ML20138K180
| ML20138K180 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 12/11/1985 |
| From: | Devincentis J PUBLIC SERVICE CO. OF NEW HAMPSHIRE |
| To: | Collins S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| SBN-905, NUDOCS 8512180307 | |
| Download: ML20138K180 (3) | |
Text
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1 SEABROOK STATION Engineering Office December 11, 1985 Pub 5c Service of New Hampshke SBN-905 T.F. B4.2.7 Now Hampshire Yonkee Division United States Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19406 Attention:
Mr. Samual J. Collins, Chief Projects Branch 2 Division of Reactor Projects
References:
(a) Construction Permits CPPR-135 and CPPR-136, Docket Nos. 50-443 and 50-444 (b) USNRC Letter dated November 15,1985, " Combined Inspection Report Nos. 50-443/85-01; 50-444/85-02," S. J. Collins to R. J. Harrison
Subject:
Response to Combined Inspection Report Nos. 50-443/85-25; 50-444/85-02
Dear Sir:
It was reported in the subject Inspection Report that certain of our activities were not conducted in accordance with commitments in the FSAR. Our response to the reported deviation, including the action taken to preclude recurrence, is provided in Attachment A, included herewith.
In addition to responding to the above deviation, we also wish to clarify our position relative to unresolved Item 443/85-25-01 concerning the Diesel Generator Brush Holder Assembly failure at the Millstone-Unit 3 plant. As discussed with NRC resident personnel, although the existing Seabrook Diesel Generator Brush lioiders are within the design parameters specified by the manufacturer, we will replace the brush holders prior to diesel generator acceptance testing. This replacement is being performed to preclude the potential of future failure and enhance diesel generator reliability characteristics.
Vprytruly
- ours, 4*
M 8512180307 851211 PDR ADOCK 05000443 John DeVincentis, Director G
PDR Engineering and Licensing Attachment cc: Atomic Safety and Licensing Board Service List Director, Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, DC 20555 P.O. Box 300. Scotxook. NH 03874. Tetephone (603) 474 %21 1
I (G OL
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- k William S. Jordan, III Donald E. Chick Diane Curran Town Manager Harmon, Weiss & Jordan Town of Exeter 20001 S. Street, N.W.
10 Front Street Suite 430 Exeter, NH 03833 Washington, D.C.
20009 Brentwood Board of Selectmen Robert C. Perlis RED Dalton Road Office of the Executive Legal Director Brentwood, NH 03833 U.S. Nuclear Regulatory Commission Washington, DC 20555 Richard E. Sullivan, Mayor City Hall Robert A. Backus, Esquire Newburyport, MA 01950 116 Lowell Street P.O. Box 516 Calvin A. Canney Manc hester, NH 03105 City Manager City Hall Philip Ahrens, Esquire 126 Daniel Street Assistant Attorney General Portsmouth, NH 03801 Augusta, ME 04333 Dana Bisbee, Esquire Mr. John B. Tanzer Assistant Attorney General Designated Representative of Office of the Attorney General the Town of Hampton 206 State House Annex 5 Morningside Drive Concord, NH 03301 Hampton, NH 03842 Anne Verge, Chairperson Roberta C. Pevear Board of Selectmen Designated Representative of Town Hall the Town of Hampton Falls South Hampton, NH 03827 Drinkwater Road Hampton Falls, NH 03844 Patrick J. McKeon Selectmen's Office Mrs. Sandra Cavutis 10 Central Road Designated Representative of Rye, NH 03870 the Town of Kensington RFD 1 Carole F. Kagan, Esquire East Kingston, NH 03827 Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Jo Ann Shotwell, Esquire Washington, DC 20555 Assistant Attorney General Environmental Protection Bureau Mr. Angi Machiros Department of the Attorney General Chairman of the Board of Selectmen One Ashburton Plare, 19th Floor Town of Newbury Boston, MA 02108 Newbury, MA 01950 Senator Cordon J. Humphrey Town Manager's Office U.S. Senate Town Hall - Friend Street Washington, DC 20510 Amesbury, MA 01913 (ATTN: Tom Burack)
Senator Cordon J. Humphrey Diana P. Randall 1 Pillsbury St reet 70 Collins Street Concord, NH 03301 Seabrook, NH 03874 (ATTN: Herb Boynton) i
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ATTACHMENT A SBN-905
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NRC Notice of Deviation 443/85-25-01 h
L The Seabrook FSAR, in Section 1.8, specifies conformance to the provisions of USNRC Regulatory Guide 1.97.- Although certain exceptions to Regulatory Guide l-
'1.97 are discussed in the FSAR, none of them involve either the Reactor Vessel p
Level Indication System (RVLIS) or the Reactor Coolant System (RCS) wide-range l-pressure signals used for safety-related valve interlocks. By letter (SBN-864) dated August 30, 1985, Public Service Company of New Hampshire l-confirmed to the USNRC, Seabrook Station's commitment to Regulatory Guide 1.97, Revision 3, and provided detailed information to be incorporated into the FSAR by a future amendment. Included in this letter is an Accident Monitoring Instrumentation List which indicates that the RCS wide-range pressure transmitters and RVLIS level transmitters are considered Regulatory l
Guide 1.97,' Design Category 1 instruments. Regulatory Guide 1.97, Revision 3, provides that the. quality assurance applied to Design Category 1 instrumentation be commensurate with nuclear Quality Assurance (QA)
(i.e.. ANSI /ASME) criteria.
Contrary to the above, as of September 10, 1985, tubing installation to both the RCS wide-range pressure transmitters and the RVLIS level transmitters had proceeded under QA program controls not commensurate with nue.=ar QA l
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criteria. The QA program (QAS-5) in use was intended for nonsa3 ty-related components and meets Regulatory Guide 1.97 Design Category 2 cri. ria, but l
does not meet the Design Category 1 criteria committed to for the subject i
RVLIS and RCS wide-range pressure instruments.
This is a deviation applicable to Docket No. 50-443.
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Response
Project Engineering personnel are in the process of reviewing all instrumentation systems that were possibly installed and inspected to the upgraded B31.1 program. Upon completion of this engineering evaluation, systems which were QA controlled by the UE&C QAS-5 program will be identified and tracked via the project Nonconformance Program. Project QA personnel are also evaluating and documenting the applicable criterion of Appendix B to 10CFR50 which were utilized as contro111ag mechanisms for the reclassified i
lines.
Action to Preclude Recurrence Appropriate design documents and associated installation and inspection procedures are being revised or generated to assure that B31.1 safety-related installations are performed under QA systems of control commensurate with Regulatory Guide 1.97 Design Category 1.
Above action will be completed by January 8,1986.
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