IR 05000444/1986052

Refers to D Richardson Re Accuracy of Specific Control Bldg Air Sys Drawings in Possession & Determined That No Conflict Exists Between NRC Discussion of Allegation 51 of Insp Rept 50-444/86-52 & Info Provided by Recipient

ML20151W949
Person / Time
Site:	Seabrook
Issue date:	04/21/1988
From:	Kane W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Tracy S EMPLOYEE'S LEGAL PROJECT
Shared Package
ML20151W952	List: IR 05000444/1986052 ML20151W997
References
NUDOCS 8805040015
Download: ML20151W949 (8)

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APR 211988

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Docket No. 50-443-Employee's Legal Project

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ATTN: Ms. Sharon Tracy Post Office Box 633 Amesbury, Massachusetts 01913

Dear Ms. Tracy:

This refers to a letter dated February 25, 1988 (attached) from Mr. D. Richardson of your staff which provided the details of his questions regarding the accuracy of specific Control Building Air (CBA) system drawings in his possession. At a meeting between the Employee's Legal Project and the NRC staff on December 29, 1987, we indicated that our response would be . pro-vided to you after receipt of the information from Mr. Richardson and the necessary research and review by our inspectors.

Our review has been completed and we have determined that no conflict exists between the NRC discussion of Allegation No. 51 on page 86 of NRC inspection report , (IR) 50-443/86-52 and the information provided by ELP. The three Pullman Power Products isometric drawings attached to the ELP letter refer to UE&C isometric, 9763-F-604106, as the design basis document. A Region I inspector reviewed this UE&C isometric drswing, entitled "Control Rooin Air Conditioning System Refrigerant Piping Isometric", and identified a note that specifies that the piping related to air conditioning units AC-6 and AC-7 is not safety-related. The refrigerant tubing illustrated on two of the drawings, ISO 1-CBA-SP-05 & 06, provided by ELP is part of the control room complex ccol- e ing system and connects the air conditioning units, AC-6A fan coil to the AC-7A condenser. Therefore, the classification of this tubing, its supports and its installation as nonseismic is consistent with the associated design basis of the facility. This fact is also true for the tubing connecting the other air conditioning unit components, AC-6B & AC-7B, as illustrated on 9763-F-604106.

Furthermore, the function of the subject air conditioning units, at the time of the original design, was to provide cooling to the computer room. As discussed in IR 50-443/86-52, the computer room air conditioning systeni is

"non-safety-related". The reference by ELP to the statement in the inspection report that ". . .all piping is seismically supported. . ." incorrectly interprets that requirement to apply to the computer room piping. However, the quoted statement, in fact, refers to the "redundant air conditioning systems" which are_ described earlier in the same inspection report section as the "safety related" control room air conditioning system, vice the "non-safety-related" computer room air conditioning system.

8805040015 080421 PDR ADOCK 05000443 PDR Ar [c 4 O y ,

A s.AW puse &alf,A cI , I OFFICIAL RECORD COPY HAVERKAMP 194 4/15/88 - 0001.0.0 04/15/88

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Employee's Legal Project 2 APR 211988 ,

The last paragraph in the "Details" section on page 86 of IR 50-443/86-52 notes that the computer room air conditioning system consists of a self-contained single unit. This fact not only reinforces the point that system and component redundancy is not required, but also reflects the design changes in'this system that have been implemented. Our inspector verified that the current New Hampshire ' Yankee piping and isometric drawings indicate both the "non-safety-related" status of the computer room air conditioning system and a present design that does not rely on units AC-6A & B or 7A & B as the primary air con-ditioning equipment for the computer room. Thus, two of the drawings provided

with the ELP letter not only reflect a system which is non-safety and non-seismic, but also illustrate tubing and components which are currently nonfunctional.

The third Pullman Power Products isometric drawing, ISO 1-CBA-SP-09, which was attached to the ELP letter, represents a section of refrigerant piping that was '

removed in accordance with a design change implemented in 1983. Our inspector verified that this removal was properly documented in an engineering change authorization and that revision 9 to the noted UE&C design drawing, 9763-F-604106, correctly illustrated the redesign. Since the implementation of this engineering change eliminated the specific line questioned by ELP, the inspec-tor selected for review the design, construction details and QA requirements for other tubing supports, which are presently installed, to evaluate compli-

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ance with the originally referenced design details of drawing, 9763-F-604106.

This NRC inspection effort revealed that the control room air conditioning sys-tem tubing supports were designed and constructed to seismic criteria. Further-more, the UE&C safety classification for these supports reflects not only a seismic design and installation, but also the quality control and inspection requirements attendant to a program for "Upgraded 831.1 Construction", as prescribed by the appropriate UE&C design specification.

The implementation of this "Upgraded 831.1 Construction" program has been the subject of previous NRC inspections of certain Seabrook piping systems which are not required to meet ASME Boiler & Pressure Vessel Code requirements, but which do perform a safety-related function. The control room air conditioning system represents a subsystem of the Control Building Air (CBA) system which was specifically inspected by the NRC in 1983 to the details and criteria of the Upgraded 831.1 program.

