ML19345B355
| ML19345B355 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 10/27/1980 |
| From: | Abel J COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML19345B354 | List: |
| References | |
| NUDOCS 8011280206 | |
| Download: ML19345B355 (3) | |
Text
Commonwealth Edison One First N tional Prza Chiergo ifhnois
[
Address Reply to Post Office Box 767
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CNcago. libnois 606':r0 October 27, 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:
Byron Station Units 1 and 2 Supplementary Response to IE Inspection Report Nos. 50-454/80-12 and 50-455/80-11 NRC Occket Nos. 50-454 and 50-455 References (a):
July 10, 1980, letter from G.
Fiorelli to C. Reed (b):
August 12, 1980, letter from J.
S. ADel to J.
G.
Keppler (c):
September 16, 1980, letter from J.
G.
Keppler to C. Reed
Dear Mr. Keppler:
Reference (a) contained the results of an inspection at Byron Station in which certain activities appeared to be in noncompliance with NRC requirements.
Reference (c) certained Commonwealth Edison Company's response to the item of noncompliance in which Commonwealth Edison requested the NRC Staff to withdraw the infraction.
In Reference (C), the NRC Staff indicated that its position remained unchanged.
Commonwealth Edison has reexamined the item of noncompliance ar.d a supplementary response is contained in Attachment A to this letter.
This response was discussed with Messrs. C.
C. Williams ano D.
W. Hayes of your office at a meeting at Commonwealth Edison's corporate headquarters on October 23, 1980.
Based on the information presented, Commonwealth Edison respectfully requests the NRC Staff to re-review their positions with regard to this item of noncompliance.
Please address any questions that you might have concerning this matter to this office.
Very truly yours, bd
,7 g3[@
f J.
Abe gf O '
"') j Director of Nuclear
' l vn F
q Licensing Attachment 7654A
NRC Docket Nos. 50-454 50-455 Attachment A Supplementary Response to Notice of Violation A supplementary response to the item of apparent noncompliance identified in Appendix A of the NRC letter dated July 9,
1980, follows.
Item Infraction 10 CFR 50, Appendix B, Criterion III, states, in part, that
" Measures shall be established to assure that applicable.
design basis.
for those structures, systems, and components
. are correctly translated into specifications, drawings, procedures, and instructions."
Commonwealth Edison Company Topical Report CE-1-A, " Quality l
Assurance Program for Nuclear Generating Stations", Revision 9, dated July 16, 1979, states in Paragraph 3.1 that "The fundamental vehicle for design control involves multi-level review and/or evaluation of design documents by individuals or groups other than the original designer or designer's immediate supervisor whose authority and responsibility are identified and controlled by written procedures.
The design documents include, but are not limited to, design and construction specifications, equipment specifications and process drawings.
Review of and evaluation by the Architect Engineer will assure that designs and materials will conform to the ASME Code and other applicable codes, standards, regulatory requirements, SAR commitments, and appropriate quality standards as applicable.
10 CFR 50, Appendix A, Criterion IV, states " Structures, systems, and components important to safety shall be designed to accommodate the effects of and be compatible with environmental conditions associated with normal operation, maintenance, testing, and postulated accidents, including loss-of-coolant accidents.
These structures systems, and components shall be appropriately protected against dynamic effects, including the effects of missiles, pipe whipping, and discharging fluids that may result from equipment failures and from events and conditions outside the nuclear power plant."
10 CFR 50, Appendix A, Criterion V, states " Structures, systems and components important to safety shall not be shared among nuclear power units unless it can be shown that such sharing will not significantly impair their ability to perform their safety functions, including, in the event of an accident in one unit, an orderly shutdown and cooldown'of the remaining units."
l
=
h Contrary to the above, it was determined that CECO did not ensure that Sargent & Lundy adequately translated tne requirements in 10 CFR 50, Appendix A, Criterion IV and V, in the design of the cooling water supply to the Emergency Diesel Generator 1A in the following instances:
1.
A common header is installed in the room housing Emergency Diesel Generator 18 and to supply the cooling water to Diesel Generators IA and 18.
2.
The "to" and " return" cooling waterlines to Diesel Generator lA pass through the room housing Unit 18.
In the event of an accident in Unit IB emergency diesel generator room, both Emergency Diesel Generators lA anc 1B could become inoperable due to loss of cooling water.
Response
As indicated in Reference (b) and confirmed in Reference (c), Item 1 was a mischaracterization by the inspector.
With regard to Item 2, Commonwealth Edison of fers the following supplementary information.
A closer examination of 10 CFR 50, Appendix A, Criterion V, indicates that it applies to systems shared between nuclear power units.
The item of noncompliance actually addresses redundant lines of the same unit.
Therefore, Criterion V is not applicable for this Case.
In reviewing 10 CFR 50, Appendix A, Criterion IV, Commonwealth Edison refers to B/B FSAR Section 3.1.2.1.4, which states:
" Safety-related systems, components, and structures in this plant are designed to accommodate all normal or routine environmental conditions as well as those associated with e
postulated accidents (where appropriate).
The design includes provisions to protect (by physical separation, barriers, or appropriate restraints) safety-related items from dynamic effects resulting from component failures, and specific credible external event. and conditions."
Thus, in the B/B design Commonwealth Edison has committed to take into consideration environmental hazards but is not limited to using separation or barriers as a single protection for redundant lines.
In addition, in the B/B design, the designer utilized the criteria for separtion delineated in a Sargent & Lundy procedure (Analytical Procedure for Meeting Separation and High/ Moderate Energy Line 1
Rupture Criteria).
This procedure addresses separation requirements i
for high energy, moderate energy, and redundant lines.
e 6
Finally, when all the systems are completed, an integrated review of the location of break points, final piping analysis and follo up analyses is performed to ensure that all requirements are met prior to plant operation.
Thus, procedures are in place and at design completion all. requirements will have been met.
Specific environmental consideration such as fire hazards, effects of missiles, floods, etc. are reviewed on an integrated plant basis and include the identified area.
As previously indicated, Commonwealth Edison does not postulate any missiles from the emergency diesel generators.
Based on this information, Commonwealth Edison considers the cooling water supply to the emergency diesel generators to be in conformance with the intent of 10 CFR 50, Appendix A, Criterion IV and respectfully requests the NRC Staff to re-review their finding that a nonconforming condition exists.
Per a request by the NRC Staff, enclosed are two copies of Drawing No. M-253, Sheet 1 of 3; Aux Bldg. Piping Diesel Gen. Room, Plan El.
401'-
0", Byron /Braidwood Stations, Unit 1.