ML17324A630

Application for Amends to Licenses DPR-58 & DPR-74,changing Tech Specs to Provide Hourly Fire Watch Patrols Instead of Continuous Watches When Limiting Condition for Operation Not Met. Hourly Defined as Plus/Minus 15 Minutes.Fee Paid

ML17324A630
Person / Time
Site:	Cook
Issue date:	02/20/1986
From:	Alexich M INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG
To:	Harold Denton Office of Nuclear Reactor Regulation
Shared Package
ML17324A631	List: ML17324A630 ML17324A632
References
AEP:NRC:0960A, AEP:NRC:960A, NUDOCS 8602260104
Download: ML17324A630 (10)

Text

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'DOCKET, 0 FACIAL: 50-315 Donald C. Cook Nuclear Power Plant> Unit 1> Indiana 8c 05000315 50-316 Donald C. Cook Nuclear Power Plant> Unit 2> Indiana 5 05000316 AUTH. NAME AUTHOR AFFILIATION

• LEXICH>M. P, Indiana 5 Michigan Electric Co.

RECIP. NAME RECIPIENT AFFILIATION DENTON> H. R. Of fice of Nuclear Reactor'egulation> Director (post 851125

SUBJECT:

Application for amends to Licenses DPR-58 DPR-74> changing 8c Tech Specs to provide hourly fire'watch patrols instead of continuous watches when limiting condition for operation not met. "Hourlg" defined as plus/minus 15 minutes. Fee paid.

DISTRIBUTION CODE; A006D COPIES RECEIVED: LTR ENCL SIZE:

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TITLE: OR Submittal: Fire Protection NOTES:

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INDIANA 8 NICHIGAN ELECTRIC CONPANY P.O. BOX 16631 COLUMBUS, OHIO 43216 February 20, 1986 AEP:NRC:0960A Donald C. Cook Nuclear Plant Unit Nos. 1 and 2 Docket Nos. 50-315 and 50-316 License Nos. DPR-58 and DPR-74 FIRE WATCH TECHNICAL SPECIFICATIONS CHANGE REQUEST Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555

Dear Mr. Denton:

This letter and its attachments constitute an application for amendment to the Technical Specifications (T/Ss) for the Donald C. Cook Nuclear Plant Unit Nos. 1 and 2. Pursuant to discussions with your staff on this matter in a meeting on November 14, 1985, we would like to change the standing fire watches required by the Action Statements of T/S Section 3.7 to hourly fire watch patrols. The reasons for the proposed changes and our analyses concerning significant hazards considerations are contained in Attachment 1 to this letter. The proposed revised Technical Specification pages are contained in Attachment 2.

We believe that the proposed changes will not result in (1) a significant change in the type of effluents or a significant increase in the amounts of any effluent that may be released offsite, or (2) a significant increase in individual~ or cumulative occupational radiation exposure.

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

In compliance with the requirements of 10 CFR 50.91(b)(1), copies of this letter and its attachments have been transmitted to Mr. R. C. Callen of the Michigan Public Service Commission and Mr. G. Bruchmann of the Michigan Department of Public Health.

Pursuant to 10 CFR 170.12(c), we have enclosed an application fee of

$ 150.00 for the proposed amendments.

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AEP:NRC:0960A This document has been prepared following Corporate procedures which incorporate a reason'able set of controls to insure its accuracy and completeness prior to signature by the undersigned.

Very truly yours, M. P. Alexich Vice Presid t Attachments cc: John E. Dolan W. G. Smith, Jr. - Bridgman R. C. Callen G. Charnoff G. Bruchmann NRC Resident Inspector - Bridgman

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ATTACHMENT 1 TO AEP:NRC:0960A REASONS AND 10 CFR 50.92 ANALYSES FOR CHANGES TO THE DONALD C. COOK NUCLEAR PLANT UNIT NOS. 1 AND 2 TECHNICAL SPECIFICATIONS

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Attachment 1 to AEP:NRC:0960A The Action Statements and Bases for T/Ss 3.7.9.2, 3.7.9.3, 3.7.9.4, and 3.7.10 currently require continuous fire watches when the Limiting Condition for Operation (LCO) is not met. We request that these continuous fire watches be changed to hourly fire watch patrols. We believe that the hourly fire watch patrol will adequately ensure timely fire detection. We also request that a statement be added to the fire protection Bases that defines an hourly fire watch patrol interval to be one hour plus or minus fifteen minutes.

This change is being requested because of the large administrative burden on the plant management required to maintain personnel to serve as fixe watches. The effort required to 'administer fire watch personnel diverts management's attention away from 'other duties which could have much greater safety significance. The job of a standing fire watch is a boring, tedious task. This introduces problems with concentration and alertness and creates adverse human factors considerations which negate any additional safety benefit that a standing watch might have over an hourly patrol. In conclusion, we believe that the continuous fire watches are counterproductive from a human factors standpoint and that they should be replaced by hourly fire watch patrols.

In addition we request that the Action Statement for T/S 3.7.10, Fire Rated Assemblies, be changed to the followings "With one or more of the above required fire rated assemblies and/or sealing devices inoperable, within one hour restore the inoperable assemblies and/or sealing devices to OPERABLE status or establish an hourly fire watch on at least one side of the inoperable assemblies and/or sealing devices or verify the OPERABILITY of fire detectors per Specifications 4.3.3.7.1 and 4.3.3.7.2 (4.3.3.8.1 and 4.3.3.8.2 for Unit 2) on at least one side of the inoperable assemblies and/or sealing devices'. Restore the inoperable fire rated assemblies and sealing devices to OPERABLE status within 7 days or, in lieu of any other report required by Specification 6.9.1, prepare and submit a Special Report to the Commission pursuant to Specification 6.9.2 within the next 30 days outlining the action taken, the cause of the inoperable fire rated assemblies and/or sealing devices and the plans and schedule for restoring the fire rated assemblies and/or sealing devices to OPERABLE status."

Also, a statement would be added to the Bases for T/S 3.7.10 which would indicate that an operable fire rated assembly/sealing device is one that is capable of performing its intended safety function.

This new Action will eliminate several of what we believe are redundant requirements. For example, believe that either establishing a if a fire door is inoperable, we fire watch or determining that detectors are operable is adequate to ensure safety.

to A NRC:0960A, Page 2 Another statement that is added to the Bases for T/S 3.7.10 reflects our belief that a fire rated'assembly and/or sealing device that is secured in the closed position is operable provided that it is capable of performing its intended safety function. For example, if a fire door is inoperable due to an inadequate closing device, securing the door in the closed position restores the door to operable status. If, however, the fire door were inoperable because it had a hole in it, it would not be operable if secured in the closed position (because it would not perform its intended safety function) and another Action would have to be taken.

Although these changes may result in some increase to the probability or consequences of a previously analyzed accident or may reduce in some way a safety margin, we believe that the results of the change would represent an overall enhancement to the safety of the plant. For this reason it is our belief that this change does not involve a significant hazards consideration as defined by 10 CFR 50.92.

In addition, the words "greater than or equal to" were used to replace the mathematical symbols in T/S 4.7.9. 3 and 4.7. 9. 4. Also re ferences in the Action for T/S 3.7.9.3 were changed to more accurately reflect the intended specification. In Specification 4.7.10.1 the word "assemblies" was changed to "assembly" for grammatical reasons. These changes are editorial and thus administrative in nature. Therefore we do not believe that these changes involve a significant hazards consideration as defined by 10 CFR 50.92.