ML20247G524

Responds to Re Util Position on Dealing W/Dc Grounds After Discussion W/Nrc in 890301 Meeting.Continued Plant Operation Will Be Allowed Only So Long as Applicable Limiting Conditions/Or Action Statements Met

ML20247G524
Person / Time
Site:	Dresden, Byron, Braidwood, Quad Cities, Zion, LaSalle, 05000000
Issue date:	05/18/1989
From:	Miller H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Reed C COMMONWEALTH EDISON CO.
Shared Package
ML20247G530	List: ML20247G524 ML20247G531
References
EA-88-161, NUDOCS 8905310002
Download: ML20247G524 (2)

Text

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MAY 181989 Docket No. 50-254 Docket No. 50-265 EA 88-161 Commonwealth Edison Company ATTN: Mr. Cordell Reed Senior Vice President Post Office Box 767 Chicago, IL 60690 Gentlemen:

This refers to the March 20, 1989 letter from Mr. N. P. Smith of your staff concerning Commonwealth Edison's dc ground policy. The letter presented Commonwealth Edison's position on dealing with de grounds after discussion:

with the NRC staff in a working level meeting held at the Region III office on March 1, 1989.

s We have reviewed the letter and find it consistent with our meeting discussions which clarified actions taken when grounds in the de system are identified. We consider your procedure on immediate actions to isolate and remove grounds to be reasonable. We recognize als'.) that, in some very infrequent cases, isolating such grounds may be impractical and pose hazards while a plant is operating.

However, we have questions about your interpretation of the FSAR and Technical Specifications (TS) that you use as a basis to justify continued operation in such instances. It is our position that any and ill grounds on the de system will require you to make a prompt determination of TS operability for effected equirn'ent. Continued plant operation would be allowed only so long as applicable LCOs and/or Action statements were met. Extended plant operation (i.e., greater than 14 days), that does not adversely impact TS operability, would be acceptable if an appropriate 10 CFR 50.59 evaluation has determined that an unreviewed safety question does not exist. NRC approval would be required for extended plant operation with de system grounds that do not satisfactorily pass the 10 CFR 50.59 " test" for an unreviewed safety question.

If you have any questions concerning this matter, please contact me (312/790-5788) ,

or Mr. R. W. Cooper of my staff (312/790-5578). )

Sincerely, 021Z3L SE!ED DY I!U.GT J. CILLER H. J. Miller, Director l U Division of Reactor Safety Eo 39$ See Attached Distribution v)o 0.8 bcc: 3 Lkbe ,cc (CL[ EW mo NV h WJ f SS RII RIII, RIII RI T I RLII r

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cc w/o ltr dtd 3/20/89:

T. Kovach, Nuclear i Licensing Manager R. L. Bax, Station Manager cc w/ letter dated 03/20/89:

DCD/DCB (RIDS)

Licensing Fee Management Branch G. Holahan, NRR  ;

D. R. Muller, NRR '

T. M. Ross, NRR I Resident Inspector, RIII Richard Hubbard J. W. McCaffrey, Chief, Public Utilities Division

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