ML20212L310
| ML20212L310 | |
| Person / Time | |
|---|---|
| Site: | McGuire, Mcguire  |
| Issue date: | 03/09/1987 |
| From: | Tucker H DUKE POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20212L314 | List: |
| References | |
| NUDOCS 8703100350 | |
| Download: ML20212L310 (9) | |
Text
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DUKE POWER GOMPANY P.O. DO x 3 3180 CHARLOTTE. N.C. 28242 IIAL B. TUCKER TELEPHOPrE vu a cumssnewt (704) G T3-4531 wtstaan emootweson March 9, 1987 U.S. Nuclear Regulatory Commission l
Document Control Desk Washington, D.C. 20555
Subject:
McGuire Nuclear Station Docket Nos. 50-369, 50-370 Proposed Technical Specification Amendment Relocation of Fire Protection Requirements to the McGuire FSAR Gentlemen:
Attached are proposed license amendments to Facility Operating Licenses NPF-9 and NPF-17 for McGuire Nuclear Station, Units 1 and 2, respectively. These proposed changes seek to relocate all Fire Protection related requirements from technical specifications to the McGuire FSAR while adding the Fire Protection program to those items included in Specifications 6.5.1 and 6.8.1. Additionally, revisions to the appropriate license conditions are proposed.
The following is a summary of the attachments to this letter:
o Attachment 1 provides a justification for the proposed change and analysis of significant hazards consideration.
o Attachment 2 provides the proposed revision to the McGuire Facility Operating Licenses and Technical Specifications.
o Attachment 3 provides proposed revisions to the Bases of Technical Specifi-cations.
o Attachment 4 provides the proposed revision to the McGuire FSAR.
Duke requests that this proposal be reviewed and approved in a timely manner. We understand that the Staff may desire to handle this particular subject via a lead plant. At the present time, Duke has not sought and does not plan to seek en-dorsement by either the Westinghouse Owners Group or AIF to be a lead plant on this subject. Duke is aware that the Westinghouse Owners Group has endorsed a forthcoming application of SNUPPS on behalf of KG&E and Union Electric (reference WOG 1etter OG-87-1 dated January 9, 1987 to H. Denton). Duke believes that our submittal is consistent with the above proposed technical specification. Duke will monitor the results of NRC review of the lead plant submittal and, if neces-sary, modify our submittal to gain approval, pk(>D
. s 8703100350 870309 DR ADOCK 05000369 PDR 14Q9g O{f
Document Control Desk' March 9, 1987 Page 2 Pursuant to 10CFR170.3(y),170.12(c), and 170.21, . Duke Power proposes that this
' application contains . license amendsents for McGuire Units 1 and 2 subject to fees based on the full cost of the review (to be calculated using the applicable
-professional staff rates shown in 10CFR170.20) and must be accompanied by an
- application fee uof $150.00, with the NRC to bill Duke Power at six-month intervals for all accumulated costs for the application or when review is completed, which-ever is earlier. Accordingly, please find enclosed a check in the amount of
'$150.00.
' Finally, with this submittal, Duke Power withdraws the proposed license ' amendment .
request submitted by letter dated September 7,1984 as supplemented April 9,1985.
Should there be any questions concerning this matter or if additional information is required, please advise.
Very truly yours, Hal B. Tucker RLG/177/j gm Attachments xc Dr. J. Nelson Grace, Regional Administrator U.S. Nuclear Regulatory Commission - Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 Mr. Dayne Brown, Chief Radiation Protection Branch Division of Facility Services Department of Human Resources P.O. Box 12200 Raleigh, North Carolina 27605 W.T. Orders NRC Resident Inspector McGuire Nuclear Station Darl Hood, Project Manager Division of Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555
' Document Control Desk March 9,~1987
-Page 4-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 Constission this ravision to the McGuire Nuclear Station License Nos. NPF-9'and NPF-17 and that all statements and matters set-forth therein are true and correct to the best of his knowledge.
