ML20027D881

Forwards Response to NRC 820702 Ltr Re Violations Noted in IE Insp Rept 50-286/82-09.Requirements of Section Iii.I of App R Do Not Apply to Facility

ML20027D881
Person / Time
Site:	Indian Point
Issue date:	08/02/1982
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
ML20027D868	List: ML20027D880 ML20027D881
References
IP-JAS-2827, NUDOCS 8211100302
Download: ML20027D881 (3)

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4 POWER AUTHORITY OF THE STATE OF NE:W. YORK INDIAN POINT NO. 3 NUCLEAR POWER PLANT P. O. BOX 215 BUCHANAN.N.Y.10511 TELEPHONE) 914 736 8200 S August 2, 1982 IP-JAS-2827 Docket No. 50-286 License No. DPR-64 Mr. T. T. Martin, Director Division of Engineering and Technical Programs U.S. Nuclear Regulatory Commiss.on Region 1 631 Park Avenue King of Prussia, Pennsylvania 19406

Subject:

Inspection 50-286/82-09

Dear Mr. Martin:

This letter responds to your Inspection Report No. 50-286/82-09 dated July 2, 1982 and received at this office on July 6, 1982.

Attachment I to this letter responds to Appendix A of your letter.

Very truly yours, John C. Brons

. Resident Manager JAS/ljm Attachment cc: IP3 Resident Inspectors' Office NRR Division of Licensing; Mr. Steven A. Varga SUBSCRIBED AND SWORN 'IO BEFAREf-ME TIIIS L7 DAY j/ 9 P./ g g k ECU OFvjt4/2 ,

NICHOLAS A. CA11LUCCI

/ Notary Public. State of New York No. 4651851 Putnam County Commission Epires March 30, IM3 l 8211100302 821104 PDR ADOCK 05000286 D PDR

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ATTACHMENT I NOTICE OF VIOLATION Appendix A of the subject report identi es a violation of the Fire Brigade Requirements of Section III. , Appendix.R to 10 CFR 50 and the Nuclear Regulatory Commission Supplemental Safety Evaluation Report ~ (SER) dated May 2, 1980. However, the require-7

-ment of Section III.I of Appendix R does not apply to the Indian

< Point Unit 3 facility.

Section 50.48(b) ' of 10 CFR 50 states:

Except for the requirements of Sections III.G, III.J, and III.0, the provisions of Appendix R to this part shall not be applicable to nuclear power plants licensed to operate 1

prior to January 1,1979; to the extent that fire protection features proposed or implemented by the licensee have been -

i accepted by the NRC Staff as satisfying the provisions of Appendix A to Branch Technical Position BTP APCSB 9.5.1 reficcted in staff fire protection safety evaluation reports issued prior to the ef fective date of this rulo. .. (foot note omitted)

Indian Point Unit 3 was licensed to operate on December 12,

+ 1975 and, prior to the effective date of Appendix R received a NRC staff fire protection safety evaluation report with no open items. Indeed, this fact was acknowledged by Mr. Harold R.

Denton in paragraph 1 of Section III..of the exemption which he granted on May 5,1982 ("By completing the modifications described

• in the FPSER and its supplements, the licensee has completed all the other requirements of the Fire Protection Rules") , and by Mr.

David G. Eisenhut in his November 24, 1980 letter which documented that no open itens -remained from previous NRC staff fire protection -

reviews based on BTP APCSB 9.5.1.

' The Authority also contends that it has fulfilled the require-ments for Fire Brigade Training as approved by Section 2.5.2 of the May 2,1980 Supplemental NRC SER, which states in part:

" Annually, brigade members participate in training sessions in actual fire extinguishement. Quarterly, brigade members partici-pate in preplanned fire brigade drills." The Authority has always interpreted this requirement such that all Fire Brigade Members would participate in at least one annual. training course.

Quarterly drills would be designed to include as large a number as possible of the Brigade Members, but not necessarily all individuals; which would be a burdensome task and would detract from normal plant operation. In fact, the Authority has conducted unannounced drills more than monthly during 1982. The Authority considers the existing training program to be adequate and reasonable and in compliance with the SER Requirement. Please note that the inspector's report states that " fourteen of thirty-eight fire brigade members participated in only one in-plant drill", when in fact, fourteen of the thirty-eight participated in two or more drills; the remaining twenty-four individuals participated in one in plant drill.

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ATTACHMENT I NOTICE OF DEVIATION 4

The subject inspection. report also identifies a deviation from a previous Authority commitment to install a . closed head, j horizontal side-wall type fire protection sprinkler nozzle for

, safety related cable trays in the cable spreading room and electrical cable tunnel. The Authority has installed radial pattern discharge sprinkler nozzles in lieu.of the side-wall type.

l The Authority is investigating the rationale behind the decision to utilize the radial type sprinkler nozzles in lieu of-the side-wall type'and will resolve any' concerns which the NRC Office of Nuclear Reactor Regulation (NRR) may have regarding this change. Mr. Steven-A. Varga (NRR Division of Licensing) has been notified of this fact verbally and by copy of this statement.

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