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Category:CORRESPONDENCE-LETTERS
MONTHYEARSVP-99-181, Forwards Biennial Update to Quad Cities Ufsar,Iaw 10CFR50.71(e).Update Includes Changes to Facility & Procedures & Are Current Through 9906301999-10-20020 October 1999 Forwards Biennial Update to Quad Cities Ufsar,Iaw 10CFR50.71(e).Update Includes Changes to Facility & Procedures & Are Current Through 990630 ML20217H4661999-10-18018 October 1999 Forwards Changes to EPIPs IAW 10CFR50.54(q) & 10CFR50,App E, Section V.Details of Changes Encl ML20217K7011999-10-13013 October 1999 Provides Response to Questions Related to Request for License Amend,Per 10CFR50.90, Credit for Containment Overpressure. Supporting Calculations Encl 05000254/LER-1999-004, Forwards LER 99-004-00,IAW Requirements of 10CFR50.73(a)(2)(i)(B).Util Is Committed to Listed Action1999-10-12012 October 1999 Forwards LER 99-004-00,IAW Requirements of 10CFR50.73(a)(2)(i)(B).Util Is Committed to Listed Action ML20217F6321999-10-0707 October 1999 Forwards Insp Repts 50-254/99-01 & 50-265/99-01 on 990721- 0908.No Violations 05000254/LER-1999-003, Forwards LER 99-003-00 IAW 10CFR73(a)(2)(v)(A).Commitment Made by Util,Listed.Any Other Actions Described in LER Represent Intended or Planned Actions by Licensee1999-10-0707 October 1999 Forwards LER 99-003-00 IAW 10CFR73(a)(2)(v)(A).Commitment Made by Util,Listed.Any Other Actions Described in LER Represent Intended or Planned Actions by Licensee ML20212K9421999-10-0505 October 1999 Informs That NRC Accepts 990513 Inservice Inspection Relief Request CR-31 for Quad Cities Nuclear Power Station,Units 1 & 2 ML20216J8241999-09-30030 September 1999 Notifies of Removal of NRC Headquarters & Region III Offices from Controlled Copy Distribution of Certain CE Documents. Specific Documents,Associated Controlled Copy Numbers & NRC Location Affected Are Shown on Attachment to Ltr SVP-99-189, Confirms Completion of Actions Identified During Review of NRC Safety Evaluation of Boiling Water Reactor Owners Group Rept, Utility Resolution Guidance of ECCS Suction Strainer Blockage1999-09-22022 September 1999 Confirms Completion of Actions Identified During Review of NRC Safety Evaluation of Boiling Water Reactor Owners Group Rept, Utility Resolution Guidance of ECCS Suction Strainer Blockage ML20212J0451999-09-21021 September 1999 Forwards Safety Evaluation of Licensee USI A-46 Program at Quad Cities Nuclear Power Station,Units 1 & 2,established in Response to GL 87-02 Through 10CFR50.54(f) Ltr ML20212D8231999-09-20020 September 1999 Informs That Effectieve 991101,NRC Region III Will Be Conducting Safety System Design & Performance Capability Pilot Insp at Quad Cities Nuclear Power Station.Insp Will Be Performed IAW NRC Pilot Insp Procedure 71111-21 ML20212C6961999-09-15015 September 1999 Forwards Insp Repts 50-254/99-17 & 50-265/99-17 on 990823- 0827.No Violations Noted SVP-99-190, Clarifies Statement Contained in NRC Insp Repts 50-254/99-12 & 50-265/99-12,dtd 990813,paragraph 4OA1.3B, Observation & Findings, Re Sys Mod to DG Air Start Sys1999-09-13013 September 1999 Clarifies Statement Contained in NRC Insp Repts 50-254/99-12 & 50-265/99-12,dtd 990813,paragraph 4OA1.3B, Observation & Findings, Re Sys Mod to DG Air Start Sys ML20211Q7961999-09-0909 September 1999 Forwards Correction to Administrative Error on Page 8 of NRC Insp Repts 50-254/99-16 & 50-265/99-16,transmitted by Ltr, ML20217H5661999-09-0909 September 1999 Discusses 990907 Pilot Plan Mgt Meeting Re Results to-date of Pilot Implementation of NRC Revised Reactor Oversight Process at Prairie Island & Quad Cities.Agenda & Handouts Provided by Utils Encl ML20211Q6511999-09-0808 September 1999 Informs That NRC Tentatively Scheduled Initial Licensing Exam for Quad Cities Operator License Applicants During Wk of 000327.Validation of Exam Will Occur at Station During Wk of 000306 ML20211G1221999-08-27027 August 1999 Forwards fitness-for-duty Program Performance Data for Each of Comm Ed Nuclear Power Stations & Corporate Support Employees within Scope of Rule for six-month Period Ending 990630,IAW 10CFR26.71(d) ML20211F8251999-08-25025 August 1999 Forwards Insp Repts 50-254/99-15 & 50-265/99-15 on 990816-20.No Violations Noted.Insp Evaluated Effectiveness of Maint Rule Program & Review Periodic Evaluation Specifically Required for 10CFR50.65 ML20211B8691999-08-20020 August 1999 Forwards Insp Repts 50-254/99-10,50-265/99-10,50-454/99-09, 50-455/99-09,50-456/99-10 & 50-457/99-10 on 990628-0721. Action Plans Developed to Address Configuration Control Weaknesses Not Totally Effective as Listed ML20211D1491999-08-19019 August 1999 Forwards Insp Repts 50-254/99-16 & 50-265/99-16 on 990719-22.Staff Identified Major Discrepancy Re Accuracy of Data Submitted to NRC for Protected Area Security Equipment Performance ML20211C7601999-08-19019 August 1999 Confirms NRC Intent to Meet with NSP & Ceco on 990807 in Lisle,Il to Discuss with Region III Pilot Plants,Any Observations,Feedback,Lessons Learned & Recommendations Relative to Implementation of Pilot Program ML20210R7451999-08-13013 August 1999 Forwards Insp Repts 50-254/99-11 & 50-265/99-11 on 990601-0720.NRC Identified Several Issues Which Were Categorized as Being of Low Risk Significance.Two Issues Involved NCVs of Regulatory Requirements SVP-99-147, Notifies of Change to Bases of TS to Licenses DPR-29 & DPR- DPR-30.Change to TS Section 3/4.9 Provides Clarity & Consistency with Sys Design Description in Ufsar,Sections 8.3.2.1 & 8.3.2.2.TS Bases Page,Encl1999-08-13013 August 1999 Notifies of Change to Bases of TS to Licenses DPR-29 & DPR- DPR-30.Change to TS Section 3/4.9 Provides Clarity & Consistency with Sys Design Description in Ufsar,Sections 