ML20071M336

Responds to NRC Re Violations Noted in IE Insp Repts 50-237/82-08,50-249/82-09,50-254/82-09 & 50-265/82-10. Corrective Actions:Pump Testing Procedures Changed

ML20071M336
Person / Time
Site:	Dresden, Quad Cities, 05000000
Issue date:	08/31/1982
From:	Delgeorge L COMMONWEALTH EDISON CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20071M330	List: ML20071M336 ML20071M343
References
4921N, NUDOCS 8209270077
Download: ML20071M336 (3)

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• * *[D Commonwealth Edison

) one First National Plaza. Chicago. Illinois OD Address Reply to: Post Office Box 767 j Chicago, Illinois 60690 Augus t 31, 1982 Mr. James G. Keppler, Regional Administrator Directorate of Inspection and Enforcement - Region III U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137

Subject:

Dresden Station Unit 2 Response to Item 1 o f I.E.

Inspection Report Nos.

50-237/82-08, 50-249/82-09, 50-254/82-09, and 50-265/82-10 NRC Docket Nos. 50-237 Reference (a): C. E. Norelius letter to Cordell Reed dated July 1,1982.

(b): L. O. DelGeorge letter to J. G.

Keppler dated July 30, 1982.

Dear Mr. Keppler:

Re ference (a) provided the results of the special inspection conducted by Mr. I. T. Yin o f you r o f fic e on Ma y 3-6, 1982, at EDS Nuclear Inc. , Walnut Creek, California, of activities concerning our Dresden Station Units 2 and 3 and Quad Cities Station Units 1 and 2. During that inspection, certain activities appeared to be in non-compliance with NRC requirements.

The Attachment to this letter provides Commonwealth Edison Company 's response to non-compliance ' item 1. The date for submitting this response was discussed with Mr. W. Little of your office in an.

August 16, 1982, telephone conversation. Our response to items 2 and 3 was provided in Reference (b) .

Please address any questions that you or your staf f may have concerning this matter to this office.

Very truly yours, f!& ^Md L. O. De1Geo rge Director of Nuclear Licens'ng TJR/1m Attachment cc: Region III Inspector - Dresden 8209270077 820922 PDR ADOCK 05000237 SEP. 2 GE.

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Attachment A Item 1 applies to Docket No. 50-237 only

1. 10 CFR 50, Appendix 8. 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 ins truc tion s . "

Commonwealth Edison Company Topical Report CE A, " Quality Assurance Program for Nuclear Generating Stations, " Revision 20, dated February 17, 1982, states in Section 3 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, system flow diagrams, design and construction specifications, load capacity data sheets, design reports, equipment specifications, process drawings."

Contrary to the above, the CCSW check' velve slamming evaluation was considered to be deficient, in that: (1) the loadings on the check valve, the pipe anchor, and the pumps had not been verified to be acceptable, (2) the use of material ultimate stresses as evaluation criteria had not been qualified, (3) the evaluation allowable for the shell type concrete anchor bolt was incorrect, and (4) the engineering conclusion to justify the existing under design condition was without supporting basis.

This is a Severity Level V violation (Supplement IV) .

Discussion Ccmmonwealth Edison believes that the piping fatigue assessment performed by EDS Nuclear is adequate and that we were not negligent in the design control process. The piping fatigue analysis that was performed is not as conservative as the detailed evaluations specified in the noncompliance. However, based on our experience to date, the piping fatigue analysis is a viable alternative and does demonstrate system integrity. However, to fully resolve this issue, the following actions cere taken:

Corrective Action Taken and Results Achieved In order to resolve the subject violation, procedure changes in the testing of the pumps will be implemented to prevent reoccurrence of the water hammer event. Since the water hammer avents will not reoccur, the check valve, pipe anchor and pumps do not need to be evaluated to withstand water hammer loads as specified in item 1 of the violation. Since the check valve and pumps have functioned adequately since the last water hammer event, we know there is no l present damage and that the components will remain operable for normal operating loads.

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.The procedure change that will be' implemented will consist of operating and. shutting of f one CCSW pump at a time when quarterly surveillance tests are performed.-- In'the past, both pumps were in operation when one of the pumps was shut ~off,- which caused the higher

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hydrodynamic loading on.the check valve. This procedure change will effectively eliminate the check valve slam and satisfy the four-items of the noncompliance. . A mere detailed discussion is also presented for items 2, 3,. and 4 o f the violation.

Concerning' item'2, ultimate stress was not used to evaluate the system design.- To determine if the water hammer analysis gave reasonable results, the results of the analysis were compared to the utlimate capability of hanger 1210-36. Item 3, the evaluation allowable for the shell type anchor bolt was improperly rounded off.

The calculation was repeated with the corrected allowable and the results did: not vary significantly from the original calculation.-

Item-4, the engineering conclusion to justify the existing design is correct since the water hammer will be eliminated and the system and system components will not see the added hydrodynamic loading.

Corrective Action Taken to Avoid Further- bbncompliance Eliminating the hydrodynamic loading dueLto check valve. slam with'a permanent procedure change will provide a permanent solution to the noncompliance..

Date when ' full compliance will be achieved The procedure change will be implemented prior to the next scheduled quarterly surveillance test. -

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