ML20134C508

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Responds to NRC 850419 Request for Addl Info Re 850215 Response to Violations Noted in Insp Rept 50-305/84-15. Corrective Action:Applicable NFPA Stds Will Be Observed in Design,Const & Operation of Facility
ML20134C508
Person / Time
Site: Kewaunee Dominion icon.png
Issue date: 07/22/1985
From: Hintz D
WISCONSIN PUBLIC SERVICE CORP.
To: Spessard R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
85-NRC-123, NUDOCS 8508160334
Download: ML20134C508 (5)


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85-NRC-123 WISCONSIN PUBLIC SERVICE CORPORATION P.O. Box 19002, Green Bay, WI 54307-9002

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July 22, 1985 Mr. R. L. Spessard, Director Division of Engineering U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137 Gentlemen:

Docket 50-305 Operating License DPR-43 Kewaunee Nuclear Power Plant Inspection Report No. 50-305/84-15

References:

1) Letter from D. C. Hintz.to W. S. Little dated February 15, 1985
2) Letter from R. L. Spessard to D. C. Hintz dated April 19, 1985 Inspection Report 84-15 was issued following an inspection conducted at the Kewaunee Nuclear Power Plant by Messr. J. L. Ulie of your offico.

Reference 1.provided our response to Inspection Report 84-15.

In reference 2 additional information was requested. The attachment to this letter provides the additional information requested in reference 2.

Very truly yours, JM D. C. Hintz Manager - Nuclear Power DJM/js Attach.

cc - Mr. S. A. Varga, US NRC Mr. Robert Nelson, US NRC 8508160334 850h05

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Mr. R. L. Sp:ssard N1-109.2 July 22, 1985 Page 1 ATTACHMENT RESPONSE FOR ADDITIONAL INFORMATION In your letter dated April 19, 1985, you requested the following additional information:

NRC REQUEST A.

A list of all NFPA standards committed to or referenced in your Fire Hazards Analysis.

WPSC RESPONSE The NFPA Guidelines listed below are referenced in the KNPP original Fire Hazards Analysis, dated 1977.

NUMBER TITLE 4 - 1977 Organization for Fire Service 4A - 1969 Fire Department Organization 6 - 1974 Industrial Fire Loss Prevention 7 - 1974 Fire Emergencies Management 8 - 1974 Effects of Fire on Operations, Management Responsibility for 10 - 1975 Portable Fire Extinguishers 10-A-1975 Appendix "A",. Portable Fire Extinguishers 12 - 1973 Carbon Dioxide Systems 12-A-1973 Halon 1301 Systems 12-B-1973 Halon 1211 Systems 13 - 1976 Sprinkler Systems, Installation 13A-1976-Sprinkler Systems, Maintenance 14 - 1974 Standpipe and Hose Systems 15 - 1973 Water Spray Fixed Systems 16 - 1973 Foam-Water Sprinkler & Spray Systems 20 - 1973 Centrifugal Fire Pumps 24 - 1973 Outside Protection

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Mr. R. L. Spessard-

- July 22, 1985

- Page 2 NUMBER TITLE 26'- 1958 Supervision of Valves

' 27 - 1975 Private Fire Brigades 30 - 1973 Flammable and Combustible Liquid Codes 49 - 1975 Hazardous Chemical Data 50A-1973 Gaseous Hydrogen Systems 51 - 1976 Welding and Cutting, Oxygen Fuel - Gas Systems 51-B-1976 Cutting and Welding Processes 69 - 1973 Ventilation Battery Rooms 72-D-1975 Proprietary Signaling Systems 78 - 1977 Lightning Protection Code 80 - 1975 Fire Doors and Windows 92M -1972 Waterproofing and Draining of Floors 194 - 1974 Fire Hose Connections 196 - 1974 Fire Hose 197 - 1966 Initial Fire Attack, Training Sessions On 204 - 1968 Smoke & Heat Venting Guide

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232AM 1972 Archives & Record Centers 490 - 1975 Storage of Ammonium Nitrate 493 - 1975 Intrinsically Safe Apparatus for use in Class I Hazardous locations and it's Associated Apparatus 495 - 1973 Explosive Materials 496 - 1974 Purged and Pressurized Enclosures for Electrical Equipment in Hazardous Locations 498 - 1976 Explosives Motor Vehicle Terminals 601 - 1975 Guard Service in Fire Loss Prevention 802 - 1974 Nuclear Reactors L

c Mr. R. L. Spassard July 22, 1985 Page 3 NRC REQUEST B.

A statement of your current commitment to conformance to those NFPA stan-dards identified in that list.

WPSC RESPONSE 3

The Kewaunee Nuclear Power Plant's Fire Hazards /nalysis was intended to be a self-evaluation document used to assess the degree of compliance with BTP 9.5-1 and was valid for the time at which the review was conducted.

In looking at the Fire Protection Safety Evaluation Report (FPSER), (Tech.

Spec. Amendment #23), issued December 12, 1978, a five (5) man NRC inspection team inspected this facility. The inspection team independently evaluated our Plant and, as a result of their inspection, twenty-eight (28) modifications we,re recommended to this facility before BTP 9.5-1 was satisfied. The inspection team's SER confirms our compliance with the criteria set in the Branch Technical Position 9.5-1 and Appendix A.

The standards listed in the Fire Protection Program Analysis did not imply ver-batim compliance but rather were a commitment to apply these standards accor-ding to good engineering judgment, professional interpretation, and good fire

. protection practice in the design and operation of the Kesaunee Plant.

NRC REQUEST C.

A statement defining your interpretation of the applicability of NFPA stan-dards to the Kewaunee facility.

WPSC RESPONSE The Kewaunee Nuclear Power Plant received its Construction Permit in 1968 and its Operating License in 1973, prior to the present-day fire protection guide-lines. The high degree of compliance now found is a credit to WPSC's high pro-fessional standards of fire protection.

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Mr. R. L. Sp ssard July 22, 1985 Page 4 WPS interprets the applicability of NFPA standards to KNPP in the following manner.

Applicable NFPA standards will be observed in the design, construction, and operation of the KNPP according to professional interpretation and good fire protection practice.

The NFPA Standards applicable to Kewaunee will be updated concurrent with the Fire Hazards Analysis for 10 CFR 50 Appendix R, in a time frame commensurate with th'e completion commitment of the modifications to meet Appendix R requirements.

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