ML20009A458

Responds to NRC 810401 Ltr Re Violations Noted in IE Insp Rept 50-322/81-02.Protests Violation That Containment Isolation Valves Were Installed Incorrectly.Valves Are Installed as Close as Possible to Containment Penetration

ML20009A458
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	04/27/1981
From:	Pollock M LONG ISLAND LIGHTING CO.
To:	Brunner E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20009A449	List: ML20009A458
References
SNRC-560, NUDOCS 8107130163
Download: ML20009A458 (4)

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._L~r__--- _a 175 EAST OLD COUNTRY ROAD H IC K SVI L LE. NEW YORK 11801 muARD S. DOROC K g}{]G_ghQ vtCE PpESiCENT-NUCLEAR April 27, 1981 Mr. Eldon J. Brunner, Acting Director Division of Resident and Project Inspection U.S. Nuclear Regulatory Commission, Region I 631 Park Avenue King of Prussia, PA 19406 NRC Inspection No. 81-02 Shoreham Nuclear Power Station, Unit No. 1 Docket No. 50-332

Dear Mr. Brunner:

This letter responds to your letter of April 1, 1981 which forwarded the report of the routine inspection of activities authorised by MRC License No. CPPR-95, conducted by Mr. Higgins of your office from February 1 to March 8, 1981.

Your letter stated that it appeared that one of our activities was not conducted in full compliance with NRC requirements. The apparent noncompliance of our response follows:

Apparent Ncncompliance with 10CFR50, Appendix B, Criterion V, and 10CFR50, Appendix A, Criteria 55-57 Contrary to the above, the requirement that containment isolation valves be located as close to containment as practical was not prescribed by documented instructions, procedures, or drawings for the small bore piping containment isolation valves.

As a result, the following outside containment isolation valves were not located as close to containment as practical:

Valves 1Cll*0lV-102 8 A and B were installed 10 to 15

' feet from the containment penetration; and, Valves 1P50 *MOV-103 A and B were installed approximately 40 feet from th^ containment penetration.

Comment j We do not consider that the valve installation conditions

! described above are nonconforming. We have completed a field inspection and engineeri'.g tvaluation of the location of the l

CIVs outside containnm.'+ for the CRD to recirculation pump purge lines (1C11*0lV-1028 A and B) and for the instrument air lines (1P50*MOV-103 A and B). The results of this investigaticn l have led to the conclusion that the intent of General Design 8107130163 810623 PDR ADOCK 0500032P G PCA

Mr. Eldon J. Brunner, Acting Director April 27, 1981 Page Two Criteria 55-57, requiring CIVs to be located "as close as practical" to containment, and Criterion V, requiring activities affecting quality to be prescribed by documented instructions, procedures or drawings, have been fulfilled at Shoreham.

Approved fabrication and installation drawings were utilized and site quality control verification applied in each case.

The two 3/4 inch CIVs for the CRD to recirculation pump purge lines are installed in accordance with approved engineering drawings 42.11-001C and 2C. Site quality control organizations utilize these documents to verify that "as installed" locations agree with the enE ineered locations. These drawings show the CIVs located 10 to 15 feet from the contain-ment penetration as noted by your inspector. We have reevaluated these locations with our engineers and have found them to be located as close as practical to the containment penetrations in light of other important considerations such as maintain-ability, seismic support design and accessibility for inservice inspection and testing.

The two 1 1/2 inch CIVs for'the instrument air line (lP50*MOV-103A and B) are installed in accordance with approved engineering isometric drawings KOlCP-1 and KOlBW-1. These drawings are used by site quality control organizations to verify that engineered locations have been maintained in the "as installed" condition.

As the inspector has noted, 1P50*MOV-103A is located approximately 40 feet from the containment penetration. Approval to relocate this valve from its original location 28 feet frca the penetration was granted on E&DCR F-27713. 1P50*MOV-103A in a large valve relative to the run pipe and, as a result , the design of the seismic support system and proximity to a main-tenance, inspection, and testing platform dictated that this location be accepted. 1P50*MOV-103B is located approximately l

28 feet from the containment penetration. Again, this location was chosen based on maintenance, inservice inspection and testing accessibility and the ability to provide adequate l

seismic support for the valve and associated piping.

1 l To summarize, our evaluation of this matter indicatec that the Criteria of 10CFR50 have been adequately fulfilled.

Activities affecting. quality are prescribed by the above referenced drawings and are verified by quality assurance organizations. When all factors governing the design location of the CIVs in question are evaluated, it can be shown that they are located as close as practical to the containment penetra-tions.

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Mr. Eldon J. Brunner, Acting Director April 27, 1981 Page Three In view of the above, no corrective or preventive action is considered necessary.

Very truly yours, h //.4W

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Millard S. Pollock Vice President-Huclear

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AFFIDAVIT STATE OF NEW YORK )

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COUNTY OF NASSAU )

MILLARD S. POLLOCK, being duly sworn, deposes and says that I am a Vice President of Long Island Lighting Company, the owner of the facility described in the caption above. I have read the Notice of Violation dated April 1, 1981 and also the response thereto prepared under my direction dated April 27, 1981. Tne facts set forth in said response are based upon reports and information provided to me by the employees, agents, and representatives of Long Island Lighting Company responsible for the activities described in said Notice of Violation and in said response. I believe the facts set forth in said response are true.

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HN#lA /o./!db MILLARD S. POLLOCK Sworn to before me this O day of bg O' , 1981.

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Ccmminica expires t.::r. 20,1.ik'.S