IB diesel generator also contributed to this second delay.

. Unit l's return to service was delayed a third time from February 23 to the currently existing date of March 3, 1987. This delay was due to additional repairs to the Unit I diesel generators, additional testing of newly installed modifications, and the implementation of an error-free startup program requiring increased levels of review.

The delays to the Unit I refueling outage discussed above would have resulted in a dual unit shutdown if Unit 2 were to have initiated its refueling outage as previously scheduled on February 19, 1987. The need to avoid a two-unit cold shutdown resulted in the need to delay the initiation of

-the previously scheduled Unit 2 refueling outage. The revised Unit.2 refueling outage start date is currently March 5, 1987.

The extended operation of Zion Unit 2 has resulted in exceeding 8 EPPY of exposure prior to the start of the scheduled refueling outage. In addition, unanticipated licensing delays have prevented the approval of the license amendment transmitted with the referenced letter. The increased scope of work associated with the Unit I refueling outage and the unanticipated licensing delays are events outside of the control of Commonwealth Edison Company.

The currently existing outage schedule for the Zion Unit 2 refueling outage calls for the initiation of a cooldown to cold shutdown conditions beginning on March 7, 1987. The ongoing period for public comment on the-proposed amendment will expire on March 12, 1987, thus allowing for issuance ,

of the license amendment on March 13, 1987. This would result in a 7-day delay in achieving cold shutdown conditions.

The work associated with the disassembly,_ refueling, steam generator eddy current, and reassembly of-the Zion Unit 2 reactor coolant system has been designated as critical path for the upcoming refueling outage. Thus, a 7-day delay in.the. achievement of cold shutdown would result in a 7-day outage extension. In addition, numerous contracts have already been established for work to be performed during this outage. A 7-day delay in the performance of this work may result in contractual penalties to Commonwealth Edison Company.

This 7-day delay, along with the loss of generation, coupled with the existing contractual liabilities constitute an unnecessary financial hardship for Commonwealth Edison Company.

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.k Mr. H.R. Denton February 26, 1987 Based upon.the above discussion, Commonwealth Edison Company believes circumstances exist that warrant the issuance of the proposed amendment prior

,to the expiration of the thirty day time period normally allotted for public comments. Therefore, it is requested that the NRC approve the requested license amendment contained in the referenced letter by March 5, 1987.

Commonwealth Edison Company personnel are available to discuss this matter at your convenience.

If you have any questions regarding this matter, please direct them to this office.

Very truly yours, P. C. LeBlond Nuclear Licensing Administrator la cc: NRC Resident Inspector - Zion J.-A. Norris - NRR M. C. Parker - IDNS SUBSCRIBED'AND S to before me--this dit ay of Mr Duld h L , 1987 wlN 0 LL W Notary Public 2769K

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