ML20237A974

Provides Bases for Util Belief That Unit Has Been Substantially Designed,Constructed & Preoperationally Tested in Conformity W/Fsar,Other licensing-related Documents,Ser & Rules & Regulations of Commission

ML20237A974
Person / Time
Site:	Braidwood
Issue date:	12/09/1987
From:	Reed C COMMONWEALTH EDISON CO.
To:	Murley T NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM), Office of Nuclear Reactor Regulation
References
3772K, NUDOCS 8712150378
Download: ML20237A974 (3)

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E One First National Plaza, Chicago, Illinois 3 dress Reply to. Postoffice Box 767 Chicago, Illinois 60690 0767 December 9, 1987 Mr. T. E. Murley U.S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation Washington, DC. 20555 Attn: Document Control Desk

Subject:

Braidwood Station Unit 2 Satisfaction of Licensing Requirements and certification of Technical Specifications NRC Docket No. 50-457

References:

(a) May 11, 1983 letter from C. Reed to H.R. Denton (b) April 8,1982 letter from T. Tramm to H.R. Den'.on (c) Aagust 27, 1985 letter from B. Youngblood to D. Farrar (d) October 23, 1984 letter from C. Reed to H.R. Denton (e) February 12, 1985 letter from C. Reed to H.R. Denton (f) October 3, 1986 letter from C. Reed to H.R. Denton

Dear Mr. Murley:

This letter provides the bases for Commonwealth Edison Company's

(" Edison") belief that Braidwood Station Unit 2 ("Braidwood") has been substantially designed, constructed and pre-operationally tested in conformity with the Final Safety Analysis Report ("FSAR"), other licensing-related documents, the Safety Evaluation Report ("SER"), and the rules and regulations of the Commission. Inherent in this statement is the acknowledgment of the normal update process which translates current documents for design, construction and other activities into submittals to the NRC, e.g. FSAR descriptions. The PSAR will be updated to reflect any changes to the plant as required by Reference (c) and 10 CPR 50.71(e).

Edison has considerable experience in nuclear power plant design, construction and operation. Similarly, Braidwood Station's ,

architect-engineer, Sargent & Lundy, and Braidwood Station's nuclear steam j supplier, Westinghouse, have considerable experience in nuclear power plant i design and construction. These three entities employ extensive design control procedures and practices, many of which have been previously described in detail for Braidwood's duplicate plant, Byron (See Reference (a)). Also documented in detail in Reference (a) are the contributory roles of quality assurance audits and independent engineering reviews in the verification of ,

the design, construction and installation activities. This combination of l experience and design control practices and reviews supports Edison's belief that Braidwood Station Unit 2 has met the requirements to receive a license.

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8712150378 871209 10 f I' I PDR ADOCK 05000457 ,O R PDR

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T.E. Murley December 9, 1987 l

Braidwood Station Unit 2 is now substantially complated. As with all i new plants, certain activities which can be deferred in accordance with the commission's regulations, including a small number of the pre-operational tests, have been identified to the NRC staff. All uncompleted items, including the deferrable construction deficiencies which have been identified to you by Region III and which have been determined not to need schedular relief, are being tracked by the station. Where appropriate, items are evaluated for their impacts on operation. This evaluation includes a review by a Senior Reactor Operator who determines the mode of operation by which each item must be completed. Edison's analysis of the remaining uncompleted activities shows that the issuance of an operating license, the loading of fuel and the testing of the facility can proceed with the reasonable assurance of no undue risk to public health and safety.

s Compliance with the NRC's regulations has previously been detailed in Reference (b). To the extent that those regulations are still in force, Edison continues to believe that it is in essential compliance with them.

Similarly, Edison believes that it is in essential compliance with all regulations promulgated, subsequently.

Furthermore, the Technical Specifications which have been prepared for Braidwood Station Unit 2 are in conformance with the as-built plant and  !

the Byron /Braidwood FSAR. The Braidwood Station Unit 2 Technical t Specifications were developed during the approval of the Braidwood Station Unit 1 Technical Specifications. The accuracy of the Braidwood Station Technical Specifications has been demonstrated by the approximate one year of  ;

direct experience with them since Braidwood Station Unit I was licensed in late, 1986. The only differences between the Technical Specifications for Braidwood Station Unit 1 and Unit 2 are unit-specific in nature. As there are only a limited number of differences, the reviews documented in references (d), (e) and (f) support the certification of the Braidwood Station Unit 2 Technical Specifications. These circumstances, and the reviews described ,

I below for the Braidwood Station Unit 2 Technical Specifications, provide a high degree of confidence in the appropriateness of the Braidwood Station Technical Specifications.

The development of the Braidwood Station Technical Specifications involved an extensive, multidisciplinary review of the entire volume to further assure their accuracy. Braidwood Station personnel conducted: (1) a 100% on-site review of proposed Technical Specifications for Braidwood Station Unit 2 identified daring the preparation of the Braidwood Station Unit 1 Full Power Technical Specifications and, (2) a 100% on-site review of all station-initiated technical changes since Edison's initial submittal of Unit 2 Technical Specifications. Additionally, input and review were obtained from several other organizations, when deemed appropriate by Braidwood Utation.

The corporate and station departments involved in the verification included:

Project Engineering, Technical Services-Nuclear, Station Electrical )

Engineering, Nuclear Fuel Services, Nuclear Licensing, Byron Technical Staff, Byron Operating, Byron Training, Byron Maintenance, Byron Radiation Chemistry and Nuclear Safety. Appropriate credit has also been taken for the reviews of the Braidwood Unit 1 Technical Specifications conducted by Westinghouse (NSSS vendor) and Sargent & Lundy (Architect-Engineer).

k T.E. Murley December 9, 1987 All substantive differences between the Braidwood Station Unit 2 Technical Specifications and the approved Braidwood Station Unit 1 Technical Specifications are unit-specific in nature. We understand that substantial agreement on the appropriateness of these differences has been achieved through discussions with the NRC Staff.

There are certain Technical Specification requirements, such as surveillance times, which are patterned after the Westinghouse Standardized Technical Specifications and are not directly linked to specific FSAR analyses. To the extent that we can demonstrate such requirements to be unnecessarily conservative, we intend to propose Technical Specification changes in the future. The current acceptability of the Technical Specifications does not preclude Edison from seeking to modify these which new information shows them to be overly conservative.

All of the safety limits, LCO's and setpoints specified in the  ;

Technical Specifications are based upon conservative analyses. To the extent J that those analyses are unnecessarily conservative, we may be proposing specific changes to redefine those limits. Changes to correct overly l .

l conservative technical specifications may also be proposed as experience is  !

I gained through the performance of those surveillance and as the Technical l Specifications are implemented during the startup program.

We have also reviewed the Technical Specifications against our understanding of the NRC Staff's SER. We are not aware of any changes j required to the Technical Specifications based on this review.  !

I Based on the previously described extensive, in-depth reviews Edison l believes that the Braidwood Station Unit 2 Technical Specifications are in  !

conformance with the as-built facility and the Byron /Braidwood FSAR. We also l believe that Braidwood Station Unit 2 has been designed, constructed and pre-operationally tested in a way that will assure it meets the requirements of the Byron /Braidwood FSAR, other licensing-related documents, the SER and the NRC's rules and regulations. Therefore, Braidwood Station satisfies the  :

Commission's requirements for a license. l l

l Very truly yours,

@P l l

Cordell Reed Senior Vice president j

3772K i

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