ML20244D574

Comments on Review of Revs 5 & 6 to Plant Updated Fsar. Response That Addresses NRC Conclusion & Specific Findings Requested within 90 Days.Response Should Also Detail Scope & Schedule of Proposed Corrective Actions.Findings Encl

ML20244D574
Person / Time
Site:	Quad Cities
Issue date:	06/07/1989
From:	Ross T Office of Nuclear Reactor Regulation
To:	Kovach T COMMONWEALTH EDISON CO.
References
TAC-67017, TAC-67018, TAC-69004, TAC-69005, NUDOCS 8906190138
Download: ML20244D574 (6)

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'* # ff , *g UNITED STATES gy g NUCLEAR REGULATORY COMMISSION 7n  ; j' WASHINGTON, D. C. 20555 k / June 7, 1989 D0cket Nos. 50-254 and 50-265 LMr Thomas J. Kovach h9t.har Licensing Manager Commonwealth Edison Company Post Oifism Box 767 Chicago,4L 60690 Dear Mr. KovacM

SUBJECT:

REVIEW OF THE QUAD CITIES UPDATED FINAL SAFETY ANALYSIS REPORT, REVISIONS 6 & 6 (TAC NOS. 67017,67018,69004,AND69005)

REFERENCES:

(a) November 20, 1987 letter from I.M. Johnson (Ceco) to H.R. Dentra (NRC) - UFSAR Rev. 5 l (b) July 27, 1988 letter f rom I,H. Johnson (CECO)toU.S.NRC-UFSARRev.6 In accordance with tne requirements of 10 CFR 50.73(e), Core m ealth Edison Coupeay (Ceco) subnitted references (a) and (b), Revisiens 5 and 6 of De Quad titic.: Updated Final Safety Analysis heport (UFSAR): to us. We reviewed a sampling of the UFSAR sections affected by these revisions for accuracy, 4 consistency, and appropriateness. Enclosed is a list detailing our specific findings.

From the results of our review, we have concluded the fS11owing:

(1) Ceco f ailed to comply with the annual filing requirement of 10 CFR 50.71(e)(4) - Rev. 5 was issued 5 months late. ,

(2) Since no sumarized outline or description detailing the scope and cont 2At of UFSAR changes was provided, it could not be detarminea l that the UFSAR r.evisions represented all facility changes completed no later than a mLximum of 6 months prior to filing.

(3) Changes made under the provisions of 10 CFR 50.59, lut not previously 1 submitted to the NRC, were not identified as required by j 10CFR50.71(e)(2)(ii). If no such changes were made, this was indeterminate from the submitted UFSAR revisions.

(4) Some applicable facility thenges reported to the N.RC in accordance with 10 CFR 50.59 were not incorporated in the UFSAR as required by 10CFR50.71(e).

(5) Some changes incorporated its the UFSAR were not evalu6ted and/cir )

reported in compliance with 10 CFR 50.59 . J (5) Certain UFSM changes require further clariticatiun to ?cMeva adequate c.cnsistency ,

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Thomas J. Kovach (7) Lists of all current pagen, after replacement, were not provided to NRC for UFSAR Figures and Appendices as required by 10 CFR 50.71(e)(1).

(8) Some analyses performed by or on behalf of Ceco, at the NRC's request, for new safety issues were not included as part of revisions to the UFSAR, as required by 10 CFR 50.71(e).

In general, except for the above, CECO has followed the requirements of 10 CFR 50.71(e). However, the significance of our findings and determinations  ;

indicates prompt and comprehensive corrective actions are warranted by Ceco to assure future UFSARs for the Quad Cities Station are submitted in compliance .

with regulatory requireme.nts. Upon recei j to provide us within the next ninety (90)ptdaysof this letter, CECO a response is requested that addresses our 1 conclusions (listedabove)andspecificfindings(enclosed). This response I should also detail the scope and schedule of proposed corrective actions. Any l and all UFSAR discrepancies or deficiencies identified in the enclosure should be reconciled in the next UFSAR revision. Furthermore, we reconinend that CECO review the applicability of our findings and conclusions as " lessons learned" l to ensure other station's UFSARs comply with regulatory requiremats.

Potential enforcement actions regarding failure to comply with portions of 10 CFR 50.71(e) are being discussed with Region III. You will be notified in the near future concerning our consensus decision. Should you need any detailed clarification or additional information related to this review of references j (a)and(b),donothesitatetoask, hierry M. Ross, Project Manager Project Directorate III-2 Division of Reactor Projects III, IV, V, and Special Prcjects

Enclosure:

As stated cc w/ enclosure:

See next page i

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Mr. Thomas J. Kovach Quad Cities Nuclect Power Station l- Commonwealth Edison Company Units _1 and 2 cc:

Mr. Stephen E. Shelton Vice President Iowa-Illinois Gas and Electric Company P. O. Box 4350 Davenport, Iowa 52808 Michael I. Miller, Esq.  !

Sidley and Austin One First National Piaze Chicago, Illinois 606 3 Mr. Richard Bax-Station nanager

-yuset Cities Nuclear Pgtter Station 227I0 206th Avenue North Cordova, Illinois 61242 Resider.t Inspecter U. S. Nuclur Regulatory Commission E2712 206th' Avenue North Cordova, Illinois 61242 Chairman Rock Island County Board of Supervisors 1504 3rd Avenue Rock Island County Office Bidg.

