ML20202E968
| ML20202E968 | |
| Person / Time | |
|---|---|
| Site: | McGuire, Mcguire  |
| Issue date: | 04/04/1986 |
| From: | Tucker H DUKE POWER CO. |
| To: | Harold Denton, Youngblood B Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8604140081 | |
| Download: ML20202E968 (3) | |
Text
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DUKE POWER GOMPANY P.O. BOX 33180 l
CHARLOTTE, N.C. 28242 HAL B. TUCKER TELEPHONE (704) 373-4531 vice reserouwr mixanas reootrvion April 4, 1986 C
peb.HaroldR.Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C.
20555 ATTENTION:
Mr. B.J. Youngblood, Director PWR Directorate #4
Subject:
McGuire Nuclear Station Docket Nos. 50-369, 50-370
Dear Mr. Denton:
In response to NRC letter dated March 10, 1986 which forwarded a request for information regarding deviation from 10 CFR 50, Appendix R, the following reply is provided.
We understand that this request is to enable NRC consultants to review specific features of McGuire Nuclear Station to current Appendix R criteria. The August 3, 1984 letter was provided to the NRC staff for
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information only. At the time of the submittal Duke was preparing for a i
major NRC fire protection inspection and identified several apparent deviations from Appendix R.
It was our intent to apprise NRC of these j
findings.
It was not our intent that the fire protection review of McGuire be reopened.
The pre-licensing fire protection review and inspection process was rigorous in assuring that the McGuire fire protection program met the requirements of that era.
In addition, McGuire Nuclear Station Unit 1 Operating License states as follows:
"The licensee shall maintain in effect and fully implement all provisions of the approved fire protection plan in the NRC staff's McGuire Safety Evaluation Report Fire Protection Review and Supplement No. 2 to the McGuire Nuclear Station Safety Evaluation Report dated March 1979. Duke Power Company shall comply with Section's III.G Fire Protection of Safe Shutdown Capability, including Section III.L Alternative and Dedicated Shutdown Capability, as appropriate;...."
(emphasis added) tseU4140061 860404 PDR ADOCK 05000369 y
PEH4 p
Harold R. Denton April 4, 1986 Page 2 Similarly, the McGuire Unit 2 license conditions states that:
"The licensee shall fully implement and maintain in effect all provision of the approved fire. protection plan as amended in September 1982 and the Fire Protection Review and Supplement No. 5 to McGuire Nuclear Station's Safety Evaluation Report dated March 1979. Prior to March 1, 1984, the licensee shall meet the technical requirements of 4
Section III.G, Fire Protection of Safe Shutdown Capability, including Section III.L, Alternative and Dedicated Shutdown Capability, as appropriate;" (emphasis added)
The phrase "as appropriate" is a critical element of these license conditions which conveyed intent that McGuire comply with those portions of Appendix R as reviewed and accepted in the subject Safety Evaluation Reports. Based on multiple detailed interpretations of Appendix R issued subsequent to McGuire Operating Licenses, it is clear that regulatory expectations continue to evolve.
Duke is concerned about the acceptance criteria the staff and its j
consultant intend to apply to this review.
If the acceptance criteria is
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the same as that which was used during the licensing of McGuire, then the l
information requested is not necessary in~that such a review has already been completed.
If, however, the acceptance criteria is new (e.g., Appendix R or some 4
present staff position), then the information requested must be justified in light of the backfit requirements.
1 In either case, it does not appear that the request is justified.
Unless informed to the contrary, no further Duke action will be taken in response to this request.
a Very truly yours, l
J 4
i Hal B. Tucker RLG/jgm xc:
Dr.-J. Nelson Grace, Regional Administrator U.S. Nuclear Regulatory Commission, Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 W.T. Orders Darl Hood, Project Manager j
NRC Resident Inspector Division of Licensing
}
McGuire Nuclear Station Office of Nuc.' Reg. Commission j
Washington, D.C. 20555 j
I Harold R. Denton April 4, 1986 Page 3 i
bxc: N.A. Rutherford R.O. Sharpe_
P.F. Guill H.D. Brandes T.A. Ledford T.L. McConnell 4
E.O. McCraw R.W. Revels MC-801.01 5
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