ML17319B671

Requests Change to 820802 Application for Amend to Licenses DPR-58 & DPR-74,consisting of Proposed Changes to Tech Spec 3.7.9.3 Re Fire Protection Sys

ML17319B671
Person / Time
Site:	Cook
Issue date:	11/23/1982
From:	Hunter R INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG
To:	Harold Denton Office of Nuclear Reactor Regulation
Shared Package
ML17319B672	List: ML17319B671 ML17319B673
References
AEP:NRC:0660F, AEP:NRC:660F, NUDOCS 8211300216
Download: ML17319B671 (12)

Text

REGULA Y INFORMATI N DISTR I BUT IO Y STEM (BIDS)

ACCESSION NBR:8211300216 DOC ~ DATE: 2/11/23 NOTARIZED: NO DOCKET FACIL:50 "315 Donald C. Cook Nuclear power PlantP Unit 1E Indiana It 05000315 50-316 Donald CD Cook Nuclear Power Planti Unit 2P Indiana 3 05000316 AUTH'AME AUTHOR AFFILIl(TION MUNTERER ~ ST Indiana 8 Michigan Electric Co, REC IP ~ NAME RECIPIENT AFFILIATION DENTONgM ~ Rs Office of Nuclear Reactor Regulationg Director

SUBJECT:

Requests change to 820802 application for amend to License DPR-58 8 DPR 74iconsisting of proposed changes to Tech Specs 3.7.9.3 re fire, protection sys.

DISTRIBUTION CODE: $ 0060 COPIES RECEIVED:LTR i ENCL 3 SIZE:.

TITLE: OR Submittal: Fire Protection NOTES:

RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAHE LTTR ENCL NRR ORBi BC 01 3 3 INTERKAL: ELD/HDS3 1 0 IE FILE 06 1 1 NRR FIORAVANT07 2 2 NRR NAMBACH 1 0 CEB 09 2 2 NRR/DL D IR 1 1 F IL 04 1 RGN3 1 1 EXTERh,AL: ACRS 11 3 3 LPDR 03 2 2 i

NRC PDR 02 1 1 NSIC 05 1 1 NTIS 1 TOTAL NUMBER OF COPIES REQUIRED: LTTR 21 ENCL 19

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INDIANA 5 MICHIGAN ELECTRIC COMPANY P. O. BOX 18 BOWLING GREEN STATION NEW YORK, N. Y. 10004 November 23, 1982 AEP:NRC: 0660F Donald C. Cook Nuclear Plant Units Nos. 1 and 2 Docket Nos. 50-315 and 50-316 License Nos. DPR-58 and DPR-74 TECHNICAL SPECIFICATION CHANGE REQUEST - FIRE PROTECTION Mr. Harold R. Denton, Director.

Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D. C. 20555

Reference:

AEP Letter AEP:NRC:0660D dated August 2, 1982

Dear Mr. Denton:

This letter and its Attachments request a change to Technical Specification (T/S) 3.7.9.3 of the Donald C. Cook Nuclear Plant Units Nos. l and 2 which amends the previous changes requested for the same T/S in the Reference letter.

Attachment No. 1 to this letter contains the justification for the proposed Technical Specification change for both Unit Nos. 1 and 2.

Attachment No. 2 to this letter contains the revised T/S pages. It should be noted that the attached amended pages reflect the changes proposed in this letter, as well as those changes previously proposed in the reference letter. All changes are indicated by vertical bars drawn on the right hand margin of the page.

These proposed changes have been reviewed and approved by the Plant Nuclear Safety Review Committee (PNSRC) .and will be reviewed by the AEPSC Nuclear Safety and Design Review Committee at. their next meeting.

We request that you process this letter in as expeditious a manner as possible for the reasons indicated in Attachment 1, We interpret that the fee transmitted with the Reference covers the processing of this request.

82ii300216 82ii23 PDR ADOCK 05000315 P , . PDR

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Mr. Harold R. Denton AEP: NRC: 0660F This document has been prepared following Corporate Procedures which incorporate a reasonable set of controls to insure its accuracy and completeness prior to signature by the undersigned.

