ML18152A197

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Informs That Util Completed Review & Hereby Request NRC Reinitiate Review of Proposed License Amend Request Re Relocation of Fire Protection Requirements,Per GLs 86-10 & 88-12
ML18152A197
Person / Time
Site: Surry  
Issue date: 09/12/1996
From: Ohanlon J
VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML18152A198 List:
References
96-104A, GL-86-10, GL-88-12, NUDOCS 9609180147
Download: ML18152A197 (28)
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. r VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 September 12, 1996 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555 Gentlemen:

VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNITS 1 AND 2 REINITIATING PREVIOUSLY SUBMITTED Serial No.

NL&OS/JBL Docket Nos.

License Nos.

PROPOSED LICENSE AMENDMENT REQUEST RELOCATION OF FIRE PROTECTION REQUIREMENTS 96-104A RS 50-280 50-281 DPR-32 DPR-37 By letter dated January 26, 1993, Virginia Electric and Power Company requested license amendments for Surry Power Station Units 1 and 2 to relocate the fire protection Technical Specifications to the Updated Final Safety Analysis Report (UFSAR) consistent with the guidance in Generic Letters 86-10 and 88-12. By letter dated April 23, 1996, we withdrew the license amendment request pending completion of a more detailed review and clarification of the fire protection licensing basis. We have now completed our review and hereby request the NRC to reinitiate t~e review of our proposed license amendment request.

Generic Letter 86-10, "Implementation of Fire Protection Requirements," and Generic Letter 88-12, "Removal of Fire Protection Requirements from Technical Specifications,"

provided guidance for a line-item improvement of Technical Specifications by allowing the fire protection program to be relocated to the plant's UFSAR. Generic Letter 86-10 requires that a license condition be added to the Facility Operating Licenses to directly reference the NRC Safety Evaluation Reports (SERs) associated with the plant's fire protection program. Although the proposed license condition would also note that changes to the fire protection program could be made without prior Commission approval provided the changes would not adversely affect the ability to achieve and maintain safe shutdown, compliance with the license condition would be defined by the detailed descriptions in the SERs. Upon further review of our fire protection SERs, we concluded that one of the SERs was unnecessarily specific and included detailed information about the fire protection program which was inappropriate as a license condition and direct measure for program compliance. provides summary descriptions of clarifications to the NRC's Fire Protection SER (FP-SER) for Surry Power Station, dated September 19, 1979. The purpose of this attachment is to clarify discrepancies and identify changes made to the

~-9609180147 960912 PDR* ADOCK 05000280 P

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Surry fire protection program since issuance of the NRC's FP-SER including those items which have been accepted by supplemental safety evaluation reports.

Virginia Electric and Power Company requests the NRC to reinitiate the review for approval of the previously submitted license amendment request with the clarifications to the NRC FP-SER as noted in Attachment 1. (A copy of the previously submitted license amendment is provided in Attachment 2 for your convenience.)

Up-to-date change pages for the Facility Operating Licenses and the Technical Specifications are provided as Attachment 3.

Should you have any questions or require additional information, please contact us.

Very truly yours,

~p~

James P. O'Hanlon Senior Vice President - Nuclear Attachments cc:

U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, N.W.

Suite 2900 Atlanta, Georgia 30323 Mr. M. W. Branch NRC Senior Resident Inspector Surry Power Station Commissioner Bureau of Radiological Health Room 104A 1500 East Main Street Richmond, Virginia 23219

l COMMONWEALTH OF VIRGINIA )

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COUNTY OF HENRICO

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  • The foregoing document was acknowledged before me, in and for the County and Commonwealth aforesaid, today by J. P. O'Hanlon, who is Senior Vice President -

Nuclear, of Virginia Electric and Power Company. He is duly authorized to execute and file the foregoing document in behalf of that Company, and the statements in the document are true to the best of his kno~l:ge and :,*

Acknowledged before me this /,4 "' day of **

1Jn6teJ, 19 CJt...

My Commission Expires: Aa:J' 3/

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Notary Public (SEAL)

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e ATTACHMENT 1 CLARIFICATION OF FIRE PROTECTION PROGRAM ITEMS FOR SURRY POWER STATION VIRGINIA ELECTRIC AND POWER COMPANY

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Background===

e ATTACHMENT 1 CLARIFICATION OF e

FIRE PROTECTION PROGRAM ITEMS FOR SURRY POWER STATION Following a fire at the Browns Ferry Nuclear Station in March 1975, the NRC initiated an evaluation of the need for improving the fire protection programs at all licensed nuclear power plants. As part of this evaluation, the NRC, in February 1976, published NUREG-0050, "Recommendations Related to Browns Ferry Fire."

This report recommended that improvements in the areas of fire prevention and fire control be made in most existing facilities and that consideration be given to design features that would _increase the ability of nuclear facilities to withstand fires without the loss of important functions. The NRC issued new guidelines for fire protection programs in nuclear power plants which reflected the recommendations in NUREG-0050.

