ML19351A409

Responds to NRC 890912 Ltr Re Violations Noted in Insp Rept 50-298/89-24.No Corrective Action Required as Util Believes That Deviation Cited Due to Difference of Opinion Re Notification of Change in Commitment

ML19351A409
Person / Time
Site:	Cooper
Issue date:	10/12/1989
From:	Trevors G NEBRASKA PUBLIC POWER DISTRICT
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NLS8900388, NUDOCS 8910200240
Download: ML19351A409 (10)

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GENERAL OFFICE

e Nebraska Public Power District " " "L'sYoThys2""*"  !

NLS8900388 [

October 12, 1989  ;

U.S. Nuclear Regulatory Commission

' Document Control Desk yi' washington, DC 20555

Subject:

NPPD Response to NRC Inspection Report 50-298/89-24 Cooper Nuclear Station' Docket No. 50-298, DPR-46 Gentlemen:

This letter is written in response to your letter dated September 12, 1989, transmitting Inspection Report 50-298/89-24. Therein you indicated that one of our activities appeared to deviate from commitments made to the NRC.

Following is a statement of'the deviation and our response.

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-STATEMENT OF DEVIATION ,.

p Failure to Implement the Approved _ Water Suppression Systems and Notify the NRC of Changed Commitment.

In letters dated June 28, 1982 and March 18, 1903, the licensee committed to provide a fully automatic water suppression. system in the service water intake structure. This commitment was accepted by the NRC in the Safety jm' Evaluation Report dated September 21, 1983.

Contrary to the above, during this inspection from July 31 through August 4,'1989, the ' inspector noted that the licensee had changed the commitment

. by providing a Halon system instead . of a water suppression system in the service water intake structure and had failed to inform the NRC of this change to the commitment. (298/8924-01)

Reason for the Deviation A brief chronology of the events which led the NRC Inspectors to cite the L alleged deviation from the District's commitment to install a wet pipe sprinkler system in the service water pump room is provided below.

June ~28, 1982 - Letter from J. M. Pilant (NPPD) to D. B. Vassallo (NRC).

Committed to wet pipe sprinkler and requested oxemption from 20 foot separation in SW Pump Room.

September 21, 1983 - Letter f rom D. B. Vassallo (NRL) to L. G. Kuncl (HPPD). Grants exemption from 10 CFR 50, Appendix R, Section III.G.2, based on installation of an A

" automatic suppression and detection" system. i i

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Note this SER does not state a wet pipe sprinkler C system, i I September 4,1984 '- Record of Telephone Conversation between J. D.  ;

Weaver and R. Eberly (NRC). NRC verbally agreed p that sprinklers, CO, or halon automatic suppression -

t is acceptable.

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L March 19, 1985 Design Change 85-01 approved to install halon in SW

[- Pump Room.

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April 3,1985 ' Record of Telephone Conversation between J. D. Weaver i i (NPPD) and T Wambach (NRC). NRC verbally agreed that

? installing halon instead of sprinklers met the SER

' , commitment and ~ it was acceptable to install the halon system prior to NRC approval of the technical -

specifications.

I-May 31, 1985 - Letter from J. M. Pilant to D. B. Vassallo. Submitted proposed Technical Specification Change No. 22 which

included LCOs and Surveillance Requirements for the l Service Water Pump Room Halon System.

L April 10, 1986 - Letter from W. O. Long (NRC) to J .' M. P11 ant.

Approved License Amendment No. 98. which included an NRC Sefety Evaluation Report on the SW Pump Room Halon E System Technical Specifications.

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The District clearly realized the need to discuss with the NRC the decision to change from 'a. wet pipe sprinkler to a halon system, prior to j installation. The District first discussed this change in a documented

-telephone conversation September 4, 1984 (Attachment 1). The lead Appendix R reviewer for Cooper Nuclear Station stated during the 9/4/84 conversation that:halon, CO, or wet pipe sprinklers would be acceptable. The District

. stated that a letter would be forwarded to notify the NRC of the District's final decision.

The Design Change (DC)' that installed the halon system in the SW Pump Room located in the intake structure (DC 85-01) was approved on March 19, 1985.

. This DC references the 9/4/84 conversation between NPPD and the NRC and states / that a Technical Specification change would be submitted. DC 85-01 "also references the 9/21/83 SER that approves installation.of an " automatic suppression system", noting that the SER did not specify sprinkleru and ,

that the NRC had verbally agreed that halon was acceptable.

