ML20217M299

Forwards Request for Addl Info Re Restart Issues for Plant, Units 1 & 2

ML20217M299
Person / Time
Site:	Quad Cities
Issue date:	04/03/1998
From:	Pulsifer R NRC (Affiliation Not Assigned)
To:	Kingsley O COMMONWEALTH EDISON CO.
References
NUDOCS 9804080063
Download: ML20217M299 (6)

Text

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WASHINGTON, D.C. 30006 0001

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April 3, 1998 Mr. Oliver D. Kingsley, President Nuclear Generation Group Commonwealth Edison Company Executive Towers West ill 1400 Opus Place Suite 500 Downers Grove,IL 60515

SUBJECT:

REQUEST FOR INFORMATION REGARDING RESTART ISSUES FOR QUAD CITIES NUCLEAR POWER STATION, UNITS 1 AND 2

Dear Mr. Kingsley:

Various conference calls and meetings have been held with Commonwealth Edison Company (Comed) regarding restart issues for Quad Cities, Uruts 1 and 2. In order for the NRC to have a better understanding of these issues, and the plant status regarding these issues, the staff -

requests that Comed provide the following information before restart of either unit.

.1.

67-Dev Limitina Condition for Operation and Administrative Technical Reauirement The safe shutdown makeup pump (SSMP) which has a 67-day Technical Specification (TS)

.imiting condition for operation (LCO) is used to achieve and maintain post-fire safe shutdown for both units, and 67-day administrative technical requirements (ATRs) are used for other equipment that is required to achieve and maintain post-fire safe shutdown. The staff is concemed that these TS and administrative ATRs reduce the availability of post-fire safe shutdown systems and components and create situations during which the post-fire safe shutdown capability is degraded or unavailable for excessive periods during power operation of one or both units. It appears that the current LCOs can result in plant configurations that do not satisfy the undertying purpose of the regulatory requirements of Appendix R to 10 CFR Part 50, i.e., to ensure that at least one means of achieving and maintaining safe shutdown conditions will remain available during and after any postulated fire in the plant. In a safety evaluation report (SER) for Appendix R to 10 CFR Part 50, items Ill.G and Ill.L that was transmitted to Comed by letter of December 30,1982, the staff stated, "Because the makeup pump provides a comparable safe shutdown function to that of the RCIC [ Reactor Core isolation Coolmg) pump, the licensee will propose technical specifications equivalent to those for the RCIC pump in order to assure maximum availability for the makeup pump." This SER was incorporated into the fire protection license condition for the plant. However, it appears that the TS LCO that was adopted snd approved by the staff is not comparable to the RCIC LCO. The staff requests that Comed re-examine the subject TS LCOs and the ATRs and submd a response that addresses the E"c ;^g.

a' In the short-term, to support plant restart and to maximize the availabsisty of post-fire safe shutdown systems and components, the staff requests that Comed commit to establish administrative TS LCOs and ATRs for post-fire safe shutdown systems and components

. that are comparable to those specified in the TS for other plant systents and components g g

that provide comparable safe shutdown functions for accidents other than fire.

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b. In the long-term, to maximize the availability of post-fire safe shutdown systems and components, the staff requests that Comed amend the TS LCO for the SSMP and the g\\

ATRs for other post-fire safe shutdown systems and components to be equivalent to GM, y at' enc []LF BENTES COPY 9004090063 900403 PDR ADOCK 05000254 P

PDR O

,2 O. Kingsley those cumently specified in the TS for other plant systems and components that provide comparable safe shutdown functions for accidents other than fire.

For any plant structures, systems, and components that previously were not included in the safe shutdown analysis (SSA) or safe shutdown methodology, but whkh will be included in the SSA and safe shutdown methodology that will be in place at the time of plant restart (e.g., station blackout diesel) Comed should identify all such plant structures, systems, and components, provide the applicable LCOs, and state whether they are govemed by plant TS or ATRs. In its response, in addition to addressing the undertying purpose of Appendix R and the intent of the SER of December 30,1982, Comed should address the regulatory requirements of 10 CFR 50.36, " Technical Specifications," and the need to establish LCOs for structures, systems, and components which operating experience or probabalistic risk assessment has shown to be significant to public health and safety.

