ML20135G629

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Responds to 771125 Request for Review & Response to NRC Proposed Tech Specs Re Fire Protection.Technical Bases Insufficient to Warrant Imposition of Requirement for 5-man Fire Brigade Per Review of Spec 6.2.2.f
ML20135G629
Person / Time
Site: Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date: 12/15/1977
From: Switzer D
CONNECTICUT YANKEE ATOMIC POWER CO.
To: Schwencer A
Office of Nuclear Reactor Regulation
Shared Package
ML20135G608 List:
References
NUDOCS 8509190602
Download: ML20135G629 (3)


Text

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CONNECTICUT YANKEE ATOMIC POWER COMPANY W P. O mon ato BERLIN. CONNLCTICUT meantrono co%% e c e,c w , o,,o,

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December 15, 1977 i g g g.{ J ge n e. VJ L, 6 L:n Docket No. 50 ~13 a m DEC 211977 Director of Nuclear Reactor Regulation g, gg g,E POWER CO.

Atta: Mr. A. Schwencer, Chief Operating Reactors Branch #1 U. S. Nuclear Regulatory Commission Washington, D. C. 20555

'Esference: (1) K. Coller letter to D. C. Switzer dated November 25, 1977.

Gentlemen:

Raddas Neck Plant Fire Protection Technical Specifications _

In Refere . e (1), Connecticut Yankee Atomic Power Company (CYAFCO) was requested to review the NRC proposed Technical Specifications relatic,g to Tire Protection.

Specifically it was requested that CTAPCO respond with specific objections to any of the propored requirements.

Accordingly, .the fo1* wing infor=ation is provided. Attachment 1 contains those Technical Specification pages which require additional review; the af f ected sec-tions or paragraphs are indicated by change bars using Reference (1) as a basis.

h Att .chsent 2 provides the justification for departures f rom Ref erenca (1).

The review of proposed Specification 6.2.2.f by bAPC0 clearly indicates the technical bases are not suf ficient to warrant the i= position of the requirenent for a five-can Fire Brigade. The philosophy for protection against fire is that of defense in depth: fire prevention, pro =pt detection, extinguish =ent, and provisions for minimizin:; the effects of fires. A thorough review of the inte-grated effect of the various features of this philosophy by CYAPCO indicates that a three-san fire brigade provide: adequate coverage for its function: extinguish fires v'.ere automatic protection is not currently provided and protect ayste=s required fer safe shutdown. A detailed discussion of the rationale for the above is provided as Attachment 3; it conclusively demonstrates that a Technical Specifi-cation requirement for a three-man Fire Brigade is adeqtate.

Coe:erning the specificatic,ns on penetration fire barriers CYAPCO anticipates confusion on the interpretation of this phrase; guidance as to what constitutes 1 a penetration fire barrier has not been provided. Until an understanding is l 8509190602 850906 i ADOCK 05000213 PDR '

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reached, these penetrations cannot be categorized, and procedures and checklists cannot be formulated. Therefore, implementation of this specification should be i deferred pending resolution of this matter.

Lastly, CYAPCO wishes to review some pertinent points concerning the development of Fire Protection Technical Specifications. The requirement for specifications was first identified in your letter dated September 30,1976, over 14 months ago.

The first NRC draf t of model specifications was provided by letter dated December 1, 1976. Corrections to this letter were provided by your letter dated December 8, 1976. The lack of thoroughness with which these letters were prepared is high-lighted by the fact that no bases for these specifications were provided. CYAPCO responded by letter dated February 25, 1977. By letter dated June 17, 1977, CYAPCO was again requested to provide interim Technical Specifications, and responded by letter dated July 20, 1977. Additional Staff connents required the supplemental letter of October 18, 1977. Finally, by letter dated November 25, 1977, CYAPCo was given yet another set of model specifications to review and identify specific objections to the proposed requirements. Only approximately 20 days from the date of the letter were allotted f o r this evolution. Accordingly, this letter fulfills O your request of Reference (1). Throughout this period of time, CYAPCO has attempted to provide timely responses to Staff requests, and has devoted a significant number of man 'aours to this issue. This discussion illustrates that the effort on the part of the NRC Staff to implement Fire Protection Technical Specifications has 1seked continuity and would be better served by well-defined regulatory objectives and bases. Although the significance of the Browns Ferry incident and its implica- )

tions are recognized, this situation has resulted in an excessive number of iters-tions, and has unduly taxed the essources of CYAPCO and NUSCO.

Following satisfactory resolution of the items identified in the attached informa-tion CYAPC0 vill be prepared to implement the appropriate specifications.

If jour review of this information results in additional detailed discussions with the NRC Staff, please be advised *, hat we are available to attend a meeting at a mutually acceptable date to- resolve the r==4ning issues such that interim speci-fications can be issued.

Very truly yours, CONNECTICUT YANKEE ATCHIC POWER COMPAhT x

9. C. Switzer j President  ;

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Then personally appeared before me D. C. Switzer, who being duly sworn, did state that he is President of Connecticut Yankee Atomic Power Coc.pany,the Licensee herein, that he is authorized to execute and file the foregoing information in the name and on behalf of the Licensee herein and that the statements best contained of his knowledge in said information are true and correct to the and belief.

Ilotary Public ff . h

% Commason E.xpues March 31, 1981 l .

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