The District again contacted the NRC on April 3, 1985, prior to installation of the halon system, to verify that installation prior to approval of the proposed Technical Specification Change was acceptable.

l During this documented telephone conversation (Attachment 2), the NRC L pointed out that changing from wet pipe sprinklocs to halon may be p unacceptable if the NRC SER specifies sprinklers. Excerpts from the SER l were reviewed and it was noted that the SER stated " automatic suppression

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, and detection" will be added and did not specifically state that sprinklers  ;

are required. The NRC agreed, verbally, that installation of a halon t system would not violate the SER comitment. The NRC also pointed out that K prior approval under 10 CFR 50.59 - was not required since this change was

!. being done under 50.48, and the NRC had previously agreed, again verbally,

( that the halon system met the Appendix R and SER requirements to install an y l- automatic suppression system. The District, prior to ' this call, clearly h; considered the proposed technical specification change submittal to be d, for.nal notification of the cormitment change, and the District was clearly L. 2 concerned that formal approval of the change was required. However, the v 'NRC verbally agreed that the SER did not specify sprinklers (see Attachment 3), and therefore, both Appendix R and the SER conmitment would be met by the halon system. ,

The District submitted Proposed Change No. 22 to the CNS Technical Specifications on May 31, 1985. This proposed change contained LCOs and

• Surveillance Requirements for the Service Water Pump Room Halon System.

The District, based on previous di~ussions with the NRC, considered this to be formal written notification o. che change in comitment. The purpose of the April 3, 1985, documented telephone conversation discussed above, was to ensure that it.was acceptable to install the halon system instead of ,

sprinklers, prior to NRC approval of the Technical Specification (TS) change.

License Amendment No. 98 approved the District's Proposed Change No. 22.

Therein, the NRC referenced the original June 28, 1982, exemption request in Section 2.0 of. the Safety Evaluation. The June 28, 1982, exemption request clearly stated that a wet pipe sprinkler system would be installed in the Service Water Pump Room. Since the NRC referenced the 6/28/82 exemption request that committed to sprinklers, but approved the use of.the halon system, the NRC clearly. acknowledged the change in commitment.

Therefore, the District believes that no further correspondence is required tol notify the NRC of the change in commitment.

While the September 21, 1983, SER by the NRC was issued based upon the District's June 28, 1982, submittal committing to sprinklers, the SER '

accompanying Amendment No. 98 acknowledges and approves the change to the halon system. Also, the 9/21/83 SER states that " automatic suppression" is required and does not specify sprinklers. Since the latest SER accurately

-reflects the change to halon and the previous SER (9/21/83) is not specific, the District believes that the current licensing basis is accurate. Therefore, we believe no further correspondence from the District is required and no revisions to the existing SERs are necessary.

Based on the above discussion, the District believes that M.e documented telephone conversations and the follow-up Technical Specification Change constituted adequate notification to the NRC that the District changed its commitment from sprinklers to halon for automatic suppression in the Service Water Pump Room. The District, therefore, does not believe that a deviation from a commitment existed.

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g, ,- Corrective Stoss Taken and Result Achieved The District does not believe that a deviation existed, and therefore, no -

E corrective action is required.

Corrective Sterc ht Will Be Taken to Avoid Porther Deviations The District believes that this deviation was cited by the NRC due to a dif ference of opinion' as to what constitutes notification of a change in commitment. In 1984, the District relied upon two (2) documented telephone it '

conversations, with formal ' written follow-up in the .. f orm of proposed Technical Specifications. The District does not believe that this was indicative of any peneric programmatic problems that require long term corrective steps. Therefore, no further action is planned.

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. Dat e When Full Cens>11ance Will Be Achieved t

NPPD is presently in full corqpliance.

Please contact me if. you have any questions or require any additional information.

sincerely,.

. . Trevors Division Manager Nuclear Support

/$w cc: ti.S. Nuclear Regulatory Comnission Region IV

.f, Arlington, TX NRC Resident. Inspector Office Cooper Nuclear Station p.

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OS$ RAS 4LA PUSUC POWE R DISTRCT g g RECORD OF TELEPHONE CONVERSATION N- d oets . 9/6/46 tw a:30 an 7ROed: TO:

Name J. D. Weaver Name *-4v therivftfhPflaaru, _

nnig I IrPPD y MRC [8[" Rug y

. ElBJECT- A""***ti" 8"pPression Systes f or Service Water Istake Strwetste t;

.b TOMCS OF CONVERSATION:

i called Ready Eberly OtRC Cheatcal Engineerina Branch) to inoutre as to whether a Balon or 002 automatic suppression system weeld be accostable to the staf f La Lieu of the sprinkler system in the service water pump room.

4 Itr. Bharly see our ae'.a reviewer for Appendia 1. Btr. Eberly read the SER the

. staff gave me and informed me that either of the systems weald be acceptable since Appendia R ealy specifies "estamatic tappressies". It would be

' O acceptable to have a CO2 system which is eenmally deactivated whenever personnel are in the room. The District will decide on which type of erstaa

'.- boot fits the plant, and write a letter informing the staff of our course of 2 octies when flaalised.

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t PRCMS:triql*J d3.7 JaggY igne,er ' Tom Wembach Name ro

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AN(M,t-scjf,W ~PDe WP R {*y Company BC

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SUSJSCT ' Balem Suppresstee Systen for Service Weter 1 stake Strveture

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en TOPICS OF., CONVERSATION:

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C. 1 had recently received the subject Design Change SS-01. Since the District

.i,, g e[ [ is completing this modification before the Tech Space can be approved by Ntt, I . ( 1 called Tee as a final chec.k that we are doing the process correctly. Tom w

is the Division' ef 1.icanains contact who has been at all NBC workshepe se h ,

f this subject.