2. Fire Risk Assessments During a public meeting on June 2,1997, Comed discussed with the staff its efforts to reduce the fire risk from that reported in the Quad Cities individual Plar t Examination of Extemal Events assessment. Subsequently, the staff has had additional discussions with Comed regarding risk reduction. The staff requests that Comed submit the results of its risk reduction effort prior to restart. In this submittal, Comed should fully describe the contributors to fire risk, including Appendix R exemptions, dual unit dependencies, and manual operator actions; the methodology applied; the results of the analysis; any permanent or compensatory actions taken or planned to 1

reduce the fire risk (e.g., the improved altemate shutdown method) and the reduction achieved by any such action.

With respect to potential contributions to fire risk from Appendix R exemptions, Comed should identify the areas with exemptions and provide an estimation of their contribution to the risk.

Comed should also discuss whether or not areas with exemptions could or should be modified to achieve risk reductions over the short-or long-term. This discussion should consider the feasibility of changing the current altemative shutdown capability over the long-term to the protection of redundant safe shutdown systems and components as specified in Section Ill.G.2 of Appendix R. To the extent that a high risk area does not have any Appendix R exemptions, Comed should identify the area and the associated fire risk. For these areas, Comed should also consider the result of changing the current altemative shutdown capability to the protection of redundant safe shutdown systems and components specified in Section Ill.G.2 of Appendix R.

To the extent that the risk reduction effort is not completed prior to plant restart, Comed should fully describe its future plans.

3. Unreviewed Safety Questions From diamaa%s with Comed, the staff understands that Comed has determined that its revised SSA and changes to the post-fire safe shutdown methodology have resulted in at least three unroviewed safety questions (USQs). The staff also understands that Comed will perform an operability evaluation in accordance with the guidance of Generic Letter 91-18, "Information to Licensees Regarding NRC inspection Manual Section on Resolution of Degraded and Nonconforming Conditions," Revision 1, to support plant resta 1 with the USQs. The staff requests that prior to plant restart, Comed (1) determine what USQs exist with respect to a

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O. Kin 0sley Appendoc R, (2) submit the license amendments required to address the USQs, and (3) submit the bases for restarting the plant with USQs.

In addition, in light of the programmatic concems with the 10 CFR 50.59 safety evaluation process identified through Comed's self-assessment efforts, the staff also requests that Comed describe what process enhancements and/or other actions that were implemented to ensure that the conclusions reached that other activities related to Appendix R do not constitute an unroviewed safety question, are valid.

4. Lona Ranae Plans From daama% with Comed, the staff understands that Comed plans to implemord additional long-term corrective actions after plant restart. These actions include the installation of an independent safe shutdown pump (ISP) and corresponding implementation of a safe shutdown methodology which win consist of providing unit specific and dedicated reactor injection capability for safe shutdown. The staff requests that prior to plant restart, Comed submit a description and status of its long-term plans for the SSA and safe shutdown methodology. As a minimum, the submittal should address the specific plant modifications that will be implemented, the schedule for modification implementation, the impacts the modifications will have on the SSA and methodology that will be in place at the time of plant restart, and the extent to which the modifications will reduce dual unit dependencies.

Please contact the staff if you have questions or need clarification of these items.

Sincerely, J

Robert M. Pulsifel, Project Manager Project Directorate lil-2 Division of Reactor Projects - lil/IV Office of Nuclear Reactor Regulation Docket Nos. 50-254,50 265 cc w/onci: See next page

4 O. Kings'.,y

-3 April 3, 1998 Appendix R, (2) submit the license amendments required to address the USQs, and (3) submit the bases for restarting the plant with USQs.

