ML20205T375

Application for Amend to License NPF-12,deleting Fire Protection Elements from Tech Specs & Incorporating Fire Protection Evaluation Rept Into FSAR Chapter 9.Safety Evaluation Encl.Fee Paid

ML20205T375
Person / Time
Site:	Summer
Issue date:	03/31/1987
From:	Nauman D SOUTH CAROLINA ELECTRIC & GAS CO.
To:	Harold Denton Office of Nuclear Reactor Regulation
Shared Package
ML20205T379	List: ML20205T375 ML20205T391
References
GL-86-10, NUDOCS 8704070278
Download: ML20205T375 (5)

Text

10CFR50.36a

• Electric 8 Gas Company A. Naumm

,. mb 29218 Nuclear Operations SCE&G A BCnanCwxney March 31, 1987 Mr. H. R. Denton, Director Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, DC 20555

Subject:

Virgil C. Summer Nuclear Station Docket No. 50/395 Operating License NO. NPF-12 Fire Protection Technical Specification Amendment Request

Dear Mr. Denton:

South Carolina Electric & Gas Company (SCE&G) has been evaluating the concept of amending the FSAR, by incorporating our Fire Protection Evaluation Report (FPER) into the FSAR Chapter 9 by reference and removing the fire protection elements from the Virgil C. Summer Technical Specifications. This will transfer the fire protection program commitments, reporting requirements and amendments from the jurisdiction of 10CFR50.73 and 10CFR50.90 to 10CFR50.71(e). The Summer Fire Protection Program will be completely described and controlled through the FSAR/FPER and Station Administrative procedures rather than through the combination of FSAR/FPER and Technical Specifications. This will be consistent with the recommendations contained in Generic Letter 86-10.

The fire protection program in place at the Virgil C. Summer Nuclear Station meets the requirements of existing Technical Specifications. With relatively straightforward changes, the fire protection program can be incorporated into the FSAR as recommended by the Generic Letter. Based on discussions with the Staff and Region II during and af ter the Appendix R Audit in June,1985, we have begun developing these changes.

Attachment I to this letter provides a detailed discussion of the existing and modified fire protection programs. Compliance with fire protection requirements shall in no way be degraded by maintaining them in appropriate plant procedures and the FSAR/FPER. The proposed changes, Attachment II, provide additional flexibility for modifying requirements under the provisions of 10 CFR 50.59. The changes are also consistent with the NRC and the industry effort to simplify the Technical Specifications.

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E Mr. H. R. D;nt:n March 31, 1987 Page 2 The Safety Evaluation, Attachment III and No Significant Hazards Determination, Attachment IV, for the above changes are included along with three (3) original and forty (40) conformed copies of an Application for Amendment to Facility Operating License NPF-12. The requested changes have been reviewed and approved by the Plant Safety Review Committee and the Nuclear Safety Review Committee. The change, will be implemented upon NRC approval and after the necessary procedural revisions have been incorporated.

Please find enclosed the application fee of $150.00 required by 10 CFR 170.

If you should have any questions, please advise.

ry tr ly 66urs, D. , Na HID/ DAN:jez Attachments: I. Description of Existing and Proposed Virgil C. Summer Nuclear Station Fire Protection Program II. Revised Technical Specifications and License Condition III. Safety Evaluation IV. No Significant Hazards Determination c: 3. W. Dixon, Jr./T. C. Nichols, Jr. C. L. Ligon (NSRC)

E. C. Roberts R. M. Campbell, Jr.

O. S. Bradham K. E. Nodland D. R. Moore R. A. Stough J. G. Connelly, Jr. G. O. Percival W. A. Williams, Jr. R. L. Prevatte J. N. Grace J. B. Knotts, Jr.

Group Managers H. G. Shealy l

W. R. Baehr l NPCF l C. A. Price File

j Attachment I i Page 1 of 2 Description of the Existing and Proposed Virgil C. Summer Fire Protection Programs 2

Existina i

The existing Fire Protection Program is complete and has all of the implementing features of the controlling documents in place. This program consists of:

(1) FSAR Section 9.5.1

.; (2) Fire Protection Evaluation Report (FPER)

(3) Technical Specification Sections 3/4.3.3.7 Fire Detection Instrumentation-3/4.7.9 Fire Suppression Systems 3/4.7.10 Fire Rated Assemblies 6.6.2.(e) Fire Brigade 6.5.1.6 and 6.5.2.8 Administrative Controls for Fire Protection Related Bases

4) Surveillance Test Procedures

5) Preventative Test Procedures

6) Fire Protection Procedures

7) Security Plan Procedures

8) Station Administrative Procedures

9) Operations Quality Assurance Plan

10) Operating License Virgil C. Summer Nuclear Station Administrative Procedure, SAP-131, establishes the Fire Protection Program, and fire protection procedures implement the various features of fire protection according to CMEB BTP 9.5-1 and 10CFR50 Appendix R as described in the FPER. FSAR Section 9.5-1 provides a general discussion of the Fire Protection Program and invokes the FPER by reference.

The FPER includes a fire hazards analysis, safe shutdown summary, deviations, and a point by point comparison to BTP APCSB 9.5-1, Appendix A. At Virgil C.

Summer Nuclear Station, the FPER has been handled as an extension of the FSAR. Surveillance Test Procedures implement the surveillances required by the Technical Specifications.

! Proposal l l

FSAR Section 9.5.1 presently contains a discussion of fire protection l operations, testing, surveillances and remedial actions for inoperability.

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Attachment I Page 2 of 2 The fire protection associated sections listed above will be removed from the Technical Specifications. The existing Surveillance Test Procedures will be retained by converting them to Fire Test Procedures. The limiting conditions and remedial action portions of these sections will be re-established by expanding an existing Station Administrative procedure. This administrative procedure will contain the portion of the plant Fire Protection program previously contained within the Technical Specifications. An equivalent level of limiting conditions, and actions to be taken will be established within this procedure and other plant procedures to provide an equivalent level of protection as described in the existing Technical Specifications.

The Administrative portion of Technical Specification 6.2.2(e) will be invoked by the Station Administrative procedure described above. In addition, the entire series of Fire Protection Procedures, Preventative Test Procedures and Security Plan Procedures will be retained, as they also implement the plant Fire Protection Program in addition to our commitments presently discussed in the FSAR/FPER.

As previously indicated, SCE&G presently has in-place all of the documents / procedures to implement the current Technical Specification requirements for fire protection. By the end of the 3rd Quarter, CY-87, SCE&G is planning to have in-place the revised administrative procedure which replaces existing Technical Specification requirements, and will have prepared other plant procedures to effect all the aspects of rearrangement.

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Attachment II l

VIRGIL C. SUMMER REVISED TECHNICAL SPECIFICATIONS AND ,

LICENSE CONDITIONS i

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