ML19312D849

Responds to NRC 800229 Ltr Re Violations Noted in IE Insp Repts 50-456/80-01 & 50-457/80-01.Corrective Actions:Will Build Three fire-proof Vaults Which Will Have 2-h Fire Rating & Be Large Enough to House Three or Four Cabinets

ML19312D849
Person / Time
Site:	Braidwood
Issue date:	03/31/1980
From:	Peoples D COMMONWEALTH EDISON CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML19312D847	List: ML19312D849
References
NUDOCS 8005050212
Download: ML19312D849 (3)

Text

• -T Commonwrith Edison

,.[%;7 ). ona f ,, First National Plaz:, Chicigo. Ilkncis 8005050hb iV Addrsss RIply to: Post Office Box 767

- ' - Chicago, lilinoia 60690 ,

March 31, 1980 Mr. James G. Keppler, Director Directorate of Inspection and Enforcement - Region III -

U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137 ,

Subject:

Braidwood Station Units 1 and 2 Response to IE Inspection Report Nos. 50-456/80-01 and 50-457/ 80-01 NRC Docket Nos. 50-456 and 50-457 Reference (a): February 29, 1980 letter to Gaston Fiorcili to C. Reed

Dear Mr. Keppler:

Reference (a) contained the results of an inspection conducted by Mr. E. R. Schweibinz of your office on January 16-17, 1980 of activities at Braidwood Station. That inspection identified an apparent item of noncompliance with NRC requirements. Commonwealth Edison Company's response to the item of noncompliance is contained in Attachment A to this letter.

Please address any additional questions that you might have concerning this matter to this office.

Very truly yours, b I D. L. Pe es Director of Nuclear Licensing OLP:WFN: rap Attachment t

2687A APR 21980 ,

NRC Docket Nos. 50-456 1

50-457 ATTACHMENT A 10 CFR 50, Appendix B, Criterion XVII, states in part, that,

" Consistent with applicable regulatory requirements, the applicant shall establish requirements concerning retention such as ... location ...." The Commonwealth Edison Company, the Quality Assurance Manual, QC No. 17-1, Section 6.2, states in part, "The quality assurance records shall be stored in a predetermined location, as necessary to meet the requirements of applicable standards, codes, and regulatory agencies." Section 6.3, states in part, "The storage facilities shall be adequate for the maintenance, preservation, and protection of the quality assurance record files from the time of receipt until their ultimate disposal". The Commonwealth Edison Company quality assurance program as defined in Topical Report CE-1-A commits to comply with Regulutory Guide 1.88, Revision 2, which endorses ANSI NAS, for prctection quality assurance records from the hazards of fire. ANSI N45.2-9, Subdivision 5.6 Facility, states in part, "Permanant and temporary record storage facilities shall be so constructed or located as to protect contents from possible destruction by causes such as fire, flooding, tornadoes, insects, rodents, and from possible deterioration by a combination of extreme variations in temperature and humidity conditions....

Records discussed in this standard are appropriately classified for fire protection purposes as National Fire Protection Association Class I and as such should be afforded the equivalent protection of a NFPA Class A four hour minimum rated facility."

Contrary to the above, on January 16-17, 1980, the inspector found the licensee had been storing quality records in a two hour rated facility. In addition to the above, Commonwealth Edison Company contractors and subcontractors have been storing quality records in one hour rated file containers.

Corrective Action Taken And The Results Achieved: ,

Commonwealth Edison will build three fire-proof vaults, which I will have a~two hour fire rating and which will be large enough to house three or four cabinets. These vaults will be appropriately located for conveninent use by Commonwealth Edison Company contractors and subcontractors during the period of plant construction.

Corrective Action To Be Taken To Aviod Further Noncompliance:

With regard to storing quality assurance records in facilities with less than four hour minimum rating, Commonwealth Edison is i pursuing an amendment to the FSAR which will take exception to the appropriate section of Regulatory Guide 1.88 during the period of construction, i.e. allow a two hour rated facility to l be acceptable during construction. ,

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l Date When Full Compliance Will Be Achieved:

1 Full compliance will be achieved for all items except the FSAR amendment by June 16, 1980. Commonwealth Edison will notity Region III when this amendment is submitted. Submittal is currently expected prior to August 1980.

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