Rock Island, Illinois 61201 Mr. Michael E. 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 Consnission 799 Roosevelt Road, Bldg. #4 Glen Ellyn, Illinois 60137

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j ENCLOSURE /

FINDINGS.FROM. REVIEW.0F. REVISIONS.5.AND 6 TO QUAPtITIES. UPDATED. FINAL.5AFETYANALYSIS. REPORT We have completed our review of CECO's update to the Quad Cities Final Safety Analysis.R2 port (FSAR), Revisions 5and6,datedNovember 20, 1987 and July 27, 1988(respectively). A sampling of FSAR sections affected by these updates were reviewed and several deficiencies and/or discrepancies were identified.

Examples of our findings from Revision 5 are described below.

(1) Figure 3.2.11 was replaced with a new power-flow map. The discussion of the operating characteristics remained unchanged. The new figure used a 20% pump speed'line, whereas, the discussion references a 30% pump speed' line. This discrepancy could lead to confusion and misunderstanding, and should be clarified in a subsequent FSAR revision.

(2) Section 7.9 describes the Rod Worth Minimizer (RWM). It appears that the RWM was replaced with a new system. The new RWM uses terms like sequence step, sequence array, and latched step. Although, the new terms are defined, some previous descriptions remained unchanged and reference terms from the old RWM, such as, rod group. The definition for group was deleted in the i revision and~it is unclear as to whether this term can be used in describing l the new RWM. The description appears to be inconsistent with the new RWM and should be clarified in a subsequent FSAR revision.

(3) ComparisonofFSARTable7.7.3andTechnicalSpecification(TS)

Table 3.7-1 (primary containment isolation groutangs) identified discrepancies in the group descriptions. This was not due to an FSAR update. It appears that the TS should be revised to reflect the current description.

FSAR Table 7.7.2 was revised to change terms (e.g., steamline high rad changedtoHi-Hi)andsetpoints(e.g.,DWh1radchangedfrom2000R/hr I

to100R/hr). No basis (i.e. 50.59 safety evaluation) could be found for these changes.

(4) Section 2.8.e was changed to reflect a modification to the Sodium Hypochlorite storage tank. This tank is used for water chlorination of the circulating water and service water systems. The modification changed the underground 30,000 gallon tank to an above ground 6,000 gallon tank. Documents reviewed for information regarding this modification included the monthly operating reports, correspondence, annual reports, and performance reports for 1986 and 1987. A 10 CFR 50.59 evaluation or reference to the existence of one was not found.

(5) A 10 CFR 50.59 evaluation or reference to the existence of one was not found for the modification to the RWM discussed above in item two.

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, (6) Modification-4-2-81-24(SuppressionPoolTemperatureMonitoring System) reported in compliance with'10 CFR 50.59 by letter dated December 1,198f, from R. Robey (CECO) to E. Case (NRC), was not described within the UFSAR.

(7) UFSAR Table 6.7.1 " Design Low Level Solution Volume" of 3470 gallons does not correspond with the minimum required Technical Specifications tank volume of 3733 gallons.

Examples of findings from our review of Revision 6 are described below.

(1) Operating modes of the Reactor Water Cleanup System (UFSAR Section 10.3.3.1). were revised witnout any apparent 10 CFR 50.59 evaluation.

(2) Analysis of boraflex degradation of storage racks in the Spent Fuel Pool that constituted configuration changes and reductions in the sub-criticality margin were not addressed in the UFSAR.

(3) An additional off-site 345 KV power line (UFSAR Section 8) was connected to the switchyard ring bus without any apparent 10 CFR 50.59 evaluation.

(4) Analysis conducted to resolve safety issues associated with Embedment Plates and Piping Configuration Control were not add essed in the UFSAR.

Principal Contributors: T. Ross P. Rescheske Dated: June 7, 1989

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June'7, 1989-

^ Thomas'J. Kovach' .(7) Lists of all' current pages,, after replacement, were not provided to NRC for UFSAR Figures and Appendices as. required by 10 CFR 50.71(e)(1).

(8) Some' analyses performad by or on behalf of CECO, at the NRC's request, for new safety issues were not included as part of revisions to the UFSAR, as required by 10 CFR 50.71(e).

In general, except for.the above, CECO has followed the requirements of 10 CFR 50.71(e). However, the significance of our findings and determinations indicates prompt and_ comprehensive corrective actions are warranted by CECO to assure future UFSARs for the Quad Cities Station are submitted in compliance with regulatory requirements. Upon recei

.to provide us within the next ninety-(90)pt of this days letter, Ceco a response is requested that addresses our conclusions (listedabove)andspecificfindings(enclosed).-Thisresponse should also detail the scope and schedule of proposed corrective actions. Any and all UFSAR discrepancies or deficiencies identified in the enclosure should be reconciled in.the next UFSAR revision. Furthermore, we recommend that Ceco review the applicability of our findings and conclusions as " lessons learned" to ensure other station's UFSARs comply with regulatory requirements. .  !

Potential enforcement actions regarding failure to comply with portions of 10CFR50.71(e)arebeingdiscussedwithRegionIII. You will be notified in

.the near future concerning our consensus decision.' Should you need any detailed clarification or additional information related to this review of references (a) and (b), do not hesitate to ask.

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

Enclosure:

As stated cc w/ enclosure:

See next page DISTRIBUTION hDocket 711e= 4 NRC & Local PDRs PDIII-2 r/f MVirgilio LLuther TRoss OGC EJordan BGrines ACRS(10)  ;

Plant file I PDIII-2:

f. f. 1 PDIII-2:PMg PDIII-2:(A)PD TRoss:dmj LLuthe -

PShemanski 6/7/89 6/~) / 6/7/89 4

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