B12949, Provides Revised Schedule for Completion of Fire Barrier Penetration Seal Program for Millstone Unit 1,description of Scope of Fire Barrier Penetration Seals Program at Plant & Schedule for Implementation of Program.Fee Paid

Provides Revised Schedule for Completion of Fire Barrier Penetration Seal Program for Millstone Unit 1,description of Scope of Fire Barrier Penetration Seals Program at Plant & Schedule for Implementation of Program.Fee Paid

ML20245D969
Person / Time
Site:	Millstone, Haddam Neck, 05000000
Issue date:	09/28/1988
From:	Mroczka E, Sears C, Sears C CONNECTICUT YANKEE ATOMIC POWER CO., NORTHEAST NUCLEAR ENERGY CO., NORTHEAST UTILITIES
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
B12949, NUDOCS 8810070386
Download: ML20245D969 (6)

Text

- _ ..

I NORTHEAST UTILITIES cenere On.cn . semen sireet. Bernn connecticut l

. m -.n u. w m.ac m . - " P O BOX 270

.o . , .c. . -w . tc H ARTFORD. CONNECTICUT 06141-0270 k k J C'.?C. .$,',7%, (203)605 5000 September 28, 1988 Docket Nos. 50-213 50-245 50-336 B12949 Re: 10CFR50, Appendix R ISAP Topic 1.100 (MP-1)

ISAP Topic 1.103 (HNP)

U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555

References:

(1) W. V. Johnston letter to E. J. Mroczka, Routine Inspection No. 50-245/87-19, dated September 23, 1987.

(2) E. J. Mroczka letter to the U.S. Nuclear Regulatory Commis-sion, Response to Inspection Report No. 50-245/87-19, dated December 8, 1987.

Gentlemen:

Haddam Neck Plant Millstone Nuclear Power Station, Unit Nos. I and 2 Fire Barrier Penetration Seal Proaram UDarade From August 17 through August 21, 1987, the NRC Staff conducted an announced team inspection of Millstone Unit No. I's compliance with the requirements of 10CFR50, Appendix R (Reference (1)). During the inspection, the audit team recognized the ongoing initiative by Northeast Nuclear Energy Company (NNECO) in conducting a comprehensive review of fire barrier penetration seals at Millstone Unit No. 1. By Reference (1), the NRC Staff requested NNECO to provide the results of the fire barrier penetration seal program review and a schedule for implementation of the planned upgrade initiatives. Reference (2) transmitted NNECO's response to the Staff's request and provided a preliminary schedule for completion of the evaluation and upgrade of the fire barrier penetration seal program, originally scheduled for completion by December 31, 1989. The purpose of this letter is to provide the NRC Staff with a revised schedule for the completion of the fire barrier penetration seal program for Millstone Unit No. 1, a descript: 1 of the scope of the fire barrier penetration seal program at Millstone Station and Haddam Neck, and also a schedule for implementation of this program for Millstone Unit No. 2 and Haddam Neck.

8810070386 800928 g6h ah, i

kl j 4 ff

,s jos_^oock_050o@3 t, ,

x -

y .

Ucs. Nuclear Regulatory Cennission -

'B12949/Page 2 .

September 28, 1988 Connecticut Yankee Atomic Power Company (CYAPCO) and NNECO, . on behalf of the Haddam Neck Plant and' Millstone Unit Nos. I and 2, hereby provide the Staff with a detailed description of the penetration seal program upgrade initiatives- i and a schedule for completion.of. the program, Backaround The functional: integrity of 'the penetration fire barriers ensures that a fire will be confined c adequately retarded from spreading to adjacent portions of-the facility. T,ds' design feature minimizes the possibility of a single fire

~

rapidly involving several areas of the facility prior to detection and extinguishment.

The fire barrier penetration seals at the' Haddam Neck Plant and Millstone Unit Nos. I and 2 were originally surveyed and documented in 1979 and 1980 by Insulation Consultants and Management Services (ICMS). At that time, most penetrations which were identified as Technical Specification related or fire sensitive, were sealed by ICMS with tested fire rated configurations. However, some shake spaces and nonstandard penetrations were sealed using ICMS guidance without a. specific test configuration.-

The fire barrier penetration seal program scheduled for implementation at the Haddam Neck Plant and Millstone Unit Nos. I and 2 involves an extensive evaluation and upgrade which includes seal configuration adequacy, the development of new procedures and the implementation of procedural changes as required to ensure the proper implementation of the revised program, and the complete mapping of fire barriers and their associated penetrations.