8.3.2.1 & 8.3.2.2.TS Bases Page,Encl SVP-99-170, Forwards Relief Requests CR-25,CR-26,CR-27,CR-28,PR-11, PR-12 & PR-13,on Basis That Compliance with Specified Requirements Would Result in Hardship or Unusual Difficulty Without Compensating Increase in Level of Quality & Safety1999-08-13013 August 1999 Forwards Relief Requests CR-25,CR-26,CR-27,CR-28,PR-11, PR-12 & PR-13,on Basis That Compliance with Specified Requirements Would Result in Hardship or Unusual Difficulty Without Compensating Increase in Level of Quality & Safety ML20210T9941999-08-13013 August 1999 Forwards Insp Repts 50-254/99-12 & 50-265/99-12 on 990628-0716.Violations Noted SVP-99-154, Notifies NRC That M Price,License SOP-31389,is No Longer Required to Maintain Operator License.Price Was Removed from Licensed Duty on 990729 & Comm Ed Requests License Be Terminated1999-08-13013 August 1999 Notifies NRC That M Price,License SOP-31389,is No Longer Required to Maintain Operator License.Price Was Removed from Licensed Duty on 990729 & Comm Ed Requests License Be Terminated ML20210R9541999-08-10010 August 1999 Informs That During 990804 Telcon Between J Bartlet & M Bielby,Arrangements Were Made for NRC to Insp License Operator Requalification Program at Plant.Insp Planned for Wks of 991018 & 25 ML20210N5651999-08-0606 August 1999 Forwards Rev 8 to Nuclear Generating Stations Emergency Plan, for Plants.With Summary of Changes ML20210M5461999-08-0606 August 1999 Discusses 990804 Telcon Between J Bartlet & M Bielby,Where Arrangements Were Made for NRC to Inspect Licensed Operator Requalification Program at Plant.Insp Planned for Wks of 991018 & 25 ML20210M9131999-08-0202 August 1999 Forwards Response to NRC AL 99-02, Operating Reactor Licensing Action Estimates, for Fys 2000 & 2001 for Comed ML20210L8371999-08-0202 August 1999 Forwards SE Accepting Licensee 60-day Response to GL 96-05, Periodic Verification of Design-Basis Capability of Safety Related Motor-Operated Valves ML20210M4691999-07-30030 July 1999 Forwards Insp Repts 50-254/99-14 & 50-265/99-14 on 990713-15.One NCV Was Identified & Discussed in Encl Insp ML20210H4661999-07-29029 July 1999 Forwards Insp Repts 50-254/99-13 & 50-265/99-13 on 990628-0702.No Violations Noted.Insp Consisted of Selective Examination of Procedures & Representative Records, Observations of Activities & Interviews with Personnel 05000254/LER-1999-002, Forwards LER 99-002-01,IAW 10CFR50.73(a)(2)(iv).Rev Includes Cause Codes & Energy Industry Identification Sys Identifiers Which Were Erroneously Omitted in Original Ler.Commitments Listed1999-07-29029 July 1999 Forwards LER 99-002-01,IAW 10CFR50.73(a)(2)(iv).Rev Includes Cause Codes & Energy Industry Identification Sys Identifiers Which Were Erroneously Omitted in Original Ler.Commitments Listed SVP-99-151, Responds to NRC 990701 Telcon RAI Re Licensee Amend Request Re Use of Containment Overpressure to Support NPSH Available for ECCS at Quad Cities Nuclear Power Station,Units 1 & 21999-07-23023 July 1999 Responds to NRC 990701 Telcon RAI Re Licensee Amend Request Re Use of Containment Overpressure to Support NPSH Available for ECCS at Quad Cities Nuclear Power Station,Units 1 & 2 SVP-99-150, Forwards Responses to 990520 RAI Re Annual 10CFR50.46 Rept1999-07-23023 July 1999 Forwards Responses to 990520 RAI Re Annual 10CFR50.46 Rept SVP-99-146, Informs of Termination of License SOP-31132-1,for G Green, as Required by 10CFR50.74(b).Individual Was Removed from License Duty on 9906251999-07-21021 July 1999 Informs of Termination of License SOP-31132-1,for G Green, as Required by 10CFR50.74(b).Individual Was Removed from License Duty on 990625 ML20210B7071999-07-16016 July 1999 Responds to Requesting Review & Approval of Three Proposed Changes to Ceco QA TR,CE-1A Per 10CFR50.54(a)(3) & 10CFR50.4(b)(7) ML20196J9061999-07-0101 July 1999 Provides Evidence That Util Maintains Guarantee of Payment of Deferred Premiums in Amount of $10 Million for Each of Thirteen Reactors,Per 10CFR140.21 ML20196J9131999-07-0101 July 1999 Submits Status of Nuclear Property Insurance Currently Maintained for Braidwood,Byron,Dresden,Lasalle County,Quad Cities & Zion Nuclear Power Stations,Per 10CFR50.54(w)(3) ML20209B8241999-06-30030 June 1999 Forwards Five 3.5 Inch Computer Diskettes Containing Revised Annual Dose Repts for 1994 Through 1998 for Individuals Receiving Neutron Dose Not Previously Included in Reported Total Effective Dose Equivalent Values.Without Diskettes SVP-99-139, Forwards Revised Action 2 & Associated TS Bases Changes, Describing Specific Alternate Method for Determining Drywell Floor Drain Sump Leakage1999-06-30030 June 1999 Forwards Revised Action 2 & Associated TS Bases Changes, Describing Specific Alternate Method for Determining Drywell Floor Drain Sump Leakage ML20209B2081999-06-29029 June 1999 Discusses Closure of Response to RAI Re GL 92-01,Rev 1,Suppl 1, Reactor Vessel Structural Integrity. Rvid,Version 2 Issued as Result of Review of Responses.Info Should Be Reviewed & Comments Submitted by 990901 05000265/LER-1999-002, Forwards LER 99-002-00 for Quad Cities Nuclear Power Station IAW Requirements of 10CFR50.73(a)(2)(i)(B).Util Commits to One Listed Action1999-06-25025 June 1999 Forwards LER 99-002-00 for Quad Cities Nuclear Power Station IAW Requirements of 10CFR50.73(a)(2)(i)(B).Util Commits to One Listed Action SVP-99-122, Forwards Regulatory Commitment Change Summary Rept, Containing Summary Info from 980601 Through 9906011999-06-25025 June 1999 Forwards Regulatory Commitment Change Summary Rept, Containing Summary Info from 980601 Through 990601 SVP-99-066, Informs That J Reed,License SOP-31034-1,was Removed from License Duty in 990618.Termination of License Is Requested1999-06-25025 June 1999 