ML19351D807

Forwards Final Response to IE Bulletin 79-01B,Environ Qualification of Class IE Equipment, Per NRC 800919 Revised Order for Mod of License

ML19351D807
Person / Time
Site:	Dresden, Quad Cities
Issue date:	10/30/1980
From:	Abel J COMMONWEALTH EDISON CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML19351D808	List: ML19351D807 ML19351D813 ML19351D817 ML19351D823 ML19351D825 ML19351D829 ML19351D833 ML19351D838 ML19351D844
References
IEB-79-01B, IEB-79-1B, NUDOCS 8011200062
Download: ML19351D807 (3)

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i& ,*/ Commonw=lth Edison  !

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' g. one Fast National Plaza Chicrgo, liiinois Address Reply to: Post Office Box 767.

Chicago, lilinois 60690 0

October 31, 1900 Mr. James G. Keppler, Director Directorate of Inspection and Enforcement - Region III U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137 ,

Subject:

Dresden Station Unit 3 Quad Cities Station Units 1 and 2 Response to NRC Order Concerning h-Environmental Qualification of Class IE Electrical Equipm

~ NRC Docket Nos. 40-2 , 50-254/265 wj.

References (a): ^D.'G. Eisenhut letter to J. S. Abel dated September 19, 1980 (b): J. G. Keppler letter to C. Reed dated January 16, 1980

_(c): J. G. Keppler letter to C. Reed dated September 30, 1980

Dear Mr. Keppler:

Reference (a) transmitted a. Revised Order for Modification of License requiring Commonwealth Edison Company to submit certain environmental qualification of electrical-equipment information by

. November 1, 1980.

Enclosed for your review are two (2) copies each of the Bechtel Power Corporation Final Reports for Dresden Unit 3, and Quad Cities Units 1 and 2, each entitled " Response to IE Bulletin 79-01B" (dated November 1, 1980). The Dresden Unit 3 report consists of three (3) volumes, and the Quad Cities Units 1 and 2 report consists of five-(5) volumes._ This information fully and completely responds to the staf f's Revised Order.

References (b) and (c) transmitted IE Bulletin 79-01B and Supplement No. 2 to IE Bulletin 79-018 respectively. Although Supplement No. 2 was' issued at a late date,. Commonwealth Edison assumes that it will be used by tne Staff to measure the adequacy s a . ...A L

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• l Mr. J. G. Keppler, Director -

1 October 30, 1980 Page 2.

of our _ responses. In that regard, we'have provided information concerning position indication limit switches as^1ndicated'below:

(1) Valve Position Indicators Supplement No. 2 to IE Bulletin 79-018, Question / Answer 5 states that " valve position indicators", among other items. should be qualified to function in'the relevant accident environment. This-submittal addresses all safety related ;imit switches which have a control function. None 'of the limit switches excluded from this report perform a safety related function, i.'e., the switches do not activ' ate or block any action designed to mitigate the consequences of an accident.

Supplement No. 2 to IE Bulletin 79-01B made significant changes in previous staff directions in the following area:

(2) One Hour Plus Reouirement Supplement No. 2-Question / Answer No. 12 states that equipment designed to perform its safety function within a short time into an event must be qualified for a pariod at least I hour in excess of the time assumed in the accident analysis. The staff had previously indicated that it would be acceptable to environmentally qualify equipment that performs its safety ,

function within a short time after an accident begins for the I period of time it can reasonably be expected to be required 1/,

This may be substantially less than 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, for example, in the

' case of an isolation valve. This submittal addresses all' equipment from the standpoint of performing its safety function within the time frame the equipment is required to function. We believe this approach to be technically justifiable.

1/ Discussed in the August 27, 1980 Bethesda, Md. meeting attended among others by P. DiBenedetto, J. Lombardo, C. Crane and E.

McKenna for the NRC, and N. Smith and H. Stolc for Commonwealth Edison and in the July 28, 29, and 30 Dresden Station meeting attended.among-others by J. Lombardo and C. Crane for the_NRC and R. Mirochna and N. Smith of Commonwealth Edison.

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Mr. J. G.-Keppler,' Director October 30,.1980 Page 3 In addition, this submittal may not be in explicit ~ agreement with NRC Staf f guidance in the following respect:

(3) Radiation Source Terms The radiation source terms ~to be used in environmental qualificatica of electrical equipment are contained in NUREG-0578' and NUREG-0588 as referenced by IE Bulletin No.79-01B. These documents require noble gases, halogens, and particulates to be released instantaneously. The enclosed Environmental Qualification submittal has assumed nobel gases are instantaneously released, with halogens and particulates released instantaneously after a time r elay of ten minutes. This is conservative relative to time dependent core release mechanisms discussed in WASH-1400.

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In th? _ case o f small break LOCA's, Commonwealth Edison has determined 'iiPCI to be a qualified system up to the point in an accident scenario where it is no longer needed. At this point,-

the harsh radiation environment is assumed to exist (large break LOCA source term). Although this requires the use of methods not explicitly contained in NUREG-0578 and NUREG-0588, we believe this approach to be technically sound.

If you have any questions in this regard, please contact this office.

Very truly yours, J.S. Abel Director of Nuclear Licensing cc: Director, Division of Reactor Operations Inspection (2 w/att.)y -

NRC RIII Inspector - Dresden w/Dresden att.

NRC RIII Inspector - Quad Cities w/ Quad Cities att. .

SUBSCRISED and SWORN to before mq this ! / .S ,

day _df' 'e s , 1980  ;

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