ML20206Q968
| ML20206Q968 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 06/24/1986 |
| From: | Mangan C NIAGARA MOHAWK POWER CORP. |
| To: | Starostecki R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| (NMP2L-0756), (NMP2L-756), NUDOCS 8607070041 | |
| Download: ML20206Q968 (2) | |
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NUMOHAWK Y NIAGARA NIAGARA RAONAWK POWER CORPORAT10N/300 ERIE BOULEVARo WEST, SYRACUSE. N.Y.13202/ TELEPHONE (315) 474-1511 June 24, 1986 (NMP2L 0756)
Mr. R. W. Starostecki, Director U.S. Nuclear Regulatory Commission Region I Division of Reactor Projects 631 Park Avenue King of Prussia, PA 19406 Re: Nine Mile Point - Unit 2 Docket No. 50-410
Dear Mr. Starostecki:
Please find attached our formal response to the Notice of Violation dated May 8, 1986, accompanying Inspection Report No. 50-410/86-09.
The response date was extended to June 23, 1986.
Very truly yours, C. V. Mangan Senior Vice President CVM/GG/cla (1634H)
Attachment xc: Director of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, DC 20555 R. A. Granin, NRC Senior Resident Inspector WPC Project File 8607070041 860624
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.a NIAGARA M0 HAWK POWER CORPORATION NINE MILE POINT - UNIT 2 DOCKET N0. 50-410 Violation #86-09-46 10 CFR 50, Appendix B Criterion III requires that the system design basis shall be correctly translated into design drawings.
The Institute of Electrical and Electronics Engineers (IEEE) Standards 308 and 384 specify that class IE electrical equipment be protected from damage during design basis events.
Contrary to the above, as of March 25, 1986, the system design basis was not correctly translated into the design drawing in that Class IE conduits 2CX164GA and 2CX192YA were routed in the Non-Category I Reactor Building stair tower in accordance with design drawings EE-460-BE and EE d60-BC and were therefore exposed to potential damage due to possible collapse of the stair tower during a seismic design basis event.
Response
The original tubing for the radiation monitoring sample and return lines was designed as QA Category II.
The sample lines which require heat tracing, were subsequently upgraded to QA Category I.
Also, conduit for the required tubing heat trace was run to the existing sample tubing lines in the stair tower.
The tubing and conduit are attached to the QA Category I Reactor Building.
However, the fact that the surrounding stair tower was a QA Category III structure was not identified during the routing of the conduit nor the re-classification of the sampling system.
Corrective Action The stair tower will be braced in accordance with Engineering and Design Coordination Report Yl8141 to resist seismic forces.
The work will be completed prior to fuel load.
Failure of the stair tower and the equipment located in the stair tower during a design base tornado, is acceptable per the Regulatory position of Regulatory Guide 1.117, Rev. 1,
" Tornado Design Classification".
Therefore, the stair tower is not required to withstand a design base tornado.
Stone & Webster is performing a review to determine if any other Category I equipment is located in Non-Category I areas.
The results of this review will be reported to the Commission in our response to a reportable deficiency per 10 CFR 50.55(e) covering the same subject as this Violation.
(See NRC Item No. 86-00-11 ).
Preventative Action A Site Engineering Group Memorandum will be issued to assure that safety-related components are not being located in non-seismic areas.
This Site Engineering Group Memorandum will be followed by a Project Guideline to cover the same subject for plant modification.
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