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OFFICIAL RECORD COPY HAVERKAMP 194 4/15/88 - 0002.0.0 04/15/88

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Employee's Legal Project 3 APR 211988 In summary, the NRC review of the isometric drawings provided by ELP indicates the existence of construction details consistent with both the approved design in effect at that time, i.e., 9763-F-604106, and the NRC statements and discus-sion documented in IR 50-443/86-52. The nonseismic classification of certain sections of the CBA refrigerant piping was correct at the time of construction and still is applicable for the redesigned computer room air conditioning sys-tem. The seismic design and safety-related treatment of other sections of the CBA refrigerant piping for the centrol room was verified. The specific piping lines questioned by ELP have been removed in accordance with subsequent design changes at Seabrook. Notwithstanding this change, NRC review ' of both the records and the programs implemented to ensure the seismic design and QA cover-age of the currently installed tubing and supports has revealed no problems, conflicts or concerns.

As we have done previously with our correspondence with you, we will place this letter and the attached letter from Mr. Richardson in the Public Document Room, as well as provide these letters to the normal distribution list for Seabrook.

We trust that our inspection activity has answered Mr. Richardson's questions in this particular matter and we thank you for your cooperation in this regard.

Sincerely, 041 irie.1 C!Ltx a :<f; William F. Kane, Director Division of Reactor Projects Attachment:

As stated

0FFICIAL RECORD COPY HAVERKAMP 194 4/15/88 - 0003.0.0 04/15/88

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Employee's Legal Project 4

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APR 211988 cc w/ Incoming 2/25/88 Letter:

R. J. Harrison, President and Chief Executive Officer

.T. C. Feigenbaum, Vice President, Engineering and Quality Programs W. J. Hall, Regulatory Services Manager D. E. Moody, Station Manager P. W. Agnes, Assistant Secretary of Public Safety, Commonwealth of Massachusetts Public Document Room (PDR)

local Public Document Room (LPDR)

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Nuclear Safety Information Center (NSIC)

! NRC Resident Inspector State of New Hampshire

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Commonwealth of Massachusetts Seabrook Hearing Service List 12/29/87 Meeting Attendees:

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Douglas E. Richardson, Researcher, Employee's i.ega! Project Michael Greenstein, District Director, U. 5. Rept. Nicholas Mavroules Mary Beth Gentleman, Esq., Assistant Secretary for Policy, Executive Office of Energy Resources, Commonwealth of Massachusetts bec w/ Incoming 2/25/88 Letter:

Region I Docket Room (with concurrences)

J. Wiggins, Branch Chief, DRP D. Haverkamp, Section Chief, DRP J. Kaucher, Project Engineer, DRP A. Cerne, SRI .Seabrook (w/ concurrences)

R. Bores, Technical Assistant, DRSS V. Nerses, PM, NRR i

RIN ACerne/mjd RI DHaverkamp RI JDurr \)RI:DRP Wiggins h e 4/tb88 4/I l

/88 4//7/88 4//h/88 4/J)/88 0FFICIAL RECORD COPY HAVERKAMP 194 4/15/88 - 0004.0.0 04/15/88 s

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Seabrook 1 Service Hearing List E. Tupper Kinger, Esq.

Thomas Dignan, Esq Assistant Attorney General John A. Ritscher, Esq. Office of Attorney General Ropes and Gray 208 State House Annex 225 Franklin Street Concord, New Hampshire 03301 Boston, Massachusetts 02110 George D. Bisbee, Esquire Mr. Bruce Beckley, Project Manager Assistant Attorney General New Hampshire Yankee Office of the Attorney General P.O. Box 330 25 Capitol Street Manchester, New Hampshire 03105 Concord, New Hampshire 03301 Ofane Curran, Esquire Dr. Murray Tye, President Sun Valley Association Harmon and Weiss 2001 S Street, N.W.

209 Summer Street Washington, D.C. 20009 Haverhill, Massachusetts 08139 D. Pierre G. Cameron, Jr. , Esquire Robert A. Backus, Esquire General Counsel Backus, Meyer and Solomon Public Service Company of 116 Lowell Street New Hampshire P. O. Box 516 Manchester, New Hampshire 03105 Manchester, New Hampshire 03106 Mr. Alfred Sargent, Chairman Phillip Ahren, Esquire Board of Selectmen Assistant Attorney General Town of Salisbury, PA 01950 Office of the Attorney General State House Station #6 Augusta, Maine 04333 Senator Gordon J. Humphrey Steven Oleskey, Esquire Mr. Thomas Burack Office of the Attorney General ATIN:

U. S. Senate One Asburton Place 531 Hart Senate Office Building P. O. Box 330 Washington, D.C. 20510 l

Boston, Massachusetts 02108 Mr. Calvin A. Canncy, City Manager Ms. Diana P. Randall City Hall 70 Collins Street 126 Daniel Street

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Seabrook, New Hampshire 03874 Portsmouth, New Hampshire 03801 J

Charles Cross, Esquire Richard Hampe, Esquire Shaines, Mardrigan and McEaschern New Hampshire Civil Defense Agency 25 Maplewood Avenue 107 Pleasant Street Post Office Box 366 Concord, New Hampshire 03874 Portsmough, New Hampshire 03801 .