Method of Proaram Unarade lhe fire barrier penetration seal program planned for the Haddam Neck Plant and Millstone Unit Nos.1 and 2 includes updating the existing fire penetration seal program documentation to better reflect actual in-plant conditions, as well as improving controls for maintaining a reliable seal program. This upgrade will be accomplished by first confirming / establishing all design barrier bases / boundaries. This information will be documented on a set of These plant layout drawings identified as Boundary Identification Drawings.

drawings will then be used to determine the applicable design basis for barrier walkdowns or for future plant modifications.

CYAPC0 and NNECO are limiting the scope of penetration seal field verifications to fire technical specifications and fire sensitive barriers. Prior to verification walkdowns, CYAPCO and NNECO will develop map location drawings and l

new penetration map detail drawings using the existing plant wall penetration maps developed by ICMS and design input from the Boundary Identification Drawings.

U.S; Nuclear Regulatory Commission j B12949/Page 3 4

~*

September 28, 1988 l A complete penetration seal documentation upgrade package will be developed.

utilizing ICMS standard seal designs rated for fire and pressure. The type of seal configuration detai7ed in the seal documentation package will be identified on the new wall penetration detail maps prior to field verification.

Using the new wall penetration detail maps, .CYAPC0 and NNECO will perform barrier walkdowns to document all penetration seal configurations to either -

tested configurations. or Generic Letter 86-10 engineering evaluations. All penetration seals determined by CYAPC0 and NNECO to be unacceptable will be repaired or replaced. Upon completion of each barrier verification, the wall penetration maps will become as-built drawings and issued as final.

In order to implement and maintain the penetration seal upgrade program, CYAPC0 I and NNECO will be performing procedural upgrades to Station,. Plant and Nuclear Engineering and Operations (NEO) procedures to assure barrier openings .are being properly controlled. These procedure revisions will assure that only tested or engineering approved seal designs are being installed and that proper seal installation and inspection criteria are being used. In addition, plant maintenance procedures which install penetration seals will be upgraded prior-to the verification walkdowns 'in order that these procedures can be used to accomplish repairs during the program.

ISAP Review The fire barrier penetration seal program upgrade is covered in the Integrated

-Safety Assessment Program (ISAP) Topic No. 1.103 for the Haddam Neck Plant and 1.100 for Millstone Unit No.1. This project was evaluated in the most recent update of-the Millstone Unit No. 1 ISAP and will be discussed in more detail in the forthcoming Millstone Unit No.1 ISAP submittal. In summary, this project ranks below the average in priority. NNECO believes that the lower than average ISAP- ranking supports the projected schedule for completion of this project. Although a specific ISAP evaluation of this project for the Haddam Neck Plant has not yet been conducted, CYAPC0 believes that the results of the Millstone Unit No.1 evaluation provide a general indication of the priority of the penetration seal program at Haddam Neck. This is supportive of the schedule proposed.

Proaram Comoletion Schedule ,

Due to the extensive effort involved in planning and performing the necessary '

field walkdowns, procedural upgrades and development of new detailed drawings better reflecting actual plant configurations, and the recently completed ISAP evaluation, NNECO hereby revises the Millstone Unit No. I schedule for implementation and completion of the fire barrier penetration seal program upgrade. Each plant upgrade will be performed essentially in series beginning with Haddam Neck proceeding on to Millstone Unit No. I and then Millstone Unit No. 2.

, q

- U.S.- Nuclear. Regulatory Commission B12949/Page 4' September 28, 1988 Listed below is' the' schedule for implementation / completion of the penetration.

seal program upgrade- for. the Haddam Neck Plant and Nillstone Unit Nos. I and 2:-

Comoletion Date Nonoutage Outage- Program Walkdowns Walkdowns Comoletion Haddam Neck Plant August 1989 October 1989 January 1990 (Cycle 15)

' Millstone Unit No. 1 July 1990 May 1991 August 1991 (Cycle 13)

Millstone Unit No. 2 August 1991 October 1990 November 1991 (Cycle 10)

Project preplanning and preparation is currently under way in order that the nonoutage field walkdowns at the Haddam Neck Plant can begin in October 1988.

The Haddam Neck Plant penetration seal program upgrade is scheduled for implementation beginning in October 1988 and completion by January 1990. This schedule was developed to coincide _ with the completion of the new switchgear CYAPC0 was' buildingandCYAPCO'scommitmegtotherequirementsof10CFR50.48.

s from the schedular requirements- of 10CFR50.48 granted a temporary exemption until the startup following the 1989 refueling outage.

