2CAN088302, Application for Amend to License NPF-6,deleting or Modifying Fire protection-related License Conditions Imposed in Sept 1978 to Eliminate Confusion Between License & App R Requirements

Application for Amend to License NPF-6,deleting or Modifying Fire protection-related License Conditions Imposed in Sept 1978 to Eliminate Confusion Between License & App R Requirements

ML20080B461
Person / Time
Site:	Arkansas Nuclear
Issue date:	08/01/1983
From:	Jeffery Griffin ARKANSAS POWER & LIGHT CO.
To:	Clark R Office of Nuclear Reactor Regulation
References
2CAN088302, 2CAN88302, NUDOCS 8308050509
Download: ML20080B461 (11)

Text

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N ARKANSAS POWER & LIGHT COMPANY FIRST NATIONAL BUILDING /P.O. BOX 551/LITTLE ROCK. ARKANSAS 72203/(5011 371-7901 August 1, 1983 JOHN M. GRIFFIN Vice President Nuclear Operations l

2CAN088302 Director of Nuclear Reactor Regulation ATTN: Mr. Robert A. Clark, Chief Operating Reactors Branch #3 Division of Licensing U. S. Nuclear Regulatory Commission Washington, DC 20555

SUBJECT:

Arkansas Nuclear One - Unit 2 Docket No. 50-368 License No. NPF-6 Proposed License Amendment Concerning Fire Protection Gentlemen:

Please refer to your letter (2CNA068302) dated June 21, 1983, to Mr. John M.

Griffin, which transmitted requests for our responses to various "open" items related to fire protection at ANO-2. In that letter, you requested we submit an application to delete or modify the fire protection related license conditions which were imposed in September 1978. Our June 30, 1983, letter (2CAN068313) to you stated we would provide you with both formal responses to your requests and schedular information concerning the planned resolution of those items by July 30, 1983.

The following information and proposed amendment to the ANO-2 Facility Operating License is provided for ycur review; and approval. This amendment is desired in order to eliminate continuing confusion and conflict between the License and requirements per 10CFR50 Appendix R.

In accordance with 10CFR50.92(c), we have determined the proposed amendment as having No Significant Hazards Considerations (NSHC), and, to satisfy the Sholly provisions, we are including the basis of our NSHC determination as part of this amendment package. Also, a copy of this amendment package has been sent to Mr. E. Frank Wilson, Director, Division of Environmental Health Protection, Arkansas State Department of Health. The circumstances of this proposed amendment are neither exigent nor emergency; however, expeditious handling is requested.

8308050509 330801 f

$DRADOCK05000 99y MEMBER MIDDLE SOUTH UTILITIES GYSTEM

\.

Mr. Robsrt A. Clark August 1,-1983 Pursuant to the requirements-of 10CFR170.22, we have determined this amendment request to require a Class II fee of $1,200.00, as it primarily involves an issue of administrative significance. Accordingly, a check ~in the amount of $1,200.00 is remitted.

Very truly yours, NN A John M. Griff JMG:DLL: rd Attachment I

i

. o STATE OF ARKANSAS )

) SS COUNTY OF PULASKI )

I, John M. Griffin, being duly sworn, subscribe to and say that I am Vice President, Nuclear Operations for Arkansas Power & Light Company; that I have full authority to execute this oath; that I have read the document numbered 2CAN088302 and know the contents thereof; and that to the best of  !

my knowledge, information and belief the statements in it are true.

< 77 $  :

John M. Gri SUBSCRIBED AND SWORN T0 before me, a Notary Public in and for the CountyandStateabovenamed,this/ day of /,M ,

d 1983.

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Notary Public f'

My Commission Expires:

CS!ES

CURRENT FACILITY OPERATING LICENSE

2. C. (3) (b) Fire Protection Arkansas Power and Light Company shall maintain in effect and fully implement all provisions of the approved fire protection program. The approved fire protection program consists of the licensee's documents as follows:

Date Document Final Safety Analysis Report Section 9.5.1 through Amendment 47 dated June 16, 1978 May 17, 1977 Letter submitting a comparison of the ANO-2 Fire Protection Program to Branch Technical Position 9.5-1.