Informs That J Reed,License SOP-31034-1,was Removed from License Duty in 990618.Termination of License Is Requested SVP-99-103, Informs NRC of Results of Subject Evaluation as Committed to in .Evaluation Consisted of Analytically Demonstrating That Cfu Factor for Rv Head Closure Studs Will Remain Below 1.0 for Remainder of Current License Period1999-06-25025 June 1999 Informs NRC of Results of Subject Evaluation as Committed to in .Evaluation Consisted of Analytically Demonstrating That Cfu Factor for Rv Head Closure Studs Will Remain Below 1.0 for Remainder of Current License Period ML20196F7921999-06-24024 June 1999 Forwards Meeting Summary,Nrc Meeting Handout & Licensee Handout from 990608 Meeting ML20196E7131999-06-23023 June 1999 Forwards Insp Repts 50-254/99-09 & 50-265/99-09 on 990421-0531.One Violation of NRC Requirements Occurred & Being Treated as non-cited Violation,Consistent with App C of Enforcement Policy ML20196E4821999-06-21021 June 1999 Discusses 990617 Meeting by Region III Senior Reactor Analysts (SRA) in Cordova,Il to Meet with PRA Staff to Discuss Initiatives in Risk Area & to Establish Dialog Between SRAs & PRA Staff 1999-09-09
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEARSVP-99-181, Forwards Biennial Update to Quad Cities Ufsar,Iaw 10CFR50.71(e).Update Includes Changes to Facility & Procedures & Are Current Through 9906301999-10-20020 October 1999 Forwards Biennial Update to Quad Cities Ufsar,Iaw 10CFR50.71(e).Update Includes Changes to Facility & Procedures & Are Current Through 990630 ML20217H4661999-10-18018 October 1999 Forwards Changes to EPIPs IAW 10CFR50.54(q) & 10CFR50,App E, Section V.Details of Changes Encl ML20217K7011999-10-13013 October 1999 Provides Response to Questions Related to Request for License Amend,Per 10CFR50.90, Credit for Containment Overpressure. Supporting Calculations Encl 05000254/LER-1999-004, Forwards LER 99-004-00,IAW Requirements of 10CFR50.73(a)(2)(i)(B).Util Is Committed to Listed Action1999-10-12012 October 1999 Forwards LER 99-004-00,IAW Requirements of 10CFR50.73(a)(2)(i)(B).Util Is Committed to Listed Action 05000254/LER-1999-003, Forwards LER 99-003-00 IAW 10CFR73(a)(2)(v)(A).Commitment Made by Util,Listed.Any Other Actions Described in LER Represent Intended or Planned Actions by Licensee1999-10-0707 October 1999 Forwards LER 99-003-00 IAW 10CFR73(a)(2)(v)(A).Commitment Made by Util,Listed.Any Other Actions Described in LER Represent Intended or Planned Actions by Licensee ML20216J8241999-09-30030 September 1999 Notifies of Removal of NRC Headquarters & Region III Offices from Controlled Copy Distribution of Certain CE Documents. Specific Documents,Associated Controlled Copy Numbers & NRC Location Affected Are Shown on Attachment to Ltr SVP-99-189, Confirms Completion of Actions Identified During Review of NRC Safety Evaluation of Boiling Water Reactor Owners Group Rept, Utility Resolution Guidance of ECCS Suction Strainer Blockage1999-09-22022 September 1999 Confirms Completion of Actions Identified During Review of NRC Safety Evaluation of Boiling Water Reactor Owners Group Rept, Utility Resolution Guidance of ECCS Suction Strainer Blockage SVP-99-190, Clarifies Statement Contained in NRC Insp Repts 50-254/99-12 & 50-265/99-12,dtd 990813,paragraph 4OA1.3B, Observation & Findings, Re Sys Mod to DG Air Start Sys1999-09-13013 September 1999 Clarifies Statement Contained in NRC Insp Repts 50-254/99-12 & 50-265/99-12,dtd 990813,paragraph 4OA1.3B, Observation & Findings, Re Sys Mod to DG Air Start Sys ML20211G1221999-08-27027 August 1999 Forwards fitness-for-duty Program Performance Data for Each of Comm Ed Nuclear Power Stations & Corporate Support Employees within Scope of Rule for six-month Period Ending 990630,IAW 10CFR26.71(d) SVP-99-154, Notifies NRC That M Price,License SOP-31389,is No Longer Required to Maintain Operator License.Price Was Removed from Licensed Duty on 990729 & Comm Ed Requests License Be Terminated1999-08-13013 August 1999 Notifies NRC That M Price,License SOP-31389,is No Longer Required to Maintain Operator License.Price Was Removed from Licensed Duty on 990729 & Comm Ed Requests License Be Terminated SVP-99-170, Forwards Relief Requests CR-25,CR-26,CR-27,CR-28,PR-11, PR-12 & PR-13,on Basis That Compliance with Specified Requirements Would Result in Hardship or Unusual Difficulty Without Compensating Increase in Level of Quality & Safety1999-08-13013 August 1999 Forwards Relief Requests CR-25,CR-26,CR-27,CR-28,PR-11, PR-12 & PR-13,on Basis That Compliance with Specified Requirements Would Result in Hardship or Unusual Difficulty Without Compensating Increase in Level of Quality & Safety SVP-99-147, Notifies of Change to Bases of TS to Licenses DPR-29 & DPR- DPR-30.Change to TS Section 3/4.9 Provides Clarity & Consistency with Sys Design Description in Ufsar,Sections 8.3.2.1 & 8.3.2.2.TS Bases Page,Encl1999-08-13013 August 1999 Notifies of Change to Bases of TS to Licenses DPR-29 & DPR- DPR-30.Change to TS Section 3/4.9 Provides Clarity & Consistency with Sys Design Description in Ufsar,Sections 8.3.2.1 & 8.3.2.2.TS Bases Page,Encl ML20210N5651999-08-0606 August 1999 Forwards Rev 8 to Nuclear Generating Stations Emergency Plan, for Plants.With Summary of Changes ML20210M9131999-08-0202 August 1999 Forwards Response to NRC AL 99-02, Operating Reactor Licensing Action Estimates, for Fys 2000 & 2001 for Comed 05000254/LER-1999-002, Forwards LER 99-002-01,IAW 10CFR50.73(a)(2)(iv).Rev Includes Cause Codes & Energy Industry Identification Sys Identifiers Which Were Erroneously Omitted in Original Ler.Commitments Listed1999-07-29029 July 1999 Forwards LER 99-002-01,IAW 10CFR50.73(a)(2)(iv).Rev Includes Cause Codes & Energy Industry Identification