IR 05000237/1993012

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-237/93-12 & 50-249/93-12.Lists Issues Raised in Subj Response Which Necessitate Further Discussion & Clarification

ML17179B157
Person / Time
Site:	Dresden
Issue date:	10/22/1993
From:	Greenman E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Wallace M COMMONWEALTH EDISON CO.
References
NUDOCS 9310280228
Download: ML17179B157 (2)

Text

Docket Nos. 50-237; 50-249 Commonwealth Edison Company ATTN: Mr. M. Vice President and Chief Nuclear Officer Executive Towers West III 1400 Opus Place, Suite 500 Downers Grove, IL 60515 OCT 2 2 1993 SUBJECT:

RESPONSE TO DRESDEN INSPECTION REPORT 50-237/93012;50-249/93012 References: (a)

Brent Clayton letter to L. 0. DelGeorge, dated May 26, 1993, transmitting Inspection Report 50-237/93012;50-249/93012 (b)

0. Farrar letter to Document Control Desk, dated June 24, 1993, transmitting requested response to Inspector Followup Item 50-237/93012-01 transmitted with Inspection Report 50-237/93012;50-249/93012 (c)

D. Farrar letter to Document Control Desk, dated September 23, 1993, providing clarification to Inspector Followup Item 50-237/93012-01.

Dear Mr. Wallace:

This will acknowledge receipt of your letter dated September 23, 1993, in response to our letter dated May 23, 1993, transmitting an Inspector Followup Item associated with Inspection Report 50-237/93012; 50-249/93012 (DRP).

Some of the issues raised in your letter, regarding the operability of the control room emergency ventilation system, necessitate further discussion and clarification.

First, your letter suggests the control room emergency ventilation system was functional because the radioactive effluent filtration capability of the control room emergency ventilation system remained functional and that the system could not be considered inoperable since a Technical Specification governing operability of the control room emergency ventilation system does not exist for Dresden Station.

Dresden Safety Analysis Report (SAR), Section 10.11.4, "Control Room Ventilation System," states that the control room heating, ventilation, and air conditioning (HVAC) system is designed to maintain the control room within the design temperature range of 70°F (minimum) to 80°F (maximum) as defined in SAR, section 10.11.2. By removing both containment cooling service water supply trains to the control room emergency ventilation refrigeration condensing unit from service, 9310280228 931022 PDR ADOCK 05000237 G

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OCT 2 2 1993 Commonwealth Edison Company

the ability of the control room HVAC system to meet one of its specified functions, i.e. cooling, should have been questioned.

Without this question being answered, the system should have been considered inoperable until a satisfactory engineering analysis was performed to justify system operability.

Second, we are concerned with your implied limitation that operability determinations need only be made for those systems having Technical Specifications. Operability of systems identified within the design bases of the plant, i.e. the Safety Analysis Report, but not addressed by the Technical Specification licensing bases must be evaluated for their impact on safety in accordance with the requirements of 10 C.F.R. 50.59.

Although we strongly encourage activities designed to improve the reliability of plant systems, these activities must be reviewed and accomplished in a manner which will not challenge the operation of the plant by placing it outside its design parameters.

This issue will be a topic fof <Lirl;U..Stioa <t&e!hea.dJext management meeting.

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L. DelGeorge, Vice President, Nuclear Oversight & Regulatory Services M. Lyster, Site Vice President, G. Spedl, Station Manager J. Shields, Regulatory Assurance Supervisor D. Farrar, Nuclear Regulatory Services Manager OC/LFDCB Resident Inspectors, Dresden LaSalle, Quad Cities, Clinton R. Hubbard J. Mccaffrey, Chief, Public Utilities Division R. Newmann, Office of Public Counsel, State of Illinois Center Licensing Project Manager, NRR State Liaison Officer Chairman, Illinois Commerce Commission J. B. Martin, Riii H. J. Miller, RIII T. 0. Martin, Riii J. E. Dyer, NRR E. J. Leeds, NRR M. L. Jordan, RIII C. D. Pederson, RIII S. Stasek, SRI, Davis Besse bee:

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