August 30, 1977 Letter transmitting the Fire Hazards Analysis and responses to staff questions. '

September 21, Letter transmitting responses to staff 1977 questions and positions.

October 26, 1977 Letter transmitting Fire Hazards Analysis Information and responses to staff questions and positions.

February 3,1978 Letter transmitting Fire Hazards Analysis Information February 28, Letter transmitting Administrative 1978 Controls information.

March 31, 1978 Letter transmitting responses to staff questions.

April 12, 1978 Letter transmitting responses to staff questions and positions.

April 17, 1978 Letter transmitting responses to staff questions and positions.

April 26, 1978 Letter transmitting responses to staff questions snd positions.

June 8, 1978 Letter transmitting affidavit for previously docketed letters.

June 13, 1978 Letter transmitting Administrative Controls information.

June 15, 1978 Letter transmitting Administrative Controls information.

June 29, 1978 Letter transmitting Administrative Control information.

July 7, 1978 Letter transmitting affidavit for previously docketed letters.

July 7, 1978 Letter transmitting Administrative Controls information.

July 13, 1978 Letter transmitting affidavit for previously docketed letters.

(c) Less Than Four neactor Coolant Pump Operation The licensee shall not operate the reactor in operational Modes 1 and 2 with fewer than four reactor coolant pumps in operation, except as allowed by Special Test Exception 3.10.3 of the facility Technical Specifications.

(d) " Instrument Trip Setpoints Drift Allowance" was deleted.

(e) Fire Protection The licensee shall complete the following modifications by the indicated dates in accordance with the staff's findings as set forth in the fire protection evaluation report, NUREC-0223 " Fire Protection Safety Evaluation Report."

Implementation Dates for Proposed Modifications Applicable Section of NUREG-0223 Date 3.1 Portable Radio Communication Equipment March 31, 1979 3.2 Separation of Power Cables in Manholes

• 3.3 Protection from Water Spray

• 3.4 Protection of Redundant Cables in the MCC Room (2096-M) December 30, 1978 3.5 Protection of Redundant Cables in the Hallway - Elevation 372 (2109-U) * , **

3.6 Protection of Redundant Cables in the Cable Spreading Room (2098-L)

• 3.7 Protection of Redundant Cables in the Switchgear Room (2100-Z)

• 3.8 Protection of Redundant Cables in the Electrical Equipment Room (2091-BB) September 30, 1978 3.9 Protection of Redundant Cables in the Lower South Electrical Penetration Room (2111-T) September 30, 1978 3.10 Protection of Safe Shutdown Cables in the Upper South Piping Penetration Room (2084-00) September 30, 1978 3.11 Protection of Redundant Reactor Protection System Cables (2136-I) * , **

3.12 Fire Dampers September 30, 1978 3.13 Portable Extinguisher for the Control Room (2199-J) November 15, 1978 3.14 Smoke Detectors * , **

3.15 Manual Hose Stations (2055-JJ, 2084-DD, Containment, Elev. 317' of Auxiliary Building * **

3.16 Portable Smoke Exhaust Equipment December 1, 1978 3.17 Emergency Lighting December 1, 1978 3.18 Reactor Coolant Pump 011 Collection System

• 3.19 Control of Fire Doors March 31, 1979 3.20 Administrative Control Changes December 1, 1978 (Numbers in parentheses refer to fire zone designations in the AP&L fire hazards analysis.)

• Prior to startup following the first regularly scheduled refueling outage.

• • Technical Specifications covering these items should be proposed not later than 90 days prior to implementation.

(f) " Overpressure Mitigating System" was deleted.

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(g) Verification of Transient Analysis Code The licensee shall complete tests to verify the use of the CESEC Code during the initial startup and power ascension testing program and submit the results for Commission review and approval.

