ML041400115
| ML041400115 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 05/14/2004 |
| From: | NRC/OCIO |
| To: | |
| References | |
| FOIA/PA-2003-0358 | |
| Download: ML041400115 (8) | |
Text
PCHG-DESG Engineering Change J. 50.59 Screen/Evaluation Identification No: 02-065 Revislon No: o Page 1 of 8a Attachment 1 Screen Plant Applicability O ENP 3 CR3 El HNP 0 RNP Implementing Document No. Revishon No: ° Imp~lemnenting Acrivity Desr~in This activity imodfe th Bor an _h ~ ~ ont
_1 The tlNP Fire Protectlon Program Uicensing basis Is described in the Operating i~cense lfOL) NP>F-63, Sectlon 2.F, Fire Protection Prograrn, which states:
Varoiina Power and Ught shal Implement and maintain In effect all provisions of the approved tire protection program as described Inthe Final Safety Analysis Report for the facility and as approved In the Safety Evaluation Report (SER) dated November 1983 (and supplements 1 through 4), and the Safety Evaluation dated January 12, 1987, subject to the following provision below.
The ihcensees may make changes to the approved fire protection program without prior approval of the Commission only ifthose changes would rot adversely affect the ability to achIeve and maintain safe shutdown Inthe event -of a fire.
The Code of Federal RegulatIon, 10 CFR 50.59 Changes, Tests and Experiments, was recently revised. To reduce duplication of effort, 10CFR5O.59(c)(4) specifically excludes from the scope of 10 CFR 60.59 changes to the facillty or procedures that are controlled by more specific requirements and criteria that are established by other regulations. Fire Protection Is specifically mentioned as one of the areaexciuded from the 10 CFR 50.59 scope. The basis for the exclusion of fire protection from 10 CFR 50.59 Is the fact that fire protection program changes are made Inaccordance with the ilcense conditions and procedures that control changes to the program.
These conditions allow changes to the program plan that do not adversely affect post-fire safe shutdown capability.
The revised 10 CFR 50.59 regulatory requirements have been adopted by Progress Energy and are currently implemented InProcedure REG-NGGC-0010, IOCFRS5.59 Reviews. Accordingly, 1he changes shall be documented in accordance with Procedure REG-NGGCOO10 and the Fire ProtectIon Review ChecklisL Based on the review of the NUREG-0800 fire protection and safe shutdown requirements and darifications of Generic Letter 81-12, it has been concluded p oed ee pertaining to the creation of a new plant es .
fire area (FIre Area 1-A.ACP) separate from th and the revised HNP 6SD Analysis Calculation E-5525 to support the revised plant Ig t t adversely affect the ability to achieve and maintain sale shutdown Inthe event ol a fire as described and the proposed changes can be made without prior NRC approval. However, this modification Is made to resolve an NRC violatIon and therefore ItIs submitted lo the NRC for review and concurrence prior to EC closure (Ref. NRC Letter EA-D-022, Final r Page 1of8, 2.a;,,V
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PCHG-DESG Engineering Change EOW,,7--
Significance Delermination for a White Finding and Notice of Vlolatloh Shearon Harris Nuclear Power Plant - NRC Inspection Report 50-400100-09).
Identification No: 02-0695 Revision No: o Page 2 of 8 SECTION 1: Predetermination ia Is a change to the.Technical Specifications or Operating Yes No
.icense necessary to Implement the proposed activity? E Initiate a contnus to
.nchangeIn he next accordanc question wth applcable procedure and go toSectlon2 1b Is the proposed activity fully bounded by a previously Yes No completed screen or evaluation performed Inaccordance with 0 0 REG-NGGC-0010? Enter he Go t Refererce secton 2 Or belowandgoto section 4 Or 1c Has the proposed activity been formally approved by the NRC?
Reference:
50.59 Page2of8
1PCHG-DESG Engineering Change Identification No: 02-0695 l Revision No: 0o Page 3 of 8 Attachment I Screen SECTION 2: Applicability of Regulatory Processes Other Than 10 CFR 50.59 Address the questions below for all aspects of the activity. If the answer is "Yes for any portion of the activity, complete the associated attachment (e.g. Question 3 and Attachment 3). Note that it Is not unusual to have more than one process apply to a given activity.
I Yes No 2 Does the proposed activity Involve a change to the Emergency D Plan or an Emergency Plan Implementing procedure needed to comply with the requirements of 10 CFR 50 Appendix E?
(Attachment 2) 3 Does the proposed activity Involve a change to the Security Plan, D the Safeguards.Contlngency Plan or the Security Personnel Training and Qualification Plan? (Attachment 3) 4 Does the proposed activity Involve a change to the Quality ;
. Assurance Program Description? (Attachment 4) 5 Does the proposed activity Involve a change to the Fire 0 D Protection Program? (Attachment 5) 6 Does the proposed activity Involve a change to the licensed D operator requalification program? (Attachment 6) 7 Does the proposed activity involve a change In thermal or a chemical effluents, Involve a change to the Enivironmental Protection Plan, or Involve a significant change to land use that could impact the environment? (Attachment 7) 8 Does the proposed activity Involve a change to the Emergency D Response Data System? (Attachment 8) 9 [RNP Only - A response to this question Is not to be a3 provided by Evaluators at BNP, CR3, and HNPJ Does the Implementing activity affect the ISFSI? (Attachment 9)
Are all aspects of the activity controlled by one or more of the D Regulatory Processes Identified Inquestion 1a and questions 2 Complee te Compete Ith through 9 above? required required attachments attacents and go b and SectIon 4 go to Section 3 50.59 Page 3of8
PCHG-DESG Engineering Change *1' Si Identification No: 02a069s Revision No: o Page 4 of 8 Attachment 1 Screen SECTION 310 CFR 50.59 Screen Yes No 1Oa Does the proposed activity Involve a change to an SSC D O that adversely affects any FSAR-described design function?