Sys Identifiers Which Were Erroneously Omitted in Original Ler.Commitments Listed SVP-99-150, Forwards Responses to 990520 RAI Re Annual 10CFR50.46 Rept1999-07-23023 July 1999 Forwards Responses to 990520 RAI Re Annual 10CFR50.46 Rept SVP-99-151, Responds to NRC 990701 Telcon RAI Re Licensee Amend Request Re Use of Containment Overpressure to Support NPSH Available for ECCS at Quad Cities Nuclear Power Station,Units 1 & 21999-07-23023 July 1999 Responds to NRC 990701 Telcon RAI Re Licensee Amend Request Re Use of Containment Overpressure to Support NPSH Available for ECCS at Quad Cities Nuclear Power Station,Units 1 & 2 SVP-99-146, Informs of Termination of License SOP-31132-1,for G Green, as Required by 10CFR50.74(b).Individual Was Removed from License Duty on 9906251999-07-21021 July 1999 Informs of Termination of License SOP-31132-1,for G Green, as Required by 10CFR50.74(b).Individual Was Removed from License Duty on 990625 ML20196J9061999-07-0101 July 1999 Provides Evidence That Util Maintains Guarantee of Payment of Deferred Premiums in Amount of $10 Million for Each of Thirteen Reactors,Per 10CFR140.21 ML20196J9131999-07-0101 July 1999 Submits Status of Nuclear Property Insurance Currently Maintained for Braidwood,Byron,Dresden,Lasalle County,Quad Cities & Zion Nuclear Power Stations,Per 10CFR50.54(w)(3) ML20209B8241999-06-30030 June 1999 Forwards Five 3.5 Inch Computer Diskettes Containing Revised Annual Dose Repts for 1994 Through 1998 for Individuals Receiving Neutron Dose Not Previously Included in Reported Total Effective Dose Equivalent Values.Without Diskettes SVP-99-139, Forwards Revised Action 2 & Associated TS Bases Changes, Describing Specific Alternate Method for Determining Drywell Floor Drain Sump Leakage1999-06-30030 June 1999 Forwards Revised Action 2 & Associated TS Bases Changes, Describing Specific Alternate Method for Determining Drywell Floor Drain Sump Leakage SVP-99-103, Informs NRC of Results of Subject Evaluation as Committed to in .Evaluation Consisted of Analytically Demonstrating That Cfu Factor for Rv Head Closure Studs Will Remain Below 1.0 for Remainder of Current License Period1999-06-25025 June 1999 Informs NRC of Results of Subject Evaluation as Committed to in .Evaluation Consisted of Analytically Demonstrating That Cfu Factor for Rv Head Closure Studs Will Remain Below 1.0 for Remainder of Current License Period SVP-99-122, Forwards Regulatory Commitment Change Summary Rept, Containing Summary Info from 980601 Through 9906011999-06-25025 June 1999 Forwards Regulatory Commitment Change Summary Rept, Containing Summary Info from 980601 Through 990601 05000265/LER-1999-002, Forwards LER 99-002-00 for Quad Cities Nuclear Power Station IAW Requirements of 10CFR50.73(a)(2)(i)(B).Util Commits to One Listed Action1999-06-25025 June 1999 Forwards LER 99-002-00 for Quad Cities Nuclear Power Station IAW Requirements of 10CFR50.73(a)(2)(i)(B).Util Commits to One Listed Action SVP-99-066, Informs That J Reed,License SOP-31034-1,was Removed from License Duty in 990618.Termination of License Is Requested1999-06-25025 June 1999 Informs That J Reed,License SOP-31034-1,was Removed from License Duty in 990618.Termination of License Is Requested SVP-99-125, Forwards Technical Info Re ECCS Suction Strainers at Quad Cities Nuclear Power Station Units 1 & 2,to Support Review of 990129 Lar.Rev 0 to TR-VQ1500-02, Clean ECCS Suction Strainer Head Loss Test Rept, Encl1999-06-15015 June 1999 Forwards Technical Info Re ECCS Suction Strainers at Quad Cities Nuclear Power Station Units 1 & 2,to Support Review of 990129 Lar.Rev 0 to TR-VQ1500-02, Clean ECCS Suction Strainer Head Loss Test Rept, Encl ML20195E3491999-06-0707 June 1999 Withdraws Util Requesting License Change for Plant Security Plan Rev.Licensee Will re-evaluate Situation & May Request Approval of Change in Future ML20207G1451999-06-0707 June 1999 Forwards Rev 45 to Comed Quad Cities Nuclear Power Station Security Plan.Rev Includes Changes Listed.Security Plan Is Withheld from Public Disclosure Per 10CFR73.21 ML20195D6351999-06-0404 June 1999 Notifies NRC of Actions That Has Been Taken in Accordance with 10CFR26, Fitness for Duty Programs SVP-99-105, Informs NRC of Rev to Schedule for Completing Setpoint/ Uncertainty Calculations & Procedure Changes,Originally Planned for Completion on 9905291999-05-20020 May 1999 Informs NRC of Rev to Schedule for Completing Setpoint/ Uncertainty Calculations & Procedure Changes,Originally Planned for Completion on 990529 ML20195B2301999-05-19019 May 1999 Requests Approval of Proposed Changes to QA Topical Rept CE-1-A,rev 66a.Attachment a Describes Changes,Reason for Change & Basis for Concluding That Revised QAP Incorporating Proposed Changes Continues to Satisfy 10CFR50AppB SVP-99-111, Informs NRC of Current Status of Actions on Response to GL 96-06, Assurance of Equipment Operability & Containment Integrity During Design-Basis Accident Conditions1999-05-17017 May 1999 Informs NRC of Current Status of Actions on Response to GL 96-06, Assurance of Equipment Operability & Containment Integrity During Design-Basis Accident Conditions SVP-99-098, Fulfills Thirty Day & Annual Reporting Requirements of 10CFR50.46 for Plant.Eccs Evaluation Change Rept Transmitted in Entirety,Fulfilling Thirty Day & Annual Reporting Requirements Specified in 10CFR50.46(a)(3)(i)1999-05-17017 May 1999 Fulfills Thirty Day & Annual Reporting Requirements of 10CFR50.46 for Plant.Eccs Evaluation Change Rept Transmitted in Entirety,Fulfilling Thirty Day & Annual Reporting Requirements Specified in 10CFR50.46(a)(3)(i) SVP-99-099, Requests Relief from Requirements of 10CFR50.55a(g) Re Submittal of Relief Requests for Those Welds for Which Examinations of Greater