M Y-Ha1 B. Tucker, Vice President Subscribed and sworn to before me this 9th day of March, 1987.
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ATTACHMENT i 2
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JUSTIFICATION FOR PROPOSED CHANGE
! ANALYSIS AND SIGNIFICANT HAZARDS. CONSIDERATION
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- . (RLG177)
' Attachment 1 SC Page 1 JUSTIFICATION FOR PROPOSED CHANGE By letter da'ted April 24, 1986, NRC issued Generic Letter 86-10 "ImplementationL
' of Fire Protection Requirements". This letter directed the incorporation of the fire protection program into the FSAR.for each facility. In the 1985 Update to the McGuire FSAR, Duke incorporated reference to the."McGuire Nuclear Station Fire Protection Review". - (Reference Duke letter dated July 1, 1986). Following-
' implementation of this change, a significant reduction in the content of the fire
, protection related technical specifications is appropriate. Such action is
' consistent'with the objectives of the NRC Technical Specification Improvement Program by reducing bcth the size and complexity of current Technical Specifi--
cations.
Attachments 2 and '3 provide proposed revisions to the McGuire Facility Operating Licenses, Technical Specifications, and Bases. The following is a brief summary of these changes:
- 1. NPF-9 License Condition C.(4) and NPF-17 License Condition C.(7) are revised to delete requirements to complete certain modifications which have been
~. completed.
- 2. .The Limiting Conditions for Operations (LCO) and Surveillance Requirements
- - (SR) for Specification 3/4.3.3.7 or Fire Detection Instrumentation are removed fren Technical Specifications.
- 3. The LCO's and SR's for Specification 3/4.7.10 Fire Suppression Systems are n removed. ,
- 4. The LCO's and SR's for Specification 3/4.7.11 Fire Barrier Penetrations are removed.
- 5. Specification 6.2.2.e on Unit Staff fire brigade requirements is removed.
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- 6. Specification 6.5.1.12 requiring the inclusion of the Fire Protection Program under the items requiring technical review and cost 7ol is added.
- 7. Specification 6.8.1.h requiring the inclusfs4 ;f tl Fire Protection Program under Procedures and Programs controls is ad 40.
, 8. Items in the Index and applicable Bases sections are removed.
The remedial action and surveillance requirements of the existing Technical Specifications on fire prctection (Specifications 3/4.3.3.7, 3/4.7.10 and 4 - 3/4.7.11) presently exist in plant procedures. The fire brigade staffing re-quirements of the existing Technical Specifications (Specification 6.2.2.e) also 4
presently exist in a plant procedure. Changes to these procedures would be subject to the added Technical Specification requirements on administrative '
controls, Section 6.
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n-Attachment 1 Page 2 1
As an additional ail in identifying, locating and using'these requirements, Duke l has elected to locate these items in McGuire FSAR Chapter 16.0.. '(Please reference Duke. letter dated September 15 1986 which introduced this concept.) For the information of the Staff, Attachment 4 provides the proposed revision to the
~McGuire FSAR which will be included in the next update. It is our plan to locate a copy of.FSAR Chapter 16.0 along with the Technical Specifications in the McGuire Control Room to allow ready access by the operators.
The addition of the fire protection program to the defined list of items requiring technical review and control and to the procedures and programs requirements in Section 6 of the Technical' Specification on administrative controls reinforces the 1
importance of the fire protection program on plant safety. Therefore, these additions are appropriate and consistent with requirements established for similar programs such as the security and emergency plans. The changes to the adminis-trative controls in Section 6 of the Technical Specifications assures a multi-i discipline review of proposed changes to those requirements which are removed from the Technical Specifications and placed in plant procedures.
i
. ANALYSIS OF SIGNIFICANT HAZARDS CONSIDERATION As required by 10CFR50.91, this analysis is provided concerning whether the proposed amendments involve significant hazards considerations, as defined by 10CFR50.92. Standards for determination that a proposed amendment involves no significant hazards 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 accident previously evaluated; or 2) create the
. possibility of a- new or different kind of accident from any accident previously evaluated; or 3) involve a significant reduction in a margin of safety.