In addition, in light of the programmatic concems with the 10 CFR 50.59 safety evaluation process identified through Comed's self-assessment enorts, the staff also regisests that Comed describe what process enhancements and/or other actions that were implemented to ensure that the conclusions reached that other activities related to Appendix R do not constitute an unreviewed safety question, are valid.

4. Lona Ranoe Plans From discussions with Comed, the staff understands that Comed plans to implement additional long-term corrective actions after plant restart. These actions include the installation of an independent safe shutdown pump (ISP) and corresponding implementation of a safe shutdown

. methodology which will consist of providing unit-specific and dedicated reactor injection capability for safe shutdown. The staff requests that prior to plant restart, Comed submit a description and status of its long-term plans for the SSA and safe shutdown methodology. As a minimum, the submittal should address the specific plant modifications that will be implemented, the schedule for modification implementation, the impacts the modifications will have on the SSA and methodology that will be in place at the time of plant restart, and the extent to which the modifications will reduce dual unit dependencies.

Please contact the staff if you have questions or need clarification of these items.

Sincerely, Orig. signed by Robert M. Pulsifer, Project Manager Project Directorate lll-2 Division of Reactor Projects - lil/IV Office of Nuclear Reactor Regulation Docket Nos. 50-254, 50-265 cc w/ encl: See next page Distribution:

Docket File PUBLIC PDill-2 r/f '

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O. Kingsley Quad Cities Nuclear Power Station.

Commonwealth Edison Company Units 1 and 2 cc:

Michael I. Miller, Esquire Commonwealth Edison Company Sidley and Austin Site Vice President-Quad Cities One First National Plaza 22710 206th Avenue N.

Chicago, Illinois 60603 Cordova, Illinois 61242-9740 Comrionwealth Edison Company Document Control Desk-Uoonsing Quad Cities Station Manager Commonwealth Edison Company 22710 206th Avenue N.

1400 Opus Place, Suite 400 Cordova, ISnois 61242-9740 Downers Grove, Illinois 60515 U.S. Nuclear Regulatory Commission Mr. Mechsel J. Wallace Quad Cities Resident inspectors Office Senior Vice President 22712 206th Avenue N.

Commonwealth Edison Company Cordova, Illinois 61242 Executive Towers West lli 1400 Opus Place, Suite 900 Chainnan Downers Grove, IL 60515 Rock Island County Board of Supervisors Mr. Gene H. Stanley 1504 3rd Avenue PWR's Vice President Rock Island County Office Bldg.

Commonwealth Edison Company RockIsland, Illinois 61201 Executive Towers West lll 1400 Opus Place, Suite 900 lilinois Department of Nuclear Safety Downers Grove,IL 60515 Office of Nuclear Facility Safety 1035 Outer Park Drive Mr. Steve Perry Spnngfield, Illinois 62704 BWR's Vice President Commonwealth Edison Company Regional Administrator Executive Towers West 111 U.S. NRC, Region lli.

1400 Opus Place, Suite 900 601 Warrenville Road Downers Grove, IL 60515 Lisle, Illinois 60532-4351 Mr. Dennis Farrar William D. Leach Regulatory Services Manager Manager-Nuclear Commonwealth Edison Company MidAmerican Energy Company Executive Towers West til 907 Walnut Street 1400 Opus Place, Suite 500 P.O. Box 657 Downers Grove, IL 60515

. Des Moines, lows 50303 Ms. Irene Johnson, Licensing Director Vice President-Law and Nuclear Regulatory Services Regulatory Affairs Commonwealth Edison Company MidAmerican Energy Company Executive Towers West lli One River Center Place 1400 Opus Place, Suite 500

106 E. Second Street Downers Grove,IL 60515

P.O. Box 4350 '

Devonport, Iowa 52606

e O. Kingsley Quad Cities Nuclear Power Plant Commonwealth Edison Company Units 1 and 2 Commonwealth Edison Company Reg. Assurance Supervisor-Quad Cities 22710 206th Avenue N.

Cordova, Illinois 61242-9740

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