ML20128D915

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Responds to 850307 Request for Addl Info Re QA Program.Items Designated as R Covered by QA Program During Operations. QA Program for Fire Protection Revised
ML20128D915
Person / Time
Site: Hope Creek 
Issue date: 05/23/1985
From: Mittl R
Public Service Enterprise Group
To: Butler W
Office of Nuclear Reactor Regulation
References
NUDOCS 8505290242
Download: ML20128D915 (4)


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Electnc and Gas Company 80 Park Plaza, Newark, NJ 07101/ 201430-8217 MAILING ADDRESS / P.O. Box 570, Newark, NJ 07101 Robert L. Mitti General Manager

' Nuclear Assurance and Regulation May 23, 1985 Director of Nu' clear Reactor Regulation U.S.

Nuclear Regulatory Commission 7920 Norfolk Avenue Bethesda, MD 20814 Attention:

Mr. Walter Butler, Chief Licensing Branch 2 Division of Licensing Gentlemen:

REQUEST FOR ADDITIONAL INFORMATION - OUALITY ASSURANCE HOPE CREEK GENERATING STATION DOCKET NO. 50-354 In a letter to Public Service Electric and Gas Company (PSE&G)' dated' March 7, 1985, the NRC staf f requested addi-tional information regarding the quality assurance program to be implemented at Hope Creek during the operations phase.

The information below provides PSE&G's response to this request for additional information.

Item 1 - Information Requested FS AR Amendment 8 (page 1.8-11) added the words underlined below to - PSE&G's commitment to Regulatory Guide 1.26:

"In addition, items designated

'R' in Table 3.2-1 will be included in the OA Program during operation to the extent required by Regulatory Guide 1.143."

Regulatory Guide 1.143, " Design Guidance for Radioactive Waste Management Systems, Structures, and Components Installed. in Light-Water-Cooled Nuclear Power Plants," addressed QA for design and construction, but it does not address OA for opera-tions.

Identify what GA measures will be applied to items des ig nated

'R' in Table 3.2-1 during the operations phase of the Hope Creek Generating Station.

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PSE&G Response

-Items designated

'R' are covered by the OA Program during operations.

Section 17.2.2 of the HCGS FSAR states, in part:

a.

"This (0A) program is applied to items and activi-ties that can-affect the health and safety of the public,..."

During the operational phase, this includes...,"

-and-b.

" Safety-related activ ities delineated in Regulatory Guide 1.33 and summarized in Table 17.2-1, Section A and additional NRC requirements contained in Table 17.2-1, Section B."

This section further states:

"The quality assurance program is applied during the operational phase using a graded approach to the extent consistent with the item's or activity's importance to saf ety."

Table 17.2-1, Hope Creek Q Activities / Services states, in part:

The listing below identifies those activities and serv ices, to which the quality assurance program applies during operations:

A.

-Safety-related activities delineated in Regula-tory Guide 1.33, Appendix A (see Regulatory Guide for further breakdown of activities)..."

-and-

"6.

Control of radioactivity (a)

Liquid radioactive waste system (b)

Solid waste system (c)

BWR gaseous effluent system.."

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'5/23/85' i

. Item 2 - Information Requeste'd FSAR Amendment 9 -addresses PSE&G's -QA Program for fire pro-tection~ in several locations:

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a)

Page.,20 of Table 11.1-l, describing differences J

from SRP acceptance criteria, states:

...certain fire-system camponents purchased and installe'dl prior to Julyll,-1978,_such as the fire water storage tanks,. the tank heaters and associ-ated controls, and the valve pit heaters.are' excluded from the ' F ' program."

b)

Section 9.5.1.1.19 on page 9.5.12, discussing the QA program for Bechtel's responsibilities, says the s ame thing. :

c)

Comment 61-added to page 40 of Table 3.2-1, states:

"'F' Program is not retroactive-to camponents purchased and. installed prior to July 1,1978.

Fire water storage tanks, the tank heaters and associated controls, and the_ valve pit unit. heaters are excluded.from the

'F' program."

Clarify that each of'these statements-refer to the

' design and construction phase, and ideptify what GA measures.will be ' applied to these itenis during the.

operations. phase.

PSE&G Response The OA program for fire protection will be applied to the above components during the operations phase.

The last sentence of comment 61, Table 3.2-1, will be revised to read:

" Fire' water storage-tanks, the tank heaters and associ-ated-controls, and the valve pit unit heaters are i

excluded from the

'F' Program during the design ~ and construction phase, but will be included in the OA Program for fire protection during the operations phase."-

In -addition, applicable drawings and - specifications will be revised as required to reflect F-designated classification.

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Dir. ~ Nuc. - Reac. Reg.

4 5/23/85 Item Information Requested ~

- FS AR: Amendment ~ 9 -(page 33 of Table 3.2-1) changed the 'seis-

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mic category ofothe unit vent stacks from I to NA and the corresponding QA requirements from.Y (10 CFR 50, Appendix B) to N (QA requirements not' applicable)'. ' Justify or eliminate-thes e. changes.

PSE &G ' Response '

The unit vent: stack, ~ North and South (including structural

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steel support-framing) is not seismic category I.

The j ustification-is as - follows :

a) - Adequate ventilation would 'still be available for all safety-related equipment inLthe event of blockage or failure of these vent paths.

b).. FS AR Section 11.5.2.2.1 also states that, during acci-dent conditions, allLflows_from compartments that could.

be. ex pected to release significant radioactive materials can be isolated.

c)

J rhe. only ' radiation. monitoring - systems that are located in the unit vent stacks, north and south, are classified as non-Class'lE,-as described in FSAR Sections 11.5. 2. 2.1 and 11.5. 2.2. 2 i respectively.

Should there be any further questions or concerns regarding the above subjects, please contact us'.

' Very truly yours,

O

C
D. H. Wagner USNRC Licensing, Project Manager A.

R. Blough IUSNRC Senior Resident Inspector

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