ML20129G931

Responds to NRC Re Deviations Noted in Insp Rept 50-443/85-06.Corrective Actions:Spec 248-20 Re Fire Protection & Yard Potable Water Piping Installation Revised to Assure That Components Conform to Stds

ML20129G931
Person / Time
Site:	Seabrook
Issue date:	05/31/1985
From:	Devicentis J PUBLIC SERVICE CO. OF NEW HAMPSHIRE
To:	Ebneter S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
SBN-799, NUDOCS 8506070413
Download: ML20129G931 (4)

Text

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SEABROOK STATION Enginnsring Offics May 31, 1985 Put$c Service of New Hampshire SBN-799 NEW HAMPSHIRE YANKEE DIVISION T.F. B4.2.7 United States Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19406 Attention:

Mr. Stewart D. Ebneter, Director Division of Reactor Safety

References:

(a) Construction Permits CPPR-135 and CPPR-136, Docket Nos. 50-443 and 50-444 (b) USNRC Letter, dated 5/3/85, " Inspection Report No. 50-443/85-06

Subject:

Response to Inspection Report No. 50-443/85-06

Dear Sir:

It was reported in the subject Inspection Report that certain of our activities were not conducted in accordance with commitments in the FSAR.

s In response to the reported FSAR deviations, we offer the following:

Notice of Deviation 50-443/85-06-02 As a result of the inspection conducted on February 25-March 1, 1985 and in accoradance with NRC Enforcement Policy (10 CFR 2, Appendix C) published in the Federal Register on March 8, 1984 (49 FR 8583), the following deviation was identified:

FSAR Section 9.5.1.1 states that equipment used in the Fire Protection System is either Underwriters Laboratories Listed (UL) or Factory Mutual (FM) approved for fire portection service.

Contrary to the above, as of February 26, 1985, non UL Listed /

FM approved valves have been specified and installed in the Fire Protection System, specifically the fire hydrant isolation, valves and underground gate valves.

Response

The procurement and installation specifications, for Fire Protection (FP) System components, have been reviewed to determine components which are not specified to be UL Listed and/or FM Approved. The items which were not specified to be UL Listed and/or FM Approved are fire hydrant isolation valves, hydrant valves, and fire hydrants. The installed fire hydrants were visually inspected and found to be UL Listed and FM Approved. Visual inspection of the hydrant valves determined that they are UL Labeled.

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' ' LMr. Stewart D. Ebnstar i

The procured hydrant' isolation valves are Pratt " Groundhog" butterfly

, valves. specified to AWWA C504, Class.150 with a 200 psi working pressure.

The Pratt " Groundhog" and-UL/FM butterfly valves are essentially the same with-the following exceptions:

1~

1) Standard AWWA butterfly-valves tend to close on their own, Lwhile UL/FM butterfly valves are designed to maintain their open position. The " Groundhog" butterfly valves were procured with a MDT operators which will hold the standard AWWA valve open.

2) The AWWA butterfly valves are leak' tight to 150 lbs. while UL/FM butterfly valves have.a higher pressure rating. The

-Fire Protection System is designed ' for 125 psi working pressure,

- hich is lower than the rating of the purchased butterfly w

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isolation valves.

. Although the hydrant isolation valves were not specified or recieved with UL Listing or FM Approval, their construction and operation will s"

satisfy the intent of UL/FM requirements for the FP system at Seabrook Station.

u Action Taken to Preclude Reoccurrence ECA _06/105718A.was issued to revise specification 248-20, " Yard

fire pret'ection and yard potable water piping installation." The l specification was revised to assure that all fire-protection system 1

components, except for the fire tank heating systems, conforms to the UL and/or FM standards.

We also intend to revise FSAR Section 9.5.1.1 to address any exceptions to the UL/FM approval requirement for Fire Protection System

~,

Components. Accordingly please find enclosed a copy of the revised FSAR-pages which address the above noted exceptions. 'This change will be incorporated into the FSAR in a future amendment.