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N 1. Tom cautioned the District that edsing halos could be the vrees approach

_if_ the SER specifies oprinklers. I read him the SER ancorpts free the LH the MC which state " automatic suppression and detection" will be added.

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Tom agreed that halon la acceptable. A plant recently set in trouble

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34 when'they chansed frce a sprinkler ayetas te a local C03 eyates on their own ignorins their Sta.

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2. I expressed our concern with the words in 10CFR50.59 that imply we miaht

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I need prior NRC approval in the fors of a Tech Spec change before addina the erstem. Too pointed out, an interestina twist which is that we are

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- doing this under 50.48. and 50.59 does not apply. 50.59 addresses "channes hY l I es described in the FEAR" and our fire protection,protras is not described v.

jf. in the PSAR as yet.

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g. . The Commission has issued the enclosed Eampt$ons free certata raments lear -

w .. af Sectica 90.48 and Appendia R to 10 CPR Part 50 for the Cooper

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y3 Statten. Tkts act%on respeeds to your mgeset dated June 8S.1982, as 3d.k supplemented with addittomal taftreatica provided os plarch 18.19 E_g,c, . @ume 1,1983.of Secties 111.8 of Appsadia R for the ype

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4. Reetter 11 dias, northeast Corner Itoen i

3M r 5. Control tutidtag tasseant

6. . 6. Amatitary Relay toes

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Sj3.', 8. Fire Area toendaries-Pour Areas m -l

a. heetter On11 ding 981' Devation . Critical swttchgear toons

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b. Reactor Building 931' Deration.

c. Rasetor Sof1 ding 903' Devatica (meludtag northeast normer). i

'p d. Reester teilding 889' and 881' Devations . quadreets and tores area.

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j* Based on our oraluattoa as flad that the level of protection currently provided to opajunctica with the proposed undtfications provides a level of fire protection equivaleet to the tachatcal rogstrements of section 111.8

"[o.. of Appsadia R. Therefers the enemptions requestad should be granted.

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. ,: , Page 2 of 3 f' The licensee roguests esemptions fram Section !!!.A. of Appendia R 19

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- within seven plant fire areas and a general anoption for four specific l' areas from the requirements of Section !!!.8. to the entent that it reeutres j' three-hove fire rated boundaries for the separation of fire areas. In all areas evaluated for exemption, we have assumed a transient fire 1eed typical 4 of these. type areas. If the licensee should introduce extraordinary i

(.- transient fire leads, appropriate supplementary fire protection maasures l entst be taken.

, 1. Service Water Intaka structure u s In the service unter intake strweture, the licensee proceses to

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. provide autentic suppression and detection, however, the separation of redundant pumps is less than twenty feet as specified by

' ), ' %ction !!!.6. The diesel driven fire pump will be removed from o the ares and all cables are it conduit. Therefore,the only O

.'r significant in-site combustiele in the fire area is the pump motor P9 lubricattag oil. The 11ceasse has stated that the probability of

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.'s O ignition of the oil is low because the lubricating ett has a high y flashpoint (appsimetely 450*F) and that sufficiently hot surfaces do avt exist la this fire area to cause the ignition of the lobe oil. l S

We have reviewed the licensee's submittals and agree that the low (

probability of ignittom of the lobe ett in conjenetton with the y

S- esisting separation distance provides reasonable assurance that the proposed astomatic detection and suppression systems will be j

activated before the ro6sadant service water consenents are deseged.

Therefore, we conclude that with the proposed sodifications, the O  % ., i

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_yrp . level of safety provided in the service water intake structure 6r dw will be equivalent to the techincal reevirements of Section !!!.0

-J./ of Appendia t and theMfore. the licensee's Mwest sMule he gn-W m:t '

h 2. Cable Spreading hoos .

E This area does att meet Section !!!.8 because tunaty feet of 4 separation free of intervening combustibles or one-hour barriers

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are not provided between redundant trains. Because of the 1 physical configurettom of the cables and equipment in the cable

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spreading ecos. the insta11 sties of a one-hour r,ated fire barrier any be difficult. lasteed the liceasse has proposed

(( the use of fire resistieg barriers to enclose vertical caale h~,

a tisers, and meditions) estomatic sprinklers for the protection B/_

x: of horizestal cables. the majority of which are rested la steel W.. conduits and are at the ceiling level. There are also severs)

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p.- cable trays is the area. As esposere Mrs is therehre most liket 389 to levolve floor level coobustibles.

.O tened as our ITrieu of the licensee's submittals, we have deterair r

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9 that the combinettom of vertical fire barriers. addittomal sprinki f

f, head coverage, and complete aetcantic soppressica and detection y provide resseseble asseresse that one train of peuer cables in the y

g cable spreading reon will to estatatand free of fire desape.

Therefore, we conclude that the proposed sodifications with the h

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1. ' aristing Mrs protection he the table spreedtag race previces a L level of fire protetties equivalent to the technical requirements 4

of Sect 10e !!!.8 ef Appendia t and the esemption should be greatec J

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