than 90% of Weld Vol Was Not Acheived During 2nd ISI Program Interval1999-05-13013 May 1999 Requests Relief from Requirements of 10CFR50.55a(g) Re Submittal of Relief Requests for Those Welds for Which Examinations of Greater than 90% of Weld Vol Was Not Acheived During 2nd ISI Program Interval SVP-99-096, Provides Suppl Response to Violations Noted in Insp Repts 50-254/98-20 & 50-265/98-23.Corrective Actions:Listed Multidiscipline Team Will Perform self-assessment IAW Station Program for self-assessments in May 19991999-05-12012 May 1999 Provides Suppl Response to Violations Noted in Insp Repts 50-254/98-20 & 50-265/98-23.Corrective Actions:Listed Multidiscipline Team Will Perform self-assessment IAW Station Program for self-assessments in May 1999 05000254/LER-1999-001, Forwards LER 99-001-00 for Quad Cities Nuclear Power Station.Licensee Shall Rept Any Operation or Condition Prohibited by Plant Tech Specs.Util Committing to Listed Actions1999-05-12012 May 1999 Forwards LER 99-001-00 for Quad Cities Nuclear Power Station.Licensee Shall Rept Any Operation or Condition Prohibited by Plant Tech Specs.Util Committing to Listed Actions ML20206F5381999-04-30030 April 1999 Forwards Magnetic Tape Containing Annual Dose Repts for 1998 for Braidwood,Byron,Dresden,Lasalle County,Quad Cities & Zion Nuclear Power Stations,Per 10CFR20.2206(c).Without Magnetic Tape SVP-99-108, Forwards Quad Cities 1998 Radiological Environ Operating Rept, IAW Plant TS 6.9.A.3.Rept Contains Results of Radiological Environ & Meteorological Monitoring Programs. Radioactive Effluent Release Rept Was Submitted 9903301999-04-30030 April 1999 Forwards Quad Cities 1998 Radiological Environ Operating Rept, IAW Plant TS 6.9.A.3.Rept Contains Results of Radiological Environ & Meteorological Monitoring Programs. Radioactive Effluent Release Rept Was Submitted 990330 SVP-99-036, Forwards Reg Guide 1.16 Rept Number of Personnel-Rem by Work & Job Function for 1998. Associated Collective Deep Dose Equivalent Reported According to Work & Job Functions1999-04-29029 April 1999 Forwards Reg Guide 1.16 Rept Number of Personnel-Rem by Work & Job Function for 1998. Associated Collective Deep Dose Equivalent Reported According to Work & Job Functions SVP-99-088, Informs That Util Is Withdrawing IST Relief Rquests RV-02B & RV-03B1999-04-29029 April 1999 Informs That Util Is Withdrawing IST Relief Rquests RV-02B & RV-03B ML20205T1141999-04-22022 April 1999 Provides Comments from Technical Review of Draft Info Notice Re Unanticipated Reactor Water Draindown at Quad Cities Nuclear Power Station,Unit 2,ANO,Unit 2 & JAFNPP ML20206B2471999-04-20020 April 1999 Informs That SE Kuczynski Has Been Transferred to Position No Longer Requiring SRO License.Cancel License SOP-31030-1, Effective 990412 SVP-99-065, Requests That License SOP-31516,for Jf Graham,Be Terminated, Per 10CFR50.74(b).Individual Was Removed from License Duty on 990319 & No Longer Requires Operator License1999-04-14014 April 1999 Requests That License SOP-31516,for Jf Graham,Be Terminated, Per 10CFR50.74(b).Individual Was Removed from License Duty on 990319 & No Longer Requires Operator License SVP-99-058, Submits Plant Specific ECCS Evaluation Changes,Per Annual Reporting Requirements of 10CFR50.46.Attachments Include Current Assessment Data Re PCT Info Limiting LOCA Evaluations1999-04-14014 April 1999 Submits Plant Specific ECCS Evaluation Changes,Per Annual Reporting Requirements of 10CFR50.46.Attachments Include Current Assessment Data Re PCT Info Limiting LOCA Evaluations SVP-99-063, Responds to NRC Re Violations Noted in Insp Repts 50-254/98-21 & 50-265/98-21.Corrective Actions:Revised Site ISI Procedure Qcap 0410-06, ISI Plan Implementation for Third Ten Year Insp Interval1999-04-0909 April 1999 Responds to NRC Re Violations Noted in Insp Repts 50-254/98-21 & 50-265/98-21.Corrective Actions:Revised Site ISI Procedure Qcap 0410-06, ISI Plan Implementation for Third Ten Year Insp Interval JAFP-99-0129, Submits Comments on Technical Review of Draft Info Notice Describing Unanticipated Reactor Water Draindown at Quad Cities Unit 2,ANO & FitzPatrick1999-04-0909 April 1999 Submits Comments on Technical Review of Draft Info Notice Describing Unanticipated Reactor Water Draindown at Quad Cities Unit 2,ANO & FitzPatrick SVP-99-057, Notifies of Change to Bases for TSs Section 3/4.5, ECCS, Re1999-04-0505 April 1999 Notifies of Change to Bases for TSs Section 3/4.5, ECCS, Re ML20205K5841999-03-31031 March 1999 Submits Rept on Status of Decommissioning Funding for Reactors Owned by Comm Ed.Attachment 1 Contains Amount of Decommissioning Funds Estimated to Be Required Pursuant to 10CFR50.75(b) & (C) SVP-99-062, Informs NRC of Rev to Schedule for Analytically Demonstrating That Cumulative Usage Factor for Reactor Vessel Head Closure Studs Will Remain Below 1.0 for Remainder of Current License Period1999-03-31031 March 1999 Informs NRC of Rev to Schedule for Analytically Demonstrating That Cumulative Usage Factor for Reactor Vessel Head Closure Studs Will Remain Below 1.0 for Remainder of Current License Period 1999-09-30
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Commonwralth I.diwn Company Qtad Cinen Gent eating Nation
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, , 22710 206th Avenue North
, Cordos a, 11.61262 9710 Tri .4096s+22 u
.I Jun'a 25,1999 l
l SVP-99-122 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D C 20555 Quad Cities Nuclear Power Station, Units 1 and 2 Facility Operating License Nos. DPR-29 and DPR-30 NRC Docket Nos. 50-254 end 50-265 )
Subject:
Regulatory Commitment Change Summary Report Please find enclosed the " Regulatory Commitment Change Summary Report" for Quad Cities Nuclear Power Station.
