ML20236W469

Forwards Safety Evaluation Accepting Util Submittals Re Manual Actions,Including Hot Shutdown Repairs to Resolve Concerns of High Impedance Faults & Electrical Isolation Deficiencies,W/Stated Execeptions

ML20236W469
Person / Time
Site:	Quad Cities
Issue date:	12/01/1987
From:	Ross T Office of Nuclear Reactor Regulation
To:	Butterfield L COMMONWEALTH EDISON CO.
Shared Package
ML20236W471	List: ML20236W469 ML20236W485
References
GL-83-33, TAC-57284, TAC-57285, TAC-64493, TAC-64494, NUDOCS 8712080045
Download: ML20236W469 (3)

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' UNITED STATES

- a NUCLEAR REGULATORY COMMISSION l lh WASHINGTON, D. C. 20655 i.

h,,**.***, . December 1, 1987 D Dockets Nos. 501254 y'

t t and'50-265-Mr. L.D. Butterfield, Jr.

9 Nuclear Licensing Manager

! Commonwealth Edison Company b Post Office Box 767' L . Chicago, Illinois 60690 .

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Dear Mr. Butterfield:

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SUBJECT:

INTERIM COMPENSATORY MEASURES AND REQUEST FOR EXEMPTION b

FROM 10 CFR PART 50, APPENDIX R, SECTION III.G.1 REGARDING HOT SHUTDOWN REPAIRS-p (TACNOS.. 57284,57285,64493AND64494-) ,

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'* .By letter dated December 18, 1984, Commonwealth Edison Company (CECO, the o 4 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 prescribed in Generic Lett'er 83-33 dated October 19,;1983.- This report identified Interim Compensatory Measures p (ICMs).that were being conducted at QCNPS for an interim r completion of Appendix R required hardware modifications) periodsafe to en.;ure (until shutdown. capability:of Units 1 or 2 for. postulated fire events. Based on a review staff previous of the aforementioned safety evaluation SE) repand (ort, the NRC approval staffand of safe has'alternative determined that the n

. shutdown capabilities at QCNPS, issued December 30, 1982, remains valid.

' 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 shutdown capability at QCNPS for certain fire events. These issues were not explicitly addressed in the reevaluation report. I Additional information was also sought on the ICMs.

1 I-CECO responded to the staff's ir.quiries with letters dated December 30, 1986, 3 March 13, 1987. July 15, 1987, and October 9,1987. In these submittals, 1 CECO proposed conducting certain manual operations, including hot shutdown

. repairs (i.e., pulling out fuses and/or replacing blown fuses), to resolve the 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 1 e submitted letters dated January 12, 1987, September 30, 1987, October 1,1987,

. November 20,.1987, and November 30,1987, requesting approval for several

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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, Ceco stated that because all the required safe Lshutdown hardware modifications had been completed, their corresponding ICMs j would-no longer be necessary. Also, in a July 17, 1987 letter, several {

deviations between the' present safe shutdown program, and what was approved i in the previous NRC SE (dated December 30,1982), were described by CECO and 8712080045 871201 PDR ADOCK 05000254 F PDR ,

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. [ technically' justified. F'uthermore, in the letter dated November 20, 1987 CECO i notified the staff that:a portion of an exemption request, 10.0 " Hot Shutdown m Repairs (FuseReplacements)"intheSeptember 30,'1987, letter was no longer .

necessary due to a non-Appendix R related plant modification to be accomplished- l during the Unit I refueling outage. Consequently, that part of the exemption

request related to the Unit 1 Reactor Core Isolation Cooling System inboard steam supply isolation valve. was withdrawn.

Enclosure 1;of this letter'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-

'i repairs,- 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 deviations described by the July 17,.1987 letter Lwould not compromise the safe shutdown capability at OCNPS and are therefore, 1 ' acceptable. Furthermore,._the staff recognizes that ICMs specified in Enclosure 2. of'the reevaluation report dated December 18, 1984 are no longer D'

required. . It $1ould also be noted, CECO submitted two additicnal 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, t

Technical exemption requests from Section 1I1.C of Appendix R, contained in Enclosure 3 of the December ~18,1984 reevaluation report, related to fire

, , protection features for selected. plant areas will be evaluated by the staff in

= a separate SE.to be issued later. ~ A schedular exemption from compliance with

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< 10 CFR 50.48 was requested by letter dated November 20, 1987. This subject L will. also be evaluated separately and issued later. The legal regulatory y' " 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 correspondence,

, which-should be forthcoming.

Original Signed by/

I Thierry M. Ross, Project Manager Project Directorate III-2 Division of Reactor Projects III, IV, V and Special Projects i

Enclosures:

DISTRIBUTION

1) Safety Evaluation $ Docket Filen 0GC-Bethesda NRC & Local PDRs EJordan

', 'cc w/ enclosures: PD3-2 Rdg. File JPartlow Docket Nos. 50-254 GHolahan PD3-2 Plant File and 50-265 LLuther ACRS (10)

TRoss-PM/PD32/DRSP: PD/PD32/DRSP:

TRoss or DMuller

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Mri L. ' D.: Butterfield, Jr. - Quad Cities Nuclear: Power Station Commonwealth Edison Company Units 1.and 2 cc:.

Mr. Stephen E.:Shelton 1Vice President .

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Iowa-Illinois Gas and Electric Company.

g P.O. Box 14350

,-Davenport. Iowa 52808 -n

' Mr. Michael Miller

, Isham, Lincoln & Beale.

t Three First National Plaza-Suite 5200

' Chicago, Illinois 60602

~Mr.1 Richard Bax-

, Station Manager Quad Cities Nuclear Power Station-

'22710 206th Avenue North

'Cordova,< Illinois 61242 Resident Inspector- .

U.S. Nuclear Regulatory. Commission-22712 206th Avenue North:

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Cordova, Illinois 61242 l

L" Chairman .

Rock' Island County' Board of Supervisors 1504 3rd Avenue Rock. Island County Office Bldg.

Rock Island, Illinois 61201 Mr. Mich'a'e1. C. Parker, Chief Division of. Engineering Illinois Department of Nuclear Safety-

'1035 Outer Park Drive Springfield, Illinois. 62704 Regional Administrator, Region III

, U.S. Nuclear Regulatory Commission 799 Roosevelt Road L Glen Ellyn, Illinois. 60137 y

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