By letter dated September 30, 1976, the NRC requested Virginia Electric and Power Company to a) develop a fire hazards analysis and an evaluation of the plant's fire protection program relative to Appendix A to Branch Technical Position 9.5-1 and b) submit proposed Technical Specifications to the then-presently-installed fire protection

. equipment for Surry Units 1 and 2.

For Surry Power Station, the fire protection program evaluation resulted in numerous plant modifications and equipment upgrades and the addition of an operating license condition and Technical Specification requirements for fire protection. By letter dated November 30, 1977, the NRC issued License Amendment Nos. 34 and 33 including a Safety Evaluation Report (SER) for Surry finding the proposed specifications acceptable on an interim basis until such time that the overall fire protection program review could be completed. By letter dated September 19, 1979, the NRC issued the Fire Protection Safety Evaluation Report (FP-SER) for Surry Power Station Units 1 and

2. This SER documented the Surry fire protection program and the modifications committed to be incorporated.

By letter dated January 26, 1993, Virginia Electric and Power Company requested a license amendment for Surry Power Station Units 1 and 2 to relocate the fire protection Technical Specifications to the Updated Final Safety Analysis Report (UFSAR) consistent with Generic Letter 86-10 and Generic Letter 88-12.

NRC Generic Letter 86-10, "Implementation of Fire Protection Requirements," and Generic Letter 88-12, "Removal of Fire Protection Requirements from Technical Specifications," provided guidance for a line-item improvement of the Technical Specifications by allowing the fire protection program to be relocated to the plant's UFSAR. However, Generic Letter 86-10 also required that a license condition be added to the Facility Operating Licenses that directly references the NRC's SERs associated with the plant's fire protection program. Although the proposed license condition would also note that changes to the fire protection program could be made without prior Commission approval provided the changes would not adversely affect 1 -

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.J the ability to achieve and maintain safe shutdown, compliance with the license would be defined by the detailed descriptions in the SERs. Upon further review of our fire protection SERs, we concluded that one of the SERs was unnecessarily specific and included detailed information about the fire protection program which was inappropriate as a license condition and direct measure for compliance.

By letter dated April 23, 1996, Virginia Electric and Power Company withdrew the license amendment request pending completion of a more detailed review and clarification of the fire protection licensing basis.

We have now completed our review and hereby request the NRC to reinitiate the review of our propose license amendment request with clarifications to the Surry Fire Protection SER as described below.

Clarifications The following is a summary of the changes made to the Surry Fir_e Protection Program since issuance of the NRC's original fire protection safety evaluation report (FP-SER) for Surry Power Station, dated September 19, 1979. The intent of this document is to identify and clarify changes which have been made to the Surry fire protection program since issuance of the NRC's 1979 FP-SER including those items which have been accepted by supplemental safety evaluation reports. Changes and clarifications are listed by referencing the corresponding section number in the 1979 FP-SER.

3.1.3 (2) to (5) Breathing Apparatus - Recharging System.

The actions identified in the FP-SER were completed as stated. Later, the breathing air compressor and recharging cascade system was upgraded again and relocated in a room in the service building.

The room is readily accessible and is separated from combustible materials in adjacent areas of the service building. The use of a water submersion cooling tank has been eliminated since the self-contained breathing apparatus (SCBA) cylinders currently used are made of materials which do not need water submersion cooling when being recharged.

Reference Section 9.10.2.3.3 of the Surry UFSAR.

3.1.6 (2) to (5) Combustibles - Transient Combustible Materials and Ignition Sources.

As part of the 1979 evaluation, administrative controls were established for a few specific concerns of combustible materials and ignition sources in specific locations. These specific controls are now out of date. Current administrative controls prohibit storage of all unnecessary combustible materials in safe shutdown areas of the station and limit the quantity and duration of combustible liquids brought into safe shutdown areas of the station.

Likewise, the use and storage of kerosene fueled portable heating units are administratively controlled at the station.

Reference Section 9.10.6 of the UFSAR. 2 -

,J 3.1.6 (6) Combustibles - Fuel Oil Tank Diked Area.

This section, regarding removal of vegetation from within the fuel oil tank diked area, is no longer applicable. The floor inside the fuel oil tank dike is now concrete. The concrete floor is a suitable alternative to application of a vegetation-control chemical.

3.1.7 (1) Charcoal Filters.

These heat detectors alarm in the control room instead of in the security building. This provides consistent alarm response since other station fire alarm signals are received in the control room.

Reference Section 9.10.2.1 of the UFSAR.

3.1.8 (2) Emergency Lighting.

This requirement for emergency lighting in a few specific plant areas has been superseded by the issuance of Appendix R.

Lighting has been installed in accordance with Appendix R for illumination of safe shutdown equipment and of access/egress routes thereto.

Reference Section 9.10.2.5 of the UFSAR.

3.1.9 (3), (9) & (11) Fire Detection Systems.

3.1.9 (8) 3.1.11 (9)

The fire detectors for the battery rooms, the containment spray pump and auxiliary feedwater pump building, and mechanical equipment room #3 are provided at the ceilings for general room protection, rather than being provided in the ventilation exhaust ducts.