This report contains summary information from June 1,1998, through June 1,1999.
Revisions to docketed regulatory commitments were processed using the Nuclear Energy Institute (NEI) guidance for Managing Nuclear Regulatory Commission (NRC) ,
Commitments, Revision 2, dated December 19,1995.
7[ 7 ]
Should you have any questions concerning this letter, please contact Mr. W. J. Beck at (309) 654-2241, extension 3100.
/
Respe ully, k/ 4 ty' ' '
Joel P. Dimmette, Jr.
Site Vice President Quad Cities Nuclear Power Station Attachment cc: Regional Administrator - NRC Region 111 NRC Senior Resident inspector- Quad C tes Nuclear Power Station
. q 9907060131 990625 PDR ADOCK 05000254 P PDR A l'nicum Company
.)
4 4 Attachment '
Quad Cities Nuclear Power Station Regulatory Commitment Change Summary Report Page 1 of 12 Original Document:
LER 1-97-030 $
Subject of Change:
Extend due date from July 31,1999 to July 15,1999. i
( Original Commitment:
l As a part of the IST Program Assessment and Revision effort that is currently on-going, one objective will be to establish a methodology (e.g. software or checklist) for ensuring l adequate documentation that the program implementation meets the as committed ASME and/or OM requirements, and thus aid in the periodic verification of IST Program l implementation. Due date July 31,1998.
I Revised Commitment: Approved July 28,1998 Same as original commitment description except due date extended to July 15,1999.
Basis:
Change improves IST programmatic controls. This effort is administrative in nature and does not affect component or system operation.
status:
On schedule for completion.
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c Attachment
, Quad Cities Nuclear Power Station Regulatory Commitment Change Summary Report Page 2 of 12 Original Document:
Quad Cities Station Diagnostic Evaluation Team (DET) Report Response December 30,1993 Subject of Change:
Deletion of commitment to replace Diesel Generator starting air skid copper tubing with stainless steel.
Original Commitment:
Replace starting air skid copper tubing with stainless steel.
Revised Commitment: Approved July 31,1998 Delete regulatory commitment.
Basis:
Based ca initial reviews, this was seen as a worthwhile enhaticement due to industry experience, but was not required for compliance. This item will no longer be tracked as a regulatory commitment associated with the DET.
m Attachment
, Quad Cities Nuclear Power Station Regulatory Commitment Change Summary Report Page 3 of 12 l
i I
Original Document:
NRC Inspection Report 98-201, Unresolved item 201-02. Quad Cities Nuclear Power l Station response, SVP 98-246, "NRC Inspection Report Numbers 50-254/98-201 and )
50-265/98-201, " dated July 6,1998. )
Subject of Change.
l Extend due date from August 14,1998 to November 14,1998. l Original Comr.itment:
Resolve issues and prepare closure package for URI 98-201-02, Ref. E1.2.1.2.b and LOCA Analysis input errors. Due date August 14,1998.
Revised Commitment: Approved August 14,1998 Same as original commitment description except due date extended to )
November 14,1998.
Basis:
Nuclear Fuel Management will be performing the procedure revision to NEP 16-75 which I will identify the responsibility of who will verify LOCA inputs in the future. This will not be I done until September 16,1998. LOCA inputs have been verified for 01C16.
Status:
This item was completed on September 22,1998.
I
b Attachment
. Quad Cities Nuclear Power Station l Regulatory Commitment Change Summary Report I Page 4 of 12 Original Document:
Appendix G Predecisional Enforcement Conference Commitment letter, SVP 98-019,
" January 9,1998 Pre-Decisional Enforcement Conference (Appendix G) Commitments made by Quad Cities Nuclear Power Station, " dated January 29,1998.
Subject of Change:
Extend due date from September 1,1998 to April 15,1999.
Original Commitment:
Identified issues from the Quad Cities ISI Program assessments will be resolved prior to September 1,1998. I I
Revised Commitment: Approved August 27,1998 Identified issues from the Quad Cities ISI Program assessments will be resolved prior to April 15,1999.
I Basis:
Aoditional time is required to complete resolution using Managed Tasks and to address all issues within the context of a common approach across all Comed sites. Effons to !
meet original date were delayed in order to coordinate efforts.
Currently, the ISI program is in full compliance with ASME Section XI code requirements. The commitment date (April 15,1999) will ensure that any additions to the ISI program inspection scope can be accomplished prior to the completion of Quad Cities' current inspection scope (March 10,2000 & February 18,2000 for Units 1 & 2, respectively). Open issues were scrutinized through the operability determination process in support of restart of both Units following resolution of Appendix R issues.
l 1
Status:
l l
Quad Cities Nuclear Power Station letter SVP 99-019 "lSI improvement Plan", dated February 11,1999, extended this action to October 27,1999. On schedule for con pletion. l i
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g l
Attachment
, Quad Cities Nuclear Power Station Regulatory Commitment Change Summary Report Page 5 of 12 Original Document:
Appendix G Predecis'ional Enforcement Conference Commitment letter, SVP 98-019, l
" January 9,1998 Pre-Decisional Enforcement Conference (Appendix G) Commitments made by Quad Cities Nuclear Power Station, " dated January 29,1998.
Subject of Change:
Extend due date from " prior to use or by September 1998, whichever occurs first, " to
" prior to use or by April 15,1999, whichever occurs first. "
Original Commitment:
All pressure testing procedures will be reviewed for omissions and errors prior to use or by September 1998, whichever occurs first.