Duke is not unique in proposing to relocate Fire Protection requirements from technical specifications. This concept has been accepted by the Staff for at least two NTOL plants. Further, the NRC Staff has suggested that this item be termed a short-term problem that could be handled by the industry using the lead j plant process. Duke is aware of several other utilities that either have proposed or will shortly propose license amendments to remove Fire Protection requirements l frem technical specifications.
l "The details of the proposed change have been previously discussed. The fire protection requirements will still be maintained utilizing multi-discipline review of'all proposed changes. The requirements are still enforceable by virtue of having a specific license condition along with details provided in the FSAR, the Fire Protection Review document, and the Fire Protection Commitment Index.
l' Duke believes that this proposed change is essentially an administrative change in j that the technical requirements are not being directly changed.
The proposed changes to the Technical Specifications do not involve a significant increase in the probability or consequences of an accident previously evaluated.
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Attachment 1
-j Page 3 i
No changes to the efisting requirements for Fire Protection equipment have been made. This proposed revision to technical specifications relocates the existing '
requirements to the McGuire FSAR, Chapter 16. Plant procedures presently exist, )
as identified on each commitment, and are unaffected by this change. Review of the Fire Protection Program and its revisions continues to be the responsibility of plant staff (TS 6.8) and of the Nuclear Safety Review Board (TS 6.5.2).
l The changes do not create the possibility of a new or different kind of accident from any previously evaluated. As above, the proposed changes do not alter the technical requirements; they are relocated from the Technical Specifications to the FSAR. Plant procedures will continue to provide the specific instructions for implementing the LCO, Action and surveillance requirements. There have been no relaxation of commitment and, as incorporated into the plant procedures, the changes are the same as present Technical Specifications.
These changes do not involve a significant reduction in the margin of safety. No technical changes to the existing requirements are being proposed. As above, the existing fire protection related requirements are being relocated to FSAR Chapter 16. Plant procedures will continue to provide the specific instructions necessary for the implementation of the requirements, just as they had when the requirements resided in Technical Specifications.
The proposed changes to License Conditions C.(4) of NPF-9 and C.(7) of NPF-17 are revised in accordance with guidance provided in Generic Letter 86-10, Implementation of Fire Protection Requirements. In addition, certain aspects of the conditions that require modifications be completed by a given date are deleted as they are unnecessary. What remains.are specific conditions for fire protection plan requirements.
This change to the license conditions does not involve c significant increase in the probability or consequences of an accident previously evaluated.
The change in license conditions from those previously incorporated into the license to the one presented in Generic Letter 86-10 does not result in any loss of control of the change process.
Previously, changes to the Fire Protection Program that affected the level of fire protection in the plant could only be made with prior Commission approval
, utilizing the license amendment process (10CFR 50.90). The new license condition requires prior Commission only for changes that would adversely affect the level of fire protection approval but utilizes the 10CFR 50.59 process.
This change does not create the possibility of a new or different kind of accident from any previously evaluated. The proposed license conditions do not involve any significant change in requirements and are recommended by the NRC in Generic Letter 86-10.
This change does not involve a significant reduction in the margin of safety. The proposed license condition does not involve any significant change in requirements and was recommended by the NRC in Generic Letter 86-10.
Based on the preceding discussions, Duke considers that this request does not involve a significant hazard.
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ATTACHMENT 2 PROPOSED REVISION TO FACILITY OPERATING LICENSES NPF-9 AND NPF-17 AND REVISION TO TECHNICAL SPECIFICATIONS k
l (RLG177) i r
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- 1. Revise NPF-9, License Condition C. (4) as follows:
(4). Fire Protection Program-
- a. .The licensee shall maintain in effect and fully imple-ment all providions of the approved fire protection plan and the NRC staff's McGuire Safety Evaluation Report Fire Protection Review in Supplement No. 2 to the McGuire Nuclear Station Safety Evaluation Report, dated March 1979. Duke Power Company shall comply with Sections III.G, Fire Protection of Safe
. ~ Shutdown capability, including Section III.L.
