ML20198D152
| ML20198D152 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 05/15/1986 |
| From: | Norelius C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Reed C COMMONWEALTH EDISON CO. |
| References | |
| REF-PT21-86 NUDOCS 8605230167 | |
| Download: ML20198D152 (2) | |
See also: IR 05000254/1985027
Text
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MAY 151986
Docket No. 50-254
Docket No. 50-265
Commonwealth Edison Company
ATTN: Mr. Cordell Reed
Vice President
Post Office Box 767
Chicago, IL 60690
Gentlemen:
This is in response to your letter of February 7,1986 which requested a
review of a prior violation and our conclusions as discussed in NRC Region III
Inspection Reports No. 50-254/85027; 50-265/85030. The specific violation
related to a Part 21 issued by Ruskin Manufacturing Company concerning fire
dampers that may fail to close under flow conditions.
It appeared that one
damper that was required to close under flow conditions was not tested for
operability as recommended by Ruskin.
We have carefully evaluated the additional information that was provided in
your response of February 7, 1986. We were not aware that the pre-fire
procedure contains a statement regarding shutdown of the HVAC system, thus
not requiring the damper to close under flow conditions. Consequently, we
have concluded that the violation should be withdrawn. We will adjust our
records accordingly.
While we agree that the fire protection function of such dampers is not safety
related in the strictest definition of safety related, they do perform a
function which is vital to the preservation of plant safe shutdown capability.
Further, we take exception to your position that 10 CFR Part 21 evaluations are
required only for safety related equipment. As stated in 10 CFR Part 21
Section 21.21(b)(1), "A Director or responsible official subject to the
regulations of this part, or a designated person, shall notify the Commission
when he obtains information reasonably indicating a failure to comply or a
defect affecting . . . a basic component that is within the organization's
responsibility . . . ." Section 21.3 defines basic component, in part, as a
plant structure, system, or component, or part thereof necessary to assure the
capability to shut down the reactor and maintain it in a safe shutdown
condition.
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MAY 151986
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In the future, we expect you will complete 10 CFR Part 21 reviews in compliance
with the above.
Sincerely,
JQcisipt Eliu:4
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Charles E. Norelius, Director
Division of Reactor Projects
cc:
D. L. Farrar, Director
of Nuclear Licensing
N. Kalivianakis, Plant Manager
DCS/RSB (RIDS)
Licensing Fee Management Branch
Resident Inspector, RIII
-Phyllis Dunton, Attorney
General's Office, Environmental
Control Division
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