This provides superior fire detection since the detection capability is not dependent on operation of the ventilation system. Reference Section 9.10.2.1 of the UFSAR.

Fire Detection Systems.

The room described as the "solid waste drumming" room is no longer used for the purpose of drumming waste. The fire detection capability required for this room is now the same as the rest of the auxiliary building. Radioactive waste is now processed in a new building on-site which is separated from other plant buildings. Appropriate fire protection systems are provided for the hazardous areas within the new facility.

Fire Doors - Fuel Building.

This section is no longer applicable. The auxiliary building and the fuel building have been re-classified as a single fire area, and the wall separating the two buildings on elevation 45'1 O" is no longer fire rated.

Hence, the door between the two areas is no longer required to be fire rated.

3.1.11 (14) Fire Doors - Emergency Switchgear Room.

The door between Units 1 and 2 emergency switchgear rooms was replaced with a 3-hour rated fire door.

The door is a normally open sliding door (rather than swinging door) with a smoke detector actuated release. The sliding door functions equivalent to a swinging door by closing automatically when the smoke detector is actuated. Reference Section 9.10.4.2 of the UFSAR. 3 -

3.1.13 (1) to (3) Fire Extinguishers.

Several statements are made throughout the FP-SER regarding portable fire extinguisher locations and types. Many of these statements are out of date regarding the specific type or exact location of the extinguisher. For example, an extinguisher with Class A rating may be provided, rather than a 2-1/2 gallon water extinguisher which is described in the FP-SER.

Portable fire extinguishers are provided in accordance with guidelines of National Fire Protection Association (NFPA) Standard 10 in areas containing equipment required for safe shutdown.

Reference Sections 9.10.2.2.8, 9.10.4.1, and 9.10.4.2 of the UFSAR.

3.1.15 (2) & (3) Floor Drains, Dikes, and Curbs.

Cover plates (rather than dikes) over the floor drains in the diesel generator rooms and in the diesel driven fire pump room were accepted by the NRC in Supplement 1 to the FP-SER (letter dated December 18, 1980). Reference Section 9.10.2.4 of the UFSAR.

3.1.16 (2) High Pressure CO2 Systems - Pilot Bottle Pressure.

This section is no longer applicable. The high pressure carbon dioxide systems have been converted to electric control and the modification was accepted by the NRC in Supplement 2 to the FP-SER (letter dated February 13, 1981 ).

3.1.17 (2), 3.1.18 (5) & (8) Hose Nozzles - Variable Gallonage Nozzles.

Due to material control concerns, the hose stations serving the control room, the switchgear rooms, and the emergency switchgear rooms are equipped with a fog nozzle. The fog nozzle can be used if determined to be appropriate. Variable gallonage nozzle with ball valve shutoff are kept under administrative control and will be brought to the fire scene by the fire brigade, rather than being kept on the hose stations. Variable gallonage nozzles are currently provided in the security building, the control room, the fire brigade scene leader locker, and on the fire truck.

This is an acceptable alternative since the fire hose stations can only be used by the fire brigade, and the brigade is trained to know the best type nozzle to use on electrical fires.

3.1.18 (6) Hose Stations - Containment Standpipe System.

A dry-type hose standpipe system has been installed in each containment building as stated. The standpipe was designed as a Class II system in accordance with NFPA 14, except that it is a dry system for use by the station fire brigade rather than an automatic system for use by building occupants. The fire brigade must open the main shutoff valves in the auxiliary building in order to use the system. This is consistent with the current Technical Specifications (approved by NRC letter dated January 17, 1984). The fire brigade will bring fire hose, which will be stored in the auxiliary building near the containment entrance, into the containment when responding to a fire. 4 -

3.1.18 (1 O) Hose Stations - Door Clearance.

Concrete floors are provided for each hydrant hose house. Subsequent to the FP-SER being issued, the ground around some of the hydrant hose houses has been paved. The concrete is not necessarily 2" above the pavement, but the pavement is sloped away. Periodic inspections of the hose houses ensure that water is not accumulating and that there is adequate clearance for opening the doors.

3.1.18 (13) Hose Stations - Hose Storage.

This paragraph is overly specific regarding the method of hose storage in hose houses. Fire hose is stored in hose houses in a manner to provide easy accessibility for fire brigade use. The fire hose is inspected through periodic surveillance procedures.

3.1.20 (1) Hose and Foam Carts.

The hose and foam fire fighting equipment listed in this section for fire brigade use is provided at a central location. It can be transported by the station fire truck or other vehicle rather than by a manual cart, as necessary.

3.1.23 (1) Monitoring Panels.

An instrument panel has been installed in the Unit 2 cable spreading room, rather than in the fuel building, to provide an alternate capability for monitoring parameters required for safe shutdown in accordance with Appendix R. Reference Sections 9.10.3.5 and 7.7.2 of the UFSAR.

3.1.24 (1) to (3) Penetrations.

