ML20077A863
| ML20077A863 | |
| Person / Time | |
|---|---|
| Site: | Dresden, Quad Cities, 05000000 |
| Issue date: | 07/14/1983 |
| From: | Farrar D COMMONWEALTH EDISON CO. |
| To: | Little W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20077A831 | List: |
| References | |
| 6950N, NUDOCS 8307220476 | |
| Download: ML20077A863 (4) | |
Text
.
4
'. #]oCommonwealth Edison
/
O na First Natiorei Pina, Chictgo, lihnois j
y
\\ O ~J Address Reply to: Post Office Box 767
\\g Chicago, titnois 60690 July 14, 1983 Mr.
W.
S. Little - Region III U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137
Subject:
Dresden Station Units 2 and 3 Quad Cities Station Units 1 and 2 Response to Inspection Report Nos.
50-237/83-12, 50-249/83-10, 50-254/83-13 and 50-265/83-11 NRC Docket Nos. 50-237, 50-249 50-254 and 50-265 Reference (a):
W. S. Little letter to Cordell Reed dated June 16, 1983.
Dear Mr. Little:
This letter is in response to the inspection conducteo by Mr.
I.
T.
Yin on April 12-14, 1983, at EDS Nuclear Inc., Walnut Creek, CA; on May 6, 1983, at Dresden and on May 16, 1983 at the Region III office of activities at Dresden and Quad Cities Station.
Reference (a) indicated that certain activities appeared to be in noncompliance with NRC requirements.
The Commonwealth Edison Company response to the Notice of Violation is provided in the enclosure.
To the best of my knowledge and belief the statements contained herein and in the attachment are true and correct.
In some respects these statements are not based upon my personal knowledge but upon information furnished by other Commonwealth Edison employees.
Such information has been reviewed in accordance with Company practice and I believe it to be reliable.
If you have any further questions on this matter, please direct i
them to this office.
l Very truly yours,
/f D.
. F rrar Di ec r of Nuclear Licensing BR/lm Attachment cc:
NRC Resident Inspector - Dresden NRC Resident Inspector.- Quad Cities N
(i pCJ 6950N 8307220476 830719 PDR ADOCK 05000237 L
M ig G
- C, Attachment Commonwealth Edison Company Response to Notice of Violation 1
iItem 1 of Noncompliance-1.
=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 1
correctly translated into specifications, drawings, procedures,.
and instructions.
Commonwealth Edison Company Topical Report-CE-1-A, " Quality Assurance Program for Nuclear Generating Stations", Revision 21, dated June'6, 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, during review of pipe anchor R133 in the PSUPP-OlC' pressure suppression system, the as-built configuration
.was found_to differ from.that specified in the original design, in.
that the anchor was' altered to become a pipe guide.
The condition was not identified during the 8echtel IEB 79-14 walkdown and EDS engineers evaluating this item did not. identify that the anchor
-had been altered.
This resulted in an erroneous piping stress analysis being. performed for the system.
This is'a Severity Level V violation (Supplement II).
- Corrective Action Taken and Results Achieved Problem No. Ql-PSUPP-01C was. reanalyzed to reflect'the actual as-built configuration of the supiort R133.
The piping system was found to be acceptable for-operability.
Modification of.the existing support ~ conf.iguration was required to qualify the system for FSAR requirements.
The subject support was revised and a'new support design' issued.
Installation and final as-built documentation of this work will be done as part of the overall schedule for completion of 79-14 scope.
Theisub' ject piping' system has been corrected and no further action is required.
.c
.. Corrective Action Taken to Avoid Further Noncompliance A review of.all the anchors and three way stops within the 79-14 scope has been conducted.
This review consisted of verifying that these. supports.were correctly modeled in the analyses based on Bechtel walkdown and any supplementary as-built information.
The results of the review found no additional discrepancies such as the one identified on the Ql-PSUPP-01C analysis.
Date When Full Compliance Will be Achieved Full compliance has been achieved.
Item 2 of Noncompliance 2.-
10 CFR 50, Appendix B, Criterion V, states in part, that
" Activities affecting quality shall be prescribed in documented instructions, procedures, or drawings...and shall be accomplished in accordance with these instructions, procedures or drawings".
Commonwealth. Edison Company Topical Report CE-1-A, " Quality Assurance-Program for Nuclear Generating Stations", Revision 21, dated June 6,.1982, states in Section 5, that "The quality assurance actions carried out for design, construction, testing, and operation activities will be described in documented instructions, procedures, drawings, specifications or checklists.
These-documents will assist personnel in assuring that important activities have been performed.
These documents will also reference-applicable acceptance criteria which must be satisfied to assure'that.the-quality related activity has been properly carried out".
Contrary to the above, during review of-Impell calculation No.
Q2-RHRS-09B(C), dated January 28, 1983, it was found that the anchor movements at'the branch to run pipe cor.nections (provided by Nutech for EDS-calculation input) were not evaluated as required by EDS Project Instruction No. 6.0 to ensure:
(1) acceptable stress levels at the deccupied branch /run pipe location, and.(2) there were'no. excessive load increases at nearby seismic restraints.
This-is aLSeverity Level V violation-(Supplement II).
L1
r_
. Corrective-Action Taken and Results Achieved.
The audit report identified calculation Q2-RHRS-09B(C) dated January 28, 1983 to be in nonconformance with Project Instruction No. 6.0.
The actual calculation in nonconformance with the instruction is Ql-RHRS-03/06B(C).
The corrective action to resolve this nonconformance has been completed.
The corrective action included the following:
Reanalysis of Ql-RHRS-03/06B(C)
This analysis, which originally did not comply with Project Instruction 6.0, has been reanalyzed in compliance with the instruction.
Corrective Action Taken to Avoid Further Noncompliance Review of all other decoupled branch line analyses All other decoupled branch line analyses for Dresden and Quad Cities were reviewed for compliance with Project Instruction 6.0., Revision 3.
This review concluded all branch line analyses are in compliance with the instruction.
Date When Full Compliance Has Been Achieved Full compliance has been achieved.
I~
k 1
.L _
j