1 Revised Commitment: Approved August 27,1998 All pressure testing procedures will be reviewed for omissions and errors prior to use or by April 15,1999, whichever occurs first.
Basis: I i
This commitment is approximately 60% complete (e.g., the class 1 and several class 2 l systems are complete). Overail, the pressure test reviews are a sub-task of the overall l lSI assessment resolution. Several of the outstanding issues involve definitional issues with Clast 2/3 cywem boundaries. Additional time is required to complete recolution(s) using Managed Tasks and to address all issues within the context of a common approach across all Comed sites. Efforts to meet original date were slowed in order to coordinate efforts across all sites.
As of August 27,1998, all class 1 boundary pressure tests are current. Completion of i the reviews / revisions to the Class 2/3 pressure test procedures will support completion l of all tests to meet the end of period testing requirem. its (spring of the year 2000). In addition, most Class 2/3 pressure tests are conduc' . on-line (system operational pressuro).
Status:
This item was completed on April 13,1998,
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. 4 Attachment
. Quad Cities Nuclear Power Station Regulatory Commitment Change Summary Report Page 6 of 12 l
l Original Document:
LER 1-98-008 Subject cf Change:
Typographical error in the procedure identified to be revised and addition of two procedures that should have been identified in the original commitment.
Original Commitment:
Revise procedures OCMM 1530-08, -11 and -16 to include work instructions to have adequate clearances for installations with 1 inch clearance or less.
Due October 31,1998.
, Revised Commitment: Approved October 12,1998 Revise procedures OCMM 1530-08, -11, QCMM 1500-16, -19, and 20 to include work instructions to have adequate clearances for installations with 1 inch clearance or less.
Due October 30,1998.
Basis:
A!though the original procedure number was incorrect (and two other procedures were ,
not included), the intent of the original commitment will still be met.
Status:
This item was completed October 12,1998.
\
I Attachment
, Quad Cities Nuclear Power Station Regulatory Commitment Change Summary Report Page 7 of 12 l
j Original Document:
NRC meeting conducted on March 12,1998.
Subject of Change:
Extend due date from Quad Cities Unit 1 Refueling Outage 01R15 to Quad Cities Unit 1 Refueling Outage 01R16.
Original Commitment:
Replace Unit 1 Drywell Cocling Fan Discharge Dampers during 01R15.
Revised Commitment: Approved November 6,1998 Dampers for Unit 1 Drywell Cooling Fans will be replaced during 01R16 per Design Change Process 9800242.
Basis: -
Commitment was made after 01R15 Modification scope freeze milestone. There is insufficient time to develop and install this modification during 01R15. As an interim measure, the degraded dampers for the 1 F and 1G fans will be repaired during 01 R15.
The repairs will clear temporary modification 97-2-111 which secures open the 1F and 1G dampers. The Unit 1 Drywell ventilation system is currently fully operable. ,
Extending the deadline for this commitment will not affect system operability. I Status:
Degraded dampers for 1F and 1G fans were repaired during 01R15. A modification has been approved for installation in 01 R16.
, Attachment
. Quad Cities Nuclear Power Station Regulatory Commitment Change Summary Report ,
Page 8 of 12 )
1 l
Original Document: )
i LER 1-97-030 l 1
Subject of Change: l l
Change in minimum test pressure and elimination of the 45cific leakage requirement (0.3 gpm).
Original Commitment:
Corrective Actions Completed:
- 1. The operations procedures (OCOS 0201-7, " Reactor Vessel and Class 1 Systems 10-Year Hydrostatic Test for ISl" and OCOS 0201-8, " Reactor Vessel and Class One Piping Leak Test") have been revised to specify that the excess flow check valves are tested at 1005 psig (nominal pressure corresponding to 100% reactor power) or ,
greater. l
- 2. The instrument maintenance procedure (OCIS 0200-22, " Refuel Outage Reactor Vessel Excess Flow Check Valve Functional Test") has been revised to specify that l the excess flow check valves are tested at 1005 psig (nominal pressure j corresponding to 100% reactor power) or greater.
Corrective Actions to be Comoleted:
)
i l l 1. The instrument maintenance procedure (OCIS 0200-22, " Refuel Outage Reactor l Vessel Excess Flow Check Valve Functional Test") will be revised to perform just-in-l time training on the acceptance criteria (0.3 gpm at 1000 psig differential pressure) l each time prior to performing this test. Due June 15,1998 1
Revised Commitment: Approved November 23,1998
- 1. The operations procedures (OCOS 0201-7, " Reactor Vessel and Class 1 Systems 10-Year Hydrostatic Test for ISI" and OCOS 0201-8, " Reactor Vessel and Class One Paping i Leak Test") will be revised to specify that the excess flow check valves are tested at i 2600 psig.
I
- 2. The instrument maintenance procedure (OCIS 0200-22, " Refuel Outage Reactor Vessel Excess Flow Check Valve Functional Test") has been revised to specify that the excess flow check valves are tested at 2600.
P' 1
Attachment
. Quad Cities Nuclear Power Station Regulatory Commitment Change Summary Report Page 9 of 12
- 3. The instrument maintenance procedure (OCIS 0200-22, " Refuel Outage Reactor Vessel l Excess Flow Check Valve Functional Test") will be revised to perform just-in-time training demonstrating the flow reduction on a known acceptable valve each time prior to performing this test.
Basis:
Comed IST Program Technical Position Paper # TP-CWE-98-02, Revision 1, " Excess Flow Check Valve Testing, " dated Noven.ber 4,1998.
The Position Paper states:
- No leakage testing of excess f, ,a check valves is required to meet IST and Appendix J requirements.
. Closure testing of excess flow check valves can be performed at all system pressures between 600 psig and the system design basis pressure. Acceptance criteria for the test shall be an audible click denoting valve closure or significant reduction in flow.
Status:
SVP Letter 98-375, " Change of 10CFR50.73 Reportability Status" dated January 21, 1999, retracted LER 1-97-030 and the commitments.
Attachment
. Quad Cities Nuclear Power Station Regulatory Commitment Change Summary Report Paga 10 of 12 Original Document:
Quad Cities Nuclear Power Station letter SVP 98-203, " " Response to Questions Raised during Confirmatory Action Letter Closure Inspection and Summary of Fire Protection Compensatory Actions, " dated May 22,1998.
