ML20203L118

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Forwards Proposed Amend to License NPF-35,amending License Condition 8 in Response to Generic Ltr 86-10 Re Implementation of Fire Protection Requirements.Fee Paid
ML20203L118
Person / Time
Site: Catawba Duke Energy icon.png
Issue date: 08/12/1986
From: Tucker H
DUKE POWER CO.
To: Harold Denton, Youngblood B
Office of Nuclear Reactor Regulation
References
GL-86-10, NUDOCS 8608250011
Download: ML20203L118 (5)


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DUKE Powen GOMPANY P.O. ISOX 33189 CHARLt#TTE. N.C. 28242 TELarnown IIAL H. TIJCKER (704) 373-4831 vis a renessant wits.aae peone criven August 12, 1986 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D. C.

20555 Attention:

Mr. B. J. Toungblood, Project Director PWR Project Directorate No. 4 Ret Catawba Nuclear Station, Unit 1 Docket No. 50-413 Dear Sir Attached is a proposed amendment to license Condition 8 of Facility Operating License NPF-35. The proposed amendment is submitted in response to Generic Letter 86-10, Implementation of Fire Protection Requirements.

This request is applicable to the Catawba Unit 1 operating license. Accordingly pursuant to 10 CFR 170.21, a check for $150.00 is enclosed.

Pursuant to 10 CFR 50.92(b)(1) the appropriate South Carolina State official is being provided a copy of this amendment request.

Very truly yours, a 4 x"A_

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x-Hal B. Tucker 8608230011 060012 ROS/50/ sib hDR ADOCK 030004g3 PDH Attachment xc Dr. J. Nelson Grace, Regional Adcinistrator U. S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 Mr. Hayward Shealy, Chief 11ureau of Radiological Health 0gh South Carolina Department of Health &

Environmental Control 2600 Bull Street lg ytisagb Columbia, South Carolina 29201

Mr. Harold R. Denton, Director August 12, 1986 Page Two xc INPO Records Center Suite 1500 1100 circle 75 Parkway Atlanta, Georgia 30339 American Nuclear Insurers c/o Dottie Sherman, ANI Library The Rxchange, Suite 245 270 Farmington Avenue Farmington, CT 06032 M&M Nuclear Consultants 1221 Avenue of the Americas New York, New York 10020 NRC Resident Inspector Catawba Nuclear Station

Mr. Harold R. Denton, Director August 12, 1986 Page Three HAL B. TUCKER, being duly sworn, states that he is Vice President of Duke Power Company; that he is authorized on the part of said Company to sign and file with the Nuclear Regulatory Commission this amendment to the Catawba Nuclear Station Unit 1 operating license NPF-35; and that all statements and matters set forth therein are true and correct to the best of his knowledge.

a4 k Hal B. Tucker, Vice President Subscribed and sworn to before me this 12th day of August, 1986.

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(1) Requested Amendment Amend Facility Operating License NPF-35 License Condition 8 to read:

Fire Protection Program (Section 9.5.1, SER, SSER #2, SSER #3, SSER

  1. 4, SSER #5)

Duke Power Company shall implement and maintain in effect all provisions of the approved fire protection program as described in the Final Safety Analysis Report, as amended, for the facility and as approved in the SER through Supplement 6, subject to the following provision below.

The licensee may make changes to the approved fire protection program without prior approval of the Commission only if those changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire.

(2) Discussion On April 24, 1986, the NRC issued Generic Letter 86-10, Implementation of Fire Protection Requirements. This document requested that each licensee incorporate the approved fire protection program by reference in the FSAR.

After having done so, the licensee could then apply for an amendment to the operating license to amend any current license condition regarding fire protection and substitute a recommended, standard condition.

Section 9.5 of the Catawba FSAR already includes a reference to the approved fire protection program for Catawba.

In recognition of Catawba's conformance with the requests of Generic Letter 86-10, Facility Operating License NPF-52 for Catawba Unit 2 includes the suggested standard license condition as License Condition (6).

Although the technical content of current Catawba Unit 1 License Condition 8 is essentially identical to the recommended, standard condition, it is desirable to have the same license condition for both Catawba units.

(3) Safety Analysis It is Duke Power Company's conclusion that revising the fire protection license condition to conform to the suggested license condition of Generic Letter 86-10 does not involve any adverse safety considerations. Both license conditions:

(1) require Duke to maintain in effect all provisions of the approved fire protection program, (2) allow Duke to make changes to features of the approved fire protection program which do not decrease the level of fire protection, and

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(3) do not allow Duke to make changes to features of the program which J

would decrease the level of fire protection in the plant without prior approval of the NRC.

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. The current license condition requires that changes to the approved fire protection program made without prior commission approval shall be reported annually to the Director of ONRR. This report has heretofore been submitted in accordance with 10 CFR 50.59(b). The standard license condition in Generic Letter 86-10 does not include the provision but instead directs licensees to submit the same information annually, along with i

i FSAR revisions required by 10 CFR 50.71(e). The two reporting methods are deemed to be equivalent.

(4) Analysis of Simpificant Hazards Consideration As required by 10 CFR 50.91, this analysis is provided concerning whether the proposed amendment involves significant hasards considerations, as defined by 10 CFR 50.91.

Standards for determination that a proposed i

amendment involves no significant hasards considerations are if operation of the facility in accordance with the proposed amendment would not 1) involve a significant increase in the probability or consequences of an

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accident previously evaluated; or 2) create the possibility of a new or different kind of accident from t.ny accident previously evaluated; or 3) i j

involve a significant reduction in a margin of safety.

The proposed amendment would not involve a significant increase in the probability or consequences of accidents previously evaluated since the proposed change is administrative in nature and would have no effect on cause mechanisms.

i The proposed amendment would not create the possibility of a new or different kind of accident than previously evaluated since the proposed i

change is administrative in nature.

In addition, no changes to margins of safety are involved in the proposed change.

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