ML20151Q943

Requests That Util Reconsider Revising 880610 Amend Request to Conform W/Staff Position on Surveillance Requirements for Fire Barrier Penetration Seals

ML20151Q943
Person / Time
Site:	Cooper
Issue date:	08/02/1988
From:	Long W Office of Nuclear Reactor Regulation
To:	Trevors G NEBRASKA PUBLIC POWER DISTRICT
References
TAC-65623, NUDOCS 8808110342
Download: ML20151Q943 (5)

Text

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8 o NUCLEAR REGULATORY COMMISSION

. g WASHING TON, D. C. 20555 k...../ August 2, 1988 Docket No. 50-298 Mr. George A. Trevors, Division Manager - Nuclear Support Nebraska Public Power District Post Office Box 499 Columbus, Nebraska 68601

SUBJECT:

STAFF POSITION RELATING TO TECHNICAL SPECIFICATIONS AMENDMENT REQUEST - CHANGE NO. 32 TO THE COOPER NUCLEAR STATION (CNS) TECHNICAL SPECIFICATIONS (TAC N0. 65623)

By letter dated June 10, 1987, the District submitted on an amendment request which would modify the CNS Technical Specifications relating to surveillance requirements for fire barrier penetration seals. By letter dated July 15, 1987, the staff described its position as to which fire barrier penetration seals are subject to Limiting Conditions of Operation (LCO) and Surveillance Requirements (SR), Your letter dated March 4,1988 revised your amendment application, to more closely conform to the staff position but the revised application is still not consistent with the staff position. The amendment, as proposed in the revised application, would exclude from the scope of the Technical Specifications, those fire barrier penetration seals which are not required for purpose of providing Appendix R safe shutdown separation. As noted in Attachment 2 of your June 10 submittal, this change would increase the probability that a fire could spread into adjacent areas of the facility before being extinguished.

The analyses resulting from 10 CFR 50.48/ Appendix R have, for many facilities (including CNS), resulted in redefinition of fire area boundaries. Many barriers which were originally constructed as fire area boundaries are not fire area barriers for purposes of protection of Safe Shutdown capability.

However, the fact that a fire area barrier is not an Appendix R safe shutdown fire area barrier does not automatically justify the deletion of its LC0's and SR's. Deletion of Technical Specifications coverage for these boundaries must be evaluated on a case basis.

It is noted thct CNS's current Technical Specifications require surveillance of every penetration seal every refueling outage. The staff acknowledges that this is an excessively conservative inspection interval. The staff position requires only that at least 10% of each type of seal be inspected during each outage, and allows up to 15 years between surveillance on individual seals.

Also, barriers and seals not required by Branch Technical Position 9-5 criteria (e.g., barriers and seals installed for property / insurance purposes only) should not be within the scope of the Technical Specification.

8808110342 E.80PO2 PD ADOCK 06000298 '

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It is requested that the District again reconsider revising its amendment request. We believe that revising the amendment to conform to the staff position would significantly reduce the surveillance burden with no significant reduction in fire protection.

Sincerely,

\3 William 0. Long, Project Manager Pro,iect Directorate - IV Division of Reactor Projects - III, IV, V and Special Projects cc: See next page l

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l DISTf(IBUTION l W cket File NRC PDR Local PDR PD4 Reading l L. Rubenstein J. Calvo P. Noonan W. Lon i OGC-Rockville E. Jordan B. Grimes ACRS(g)10 l J. Craig D. Notley D. Kubicki D. Dubois J. Jaudon, RIV PD4 Plant File C. McCracken

• See previous concurrence

• PD4/LA *PD4/FM ECE b PD4/D PNoonan WLong:sr CMcCracken JCalvo/'7I'0 1 07/25/88 07/22/88 07/J[/88 of ,W/ t /88 1

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1 It is requested that the District again reconsider revising its amendment request. We believe that revising the amendment to conform to the staff position would significantly reduce the surveillance burden with no significant reduction in fire protection.

Sincerely, William O. Long, Project Manager Project Directorate - IV Division of Reactor Projects - III, IV, V and Special Projects cc: See next page i

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l DISTRIBUTION Docket File NRC PDR Local PDR PD4 Reading L. Rubenstein J. Calvo P. Noonan OGC-Rockville E. Jordan B. Grimes W. Long ACRS (10 )

J. Craig 0. Notley D. Kubicki D. Dubois J. Jaudon, RIV PD4 Plant File PD4/ PD4/PM ip/ PD4/D PN b' WLong:sr JCalvo 07$/8 07/p')/88 07/ /88

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2 It is requested that the District again reconsider revising its amendment request. We believe that revising the amendment to conform to the staff position would significantly reduce the surveillance burden with no significant reduction in fire protection.

Sincerely.

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William 0; Long, Project Manager Project Directorate - IV Division of Reactor Projects - III, IV, V and Special Projects cc: See next page

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• Mr. George A. Trevors Nebraska Public Power District Cooper Nuclear Station l

f cc:

l Mr. G. D. Watson, Genere; Counsel I Nebraska Public Power District P. O. Box 499 l Columbus, Nebraska 68601 Cooper Nuclear Station ATTN: Mr. Guy R. Horn, Division Manager of Nuclear Operations P. O. Box 98 Brownville, Nebraska 68321 Dennis Grams, Director Nebraska Departrent of Environmental Control P. O. Box 98922 Lincoln, Nebraska 68509-8922 Mr. Larry Bohlken, Chairman Nemaha County Board of Comissioners Nemaha County Courthouse 1824 N Street Auburn, Nebraska 68305 1

Senior Resident Inspector  !

U.S. Nuclear Regulatory Comission P. O. Box 218 Brownville, Nebraska 68321 Regional Administrator, Region IV U.S. Nuclear Regulatory Comission

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611 Ryan Plaza Drive, Suite 1000 '

Arlington, Texas 76011 Mr. Harold Forchart, Director Division of Radiological Health ,

Department of Healtn l 301 Centennial Mall, South P. O. Box 95007 Lincoln, Nebraska 68509-5007

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