Subject of Change:
Identification and clarificaWn of specific areas of the plant that are susceptible to the underlying issues identified in SVP 98-203 regarding Fire Watches.
Original Commitment:
Per SVP 98-203, Fire Watches were established in the areas listed in the following table as compensatory measures for actual and potential wmknesses in Quad Cities imp!ementation of Appendix R safe shutdown requirernents.
Issue / Commitment Current implementation Applicable Fire Areas Station Blackout (SBO) Cable - 1) Once per hour fire watch. 13-1, 24-1, TB-IV Temporarilyinstalled cable. 2) Heightened level of Once per hour fire watch; awareness.
Heightened level of awareness.
ResidualHeat Removal (RHR) 1) Once per hour fire watch. RB-1 N, RB-1 S, Valve Hot Shorts. 2) Heightened level of RB-2N, RS-2S, Once per hour fire watch; awareness. TB-l and TB-Il Heightenedlevelof awareness.
High Pressure Coolant 1) Once per hour fire watch. RB-1 N, RB-2S Injection (HPCI) Pump room 2) Heightened level of penetration coals. awareness.
Once per hour fire watch; Heightened level of awareness.
125 Vdc Issues. 1) Once per hour fire watch. Specific areas are being Once per hour fire watch; 2) Heightened level of identified. However, current fire Heightened level of awareness. awareness. watch program is providing a once per hour fire watch in the following power block fire areas:
RB-1N, RB-1S, RB-2N, RB 2S, TB-1, TB-II, TB-lll, TB-IV, TB-V, 13-1,14-1,23-1, and 24-1, RB1/2 3
l Attachment i o Quad Cities Nuclear Power Station Regulatory Commitment Change Summary Report Page 11 of 12 Multiple Spurious Operations. 1) Once per hour fire watch. Specific areas are being Once per hour fire watch; 2) Heightened level of identified. However, current fire Heightened level of awareness. awareness. watch program is providing a once per hour fire watch in the following power block fire areas:
RB-1N, RB-1S, RB-2N, RB-2S, TB-1, TB-II, TB-Ill, TB-IV, TB-V, 13-1,14-1,23-1, and 24-1, RB1/2.
Revised Commitment: Approved January 6,1999 lasue/ Commitment Current Ireplementation Applicable Fire Zones RHR Valve Hot Shorts. 1) Once per hour fire 1.1.1.2, 1.1.1.3, 1.1.2.2, 1.1.2. 3, Once per hour fire watch; watch. 8.2.6.C, 6.3 Heightened level of 2) Heightened level of (Nuclear Design Information awareness. awareness. Transmittal ODC-98-222)
HPCIPump room 1) Once per hour fire 11.1.3,11.1.4 penetration seals. watch. (Nuclear Design Information Once per hour fire watch; 2) Heightened level of Transmittal ODC-98-222)
Heightened level of a'Nareness, awareness. l 125 Vdc issues. 1) Once per hour fire 11.4.A,11.4.B. 2.0, 3.0, 6.3, 8.2.1.A, l Once per hour fire watch; watch. 8.2.1.B, 8.2.2.A, 8.2.3.A, 8.2.4, 8.2.5, I' Heightened level of 2) Heightened level of 8.2.6.A, 8.2.6.B, 8.2.6.C, 8.2.6.D, awareness. awareness. 8.2.6.E, 8.2.7. A, 8.2.7.B, 8.2.7.C, 8.2.7.D, 8.2.7.E, 8.2.8. A, 8.2.8.B, 8.2.8 C, 8.2.8.D (Nuclear Design Information Transmittal ODC-98-307)
Multiple Spurious 1) Once per hour fire 1.1.1.2, 1.1.1.3, 1.1.2.2, 1.1.2.3, 6.3, Operations. watch. 8.2.6. A, 8.2.6.C, 8.2.7.C,8.2.7.A, Once per hour fire watch; 2) Heightened level of 8.2.8. A, 8.2.8.B, 8.2.8.C, 8.2.8.D Heightened level of awareness. (Nuclear Design Information awareness. Transmittal ODC-98-222)
I Basis:
l The current fire watches were implemented in response to questions raised during the Confirmatory Action Letter closure inspection by the NRC. At the time, all of the potential issues involving multiple spurious operations and 125 Vdc control power were not clearly identified. Therefore, fire watches were established in the power block as an interim measure to allow safe restart of both units. Since then, further investigation has allowed the identification of the specific areas of the plant that are susceptible to the underlying issues identified in SVP 98-203. The reduction in fire watches is a result of progress made in clearly identifying the specific vulnerabilities identified in SVP 98-203.
Although this reduction is a change to the station's commitments, it does not represent a reduction in afforded safety or commitment to resolution of the underlying issues.
Attachment Quad Cities Nuclear Power Station Regulatory Commitment Change Summary Report Page 12 of 12 Original Document:
Quad Cities Nuclear Power Station letters, ESK 97-115," individual Plant Examination of External Events - lPEEE," dated May 30,1997, SVP 97-234,"10 CFR 50, Appendix R, " dated October 31,1997, and SVP 97-282, "10CFR50, Appendix R, " dated December 23,1997 4
Subject of Change:
Removal of the Quick Response Team. j Original Commitment:
From ESK-97-115: A Quick Response Team (QRT) will be implemented to provide an immediate response and communication for fire alarms in high vulnerability areas by June 15,1997. The team will be staffed such that it will not impact safe shutdown st.ffing.
From SVP-97-234: A dedicated, fully qualified 5-person fire brigade has been posted to provide a quick response to a fire. This 5-person fire brigade has replaced the previously committed 3-person quick response team.
From SVP-97-282: the original dedicated, fully qualified 5-person fire brigade . . has been replaced with the 3-person incipient fire quick response team as required by the operability evaluation.
I Revised Commitment: Approved January 27,1999 The Quick Response Team (QRT) is no longer in place.
Basis:
The QRT was implemented as a compensatory measure in June 1997. This compensatory measure was a result of Quad Cities IPEEE value of SE-03 for fire risk.
As part of Quad Cities Fire Protection improvement Program, the Fire Risk model has been revised ucing more detailed cable routing information and eliminating gross assumptions. The results of the revised Fire Risk Model have produced a value of 6.6E-
- 05. Since the risk due to a fire is more in 'ine with industry values, this compensatory measure sball be eliminated.
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