Alternative and Dedicated Shutdown Capability, as appropriate; III.J, Emergency Lighting (except for the Standby Shutdown Facility and the exterior access and egress route west of the Turbine Building); and III.0, Oil Collection System for Reactor Coolant Pump, of Appendix R to 10 CFR Part 50, dated November 19,.1980. -
- b. 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. Revise NPF-17, License Condition C.(7) as follows:
(7) Fire Protection Program (Section 9.5.1 of SER, SSER #2, #5, f 6)
(a) The licensee shall fully implement and maintain in effect all provisions of the approved fire protec-tion plan as amended in September 1982 and the Fire Protection Review in Supplement No. 5 to the McGuire l Nuclear Station Safety Evaluation Report, dated 4
March 1979. Prior to March 1, 1984, the licensee i shall meet the technical requirements of Sections
( III.G, Fire Protection of Safe Shutdown Capability, including Section III.L. Alternative and Dedicated Shutdown capability, as appropriate; III.J, Emer-gency Lighting (except for the Standby Shutdown Facility and the exterior access and egress route west of the Turbine Building); and III.0, Oil L Collection System for Reactor Coolant Pump, of Appendix R to 10 CFR Part 50, and shall complete to the satisfaction of the NRC all required fire L protection items identified in Table 9.5-1 as revised in Supplement No. 6 and Appendix B of Supplement 5 to the Safety Evaluation Report (NUREG-0422, February 1983 and April 1981).
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(b) 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.
INDEX
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LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REQU SECTION --
P., AGE TABLE 4.3-6 REMOTE SHUTOOWN MONITORING INSTRUMENTATION SURVEILLANCE REQUIREMENTS..........................3/4 3-54 Accident Monitoring Instrumentation....................... 3/4 3-55 TA8LE 3.3-10 ACCIDENT MONITORING INSTRUMENTATION.................. 3/4 3-56 TABLE 4.3-7 ACCIDENT MONITORING INSTRUMENTATION SURVEILLANCE REQUIREMENTS..........................3/4 3-57 3M a Ca m ivo :.. :n :-A m r .
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Radioactive Liquid Effluent Monitoring Instrumentation.... 3/4 3-66 TABLE 3.3-12 RADI0 ACTIVE LIQUID EFFLUENT MONITORING INSTRUMENTATION.................................... 3/4 3-67 TA8LE 4.3-8 RADI0 ACTIVE LIQUID EFFLUENT MONITORING INSTRUMENTATION SURVEILLANCE REQUIREMENTS.......... 3/4 3-69
'k Radioactive Gaseous Effluent Monitoring Instrumentation... 3/43,-71 TABLE 3.3-13 .
RADIOACTIVE GASEOUS EFFLUENT MONITORING INSTRUMENTATION.................................... ')/4 3-72 TABLE 4.3-9 RADIOACTIVE GASEOUS EFFLUENT MONITORING INSTRUMENTATION SURVEILLANCE REQUIREMENTS. 3/4 3-75. . . . . . . .
Loose-Part Detection System .............................. 3/4 3-78 3/4.3.4 TURBINE OVERSPEED PROTECTION.............................. 3/4 3-79 3/4.4 REACTOR COOLANT SYSTEM 3/4.4.1 REACTOR COOLANT LOOPS AND COOLANT CIRCULATION Stactup and Power Operation..............................
3/4 4-1 Hot Standby.............................................. 3/4 4-2 Hot Shutdown............................................. 3/4 4-3 Cold Shutdown - Loops Filled............................. 3/4 4-5 8703100354 870309 PDR ADOCK 0500 9 P . .