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1 Board of. Selectmen- Mr. Owen B. Durgin, Chairman RFD Dalton Road. Durham Board of Selectmen Brentwood, New Hampshire 03833 -Town of Durham Durham, New Hampshire 03824 Ms. Roberta C. Pevear Administrative Judge Town of Hampton Falls Jerry Harbour Drinkwater Road Atomic Safety and Licensing Board Hampton Falls, New Hampshire 03844 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Ms. Anne Verga Mr. Guy Chichester, Chairman Chairman, Board of Selectmen Rye Nuclear Intervention Committee Town Hall .c/o Rye Town Hall South Hampton, New Hampshire 03827 10 Central Road e Rye, New Hampshire 03870 Mr. Angle Machiros, Chairman Jane Spector Board of Selectmen Federal Energy Regulatory Comm.

for the Town of Newbury 825 North Capitol Street, N.E.

25 High Road Room 3105 Newbury, Massachusetts 01950 Washington, D.t. 20426 Ms. Rosemary Cashman, Chairman Mr. R. Sweeney Board of Selectmen New Hsmpshire Yanken Division i Town of Amesbury Public Service Company of Town Hall New Hampshire

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Amesbury, Massachusetts 01913 Suite 610, Three Metro Center Bethesda, Maryland 20814 Honorable Peter J. Matthews Mr. Donald E. Chick, Town Manager Mayor, City of Newburyport Town of Exeter City Hall 10 Front Street Newburyport, Massachusetts 01950 Exeter, New Hampshiro 03823 ,

Administrative Judge Administrative Judge Alan S. Rosenthal, Chairman Thomas S. Moore, Esquire

, Atomic Safety and Licensing Appeal Atomic Safety and Licensing Appeal Board Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555

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Administrative Judge Administrative Judge Howard A. Wilber Emmeth A. Luebke Atomic Safety and Licensing Appeal Atomic Safety and Licensing Board ,

Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D. C. 20555 Washington, D.C. 20555

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Edwin J. Reis, Esquire H. Joseph Flynn, Esq.

Office of the General Counsel Assistant General Counsel U.S.-Nuclear Regulatory Commission Federal Emergency Management Agency.

. Washington, D.C. 20555 500 C. Street, S.W.

Washington, D.C. 20472 Edward A. Thomas

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Carol S. Sneider, Esq.

Assistant Attorney General

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~ Federal Emergency Management Agency . .

442 J. W. McCormack (POCH) Office of the Attorney General Boston, Massachusetts 02109 One Ashburton Place, 19th Floor Boston, Massachusetts 02108 Paul McEachern, Esq. Richard A. Haaps, Esq Shaines and McEachern Haaps and McNicholas 25 Maplewood Avenue 35 Pleasant Street Portsmouth, New Hampshire 03801 Concord, New Hampshire 03301 J. P. Nadeau Allen Lampert Board of Selectmen Civil Defense Director

. 10 Central Street Town of Brentwood Rye, New Hampshire 03870 20 Franklin Street Exeter, New Hampshire 03833 William Armstrong Sandra Gavutis, Chairman Civil Defense Director Board of Selectmen Town of Exeter RF0 #1, Box 1154 10 Front Street Kensington, New Hampshire 03827 Exeter, New Hampshire 03833 i Anne Goodman, Chairman William S. Lord '

Board of Selectmen Board of Selectmen

13-15 Newmarket Road Town Hall - Friend Street Durham, New Hampshire 03824 Amesbury, Massachusetts 01913 Michael Santosuosso, Chairman Jerard A. Croteau, Constable Board of Selectmen 82 Beach Road South Hampton, New Hampshire 03827 P. O. Box 5501 ,

Salisbury, Massachusetts 01950

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' Stanley W. Knowles, Chairman Judith H. Mitzner

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Board of Selectmen Silverglate, Gertner, Baker, Fine, ,

. P. O. Box 710 Good, and Mitzner

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North Hampton, New Hampshire 03862 88 Broad Street Boston, Massachusetts 02110

Norman C. Kantner Gary W. Holmes, Esq.

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Superintendent of Schools Holmes and Ellis School Administrative Unit No. 21 47 Winnacunnet Road Aluani Drive Hampton, New Hampshire 03842 i Hampton, New Hampshire 03842 ,

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Charles P.-Graham,' Esquire

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Mr. RobertLCarrigg, Chairman ,

McKay, Murphy.and Graham Board of Selectmen ,

100 Main Street- . .

Town Office *

Amesbury, Massachusetts 01913 Atlantic Avenue North Hampton, New Hampshire 03870 '

Jane Doughty Mr. Edward A. Brown, President and Seacoast Anti-Pollution League Chief. Executive Officer 5 Market Street New Hampshire Yankee Division ,

Portsmouth, New Hampshire 03801 Public Service Company of New Hampshire P. O. Box 700 l

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Seabrook, New Hampshire 03874

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Adjudicatory. File i Atomic Safety and Licensing' Board '

Panel Docket  !

U.S. Nuclear Regulatory' Commission Washington, DC 20555 i

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