Very truly yours, R. S. Hunter Vice President RSH/sag cc: John E. Dolan - Columbus M. P. Alexich R. W. Jurgensen W. G. Smith, Jr. - Bridgman R. C. Callen G. Charnoff Joe Williams, Jr.

NRC Resident Inspector at, Cook Plant - Bridgman

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ATTACHMENT 1 TO AEP:NRC:0660F DONALD C. COOK NUCLEAR PLANT UNIT NOS. 1 AND 2 JUSTIFICATION FOR PROPOSED TECHNICAL SPECIFICATIONS FIRE PROTECTION SYSTEM

Technical S ecification 3.7.9.3 for Both Unit Nos. 1 and 2.

i) The addition of Action Statement "a" will establish new operation requirements for whenever one or more of the low pressure CO systems are isolated for personnel protection. This also makes the previous Action.

Statement "a", Action Statement "b" and the previous Action Statement "b",

Action Statement "c". The proposed Action Statement "a" requires either the verification that the fire detection system is operable (as per Specification 4.3.3.7 for Unit 1, or as per Specification 4.3.3.8 for Unit 2), or the establishment of an hourly fire watch patrol whenever one or more low pressure CO 'systems are isolated. This Statement will relieve us from the requirement of performing a continuous fire wretch under these conditions.

Presently, whenever a CO system is isolated to permit entry for tours, maintenance, construction, or surveillance testing, a continuous fire watch is posted in each affected fire zone, This means that isolation of a C02 system serving several fire zones presently requires several fire watches; that is, one fire watch for each zone affected by C02 system isolation.

This requirement has resulted in a significant manpower expenditure, particularly when a C02 system serving multiple zones is temporarily isolated. For example, the present Technical Specification requires that four fire watches be posted in each. of the 4KV switchgear complexes, or five watches be posted in each reactor cable tunnel. when their respective automatic CO systems are temporarily isolated. Thus, to permit personnel access simultaneously to both 4KV complexes and both cable tunnels, .a total of eighteen (18) fire watches are required to support as few as four gob sites per shift. Besides imposing a significant personnel burden, this requirement is also creating safety problems. with regard to the accountability of the additional personnel required in each of these areas in the event of a fire or other emergency. By the addition of this Action Statement to our Technical Specifications, we will be eliminating the excessive amount of personnel in these areas, while still providing the necessary fire protection capabilities.

ii) Two changes. are being proposed here for Action Statement "b", which was formerly Action Statement "a". These changes can be described as follows:

A) The changing of the requirement to establish a continuous fire watch with backup fire suppression equipment whenever one or more of the low pressure CO systems listed in Table 3.7-6 is inoperable; to the requirement of establisfiing a continuous fire watch with backup fire suppression equipment to an area containing redundant safe shutdown systems or components whenever one or more of the low pressure CO systems listed in Table 3.7-6 is 2

inoperable. This proposed change was previously submitted in our letter AEP:NRC:0660D. As stated in that letter, approval of this proposed revision would remove unduly restrictive Action Statement which is not imposed on current Westinghouse plants.

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B) The second change proposed to Action Statement "b" is a revision to a statement previously proposed in our letter AEP:NRC:0660D.

Specifically, the change is the deletion of the statement "for other areas, establish an hourly fire watch"; and the insertion of the statement "for other areas ensure that backup fire suppression equip-ment is available and establish an hourly fire watch." The term "other areas" used in these statements refers to all the areas pro-agnew tected by one or more of the low pressure C02 systems listed in Table 3.7-6 which do not contain redundant safe shutdown systems or components. The insertion of the proposed statement is creating a and more restrictive requirement for us to perform than the one proposed. in our letter AEP:NRC:0660D. However, it still removes the unduly restrictive Action Statement of performing a continuous fire watch in areas where redundant safe shutdown systems or components do not exist.

ATTACHMENT 2 TO AEP:NRC:0660F DONALD C. COOK NUCLEAR PLANT UNIT NOS. 1 AND 2 PROPOSED TECHNICAL SPECIFICATION CHANGES PIRE PROTECTION SYSTEM

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