Very truly y urs, John DeVincentis, Director Engineering and Licensing Enclosure; cc: Atomic Safety and Licensing Board Service List r-

SB 1 & 2 A1:ndment 53 FSAR August 1984 9.5 OTHER AUNLIARY SYSTEMS 9.5.1 Fire Protection System 9.5.1.1 Design Bases The plant fire protection system is a non-safety-related system designed to detcet and alarm, control and extinguish fires that may occur. To accomplish this end, the concept of defense in depth is a criterion for design. This concept, applied to fire protection, aims at a balanced program which will:

a.

Prevent fires from starting.

b.

Detect fires quickly, and quickly suppress those that occur, thus limiting their damage, c.

Design and locate plant equipment such that if a fire occurs and burns for a long time, despite a. and b., that essential plant activities will still be performed.

d.

. Ensure that neither inadvertent operation nor failure of a system will induce a failure of any safety-related system.

The guidance provided by APCSB BTP 9.5-1 and its Appendix A and 10 CFR 50 i

Appendix R is utilized in meeting the design basis..

63 The fire protection systems have been ' designed using the general guidelines I-of the following codes and standards:

b a.

Auerican Nuclear Insurers (AN1) - Specifications for Fire l

N Protection of New Plants.

e b.

National Fire Protection Association (NFPA) and ANS Codes as l'

f listed in Table 9.5-1.

i h tu - i-23 9 c.

Building Officials and Code Administration - (BOCA) - Basic

{

Building Code, f'

p$

Equipment in the fire protection systems, except for the fire tank heating J

zy Oi systems," conforms to the standards of the National Fire Protection k'~ 4 R J Association, and is Underwriter's Laboratory (UL) listed and/or Factory h3 Mutual approved.

O O"

'2' For a listing of unusually hazardous materials which will be used onsite and "C

which could present unexpected fire hazards or could complicate fire-fighting activities, re fer to Table 9.5-10.

ya 9.5.1.2 System Doncription a.

Fire Prevention I

The plant fire protection system utilizes design aspects which employ separation criteria, non-combustible outerial, fire 9.5-1 b

u_.

4 William S. Jordan, III-Donald'E. Chick Diane Curran Town Manager Harmon, Weiss & Jordan -

Town of Exeter 20001 S. Street, N.W.

10 Front Street

-Suite 430 Exeter, NH 03833 Washington, D.C.

20009 Brentwood Board of Selectmen Robert G. Perlis RED Dalton Road Office of the Executive Legal Director Brentwood, NH 03833 U.S. Nuclear. Regulatory Commission Washington, DC 20555 Richard E. Sullivan, Mayor City Hall Rob rt A. Backus, Esquire Newburyport, MA 01950

-116 Lowell Street P.O. Box 516 Calvin A. Canney Manchester, NH 03105 City Manager City Hall Philip Ahrens, Esquire 126 Daniel Street Assistant-Attorney General Portsmouth, NH 03801 Augusta, ME 04333 Dana Bisbee, Esquire Mr. John B. Tanzer Assistant Attorney General Designated Representative of Office of the Attorney General the Town of Hampton 208 State House Annex 5 Morningside Drive Concord, NH 03301 Hampton, NH 03842 Anne Verge, Chairperson Roberta C. Pevear Board of Selectmen Designated Representative of.

Town Hall the Town of Hampton Falls South Hampton, NH 03827 Drinkwater Road

'Hampton Falls, NH 03844-Patrick J. McKeon Selectmen's Office Mrs. Sandra Gavutis 10 Central Road Designated Representative of Rye, NH 03870 the Town of Kensington RFD 1 Carole F. Kagan, Esquire l

East Kingston, NH 03827 Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission l

Washington, DC 20555 Jo Ann Shotwell, Esquire Assistant Attorney General

-Environmental Protection Bureau Mr. Angi Machiros Department of the Attorney General Chairman of the Board of Selectmen One~Ashburton Place, 19th Floor Town of Newbury Eoston, MA 02108 Newbury, MA 01950 Senator Gordon J. Humphrey Town Manager's Office U.S. Senate Town Hall - Friend Street Washington, DC 20510 Amesbury, MA 01913 (ATTN: Tom Burack)

Senator Gordon J. Humphrey

' Diana P. Randall 1 Pillsbury Street 70 Collins Street Concord, NH 03301 Seabrook, NH 03874 (ATTN: Herb Boynton)

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