ML20235J594

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Submits Addl Info to Justify FSAR Changes Re Reclassification of Diesel Generator Support Sys Components to Ig from IC Noted,Per Util
ML20235J594
Person / Time
Site: Byron, Braidwood, 05000000
Issue date: 07/09/1987
From: Ainger K
COMMONWEALTH EDISON CO.
To:
NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
NUDOCS 8707150655
Download: ML20235J594 (3)


Text

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N Comm nwealth Edison

(%/f[ Address Reply to: Post Offics Box 767 One First Nttional Plaza, Chicago, Illinois Chicago, Illinois 60690 0767 July 9, 1987 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

Subject:

Byron Station Units 1 and 2 Braidwood Station Units 1 and 2 Diesel Generator Support Systems NRC Docket Nos. 50-454/455 and 50-456/457 Reference (a): March 2, 1987 letter from K.A. Ainger to H.R. Denton Gentlemen:

Reference (a) provided Byron /Braidwood F3AR changes concerning the reclassification of diesel generator support sysf.em components to IG from IC.

As a result of NRC Staff review of this matter, additional information is being provided to justify the FSAR changes.

Replacement parts on originally supplied ASME Section III diesel generator auxiliary equipment are being recle.ssified to IG because some parts suppliers have dropped their ASME N-Stamp.

Commonwealth Edison has attempted to procure a N-Stamped component for the diesel generator lubricating oil system from the original diesel generator vendor. The diesel generator vendor will provide an identical component with the same material and performance characteristics as the original, but this part will not be N-Stamped. We have identified only one other supplier who will provide this component with an N-Stamp, however the cost of this item is approximately 23 times the cost of the rion N-Stamped part from the original j

diesel generator supplier ($30,000 vs. $1,300). Additionally, a six month delivery time is involved with the N-Stamped component. This price premium and long lead time is not justifiable in view of the equivalence of the l

parts for the intended application.

j l

Commonwealth Edison has developed a program to address this l

situation on a generic basis. The program is titled " Byron /Braidwood Stations Component and parts Classification and procurement program". This is a technically based program that divides the like-for-like philosophy

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into four major steps. prior to procurement of a component on a safety I

related system, an evaluation is performed.

The first step of the I

evaluation identifies.the safety functions that a component is required to perform.

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D DO o

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. In the second step, all parts of the component that perform a safety function are classified as safety related. A failure modes and effects analysis is applied to the safety related parts in the third step to determine the important characteristics for each part. These characteristics reflect the safety function of each part. The last step identifies procurement and dedication requirements based on information derived from the prior steps.

Since this program is technically based, it is not adversely affected when NRC or quality assurance requirements are revised. As a result, this program maintains the original design basis of the plant.

In addition to this program described above, all safety related components are subjected to a quality control inspection upon receipt at the stations. This activity complies with the commonwealth Edison Quality Assurance Program requirements. As part of this, a joint engineering / quality assurance team is utilized to perform an in-process or receipt inspection when circumstances warrant, such as in the case of the replacement part for the diesel generator lubricating oil system.

Reference (a) contained a revision to FSAR Table 3.2-1 to indicate the reclassification of the diesel generator replacement parts.

Enclosed with this letter is a clarification to Table 3.2-1 to indicate the classification of diesel engine mounted components.

Reference (a) iILdicated the classification of the diesel generator air dryer package as safety category II.

We believe this classification is appropriate because the air dryer is upstream of the accumulators which provide the air for starting the engine. Flow through the dryer is not required during the safety related function of the starting air system since the accumulators are verified to be adequately charged at all times by safety related instruments. The design of the starting air system is consistent with all other safety related applications of compressed gas in the plant in that the gas is provided from a safety related accumulator. The accumulator is charged from a non-safety related system, verified to be operable and then isolated from the non-safety related portion of the system.

Please direct eny further questions regarding this matter to this office.

Very truly yours,

/

K. A. Ainger Nuclear Licensing Administrator Enclosure cc: NRC Region III Office Byron Resident Inspector Braidwood Resident Inspector 3285K

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l AMENDMENT 46 e

o B/B-FSAR JANUARY 1985 TABLE 3.2-1 (Co n t ' d )

PRINCIPAL STRUCTURES, SAFETY QUALITY 3

SYSTEMS, AND COMPO:iENTS CATEGORY C RO UP E LICT M C AL 16.

CV - Chemical and Volume Control *

(All except Boric Acid and Boron Thermal Regenera tion) a.

Regenerative Heat Exchangers Tube Side I

B N/A Shell Side I

C N/A b.

Letdown Heat Exchangers Tube Side I

B N/A Shell Side I

C N/A 5

c.

Seal Water Heat Exchangers

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Tube Side I

B N/A Shell Side I

C N/A d.

Excess Letdown Heat Exchangers Tube Side I

B N/A Shell Side I

B N/A e.

Volume Control Tank I

B N/A f.

Reciprocating Charging Pumps I

B N/A q.

Recipr 3cating Charging Pump Motors II N/A Non-IE L.

Centrifugal Charging Pumps I

B N/A 1.

Centrif ugal Charging Pump Motors I

N/A IE i

j. Mixed Bed Demineralizers I

C N/A k.

Cation Bed Demineralized I

C N/A 1.

Resin Fill Tank II D

N/A m.

Chsmical Mixing Tank II D

N/A n.

Letdown Reheat Heat Exchanger - Tube Side I

B N/A

- Shell Side I

C N/A o.

Reactor Coolant Filter I

B N/A p.

Seal Water Injection Filter I

B N/A q.

Seal Water Return Filter I

B ty.A r.

Containment Isolation I

B

  • L 17.

CW - Circulatitq Water (Including Ice Melting and Cooling Tours, Screens, Trash Rakes, Condenser Tube Cleaniny) (Excluding Makeup and Blowdown in System WL)

II N/A

.Non-IE 18.

CX - Conputer (Excluding Inouts) and Suoply Power II N/A Non-IE 19.

DC - Battery and D-C Distribution All d-c equipment necessary for Category I a.

items to perform their function including batteries, chargers, distribution panels, and cables for these safety related items, including the following:

I N/A IE 1.

125-Vdc Buses:

111, 112, 211, 212 l

2.

125-Vdc Batteries and Chargers

111, l

112, 211, 212 l

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b.

All other d-c equipment including batteries, chargers, distribution panels and cables for j

l non-safety related items.

II N/A Non-IE 20.

DG - Diesel Generator

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C0/Mf0/1M N NC IYll? $

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?!,teinc.)f U+NAj fube et/digU$4ld/l COClH!

syte ep 21.

DM - Drains, Miscellaneous Buildinos, Floor and Roof Includi ;g Sump Pumps - Non-Raoloac tive (Cr1D

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House, Pumphouse)

II N/A Ncn-!E

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