ML20096G867

Requests That Proposed Requirement for Installation of Fire Detection & Fixed Suppression Sys Be Submitted to NRC Mgt for Approval.Facilities Design Incorporates Fire Detection & Suppression Sys Previously Acceptable to NRC

ML20096G867
Person / Time
Site:	McGuire, Mcguire
Issue date:	09/04/1984
From:	Tucker H DUKE POWER CO.
To:	Adensam E, Harold Denton Office of Nuclear Reactor Regulation
References
NUDOCS 8409110195
Download: ML20096G867 (3)

Text

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-- DUKE POWER GOMPANY P.O. HOX 33180 CHARLOTTE, N.O. 28242 HALB. TUCKER TELEPHONE vu,a reses ent (704) 373-4531

====r====== September 4, 1984 i

Mr. Harold R. Denton, Director.

Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory C,wmission Washington, D. C. 20555 Attention: Ms. E. G. Adensam, Chief Licensing Branch No.'4

Subject:

.'McGuire Nuclear Station Docket Nos. 50-369 and 50-370

Dear Mr. Denton:

Duke Power has recently received verbal communication from staff fire pro-tection reviewers in ONRR and Region II. relative to 10 CFR 50, Appendix R.

Section III.G.3. This section states, in part, that "In addition, fire

~ detection and fixed suppression system shall be installed in the area, room

.or zcne under. consideration". The NRC staff asserts that this has not been adequately reviewed at McGuire and they believe that exemptions to the pre-sent interpretation of this regulation may be required.

Duke considers that this section of Appendix R has been reviewed properly and that a specific exemption request is not required. This is based on the fact that detailed reveiws of the fire suppression capabilities at McGuire have been conducted in light of the specific license conditions for McGuire.

As background, the initial Fire Hazard Analysis for McGuire was issued in September 1977 and updated in 1979, and safety evaluation reports ware issued in March 1979 and April 1981 concerning the fire protection system.

Appendix R became effective in February 1981. Appendix R,Section III.G was made a part of the license condition for McGuire since Appendix R applies to plants with OL prior to January.1979. The detailed review of

~

the Standby Shutdown System was conducted by NRC with a Safety Evaluation Report-issued in February 1983. This review included a knowledge of those

-areas that had fire detection and suppression. The hazard analysis and safety evaluation reports provided detailed listings of where. suppression

~

is provided and numerous questions were answered concerning the extent of this coverage during the review process.

Concurrent with these activities, Duke received a copy of Generic Letter 81-12. "To All Power Reactor Licensees with Plants Licensed Prior to

' January 1, 1979." For Oconee Nuclear Station Duke was~ required to submit a comparison of the (then) ongoing design and construction of the Standby Shutdown System and related fire protection modifications to provisions f

0 9- a F PM , j L 10

TMr. Har:1d RJ Denten Dirictcr

'

• September 4, - 1984

=Page 2 Jof the rule. These Modifications-included construction of a fire rated wall to separate East and West Penetration rooms. Duke originally under-stood " area, roca or zone'under consideration", to be the penetration rooms and requested exemption from the. requirement to provide fixed suppression throughout penetration rooms.. The Staff reviewed the exemption request and responded that an exemption was not required.for penetration rooms-

.but;would be required for the Control Room. Duke then understood that

" area, room or zone," meant the location where normal control function occured. This was reasonable because the Staff reviewers with whom Duke-was interfacing, were aware that the Standby Shutdown System was provided as an-assured'means of shutdown for: loss of function basically.throughout the Station (i.e. all. fire areas). At that time, the only required exemption was for the Control Rooms. The current interpretation of. " area, room or zone under. consideration" is a new interpretation of an existing staff position.

' Supplement 6 of the Safety Evaluation Report issued in February 1983 '

states.that McGuire meets Appendix R Section III.G. This SER also states where suppression and detection are provided. Based on these reviews

-cand resulting SER's, we concluded that no additional actions on our part ,

=were required to meet Appendix R,Section III.G.

'Since the McGuire design incorporates fire detection and suppression systems which the NRC staff has previously found to be acceptable, the requirement that Duke file an exemption request to a new staff inter-pretation of a. regulation lays the goundwork for potential additional plant modifications to meet this new interpretation. Duke considers that this is a potential ibackfit and the requirements 'of 10 CFR 50.109 Generic Letter 84-08, and NRC Manual Chapter 0514 should be considered.

'In this particular instance, it has not been demonstrated-that this new interpretation'will provide a significant improvement in safety over the

-previous Staff position.

Duke requests that the proposed requirement be submitted to NRC management for approval, in accordance with the Office of Nuclear Reactor Regulation

-(NRR) procedure for management of plant specific backfitting, prior to

' transmittal as a licensing requirement.

Unless' informed'to the contrary Duke will take no further action in response to these informal staff requests.

Very truly yours,

&b ,

Hal B. Tucker RLG: sib

.m.

'lt . .

JMr. Harold-R..'Denton, DirzctorL

'Se'ptem*oer 4, .1984 '

.Page 3

'cc: 'Mr. James P. O'Reilly, Regional Administrator-U. S. Nuclear Regulatory Commission

' Region II

101 Marietta Street, NW, Suite 2900 Atlanta, Georgia -30323 Mr. Ralph Birkel

. Division of Project' Management Office of: Nuclear Reactor Regulation

.U. S.= Nuclear Regulatory Commission Washington, D. C. 20555 W. T. Orders

'NRC Resident Inspector

.McGuire Nuclear Station