These sections address concerns with penetration seals for a few specific locations. The penetration seal program for the entire station has been upgraded. All penetrations in fire barriers are sealed to provide a three-hour fire resistance rating or are evaluated in accordance with Generic Letter 86-10 for Appendix R. Various 3-hour rated materials are used for the penetration seals.

Reference Section 9.10.2.8 of the UFSAR.

3.1.27 (1) Ventilation System - Charging Pumps.

This section is no longer applicable.

In accepting this item, the NRC stated that their original concern was that new charcoal filters requiring fire protection may be added when the charging pump ventilation was modified (letter from NRC dated May 29, 1980). No new filter was added for the charging pumps. The ventilation system was modified such that the charging pump cubicle exhaust goes directly to the Auxiliary Building exhaust_ header, which in turn can be aligned to go to the building exterior either directly or by way of the existing charcoal filters. 5 -

3.2.2 (1) Fire Dampers.

Ventilation for mechanical equipment room #3 has been re-configured such that ducts now penetrate the walls to the emergency switchgear rooms rather than to the turbine building. Fire dampers are provided in the ducts.

3.2.3 (A) & (B) Safe Shutdown.

These sections are no longer applicable.

The requirements for separation of safe shutdown systems have been superseded by the Appendix R SERs (reference the Appendix to this Attachment}, which have been issued since the FP-SER. Reference Section 9.10.3 of the UFSAR.

3.2.4 (1) Charcoal Filter Hazard.

This section is no longer applicable. There was a concern that a fire in the Control Room emergency ventilation filters may damage cables required for safe plant shutdown. It was verified that the only safety-related cable near the charcoal filters is the power feed to the respective emergency ventilation fan motor.

The issue was accepted in Supplement 1 to the FP-SER (letter dated December 18, 1980).

3.2.5 (1) In-situ Testing - Smoke Detectors.

This section is no longer applicable. The NRC stated in a letter dated October 9, 1980 that in-situ testing was not necessary and that bench testing should be performed. We stated in letter Serial No. 477, dated August 13, 1982, that bench testing had been performed, and that on-going functional testing of the detectors would be performed as part of the station's periodic testing program. Periodic test procedures are in place to functionally test the smoke detectors.

Section 4.0, Evaluation of Plant Features, and Section 5.0, Evaluation of Specific Plant Areas.

These sections provide detailed descriptions of the plant as it was at the time of the evaluation. These descriptions do not adequately represent present plant configurations nor do they address the many fire protection modifications made as a result of the FP-SER commitments. Also, these descriptions do not reflect the many modifications made to enhance the ability to safely shutdown in the event of a fire that were made as a result of Appendix R commitments. Each subsection within 4.0 and 5.0 was incorporated directly into the UFSAR Section 9.10. As changes have been made to the plant, the corresponding paragraphs within UFSAR Section '9.1 O have been updated. Due to the specificity of these sections of the FP-SER, they should no longer be used.

The corresponding description in the UFSAR should be relied on for current information regarding plant features and specific plant areas. Reference Sections 9.10.2, 9.10.3, and 9.10.4 of the UFSAR. 6 -

APPENDIX TO ATTACHMENT 1 LIST OF NRC SAFETY EVALUATION REPORTS ASSOCIATED WITH THE FIRE PROTECTION PROGRAM FOR SURRY POWER STATION By letter dated November 30, 1977, the NRG issued License Amendment Nos. 34 and 33 for Surry Units 1 and 2, respectively, including a Safety Evaluation Report (SER).

The amendment issued new Technical Specification requirements for then existing fire protection equipment. The SER found the proposed specifications acceptable on an interim basis until such time that the overall fire protection program review could be completed.

By letter dated September 19, 1979, the NRG issued License Amendment Nos. 54 and 53 for Surry Units 1 and 2, respectively, including the Surry Fire Protection Safety Evaluation Report (FP-SER). The amendment added a license condition related to the completion of modifications for fire protection.

The SER found the proposed modifications described therein to be acceptable both with respect to the improvements in the fire protection program that they provided and with respect to continued safe operation of the facility, while the remaining modifications were to be completed.

By letter dated May 29, 1980, the NRG forwarded an evaluation from their review of additional information provided regarding the fire protection program for Surry Power Station Units 1 and 2.

By letter dated October 9, 1980, the NRG forwarded a summary of the modifications necessary for resolution of open items regarding NRG proposed rule on minimum fire protection requirements and an evaluation of fire doors and hose stations for Surry Power Station Units 1 and 2.

By letter dated December 18, 1980, the NRG issued Supplement 1 to the Fire Protection Safety Evaluation Report for Surry Units 1 and 2.

By letter dated February 13, 1981, the NRG issued Supplement 2 to the Fire Protection Safety Evaluation Report for Surry Units 1 and 2.

By letter dated December 4, 1981, the NRG issued a Safety Evaluation Report for Sections 111.G.3 & 111.L to Appendix R for Surry Power Station Units 1 and 2.

By letter dated April 27, 1982, the NRG issued License Amendment Nos. 77 and 78 for Surry Units 1 and 2, respectively, including an SER. This amendment modified the Technical Specifications to require the availability of a feedwater pump from the opposite unit at all times during the operation of either unit.

- 1 A By letter dated November 18, 1982, the NRC issued a supplement to the Safety Evaluation Report for Sections 111.G.3 & 111.L to Appendix R for Surry Power Station Units 1 and 2.

By letter dated January 17, 1984, the NRC issued License Amendment Nos. 93 and 92 for Surry Units 1 and 2, respectively, including an SER. This amendment modified the Technical Specifications requirements for fire protection systems and equipment.

By letter dated February 25, 1988, the NRC approved exemptions to Appendix R for Surry Power Station Units 1 and 2.

By letter dated July 23, 1992, the NRC approved the Appendix R Post-Fire Safe Shutdown Methodology for Surry Power Station Units 1 and 2.

- 1A e

ATTACHMENT 2 PROPOSED TECHNICAL SPECIFICATIONS CHANGE REQUEST RELOCATION OF FIRE PROTECTION REQUIREMENTS SURRY POWER STATION (Virginia Electric and Power Company letter to the NRC, Serial No.92-727, dated January 26, 1993)

VIRGINIA ELECTRIC AND POWER COMPANY

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VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VmoINIA 23261 January 26, 1993 United. States Nuclear Regulatory Commission Attention: Document Control Desk Washington, D. C. 20555 Gentlemen:

VIRGINIA ELECTRIC AND POWER COMPANY Serial No.

NLP/GDM Docket Nos.

License Nos.

SURRY POWER STATION UNITS 1 AND 2 PROPOSED TECHNICAL SPECIFICATION CHANGES92-727

  • 50-280 50-281 DPR-32 DPR-37 Pursuant to 1 O CFR 50.90, the Virginia Electric and Power Company requests amendments, in the form of changes to the Technical Specifications, to Operating License Nos. DPR-32 and DPR-37 for the Surry Power Station Units 1 and 2, respectively. The proposed changes add the NRC standard fire protection license condition to each unit's Operating License, and relocate the fire protection requirements from the Technical Specifications to the Updated Final Safety Analysis Report. The proposed changes are included in Attachment 1.

The Change request has been prepared pursuant to the guidance provided NRC Generic Letters 86-1 O and 88-12, and is consistent with NRC and industry *efforts to simplify the Technical Specifications.

This request has been reviewed and approved by the Station Nuclear Safety and Operating Committee and the Management Safety Review Committee. It has been determined that the proposed changes do not involve an unreviewed safety question as defined in 1 O CFR 50.59 or a significant hazards consideration as defined in 1 O CFR 50.92.

A discussion of the changes and the basis for our no significant hazards consideration determination is included in Attachment 2.

Very truly yours.

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'., *J_. _;. **!l.,._;r -,

W. L. Stewart Senior Vice President - Nuclear Attachments

1. Proposed Technical Specification Changes
2. Discussion and Significant Hazards Consideration Determination

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U. S. Nuclear Regulatory Commission Region II 101 Marietta Street, N. W.

Suite 2900 Atlanta, Georgia 30323 Mr. M. W. Branch NRC Senior Resident Inspector Surry Power Station Commissioner Department of Health Room 400 109 Governor Street Richmond, Virginia 23219

~~~~~-.

__ ___!___ -- -~"---

e ATTACHMENT 1 SURRY POWER STATION PROPOSED TECHNICAL SPECIFICATION CHANGES

(3) e

  • when the Health Physics Coordinator for *the Steam Generator Repair Program determines, based on an evaluation involving ALARA considerations, that their use will increase overall occupational radiation exposure to workers involved in the repair activities.

(c)

The health physics program and procedures which have been established for the steam generator repair program shall be implemented.

(d)

Progress reports shall be provided at 60 day intervals from the start of the repair program and due *30 days after close of the interval with a final report provided within 60 days after completion of the repair. These reports will include:

(i)

A summary of the occupational. exposure expended to date using the format and detail of Table 5.3-1 of the report entitled "Steam Generator Repair Program."

(ii)

An evaluation of the effectiveness of dose reduction techniques as specified in Chapter 6 of the report entitled "Steam Generator Repair Programs" in reducing occupational exposures.

(iii)

An estimate of radioactivity released in both liquid and gaseous effluents.

(iv)

An estimate of the solid radioactive waste generated during the repair effort including volume and radioactive content.

Sixty days prior to fuel loading, the program for preoperational testing and startup shall be submitted for NRC review.

H.

The licensee shall maintain in effect and fully implement all provisions of the Commission-approved physical security plan, including amendments and changes made pursuant to the authority of 10 CFR 50.54(p). The approved security plan consists of documents withheld from public disclosure pursuant to 1 O CFR 2.790(d), referred to as Surry Power Station Unit Nos. 1 and 2 Physical Security Plan, dated November 30, 1977, as revised September 25, 1978, supplemented (Chapter 1 O) October 25, 1978, revised January 12, 1979, and supplemented February 16, 1979.

Surry - Unit 1

e e I.

The licensee shall implement and maintain in effect the provisions of the approved fire protection program as described in the Updated Final Safety Analysis Report and as approved in the SER dated September 19, 1979, and supplements thereto subject to the following provision:

J.

K.

The licensee may make changes to the approved fire protection program without prior approval of the Commission only if those changes would not

  • adversely affect the ability to achieve and maintain safe shutdown in the event of a fire.

The licensee shall fully i,:nplement and maintain in effect all provisions of the Commission-approved physical security, guard training and qualification, and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822) and to the authority of 1 O CFR 50.90 and 1 O CFR 50.54(p).

The plans, which contain Safeguards Information protected under 1 O CFR 73.21, are entitled: "Surry Power Station Physical Security Plan," with revisions submitted through February 24, 1988; "Surry Power Station Guard Training and Qualification Plan," with revisions submitted through May 29, 1987; and "Surry Power Station Safeguards Contingency Plan," with revisions submitted through January 9, 1987. Changes made in accordance with 1 O CFR 73.55 shall be implemented in accordance with the schedule set forth therein.

Secondary Water Chemistry Monitoring Program The licensee shall implement a secondary water chemistry monitoring program to inhibit steam generator tube degradation. This program shall include:

1.

Identification of a sampling schedule for the critical parameters and control points for these parameters;

2.

Identification of the procedures used to quantify parameters that are critical to control points;

3.

Identification of process sampling points;

4.

Procedure for the recording and management of data;

5.

Procedures defining corrective actions for off control point chemistry conditions; and

6.

A procedure for identifying the authority responsible for the interpretation of the data, and the sequence and timing of administrative events required to initiate corrective action.

Surry - Unit 1

e e when the Health Physics Coordinator for the Steam Generator Repair Program determines, based on an evaluation involving ALARA considerations, that their use will increase overall occupational radiation exposure to workers involved in the repair activities.

(c)

The health physics program and procedures which have been established for the steam generator repair program shall be implemented.

(d)

Progress reports shall be provided at 60 day intervals from the start of the repair program and due 30 days after close of the interval with a final report provided within 60 days after completion of the repair. These reports will include:

(i)

A summary of the occupational exposure expended to date using the format and detail of Table 5.3-1 of the report entitled "Steam Generator Repair Program."

(ii)

An evaluation of the effectiveness of dose reduction techniques as specified in Chapter 6 of the report entitled "Steam Generator Repair Programs" in reducing occupational exposures.

(iii)

An estimate of radioactivity released in both liquid and gaseous effluents.

(iv)

An estimate of the solid radioactive waste generated during the repair effort including volume and radioactive content.

(3)

Sixty days prior to fuel loading, the program for preoperational testing and startup shall be submitted for NRC review.

H.

The licensee shall maintain in effect and fully implement all provisions of the Commission-approved physical security plan, including amendments and changes made pursuant to the authority of 1 O CFR 50.54(p). The approved security plan consists of documents withheld from public disclosure pursuant to 1 O CFR 2.790(d), referred to as Surry Power Station Unit Nos. 1 and 2 Physical Security Plan, dated November 30, 1977, as revised September 25, 1978, supplemented (Chapter 10) October 25, 1978, revised January 12, 1979, and supplemented February 16, 1979.

I.

The licensee shall implement and maintain in effect the provisions of the approved fire protection program as described in the Updated Final Safety Analysis Report and as approved in the SER dated September 19, 1979, and supplements thereto subject to the following provision:

Surry - Unit 2 The licensee may make changes to the approved fire protection program without prior approval of the Commission only if those changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire.

__J

r - -

e e J.

The licensee shall fully implement and maintain in effect all provisions of the Commission-approved physical security, guard training and qualification, and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 1 O CFR 73.55 (51 FR 27817 and 27822) and to the authority of 1 O CFR 50.90 and 1 O CFR 50.54(p).

The plans, which contain Safeguards Information protected under 1 O CFR 73.21, are entitled: "Surry Power Station Physical Security Plan," with revisions submitted through February 24, 1988; "Surry Power Station Guard Training and Qualification Plan," with revisions submitted through *May 29, 1987; and* "Surry Power Station Safeguards Contingency Plan," with revisions submitted through January 9, 1987. Changes made in accordance with 1 O CFR 73.55 shall be implemented in accordance with the schedule set forth therein.

K.

Secondary Water Chemistry Monitoring Program The licensee shall implement a secondary water chemistry monitoring program to inhibit steam generator tube degradation. This program shall include:

1.

Identification of a sampling schedule for the critical parameters and control points for these parameters;

2.

Identification of the procedures used to quantify parameters that are critical to control points;

3.

Identification of process sampling points;

4.

Procedure for the recording and management of data;

5.

Procedures defining corrective actions for off control point chemistry conditions; and

6.

A procedure for identifying the authority responsible for the interpretation of the data, and the sequence and timing of administrative events required to initiate corrective action.

Surry - Unit 2

e TECHNICAL SPECIFICATION.

TABLE OF CONTENTS SECTION IIILf 3.15 DELETED 3.16 EMERGENCY POWER SYSTEM 3.17 LOOP STOP VALVE OPERATION 3.18 MOVABLE INCORE INSTRUMENTATION 3.19 MAIN CONTROL ROOM BOTTLED AIR SYSTEM 3.20 SHOCK SUPPRESSORS (SNUBBER$)

    • 3.21 DELETED 3.22 AUXILIARY VENTILATION EXHAUST FILTER TRAINS 3.23 CONTROL AND RELAY ROOM VENTILATION SUPPLY FILTER TRAINS 4.0 SURVEILLANCE REOLJIREMENTS 4.1 OPERATIONAL SAFETY REVIEW 4.2 AUGMENTED INSPECTIONS 4.3 ASME CODE CLASS 1, 2, AND 3 SYSTEM PRESSURE TESTS 4.4 CONTAINMENT TESTS 4.5 SPRAY SYSTEMS TESTS 4.6 EMERGENCY POWER SYSTEM PERIODIC TESTING 4.7 MAIN STEAM LINE TRIP VALVE 4.8 AUXILIARY FEEDWATER SYSTEM 4.9 RADIOACTIVE GAS STORAGE MONITORING SYSTEM 4.10 REACTIVITY ANOMALIES 4.11 SAFETY INJECTION SYSTEM TESTS 4.12 VENTILATION FIL TEA TESTS 4.13 DELETED 4.14 DELETED TSi TS 3.16-1 TS 3.17-1

. TS 3.18-1 TS 3.19-1 TS 3.20-1 TS 3.22-1 TS 3.23-1 TS 4.0-1 TS 4.1-1 TS 4.2-1 TS 4.3-1 TS 4.4-1 TS 4.5-1 TS 4.6-1 TS 4.7-1 TS 4.8-1 TS 4.9-1 TS 4.10-1 TS4.11-1 TS 4.12-1

e TECHNJCAL SPECJFJCATJON TABLE Of CONTENTS SECTION TJILf 4.15 AUGMENTED INSERVICE INSPECTION PROGRAM FOR HIGH ENERGY LINES OUTSIDE OF CONTAINMENT 4.16 LEAKAGE TESTING OF MISCELLANEOUS. RADIOACTIVE MATERIALS SOURCES 4.17 SHOCK SUPPRESSORS (SNUB~ERS) 4.18 DELETED 4.19 STEAM GENERATOAINSERVICE INSPECTION 4.20 CONTROL ROOM AIR FILTRATION SYSTEM 5.0 DESIGN FEATURES 5.1 SITE 5.2 CONTAINMENT 5.3 REACTOR 5.4 FUEL STORAGE 6.0 ADMINISTRATIVE CONTROLS 6.1 ORGANIZATION, SAFETY AND OPERATION REVIEW 6.2 GENERAL NOTIFICATION AND REPORTING REQUIREMENTS 6.3 ACTION TO BE TAKEN IF A SAFETY LIMIT IS EXCEEDED 6.4 UNIT OPERATING PROCEDURES 6.5 STATION OPERATING RECORDS 6.6 STATION REPORTING REQUIREMENTS 6.7 ENVIRONMENTAL QUALIFICATIONS 6.8 PROCESS CONTROL PROGRAM AND OFFSITE DOSE CALCULATION MANUAL TSiii TS 4.15-1 TS 4.16-1 TS 4.17-1 TS 4.19-1 TS 4.20-1 TS 5.1-1 TS5.1-1 TS *5.2-1 TS 5.3-1 TS 5.4-1 TS 6.1-1 TS 6.1-1 TS 6.2-1 TS 6.3-1 TS 6.4-1 TS 6.5-1 TS 6.6-1 TS 6.7-1 TS 6.8-1

e TS 6.1-3

7.

DELETED

8.

DELETED

9.

The health physics technician requirement of Specification 6.1.B.5 may not be met for a period of time not to exceed 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in order to accommodate an unexpected absence provided immediate action i~

taken to fill the required position.

1 O.

Procedures will be established to insure that NRC policy statement guidelines regarding working hours established for employees are followed.

In addition, procedures will provide for documentation of authorized deviations from those guidelines and that the documentation is available for NRC review.

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h.

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TS 6.1-8

9.

Review of the Plant Security Plan and implementing procedures and shall submit recommended changes to the Station Manager.

1 O.

Review of the Emergency Plan and implementing procedures and shall submit recommended changes to the Station Manager.

11.

Review of every unplanned onsite release of radioactive material to the environs exceeding the limits of Specification 3.11, including the preparation of reports covering- *evaluation, recommendations anc;f disposition of the corrective action to prevent recurrence and the forwarding of these reports to the Vice President - Nuclear Operations and to the Management Safety Review Committee.

12.

Review of changes to the Process Control Program and the Offsite Dose Calculation Manual.

13.

Review of the Fire Protection Program and implementing procedures and shall submit recommended changes to the Station Manager.

Authority The SNSOC shall:

1.

Provide written approval or disapproval of items considered under (1) through (3) above. SNSOC approval shall be certified in writing by an Assistant Station Manager.

2.

Render determinations in writing with regard to whether or not each item considered under (1) through (5) above constitutes an unreviewed safety question.

3.

Provide written notification within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to the Vice President -

Nuclear Operations and to the Management Safety Review Committee of disagreement between SNSOC and the Station Manager, however, the Station Manager shall have responsibility for resolution of such disagreements pursuant to 6.1.A above; Records The SNSOC shall maintain written minutes of each meeting and copies shall be provided to the Vice President - Nuclear Operations and to the Management Safety Review Committee.

e ATTACHMENT 2 SURRY POWER STATION DISCUSSION OF PROPOSED CHANGES AND SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION

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e DISCUSSION OF CHANGE INTRODUCTION Pursuant to NRC guidance, the proposed Technical Specification changes remove the fire protection requirements from the Technical Specifications for relocation to the Updated Final Safety Analysis Report (UFSAR). A revised license condition is also proposed for incorporation into the Operating License for each Unit which addresses adherence and changes to the Fire Protection Program.

BACKGROUND Generic Letter 86-1 O, "Implementation of Fire Protection Requirements," Section F, requested that licensees incorporate their Fire Protection Programs into their UFSAR.

Upon completion of this effort, the licensees were requested to apply for an amendment to 1) replace current licensing conditions regarding fire protection with a new standard condition, and 2) remove unnecessary fire protection Technical Specifications. Generic Letter 88-12, "Removal of Fire Protection Requirements From Technical Specifications," provided additional guidance for the preparation of a license amendment request to implement Generic Letter 86-10.

The proposed changes have been developed in accordance with the guidance contained in the Generic Letters and are consistent with NRC and industry efforts to simplify the Technical Specifications.

A new section has been created in the UFSAR (16.2) to contain the fire protection requirements currently contained in the Technical Specifications.

Information previously contained in the Technical Specification Bases is also included in this section. No changes have been made to the technical content of the fire protection requirements being relocated to the UFSAR pursuant to the direction of Generic Letter 88-12.

Compliance with the fire protection requirements will be assured by maintaining these requirements in the UFSAR and appropriate station procedures.

The proposed changes provide flexibility in updating and maintaining the fire protection program.

Since no technical changes are being made, the relocation of the fire protection program is strictly administrative in nature.

SPECIFIC CHANGES The proposed changes to the Technical Specifications are as follows: --

  • Licensing Condition 3.1 will be deleted in the Operating Licenses for Units 1 and 2 and will be replaced by the NRC standard fire protection license condition provided in Generic Letter 88-12. This condition requires the licensee to maintain the fire protection program as described in the UFSAR and as approved by the NRC Safety Evaluation Report.

It also notes that changes to the program are allowed without NRC approval provided they do not adversely affect the ability to achieve safe shutdown in the event of a fire.

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  • The Technical Specification Table of Contents will be revised to indicate that Specifications 3.21 and 4.18 have been deleted.

These specifications discuss the fire protection features required to prevent or mitigate a fire, and the surveillance requirements for fire protection equipment, respectively.

to the Fire Brigade composition requirements.

  • Technical Speci.fication 6.1.C.1.f.13 will be added to require the Station Nuclear Safety and Operating Committee to review changes to the Fire Protection Program and implementing procedures and to submit the recommended changes to the Station Manager.

SAFETY SIGNIFICANCE The proposed Technical Specification changes relocate the fire protection requirements from the Technical Specifications to the UFSAR and station procedures.

No technical changes are being made. The Fire Protection Program requirements are being retained and remain an integral part of station operations, even though they will no longer reside in the Technical Specifications. This is an administrative change only and, as such, does not represent a safety concern.

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10 CFR 50.92 EVALUATION

  • BASIS FOR NO SIGNIFICANT HAZARDS DETERMINATION We have reviewed the proposed changes against the criteria of 1 O CFR 50.92 and have concluded that the changes do not pose a significant safety hazards consideration as defined therein. Specifically, operation of Surry Power Station with the proposed amendment will not:
1.

Involve a significant increase in either the probability of occurrence or consequences of any accident o.r equipment malfunction scenario -that is important to safety and which has been previously evaluated in the UFSAR.

The requirements of the Fire Protection Program have not been changed by the proposed amendment. Relocation of the Fire Protection Program requirements into the UFSAR and station procedures does not decrease any portion of the program. The same fire protection requirements exist as before the change.

2.

Create the possibility of a new or different type of accident than those previously evaluated in the safety analysis report. The requirements of the Fire Protection Program have not been changed by the proposed amendment. This is an administrative change to relocate the Fire Protection Program requirements from the Technical Specifications to the UFSAR and station procedures.

Consequently, the possibility of a new or different kind of accident from any accident previously evaluated has not been created.

3.

Involve a significant reduction in a margin of safety. Implementation of the Fire Protection Program requirements is assured by the UFSAR and station procedures. Since the program is being retained intact, there is no reduction in the margin of safety.

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