ML20010B945
| ML20010B945 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 08/12/1980 |
| From: | Abel J COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| NUDOCS 8108180506 | |
| Download: ML20010B945 (4) | |
Text
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Commonwealth Edison
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,One First Nabonal Plaza Chicago, lihnois Address Reply to: Post Office Box 767 Chicago, !!!inois 60690 August 12, 1980 4
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Mr. James G.
Keppler, Director 9
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Directorate of Inspection and 2 Agg y y yggy,
Enforcement - Region III U.S. Nuclear Regulatory Commission
"*** Em7 T 799 Roosevelt Road Glen Ellyn, IL 60137 4
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Subject:
Byron Station Units 1 and 2 Response to IE Inspection Report Nos. 50-454/80-12 and 50-455/80-11 NRC D H 7t Nos. 50-454 and 50-455 Reference (a)
July 10, 1980 letter from G.
Florelli to C. Reed
Dear Mr. Keppler:
[~j Reference (a) contained the results of an inspection conducted by Mr. K. R. Naidu, J.F.
- Schapker, R.
L.
Lee, D.
W.
Hayes and C.
C.
Williams of your office on June 17, 18 and 19, 1980 of activities at Byron Station.
During that inspection, certain activities appeared to be in noncompliance with NRC requirements.
Attachment A to this letter contains Commonwealth Edison Company's response to the item of noncompliance.
Based on the information contained in this response, Commonwealth Edison respectfully requests the NRC Region III to change the infraction to an observation.
Please address any questions that you might have concerning this matter to this office.
James S. Abel Director of Nuclear Licensing JSA:WFN: rap attachment p}
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AUG 151980 8108180506 810812 PDR ADOCK 05000454 0
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NRC Docket Nos. 50-454 50-455 ATTACHMENT A RESPONSE TO NOTICE OF VIOLATION of the NRC letter dated July 9,The item of apparent noncompliance ide following paragraphs.
1980 is responded to in then Appendix A Item Infraction 10 CFR 50 Appendix B, Criterion III, states, in part, that
" Measures,shall be established to assure that ap li basis... for those structures,
- systems, cable... design p
correctly translated into specifications, drawingsand componenets...are instructions."
, procedures, and Assurance Program for Nuclear GenerattCommonwealth Edis
" Quality dated July 16, ag Stations", Revisinn 9,
- 1979, states in Parr raph 3.1 that "The fundamental vehicle for design control invol'ss multi-level re i 3
evaluation of design documeni, oy individuals or g
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v ew and/or the original designer or F;aigner's immediate s roups other than written procedures. authority and responsibi.'Aty are identified and contr ll upervisor whose tc, design and construction specificationsThe design documen limited o
ed by specifications and process drawings.
equipment the Architect Engineer will assure that designsReview of and evaluation by conform to the ASME Code and other applicable ccMeand materials will regulatory requirements, standards as applicable. SAR commitments, and approp,riate quality s
standards, 10 CFR 50, Appendix A, Criterion IV, and components important to safety shall be designed tstates " Structures, the ef fects of and be compatible with environm
- systems, o accommodate associated with normal operation, maintenance ental conditions postulated accidents, and loss-of-coolant accident
, testing, and structures systems, and components shall be appropriat l s.
These against dynamic effects, whipping, and discharging fluids that mayincluding the ef fects of missilese y p failures and
, pipe from events and conditions outside the nuclearresult of equipment plant."
power 10 CFR 50, Appendix A, Criterion V, states " Structures, componentr important to safety shall not be shared among systems and power uni s urless it can be shown that such sharin significantly impair their ability to perform their s f t nuclear g will not O
functions, incluaing, orderly shutdown and cooldown of the remaining unitin the eves:t of a aey
, an s."
, k Contrary to the above, it was determined that CECO. did not ensure that Sargent and Lundy adequately translated the requirements in 10 CFR 50, Appendix A, Criterion IV and V, in the design of the cooling water supply to the Emergency Diesel Generator lA in the following instances:
1.
A common header is installed in the room housing Emergency Diesel Generator 18 to supply the cooling water to Diesel Generators IA and 18.
2.
The "to" and " return" cooling waterlines to Diesel Generator 1A pass through the room housing Ur.it 18.
In the event of an accident in Unit 18 emergency diesel generator room, both Emergency Diesel Generators lA and 1B could become inoperable due to loss of cooling water.
Response
With regard to Item 1, the inspector's observation is not correct as there is njl such common header.
With regard to Item 2, in actuality the 1A and 18 rooms in this C(-]
observation are reversed, i.e.
the 1B "to" and " return" lines pass through the 1A room.
Regardless, Commonwealth Edison has reviewed the present design and concludes that it is adequate to satisfy the intent of Criterion IV and V of 10 CFR 50, Appendix A.
The basis for this conclusion as well as the basis for the design follows:
1.
All valving including the cross connects are located outside the diesel generator rooms; 2.
The 18 room is located on an outside building wall and cannot be entered piping wise from the south; 3.
Since the turbine building is Category II, piping cannot enter the room from the east; 4.
No entrance is possible from the west, and entering from above or below would result in a similar pipe routing through the 1A switchgear room and 1A diesel oil storage room, respectively; 5.
The 1A and 1B piping is separated immediately upon entering the 1A room; 6.
No..issiles are postulated from the emergency diesel generators;
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7.
Essential service water piping is mcderate energy; and
, 8.
The cooling water lines in question are all of the same size and wall thickness and, the re fo re, any break in one line would not cause a break in another line.
Based on the information presented, Commonwealth Edison respectfully requests the NRC Region III to change the apparent infra-tion to an observation.
In addition, Commonwealth Edison believes that the type of concern expressed in this inspection report, i.e.
site inspections which review the adequacy of the design with respect to 10 CFR 50, are more appropriately addressed to the Office of Nuclear Reactor Regulation (NRR), rather than issued as non-compliance items to the Applicant.
Then, NRR can consider the item as a design deficiency during their detailed review of the Byron and Braidwood Final Safety Analysis Report.
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