ML20023D818
| ML20023D818 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 01/28/1983 |
| From: | Brons J POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK |
| To: | Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20023D816 | List: |
| References | |
| IP-JAS-255, NUDOCS 8306030345 | |
| Download: ML20023D818 (5) | |
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e POWER AUTHORITY OF THE STATE OF NEW YORK INDIAN POINT NO. 3 NUCLEAR POWER PLANT P. O. BOX 215 BUCH AN AN, N. Y.10511 TELEPHONE: 914-73942OO S
January 28, 1983 IP-JAS-255 Mr. T. T. Martin, Director Division of Engineering and Technical Programs U. S. Nuclear Regulatory Commission Region 1 631 Park Avenue King of Prussia, Pennsylvania 19406
Subject:
Inspection No.
50-286/82-09
Dear Mr. Martin:
This letter provides additional information concerning the Authority's installation of radial pattern sprinkler nozzles in lieu of the previously committed closed head, horizontal side-wall type, a deviation identified in the subject inspection report.
The Authority has completed an evaluation of the installed radial type sprinkler nozzles and has concluded that the coverage provided by the installed nozzles is equal to or superior to a system utilizing the side-wall type nozzles and do not alter the capability of the suppression system to provide sufficient fire protection. A copy of the Authority's safety evalua-tion is provided with this letter.
The Authority had embarked on a comprehensive fire protection program at Indian Point 3 plant to significantly upgrade the fire protection and detec-tion capability throughout the plant.
Included within the scope of this work were the safety related cable trays for which the Authority would subsequently commit to providing side-wall type nozzles for coverage as recommended by the NRC in their May 21, 1979 letter. After the commitment was made, the Authority's consultant was officially requested to utilize the side-wall type nozzles instead of the radial type sprinkler nozzles recommended earlier. This request was made four months af ter the original design was completed and the installation work was contracted.
Due to an oversight in noting the Authority's commitment to the NRC, the design and installation of the side-wall type nozzles were not accomplished.
It is felt that this was a random error as a consequence of the Authority's attempt to meet the NRC committed schedular constraints and the complexity of the upgrade program. Since the design documents were not changed to reflect the side-wall type sprinkler nozzles a field check could not have caught the discrepancy.
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..Mr.
T.- T. Martin Page Two
-January 28, 1983 The Authority believes that the system was' accepted af ter being inspected
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using as-built-drawings which correctly reflected the system installed but which were incorrect in that they did not reflect the requested modification.
Very truly yours, 7
.JCB:ms Resident Manager Attachment cc: Resident Inspector's Office - IP#3
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ATTACHMENT' Safety Evaluation:
INSTALLATION OF RADIAL TYPE SPRAY HEADS ~
IN THE CABLE. TUNNEL AND THE CABLE SPREADING ROOM t
.t-POWER AUTHORITY OF THE STATE OF'NEW YORK INDIAN POINT 3 NUCLEAR POWER PLANT DOCKET NO. 50-286 JANUARY, 1983-
s Installation of Radial Type Spray Heads in the Cable Tunnel and the Cable Spreading ~ Room 1.
PURPOSE To verify that the existing radial closed head spray nozzles located in the cable spreading room and the last 15 feet of the cable tunnel adja -
cent to the cable spreading room, provide adequate coverage in protecting safety related power cables located in cable trays 18N, 19N and 22N.
II.
DESCRIPTION The cable tunnels and cable trays 18N, 19N and 22N', located in the cable spreading room at the end of the cable tunnel in the control building, are protected against fire damage by an automatic, dry-pipe, closed head preaction sprinkler system. An independent water supply for the sprinkler system is provided on each side of the electrical tunnel.
Rate of rise type heat detectors are installed above the cable trays.
The heat detectors actuate a deluge valve which is alarmed and annun-ciated in the control room.
In the last 15 feet of the cable tunnel and in the cable spreading room, closed head, preaction sprinkler heads (EA-1), providing a 65 degree radial discharge pattern, have been installed. Originally it was pro-posed to use horizontal side wall mounted sprinkler heads in this area.
This evaluation is intended to illustrate that the change in sprinkler heads did not alter the capability of the system to provide sufficient fire protection.
III. EVALUATION In order to establish that the existing sprinkler system satisfies the intent of the NFPA code, a request was made, to the engineering consult-ing firm that designed the system, to evaluate the capabilities of the system with the consideration that radial spray heads were used in lieu of side wall mounted heads in the cable tunnel and cable spreading room.
J Paragraph 1-10 of NFPA-15-1977 requires that water spray system design
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' shall be entrusted only to responsible persons fully experienced in' this L
I field.
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Calculations by the design engineer gevealed that the radial spray heads will provide a density of 1.6 gpm/f t on the cable trays. This exceeds the density of.3 gpm/ft specified in the NFPA code. Additionally, the A,I location of the nozzles over each tray, with the nozzles positioned to provide a solid spray cone of water along the tray, provides the cable
"(EAl trays with fire protection equal to a system utilizing side wall nozzles l'
and meets all applicable NFPA codes.
After reviewing the piping arrangement and the location of the radial spray heads, it has been determined that the existing spray nozzles
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This modification will not increase the' probability of occurrence or consequences of an accident or malfenction of. equipment-important:to safety previously evaluated in the ISAR nor will it;-.' create the possibil 1
-ity of an accident or malfunction of type'other than-anyfevaluated previously in the FSAR.
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This modification will not affect the environmental impact of the plant nor will it degrade the_ Security-Plan'or'the Fire Detection and:Suppres-
-sion Systems.-
The modification does not involve a_ change in the' Technical Specifica -
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tions nor does'it reduce:the margin of safety as defined in the Basis for Technical Specifications.
Thus, the subject modification is deemeil not_to involve any unreviewed safety question.
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