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PROPOSED FACILITY OPERATING LICENSE (5) Pursuant to the Act and 10 CFR Parts 30 and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.

2. C. This amended license shall be deemed to contain and is subject to

, conditions specified in the following Commission regulations in 10 CFR Chapter I; Part 20, Section 30.34 of part 30, Section 40.41 of part 40, Sections 50.54 and 50.59 of Part 50, and Section 70.32 of Part 70; and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

s (1) Maximum Power Level The licensee is authorized to operate the facility at steady state reactor core power levels not in excess of 2815 megawatts thermal. Prior to attaining this power level the licensee shall comply with the conditions in Paragraph 2

2.C.(3).

(2) Technical Specifications The Technical Specifications contained in Appendices A &

Amendment l B, as revised through Amendment No. 39 are hereby

1. 39 l incorporated in the license. The licensee shall operate 1/7/82 l the facility in accordance with the Technical Specifications.

, (3) Additional Conditions The matters specified in the following conditions shall be completed to the satisfaction of the Commission within the stated time periods following the issuance of the license or within the operational restrictions indicated. The removal of these conditions shall be made by an amendment to the license supported by a favorable evaluation by the Commission.

(a) " Fuel Performance" was deleted.

(b) " Fire Protection" was deleted.

(c) Less Than Four Reactor Coolant Pump Operation The licensee shall not operate the reactor in operational Modes 1 and 2 with fewer than four reactor coolant pumps in operation, except as allowed by Special Test Exception 3.10.3 of the facility Technical Specifications.

(d) " Instrument Trip Setpoints Drift Allowance" was deleted.

(e) " Fire Protection" was deleted.

PROPOSED REVISION OF ANO-2 FACILITY OPERATING LICENSE PARAGRAPHS C.(3).(b) AND C.(3).(e)

BASIS FOR CHANGES AND EVALUATION OF EFFECT ON PLANT OPERATION FACILITY OPERATING LICENSE PARAGRAPH C.(3).(b). Fire Protection Paragraph C.(3).(b) of the ANO-2 Facility Operating License (FOL), which is entitled " Fire Protection," presently states AP&L will implement its approved fire protection program as contained in eighteen pieces of correspondence listed in the FOL. This paragraph of the license should be deleted, as 10CFR50.48 and 10CFR50 Appendix R require AP&L to implement a more rigorous fire protection program than the current license condition requires, and those regulations supersede the necessity for a License requirement.

The first item on the list contained in the FOL, Section 9.5-1 through Amendment 47 of the Final Safety Analysis Report, is no longer a valid reference, as 10CFR50.71 requires licensees to update their FSARs on at least an annual basis, in order to maintain that document as current. The particular reference to the Amendment 47 FSAR has been superseded, as the current FSAR is required to reflect fire protection features installed at ANO in accordance with the Fire Protection Safety Evaluation Report (SER) and 10CFR50 Appendix R.

The second item, a May 17, 1977, letter to NRC, was provided to the NRC to establish a comparison of ANO-2 to Branch Technical Position (BTP) 9.5-1.

Subsequent to submittal of that letter, the Fire Hazards Analysis was performed, the Fire Protection Safety Evaluation Report (SER) was issued, several modifications were completed, etc., all of which supersede this document, as it reflects the ANO-2 design as of M y 17, 1977. Thus, this item should be deleted from the License.

Items 3, 4, and 5, i.e., correspondence from AP&L to the NRC dated August 30, September 21, and October 26, 1977, transmitted information which was reiterated in the Fire Hazards Analysis transmittal dated February 3, 1978 (Item 6 in the FOL list). The Fire Hazards Analysis resulted in part to the establishment of the SER commitments which are reiterated in the License. Hence, items 3, 4, 5, and 6 should be deleted from the FOL, as they have been superseded by other requirements.