1ob Does the proposed activity Involve a change to a .
procedure that adversely affects how any FSAR-described SSC design functions are performed or controlled?
loc Does the proposed activity Involve revising or replacing D any FSAR-described evaluation methodology that is used In establishing the design bases or used In the safety analyses?
10d Does the proposed activity Involve a test or experiment not D O described In the FSAR, where an SSC is utilized or controlled In a manner that Is outside the reference bounds of the design for that SSC or is Inconsistent with analyses or descriptions in the FSAR?
Are any of these questions (1Oa, 1Ob, IOc, or 1Od) answered completi Vd Enter
'Yes?" ata Justificaton art Attachmert 10 References end ob below Secton 4 and go I Section 4 Justification:
Changes addressed under Attachment 5, Fire Protection Program.
References:
See Attachment 5 50.59 Page 4 of B
A PCHG-DMESG Engineering Change a Z--
Identification No: 02-0695 l Revision No: 0 Page 5 of 8 Attachment 1 Screen SECTION 4: Signatures and Distribution Evaluator: F-Chrls Georgesonm (PrInVSign) Date: 6 17/02 Reviewer: [V'nod Purl (Print/Slgn) Date: 7117102 Supervisor: EjRonVemer (Print/Sign) Date:
Additional Reviews (ifrequired)
Reviewer. K David McAfee_ (Pant/Sign) Date: 7/17/02 Reviewer. i rMiIke Fletcher3 (Pint/Sign) Date: 7/1602 Reviewer NIA (PaintSign) Date: NIA 50.59 Page 5 of 8
PCHG-DESG E nglneering Change Identification No: 02-0695 Revision No: 0 Page 6 of 8 Attachment 5 Fire Protection Program Screening Evaluation Plant Appilcability: .0 BNP O CR3 i HNP 03 RNP Implementing Document No: Revision No: a
- 1. Will the proposed activity adversely affect the ablity to achieve and maintain. YES NO safe shutdown In the event of a fire, Including, but not imited to; required sate 0 shutdown equipment, communications equipment, and emergency ighting?
Justification and references:
ThMe amAtu rsoliveas an NRCOMolatlon concemina a 40% dearadatlon of the T-La fir tj.A.' Y I 0
50.59 Page 6 of 8
A PCHG-DESG Engineering Change
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% W uni u ubuu becuson V.0.1 or July Mt1,11ii uenerw Letner 8i-i2 and clarifications NRC Letter -E , Final Significance Determination for a Whit ri Notice of Violation nd Shearon Harris Nuclear Power Plant - NRC Inspection Report 50-400/0-O) 1 i OP-036
- 2. Will the proposed activity adversely affect the Fire Protection Program or fire YES NO prevention measures, Including but not limited to; control and extinguishment, C 03 separation, lre barriers, curbs and drains, control of ignition sources and combustible loading, fire fighting capability, or post-fire shutdown operations?
Justificatlon and references:
The Fire Protection Program and fire prevention measures, Including but not Eit ontrol and
& ;~kLa.L 2161A.
extinguIshment, separation, fire barriers, curbs and drains, control of Ignition s ces and combustible loadl fighting capability, or post-fire shutdown operations are strengthened by this a tiviy because a new o sled concrete and penetration seal fire barrier Is installed to sub-divide a previous i
- rMMS n caixwn aoes not charin or iupaui undalllu mud deimaulon tyubIiji I" UuJ areas U hIU Uanore are no "i8aed fire suppression systems. Access to and locations of hose stations and fire extinguishers are not changed. All modified penetration seals, fre dampers, and doors have been added to the fire protection program.
This activity also specifies a new safe shutdown strategy and an electrical sale shutdown analysis for the new fire area. Fire fighting guidance for the new fire area is also provided through a revised pre-fire plan.
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R eterences II SSA (Calculation~s NURa ection 9.5.1 of July 1981. NRC Generic Letter B1-12 End clarificatlons, IQRC Letter EA- 22, Final Significance Determinatlon for a Wd d Notice of Violation (Shearon Harrs Nuclear Power Plant- NRC Inspection Reporl 50-400/00-09) AbP-036 50.59 Page 7 of 8
PCHG-DESG Engineering Change k I
i Identification No: 02-0695 J Revision No: 0 Page 8 of 8...
iUthe proposed activity adversely affects the ability to achieve and maintain safe shutdown In the event of a lire, PNSC review [BNP, CR3, HNPJ and NRC approvals are required prior to Implementatlon.
Evaluator: 'CChris Georoeson (SSAi (PrInVSign) Date: 6/17/02 Evaluator. iPIke Fletcher (FP1 (Print/Sign) Date: 7/16/02 Reviewer. (Davld McAfee:~ (Print/Sign) Date. -717/02 50.59 Page 8 of 8
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