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April 21, 1999

The Commission has approved the contents of the proposed Abnormal Occurrences report to Congress subject to the comments provided below. The staff should incorporate the changes to the report and the forwarding letters, as appropriate, and provide them for the Chairman's signature.

1. Changes to the Report to Congress on Abnormal Occurrences, Fiscal Year 1998:

1. The title page should be updated to reflect the report's correct originating organization within the NRC, since AEOD no longer exists.

2. The discussion regarding the promulgation of the AO criteria on page 10 of the report should be updated to reflect the latest Commission direction on "Other Events of Interest" in the 9/4/98 Staff Requirements Memorandum on SECY-98-175, dated September 4, 1998.

3. The page numbers in the Table of Contents should be corrected to correspond to the actual text and the staff should conduct a quality assurance review of the document before it is issued.

4. The proposed text in Appendix C for NRC and Agreement State materials licensees contains the statement that there were no reports of contamination in FY 98 resulting from loss of control of licensed materials. However, on September 18, 1998, NRC issued PNO-II-98-041 concerning the finding of thorium contamination at a castings plant in Alabama. The text should be revised to take this event into account. In doing so, comment should be made that this is the 29^th radioactive contamination event at a U.S. metal making mill since 1983.

5. In the Proposed Appendix C Events, page 3, the last paragraph prior to item number 3 should be deleted. On page 3 in the 2^nd paragraph, the 5^th sentence

(Currently, ComEd is completing ... response timeline estimation.) should be replaced with the following:

"During a January 1999 meeting, ComEd informed the NRC that it had completed its safe shutdown analysis optimization study. The results of this study indicated that, for certain cases, additional systems could have been used for post-fire safe shutdown. In addition, this study concluded that, for fires in certain plant areas, some of the credited shutdown actions could have been taken from inside the control room in lieu of having to take these actions from outside the control room. Therefore, the results of this study may demonstrate that the original fire risk estimates reported in the IPEEE were overstated. The staff has not yet reviewed ComEd's revised fire risk assessment.

To further reduce risk, ComEd is considering changes to allow operation from the control room of the safe shutdown makeup pump, station blackout diesel, and the high pressure coolant injection pump. In addition, plant improvements are planned for the 125Vdc breaker control power distribution system and the fire protection features provided for the unit 1 reactor feed pump area in the turbine building. ComEd's fire protection improvement program is scheduled to be completed by the end of the spring 2000 refueling outage for unit 1 and the spring 2001 refueling outage for unit 2.

Even though the post-fire safe shutdown methodology weaknesses did not result in an actual challenge or failure of a safety system, the potential that a severe fire could challenge the effective implementation of this methodology for certain fire areas did exist."