Items 8, 9, 10 and 11, i.e., letters from AP&L dated March 31, April 12, April 17, and April 26, 1978, provided information to the Staff which was later used in the formulation of the Fire Protection SER and in the development of the SER commitments contained in the License. These references should be deleted, as they have been superseded by the SER and by Appendix R as well.

Items 7, 13, 14, 15 and 17, which reference letters dated February 28, June 13, June 15, June 29, and July 7,1978, respectively, should be deleted from the License, as these letters transmitted information which was

incorporated into the approved Fire Protection Plan and ANO-2 plant procedures, the later of which are required both by the SER and by Appendix R.

Items 12, 16 and 18, i.e., letters dated June 8. July 7, and July 13, 1978, respectively, should be deleted from the License as they transmitted affidavits for previously docketed let.ers, and, as such, provided no additional fire protection information to the Staff.

In order to reflect current regulatory commitments regarding fire protection, ANO-2 Facility Operating License Paragraph C.(3).(b) should be deleted as AP&L is required to implement its approved fire protection program in accordance with 10CFR50.48 and 10CFR50 Appendix R.

FACILITY OPERATING LICENSE PARAGRAPH C.(3).(e) Fire Protection Paragraph C.(3).(e) of the ANO-2 Facility Operating License (FOL), also entitled " Fire Protection," presently states AP&L shall complete modifications associated with the Fire Protection SER, NUREG-0223. This paragraph of the License should be deleted for the reasons previously stated, i.e. because 10CFR50.48 and 10CFR50 Appendix R require AP&L to implement a more rigorous fire protection program consistent with those regulations.

During the period June 21-25, 1982, Messrs. J. P. Jaudon and M. E. Murphy of the NRC Region IV Staff inspected ANO-2 (and ANO-1) in order to evaluate modifications resulting from the Fire Protection SER. A total of 20 items were identified in that document as requiring modification, and these items are listed in the License along with their original schedule for completion.

Some of the SER items were not completed at the time of the inspection, but violations for overdue items were not issued because the ANO NRC Licensing Project Managers had determined that the incorporation of Appendix R to 10CFR50 on February 17, 1981, superseded the SER schedules incorporated into the licenses of Units 1 and 2, as referenced in Inspection Reports 50-313/82-15 and 50-368/82-12, dated August 6, 1982 (0CNA088203).

As a result of the above mentioned inspection, the majority of the SER items were either closed by the Inspection Report, or else were judged to meet the modifications required by the Safety Evaluation Report and were subsequently being further evaluated under the criteria imposed by Appendix R. Some of the items were soley judged to require such additional review by AP&L, as some SER modifications, such as those requiring the installation of fire retardant boards, blankets, or cable coatings, are no longer acceptable under that regulation. SER items required to be maintained in association with Appendix R have been, and will continue to be, of course, maintained.

The inspectors acknowledged Appendix R requirements may have replaced and added to the requirements of the original SER. Those modifications which are no longer valid under 10CFR50 Appendix R should not be required to be maintained or completed unless associated with our July 1,1982 (0CAN078202), submittal. As our Appendix R Fire Protection program is currently being implemented, it is appropriate the License be amended to reflect that program.

No Significant Hazards Consideration The proposed amendment request does not involve a No Significant Hazards Consideration (NSHC) because:

a. operation of ANO-2 in accordance with this change would not involve a significant reduction in a margin of safety, nor involve a significant increase in the probability or consequences of a previously evaluated accident, nor introduce the possibility of a previously unanalyzed accident; and

b. the proposed amendment matches the example shown below:

(ref: 010P 28, Federal Register, Vol. 48, p. 14,870)

(vii) A change to make a license conform to changes in the regulations, where the license change results in very minor changes to facility operations clearly in keeping with the regulations.

Basis: The proposed amendment to the ANO-2 Facility Operating License allows AP&L to implement a fire protection program which reflects current regulatory requirements as instituted by 10CFR50.48 and 10CFR50 Appendix R, and as constituted in AP&L's submittals concerning the compliance of ANO-2 with those regulations.