IR 05000237/1990023
| ML17202U981 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 02/06/1991 |
| From: | Miller H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Reed C COMMONWEALTH EDISON CO. |
| References | |
| NUDOCS 9102120160 | |
| Download: ML17202U981 (2) | |
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UNITED STATES
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Docket No. 50-237 Docket No. 50-249 Commonwealth Edison Company ATTN:. Mr. Corde lJ * Reed Senior Vice President Opus Wes.t I Il 1400 Opfrs Place Downers Grove, IL : 60515
. Gentlemen:
REGION Ill
. 799 'R()OSEVELT ROAD GLEN ELLVN, ILLINOIS 60137 FEB 6 1991
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Thank you for your response dated Janu.ary.7, 1991, fo-.t.he* December 7, J990
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Notice of Violation (NOV) issued with NRC Inspedion Report 50-237/90023;.'
50-249/90023 for the Dresden Station~
We have reviewed your written comments objettin~ to a porti-On of Item 2.c of the NOV. *Our respo~se addresses each of
the Jpecific comments:contained in y6~r l~tter..
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A~ indicated in your response~ one oi the criteria requiring a valve to be locked p~r Dresden Administrative Protedure. (OAP) 7-14~ "Control and Criteria for Locked Equipmerit and Valves". i~cludes."manual valves which provide a.
. co.ntrolled path* to the Environs: including primary _and secondary containment*
" * iso.lati9n.valves."
Your assertion *;that _the drywell air sample. system is a *
closed loop system is correct;':however; the portion of the system downstream of the isolation ~valve*s. is non-safety related and, 'therefore, cannot be credited as preventing a path. to the environment *. This po.rtion of.the syste is not subjected.to ~eriodic integr~ted leak r~te test pre~sure and cannot be considered a primary containme*nt boundary.* No evidence was provided to support your assumption* that NRC. app~oval of the isolation design of thi system was based solely upo_n this being a closed. loop syste We believe an*
additional basis was a cost/benef._it decision regarding the feasipility of backf'itting a*utomat1c isolation provisions.*.NRC approval does not alter* the fact that a path to the enviroriment still exists nor does it preclude application**-
of other requirement *
Your contention that the NRC had revie~ed lea~ing these valves ~nlocked coul~
not be verified. Although.the NRC did approve the containment isolation design provisions of this *system, your-February 25, 1980 submittal and subsequent NRt Safety Evaluation Report (SER) dated March 5, 1980 did not include valve locking requirements *. With regard to Table I ~nd its application to Table II in. the SER dated September 24, 1982, this SER and your response letter dated November 18, 1982 indicated that d~ring the August 1982 site visit, you had agreed to review all containment penetrations and not limit the scope td Table I No evidence ~as* provided to indicate that all valves listed in Table I were explicitly reviewed by the NRC for inclusion in Table II *
The NRC's position delineated in Section V of the September 24, 1982 SER wa ~hat, ~nless it can be demon~trated accep~able o~ some other defined b~sis,.
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isolation valves should be either automatic or locked closed. A case i_n poin ~ol(
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Cominonwea l th Edi sori Company _
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.6 1991 indicating a~ unacceptabl~ basis would be you~ request-~~scribed in this same SER for exemption from Appendix J leak detection. reql!irements for spetif Reactor Building.Closed Cooling Water System !=Ontainment isolation valve The NRC rejected your justification that the. closed loop nature of the. system-ins'ures its integrity in the event of a single active.failur.
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Ou~ coht~usion ~ta~ds a~*d6cumented in.the above inspection repori th~t the failure to-lock these va.lves closed was contrary to your own procedure and.the
".'":requirements of 10 CFR 50, Appendix B, Criterion Vas well as the,SEP
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lock :tlose~.these valve_s, we have no. other concerns in thiS.area at this tim,* *,
-c'c w/enclosure:;:
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D. Galle, Vice Pres-ident.:}i3wR
- Operatfons *. * -
- T. Kovach~ Nuclear*.
~i cel')S i ng Manager *
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.E. D/Eenigenburg~ StationManager DCD/DCB (RIDS)..
OC/LFDCB
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Resident l'nspectors La Sa 11 e, *... -
. * *:bresden, Quad Citi_es Richard Hubbard
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J. W'. Mccaffrey, Chief, Public*.
Utilities D~vision
- Robert Newmann, Office of Public
... Counsel, State of Illinois *center:*
B. Siegel, LPM~. NRR
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Sincerely,
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- *H ert J. Miller, Dire.ctor Divisi-0n of Re~ctor Projects
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