IR 05000456/1987029
| ML20237B728 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 12/11/1987 |
| From: | Norelius C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Reed C COMMONWEALTH EDISON CO. |
| References | |
| NUDOCS 8712170100 | |
| Download: ML20237B728 (2) | |
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DEC 11 ggy I
Docket No. 50-456 Docket No. 50-457 Commonwealth Edison Company ATTN: Mr. Cordell Reed Senior Vice President
Post Office Box 767 Chicago, IL 60690 Gentlemen:
Thank you for your letter dated October 23, 1987, informing us of the steps you have taken to correct the violations identified in Inspection Report No. 50-456/87029(DRP); 50-457/87027(DRP) forwarded by our letter dated September 25, 1987.
Your response acknowledged that a procedure violation occurred on August 8, 1987, when valve IRH8716-A was in a closed position for one hour and four minutes. Your response stated that you do not believe that the level of degradation induced in the residual heat removal system during the event constituted a violation of Technical Specifications 3.5.2 and 3.0.3.
In a subsequent letter dated November 3,1987, you stated your position that manipulation of valves such as RH 8716 or RH 8735 is acceptable during operation in modes 1 through 5 while observing the applicable 72-hour Technical Specification (T/S) action statement time clock of T/S 3.5.2 and concluded that T/S 3.0.2, 3.0.3, and 3.5.2 were not violated.
Your letter referred to a Westinghouse evaluation previously provided to Byron Unit 1, that showed one RHR pump discharging into two reactor coolant system cold legs resulted in an ECCS subsystem being " capable of performing its specified function", and therefore operable. Your response also discussed additional mitigating factors and your desire to meet with the NRC to further discuss this matter.
Technical Specifications Limiting Condition for Operation 3.5.2 includes the requirement of an operable flow path for each ECCS Subsystem. Maintenance of an operable flow path is specified in T/S Surveillance Requirement 4.5.2, which requires periodic verification that each valve in the flow path is in its correct position. The correct position of valve RH 8716, as described in the FSAR, plant drawings and procedures, is "open."
The surveillance requirement ensures that, as a minimum, the assumptions used in the safety analysis are met and that subsystem operability is maintained, and further, provides an accept-able level of total ECCS flow to all injection points equal to or above that assumed in the ECCS Loss of Coolant Accident (LOCA) analysis (T/S 3/4.5 ECCS Bases).
We do not agree with your position that it is acceptable to manipulate valves such as RH 8716, where such manipulation results in configurations different from those recognized by regulatory documents. Although your Westinghouse
,4 safety analysis may provide "before the fact" bases for changes to procedures, I
l 'O 8712170100 871211 PDR ADOCK 05000456
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Commonwealth Edison Company
DEC 11 1987 the FSAR, or T/S, the analysis is not a substitute for those regulatory documents.
' Based on a review of the cited violation and your response, we hereby confirm our previous classification of the violation as a Severity Level IV in its entirety. The corrective actions described in your response are considered adequate to prevent recurrence of the cited violation, and no further response is required.
Sincerely, ORIGINAL SIGNED BY C. E. NOPTT"D Charles E. Norelius, Director i
Division of Reactor Projects
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cc:
T. J. Maiman, Vice President, PWR Operations D. Butterfield, Nuclear Licensing Manager M. Wallace, Manager of Projects D. Shamblin, Project Manager W. Vahle, Construction Superintendent E. E. Fitzpatrick, Station Manager P. L. Barnes, Regulatory Assurance Supervisor DCD/DCB (RIDS)
Licensing Fee Management Branch Resident Inspector, RIII Braidwood Resident Inspector, RIII Byron D. W. Cassel, Jr., Esq.
Richard Hubbard J. W. McCaffrey, Chief, Public Utilities Division H. S. Taylor, Quality Assurance Division E. Chan, 0GC G. Berry, 0GC J. Stevens, NRR The Honorable A. Dixon Callihan, ASLB The Honorable Richard F. Cole, ASLB The Honorable Ivan W. Smith, ASLB The Honorable Gary J. Edles, ASLAP
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The Honorable Dr. W. Reed Johnson, ASLAP (2g The Honorable Christine N. Kohl, ASLAP
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