Additionally, the schedule for implementation of the penetration seal program upgrade at Millstone Unit No. I has been revised and a schedule for Millstone Unit No. ' 2 is being provided which allows sufficient time for performing the necessary field walkdowns during normal plant operation and scheduled refueling outages.

NNECO and CYAPCO Position - Sealina Internal to Conduits Appendix R to 10CFR50 and Appendix A te, BTP 9.5-1 require that penetrations through fire area boundaries be sealed to _the rating of the fire area boundary or be justified by engineering evaluation to be sufficient to withstand the hazards associated with the area in question. In addition, each licensee must retain records documenting the seal adequacy and this documentation must be available to the NRC Staff on request.

Millstone Unit Nos. I and 2 and Haddam Neck are licensed to the May 1976

-version of Appenuix A to BTP 9.5-1. In 1978, the NRC issued Safety Evaluation Reports for these plants accepting the then current configurations. At the time of these reports, and in accordance with Appendix A to BTP 9.5-1, only sealing around components penetrating the designated fire barrier boundaries (i.e., piping, cable trays, conduit, etc.) was required. The 1976 version of  !

i (1) H. R. Denton letter to J. F. Opeka, " Fire Protection Exemption," dated August 25, 1986.

__________.___._____-_-__._m_-____-__.-.._.-____.m -

- _m - . _ . _ _ _ . _ _ - _ _ _ _ _ _ _ _ - . _ _ . , . _ _ _ _ _ . .._ _ .

U.S. Nuclear Regulatory Commission B12949/Page 5 1 September 28, 1988 BTP 9.5-1 did not address the internal sealing of conduits. In subsequent revisions to Appendix A to BTP 9.5-1 and then with the issuance of Appendix R to 10CFR50, sealing inside of conduits penetrating fire area boundaries became a regulatory requirement for those plants licensed to these later revisions.

Since Millstone Unit Nos. I and 2 and Haddam Neck are committed to meet the requirements of the May 1976 version of Appendix A to BTP 9.5-1, conduits penetrating fire area boundaries need not be sealed internally. This approach was confirmed during conversations with the NRC Staff on May 18,1988 and on May 24, 1988. A recent inspection conducted at Fort Calhoun Station was cited as the basis for this determination. Consistent with this, it is NNEC0's and CYAPCO's position that for designated fire barriers, internal conduit sealing is not required for Haddam Neck and Millstone Unit Nos. I and 2. This position was discussed with the NRC Staff during a meeting on August 30, 1988.

Haddam Neck and Millstone Unit Nos. I and 2 are also committed to meet the requirements of Appendix R to 10CFR50, Sections III.G, J and O. Appendix R does require the installation of internal conduit seals for conduit penetrating fire area boundaries. However, as discussed with the NRC Staff in a telephone conversation on May 24, 1988, the requirements for internal sealing of conduits is not retroactive and is not required for Haddam Neck and Millstone Unit Nos. I and 2. This position was discussed with the NRC Staff during a meeting on August 30, 1988. Consistent with this, it is our position that for designated Appendix R fire barriers, internal conduit sealing is not required for Haddam Neck and Millstone Unit Nos. I and 2, except for internal conduit seals required for the new Haddam Neck switchgear building.

CYAPC0 and NNEC0 hereby request NRC Staff review and concurrence with our position concerning internal conduit seals. Enclosed is a check for $150 per the requirements of 10CFR170.

Conclusion In conclusion, we trust the Staff finds this information satisfactory. CYAPC0 and NNECO remain available to discuss any questions the Staff may have on any aspects of the fire barrier penetration seal program upgrade planned for the Haddam Neck Plant and Millstone Unit Nos. I and 2.

Very truly yours, CONNECTICUT YANKEE ATOMIC POWER COMPANY NORTHEAST NUCLEAR ENERGY COMPANY

$.b.U '

E. J. Mroczka Senior Vice President By: C. F. Sears Vice President

l U.S. Nuclear Regulatory Commission .i B12949/Page 6 {

• , September 28, 1908

- cc: W. T. Russell, Region I Administrator A. B. Wang, NRC Project Manager, Haddam Neck Plant-M. L. Boyle, NRC Project Manager, Millstone Unit No. 1 .

D. H. Jaffe, NRC Project Manager, Millstone Unit No. 2 1 J. T. Shedlosky, Senior Resident Inspector, Haddam Neck Plant W. J. Raymond, Senior Resident Inspector, Millstone Unit Nos. 1, 2 and 3

_ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _