ML20040F745

Requests Extension Until 820630 for Submittal of Justification for Exemption from Fire Protection Rule, 10CFR50,App R.Safety Would Be Degraded by Introducing Unnecessary Excessive Design Change

ML20040F745
Person / Time
Site:	Cooper
Issue date:	01/29/1982
From:	Pilant J NEBRASKA PUBLIC POWER DISTRICT
To:	Vassallo D Office of Nuclear Reactor Regulation
References
LQA8200075, NUDOCS 8202100251
Download: ML20040F745 (2)

Text

e-GENERAL OFFICE B

_ Nebraska Public Power District

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i LQA8200075 10 January 29, 1982

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= w'~ %p$po Director, Nuclear Reactor Regulation l'/'

O Attn:

Mr. Domenic B. Vassallo, Branch Chief Operating Reactors Branch No. 2

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Division of Licensing

@W U.S. Nuclear Regulatory Commission Washington, DC 20555 Subj ect: Fire Protection Rule 10CFR50, Appendix R Cooper Nuclear Station NRC Docket No. 50-298, DPR-46

Reference:

1) Letter from T. A. Ippolito to J. M. Pilant dated September 22, 1981, same subject

2) Letter from J. M. Pilant to T. A. Ippolito dated October 30, 1981, same subject

Dear Mr. Vassallo:

Reference 1 requested that Nebraska Public Power District provide a schedule for submitting specific information and justification for the alternative features at Cooper Nuclear Station that would provide a sound basis for an exemption to the subject regulation.

Reference 2 summarized the study the District was performing of safe shutdown systems and indicated that this study would be completed by March 15, 1982. Now that this study is nearing completion, and the District has had the benefit of numerous discussions between the Staff and the Nuclear Utility Fire Protection Group, it is recognized that we must more fully document our previous review of associated circuits and review additional areas to the criteria of III.G 2 which were not recognized when we requested cur extension to the March 15, 1982 date.

For these reasons the District respectfully requests that the NRC grant an extension to June 30, 1982 for submittal of the above information.

The District does not consider this additional time for thorough analysis to be detrimental to safety at CNS because the issue of Safe Shutdown Capability was recently finalized by Amendment 66 00 b

_(November 21, 1980) to the facility license and was ehen considered

'y adequate by the NRC staff. The November 24, 1980 letter from D. G.

Eisenhut to All Licensees stated that CNS did not have any "open"

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items concerning fire protection features.

In addition to separation of safe shutdown capability, the following specific areas of fire protection were recently extensively augmented at CNS to the NRC's satisfaction:

8202100251 820129

-PDR ADOCK 05000298 F

PDR 2

Mr. Domenic B. Vassallo January 29, 1982 Page 2

- Fire hazards mitigation: Numerous plant modifications and studies were performed.

- Fire detection systems: Plant modifications were performed.

- Fire suppression systems:

Plant modifications were performed such as installation of fire barriers and suppression systems.

- Fire fighting capabilities: The fire brigade was augmented and com-munications were reviewed.

- Administrative controls: Surveillance procedures and instructions were written and technical specifications were approved.

- Emergency lighting: The provisions of 10CFR50, Appendix R, III.J were recently. implemented.

Additionally,10CFR50.109 allows the Commission to " require backfitting of a facility if it finds that such action will provide substantial additional protection which is required for the public health and safety or the common defence and security." It has not been satis-factorily determined that the arbitrary backfits for separation of safe shutdown capability will provide substantial additional pro-tection.

Per revised 10CFR50.48(c)(6) the District asserts that hurried modifications to the safe shutdown systems per the original schedule in Appendix R without careful evaluation would not necessarily enhance fire protection at CNS, and that such. modifications may be detrimental to overall facility safety.

Safety would be degraded by introducing unnecessary excessive design change; by introducing excessive complexity in the present fire safe shutdown procedures; and by increasing the potential for installation damage and design error.

Please contact me if you require further clarification regarding our

-efforts and schedule.

Sincerely, 44 Jay. Pilant Division Manager of Licensing and Quality Assurance JMP:JDW:cmk

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