ML20212G819
| ML20212G819 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 07/23/1986 |
| From: | Turbak M COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| REF-PT21-87-013-000 1900K, PT21-87-013-000, NUDOCS 8701210180 | |
| Download: ML20212G819 (2) | |
Text
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COfRRIORWealth Esilson f
_" /. One First National Plaza. Chicago, Illinois
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Address Reply to: Post Omce Box 767
\\ d Chicago,luinois 60690 0767 July 23, 1986 Mr. James Keppler Regional Administrator U.S. Nuclear Regulatory Commission 799 Roosevelt road Glen Ellyn, IL. 60137
Subject:
Quad Cities Station Units 1 and 2 10 CFR Part 21 Evaluations NRC Docket Nos. 50-254/265
References:
(a)
N.J. Chrissotimos letter to Cordell Reed dated Janusry 2, 1986 (b)
D.L. Farrar letter to J.G. Keppler dated February 7, 1986 (c)
C.E. Norelius letter to Cordell Reed dated May 15, 1986
Dear Mr. Keppler:
Reference (a) transmitted a routine safety inspection of activities at Quad Cities Station. The inspection report identified an apparent violation regarding the proper and accurate evaluation of a Part 21 report issued by Ruskin Manufacturing Company concerning a specific fire damper.
Reference (b) provided our response which included additional information and a request to review the violation.
Reference (c) transmitted the evaluation of the additional information and your conclusion that the violation would be withdrawn. We agree with this conclusion.
In addition, however, the letter stated that you take exception to our belief that 10CFR Part 21 evaluations are required only for safety-related equipment. We disagree with this conclusion.
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.
0 IE/7 87012 h 54 jul 2 51986 PDR PDR O
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. The Commonwealth Edison Corporate Quality Assurance Program Manual defines safety-related items as follows:
Safetv-Related Items - A plant structure, system, component or part thereof necessary to assure:
a.
The integrity of the reactor coolant pressure boundary, b.
The capability to shutdown the plant and maintain it in a safe shutdown condition, c.
The capability to prevent or mitigate the consequences of accidents or intentional acts which could result in potential off-site exposure comparable to those referred to in 10CFR100.11, or d.
Adequacy of the design, inspection, testing or consulting services important to safety that are associated with the safety-related items.
It is clear that our definition of safety-related, which is almost verbatim with the NRC definition of basic component in Section 21.3(a)(1), is in agreement with NRC rules pertaining to 10CFR Part 21.
Moreover, NUREG-0302 Rev. 1 titled " Remarks PreseAted (Questions / Answers Discussed) at Public Regional Meetings to Discuss Regulations (10CFR Part 21) for Reporting of Defects and Noncompliance" dated July 12-26, 1977 asks the same question. Page 21.3(a)-1 of the NUREG specifically asks "Does Part 21 apply to only " safety related" items?" The response is," Yes. Part 21 applies to any defects and noncompliance which 4
could create a substantial safety hazard in activities that are within the regulatory authority of the Nuclear Regulatory Commission; therefore only those items which are " safety related" are within the scope of Part 21."
For the above reasons, we believe 10 CFR Part 21 reviews are conducted in compliance with NRC rules and request that you evaluate our position taking into account this additional information.
Please direct any further questions regarding this issue to this office.
Very truly yours, l
b.E.C 1
i M. S. Turbak Operating Plant Licensing Director
/klj cc: NRC Resident Inspector-Quad Cities j
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