ML20069C724

Responds to NRC 820216 Ltr Re Violations Noted in IE Insp Repts 50-237/82-01,50-249/82-01,50-254/82-01 & 50-265/82-01. Refutes Items of Noncompliance.No Changes Made to Current Analysis Procedures & Subj Whip Restraints

ML20069C724
Person / Time
Site:	Dresden, Browns Ferry, Quad Cities, 05000000
Issue date:	04/01/1982
From:	Delgeorge L COMMONWEALTH EDISON CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20069C715	List: ML20069C724 ML20069C748
References
3777N, 820401-4, NUDOCS 8207210201
Download: ML20069C724 (5)

Text

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' #h Commonwealth Edison

) one First National Plata, Chiergo. Illinois

[

( O 7 Address Reply to: Post Office Box 7@

N / Chicago. Illinois 60690 April 1, 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 Units 1 and 2 Quad Cities Station Units 1 & 2 Partial Response-to Inspection Reports 50-237/82-01, 50-249/82-01, 50-254/82-01 and 50-265/82-01 NRC Docket Nos. 50-237/249/254/265 Reference (a): C. E. No r ellu '. letter to Cordell Reed dated February 16, 1982.

Dear Mr. Keppler:

Reference (a) provided the results of a special inspection conducted by Mr. I. T. Yin of your office on January 4-7, 1982 at EDS Nuclear Inc., Walnut Creek, California, of activities at Dresden Units 2 and 3 and Quad Cities Units 1 and 2. The attachment to this letter provides the Commonwealth Edison Company response to the Notice of Violation items 1. (2) and 2. we expect to provice our ~

response to the remaining item 1. (1) concerning I.E.Bulletin 79-14 suspension system operability by April 12, 1982.

The timeliness of our responses and the engineering details of the remaining response have been discussed with Mr. D. Danielson of your office on numerous occasions, including telephone discussions on March 2, 4, and 18, 1982. Because of the complexity of the issues involved, Mr. D. Danielson has agreed to our proposed extensions of the response dates.

To the best of my knowledge and belief the statements contained in the attachment are true and correct. In some respects these statements are not based on my personal knowledge but upon information furnished by other Commonwealth Edison employees and consultants. Such information has been reviewed in accordance with Company practice and I believe it to be reliable.

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J. G. Keppler April 1, 1982 Please direct any questions you may have concerning this matter to this office.

Very truly yours, L. O . DelGeo rge Director 'o f Nuclea r Licensing 1m cc: Region III Inspector - Dresden Region III Inspector - Quad Cities -

SUBSCRIBED and SWORN to before me th,is / a e day of /f h A , 1982 he4a 5$ J

' ' Nota ry Pub..ic 3777N I

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9 COMMONWEALTH EDISON COMPANY Dresden Station Units 2 and 3 Quad Cities Station Unit 1 and 2 Response to Notice o f Violation

1. 10 CFR 50, Appendix B, Criterion V, states in part that,

" Activities af fecting 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 A, " Quality Assurance Program for Nuclear Generating Stations, Revision 9, dated July 16, 1979, states in Section 6, that "A document control system will be used to assure that documents such as specifications, procedures and-drawings are reviewed for adequacy and approved for release by authorized personnel. Such documents will be distributed to and used at the locations where the prescribed activity is performed. Changes to these documents will be handled similarly and will be reviewed and approved, unless delegated by the originating organization to another responsible organization".

, Contrary to the above, the EDS IE Bulletin 79-14 evaluation procedure did not specify that . . . . (2) safety relief valve thrust loads be included in the piping stress calculations.

Response

Corrective Action Taken and Results Achieved and Corrective Action To Be Taken to Avoid Further Noncompliance.

CECO believes that omission of the safety. relief valve discharge loads from the IE Bulletin 79-14 seismic analysis l 1s not in violation of the intent of IE Bulletin 79-14.

I Relief valves were not considered in the original design

, because the loads were small enough so as to be insigni-

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ficant compared to other loads. Therefore the 79-14 requirement to compare "as-built" to "as-designed" would exclude relief valve loadings.

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To ensure a complete resolution of this issue, CECO instructed EDS Nuclear Inc. to perform an analysis to

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evaluate the impact of safety relief valve thrust loads on the 79-14 seismic analysis results. The results of this evaluation prove that the piping stresses and support loads due to the operation of these valves have negligible impact on the 79-14 results. This evaluation is documented in EDS calculation SC-13 Rev. O.

Based upon the above, no changes will be made to the current analysis procedures.

Date When Full Compliance Will Be Achieved Full Compliance has been achieved.

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 A, . " Quality Assurance Program for Nuclear Generating Stations,"

Revision 15, dated January 2, 1981, states in Section 5 that "The quality assurance actions carried out for design, construction, testing, and operation activities will be describeo 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."

The Bechtel Power Corporation IE Bulletin 79-14 walkdown inspection procedure established for Dresden and Quad l Cities requires that pipe whip restraint clearance should l

be measured in the same manner as for sleeves and l

penetrations, giving suf ficient dimensions to locate the pipe position in the sleeve.

Contrary to the above, the pipe whip restraint gaps were not measured during the IE Bulletin 79-14 system walkdown inspection.

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Response

Corrective Action Taken and Results Achieved and Corrective Action to Be Taken to Avoid Further Noncompliance CECO believes that the absencea of pipeclearance information whip restraint in for pipe whip restraint number PWHP-2,is not a violation of the requirements o Dresden Unit 2, IE Bulletin 79-14. Specifically , the absence o f or inclu-sion of clearances were the result of requirements as set forth in IE Bulletin 79-14 Supplement 2 dated September 7, 1979. These requirements CECO specified insulation removal of has complied with these obstructed pipe supports.

requirements.

At the time of the walkdown, the subject whip restraint was covered with thermal insulation; this is2,documented ISI-203, sheet which included on aa markup of drawing no. Because the whip notation " Circ. of insulation 60 inches".(circumference o f 44 3/4"),

restraint ring 0.D. is 14 1/ 4" the insulatica would have covered this whip restraint and clearances "The couldinsulation not be measured type anddue to insulation outside circumference coverage.

of the pipe plus insulation covering," was recorded as required by the procedure.

The intent of the walkdown procedure was not to remove insulation at each obstructed detail, and therefore some measurements, including clearances, could not be recorded.

Paragraph IV J of the walkdowna minimum procedure of 10% ofrequired insula-obstructed pipe tion removal o f ". . .

supports" (this is in conformance1979). with IEThisBulletin 79-14, requirement Supplement 2, dated September 7,Therefore the insulation was not remove has been met.

measure clearances for this restraint.

It is acknowledged that if a whip restraint wereThis to bewould, overloaded in a seismic event it could break.

however, not af fect the integrity of the piping system or its seismic hangers during the postulated event.

Based upon the above, the absence of clearance information for the' subject whip restraint should not be considered a It is our contention that lack of procedural breakdown. clearance information does not constitute a viola the walkdown procedures and therefore no corrective action will be taken.

Date When Full Compliance Will Be Achieved Full Compliance has been achieved.

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