View source for A06837, Responds to NRC Re Violations Noted in Insp Rept 50-336/87-16.Corrective Actions:Hourly Fire Watch Patrol Established & Exemption Request from Section III.G.2.b of 10CFR50,App R for Listed Valves Will Be Submitted by 880201

{{Adams
| number = ML20236F969
| issue date = 10/23/1987
| title = Responds to NRC Re Violations Noted in Insp Rept 50-336/87-16.Corrective Actions:Hourly Fire Watch Patrol Established & Exemption Request from Section III.G.2.b of 10CFR50,App R for Listed Valves Will Be Submitted by 880201
| author name = Mroczka E, Sears C
| author affiliation = NORTHEAST NUCLEAR ENERGY CO., NORTHEAST UTILITIES
| addressee name = Russell W
| addressee affiliation = NRC OFFICE OF INSPECTION &amp; ENFORCEMENT (IE REGION I)
| docket = 05000336
| license number = 
| contact person = 
| document report number = A06837, A6837, B12721, NUDOCS 8711020357
| title reference date = 09-27-1987
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC
| page count = 5
| project = 
| stage = Other
}}

=Text=
{{#Wiki_filter:-_                    - - ___ _ - - - _-______ - _______ - _____________                                          .__      -- - -
            . e-NORTHEAST UTILITIES                                                                           cenerai Omces . seiden street. Berlin, connectict . 4 l                                   amw mm..u m ** ""                                                   P.O. BOX 270 k  k              2 NI[v2 mmwa-[Uc         .mm.
                                                                                       /u                                       HARTFORD. CONNECTICUT 06141-0170 -
(203) 665 5000 October 23,1987 Docket No. 50-336 B12721 A06837 Re: 10CFR50, Appendix R William T. Russell Regional Administrator Region i U. S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19406

==Reference:==
(1) William V. Johnston letter to E. 3. Mroczka, dated September i
25,1987 transmitting Inspection Report No. 50-336/87-16.
Gentlemen:
Millstone Nuclear Power Station, Unit No. 2 Inspection No. 50-336/87-16 s
The NRC Staff transmitted to Northeast Nuclear Energy Company (NNECO) the subject inspection report in Reference (1). As discussed in Reference (1), the Staff cited NNECO for one violation to 10CFR50, Appendix R, Section Ill.G.1, which requires fire protection features to be provided for systems and components important to safe shutdown, such that one train ~of systems necessary to achieve and maintain hot shutdown remains free of fire damage.
In accordance with the Reference (1) request and pursuant to 10CFR2.701, NNECO hereby provides the attached information in response to the Notice of Violation of Reference (1) and a schedule to implement the open -items of Reference (1).'                                                                                                                              '
We trust you find the attached information satisfactory.
Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY                                       .
1 b.h. Mh E. 3. Mroczka Senior Vice President 8711020357 871023 gDR      ADOCK 050                                               6 By: C. F. Sears
   '~: -                                                                                               Vice President cc:                            D. H. Jaffe, NRC Project Manager, Millstone Unit No. 2                                                           ,
W. 3. Raymond, Senior Resident Ynspector, Millstone Unit Nos.1,2 and 3                                          l NRC Document Control Desk I
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Docket No. 50-336                                           i B12721                                          !
A06837 a
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: ' Millstone Nuclear Power Station Unit No. 2 Inspection No. 50-336/87-16 b
6 October,1987

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Attachment 1
                                                                                                                     .                         >         0i B12721/Page1                                  '                                                              '           q \ '' "                 l
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I.       Violation B                                 ,y'    ?                                                                   '?,
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: l. . Description of Viciation                         j                                                                             '
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                                                                                                  ,                                                                            s 10CFR50, Apper. dix R, Section III.G.1 requires that fire prot'ection                                                         !
features shall be provided ror systems and component's important to                                                           I safe shutdown, such that che thin of systems necessary to achieve                                                               I and maintain not shutdown' remains free of fire damage. One method of achieving this is to provide separation of redundant safe shutdown equipment by a horizontal distance of more than 20 feet with no                                                              1 intervening combustibles in accordance with 10CFR50, Appendix R, Section IU.G.2.b. An exemption from the above requirements may be                                                           .;
requested and granted by the commission in accordance with the                                                                  ;
10CFR70.12 requirements.
                                                                                              \                                                                                 i Centrsy to the above, the distance separating the redundant                                                                  i aux'iriary feedwater header:.,and their isolation valves 2-FW-43A and 2 FW-43P, Twas less than the required 20 feet and there were 7                                                                                                                          i interver46g combustible                    in addition no exemption from the above                                          .{
r requirements was, reque}ted, f w                                                                                    h
: 2.        Admission or Denial of Violation f
NNECO does not dontest the violation as set forth in the Noticet of Violation.                       r
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: 3.           eason for Violati n f              [<               ',' I r             <
i4NECO was fully aware of the requirements and believel it was in                                                            ';
i iull compliance without an exemption request. An analysisj had bee'n" performed which concluded, that the valves are designed to fail open                                          -
and that multiple hot shorts would be required for the/ valves to fail closed, that both valves faling closed was not a credible event and                                                          i therefore tid jedundant components could be considered free of fire damage. Basetun this analysis an exemption request was not filed.
It was considered'that the evaluation provided a wificient basis for not submit 1[g an exemption request.
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: 4.        Corrective Action Taken J
Following the identification of the absence of an exemption request frorn Section III.C.2.b of 10CFR50, Appendix R for the discharge
                                             /    vs.lves 2-FW-43A and 2-F7-43B of the auxiliary feedv/ater system, NNECO established an hourly fire watch patrol of the fire area.
NNECO will maiptain the hourly fire watch patrol until such time as the Staff has received and approv4,the z,x:.nption requgst.
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The esUinated dat9 for exemption re test submittal R February 1,                                                              l 38f4               -
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: 5.    - Corrective' Actions to Avoid Future Violations-l NNECO believes that the lack of an exemption request in this instance is an isolated occurrence. NNECO believes that changes to the current process to . determine the need for an exemption request are not warranted.-
: 11.  . Response to Open Items                                                                                                                         l The following information addresses the open items cited on Docket No. 50-336 for Millstone Unit No. 2 during the inspection conducted on July 13-17,1987.
Item A
                             'In several plant. locations the fire detection systems do not conform with the guidance of the National Fire Protection Association (NFPA) Standard                                                                        ,
No.72E.                                                      '
i Response                                                                                                                                        ;
NNECO plans to add additional and/or relocate detectors in accordance                                                                           4 with NFPA 72E in these locations:                                                                                                                 '
Waste Tank Pump Room                                           ' Zone' A-lC Intake Structure                                                 Zone I-l                                                                       .
HPSI Room                                                        Zone A-4                                                                         -
Storage Crib Area                                               Zone A-9                                                                        4 Motor Driven Auxiliary Feedwater Pump Room                      Zone T-3                                                                        )
a1 The addition and/or relocation of fire . detectors will be completed by                                                                         {
March 30,1988.                                                                                                                                  !
I Itern B                                                                                                                                         j Several fire doors in the Auxiliary and Turbine Buildings have been                                                                             l modified with fusible link " hold-open" devices such that they do not                                                                         .>
conform with the NFPA Standard No. 80.                                                                                                          ,
kesponse i
NNECO will replace the fusible link " hold-open" devices on the fire doors                                                                      ;
in accordance with NFPA 80 guidelines.                                                                                                          ;
The replacement of fusible link devices with approved NFPA 80 devices will be completed by January 30,1988.
Item C                                                                                                                                          <
                             'The sprinkler system in Fire Zone A-19A is obstructed by a newly installed
  <                           ceiling partition.                                                                                                                              l L
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1,                                                                    . B12721/Page 3

===Response===
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NNECO will. add an additional sprinkler below _the obstruction in -
Zone A-19A. -
The addition of a sprinkler will be completed by March 30,1988.
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