VII '
McGUIRE - UNITS 1 and 2 1
l INDEX LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REQUIREMENTS SECTION
- PAGE 3/4.7.5 3 TAN 08Y NUCLEAR SERVICE WATER PON0....................... 3/4 7-12 3/4.7.6 CONTROL AREA VENTILATION SYSTEM. . . . . . . . . . . . . . . . 3/4 . . . 7-13 3/4.7.7 AUXILIARY BUILDING FILTERED VENTILATION EXHAU$T3/4 SYSTEM...
7-16 3/4.7.8 SNUB 8ERS................................................. 3/4 7-18 TABLE 3.7-4a SAFETY-RELATED HYORAULIC SNUBBERS (UNITS 13/4 AND 7-23 2)....
TABLE 3.7-4b l SAFETY-RELATED MECHANICAL SNUBBERS (UNITS3/4 1 ANO 7-26 2)...
1 FIGURE 4.7-1 SAMPLING PLAN FOR SNU68ER FUNCTIONAL TEST ,
3/4 7-29 ........... 1 3/4.7.9 SEALED SOURCE CONTAMINATION. . . . . . . . . . . . . . . . . . 3/4 . . . 7-30 3/4.7.10 T!" C'.'.""Zi!!^" ;";T^X- } Q.LTY D
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h . . . ? 7-An 3/4/7.12 AREATEMPERAkUREMONITORING......................./....... 3/4 7-42 TABLE 3.7-6 AREA TEMPERATURE MONITORING............................ 3/4 7-43 3/4.7.13 GROUNDWATER LEVEL......................................... 3/4 7-44 TABLE 3.7-7 GROUNDWATER LEVEL MONITORING STATIONS.................. 3/4 7-46 3/4.8 ELECTRICAL POWER SYSTEMS 3/4.8.1 A.C. SOURCES Operating................................................ 3/4 8-1 TABLE 4.8-1 DIESEL GENERATOR TEST SCHEDULE. . . . . . . . . . . . 3/4 . . . .8-8
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XII -
McGUIRE - UNITS 1 and 2 -
INDEX BASES SECTION
_ PAGE 3/4.7.3 COMPONENT C00 LING WATER SYSTEM............................ 8 3/4 7-3 i 3/4.7.4 NUCLEAR SERVICE WATER SYSTEM..............................
8 3/4 7-3 3/4.7.5 STANOBY NUCLEAR SERVICE WATER PON0........................ 8 3/4 7-3 3/4.7.6 CONTROL AREA VENTILATION SYSTEM........................... 8 3/4 7-4 3/4.7.7 AUXILIARY BUILDING FILTERED VENTILATION EXHAUST SYSTEM.... 8 3/4 7-4 3/4.7.8 SNUBBERS.................................................. B 3/4 7-5 3/4.7:9 SEALED SOURCE CONTAMINATION............................... 8 3/4 7-6 "D % t T t. b .
3/4.7.10 ":": : ."T.:E!!!" EYE'E" . . /; 7 o
'bLLLTib 3/4.7.11 T:": """"!E" ^5"!'P3?!0"!. . . . . . . . . .
" l't 7 7 3/4.7.12 AREA TEMPERATURE MONITORING............................... B 3/4 7-7 3/4.i.13 GROUNDWATER LEVEL......................................... B 3/4 7-8
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3/4.8 ELECTRICAL POWER SYSTEMS 3/4.8.1, 3/4.8.2 and 3/4.8.3 A.C. SOURCES, O.C. SOURCES AND ONSITE POWER DISTRIBUTION SYSTEMS........................
B 3/4 8-J 3/4.8.4 ELECTRICAL EQUIPMENT PROTECTIVE DEVICES................... B 3/4 8-3 3/4.9 REFUELING OPERATIONS 3/4.9.1 BORON CONCENTRATION......... ............................. 8 3/4 9-1 '
3/4.9.2 INSTRUMENTATION........................................... B 3/4 9-1 3/4.9.3 OECAY TIME................................................ B 3/4 9-1 3/4.9.4 CONTAINMENT BUILDING, PENETRATIONS......................... B 3/4 9-1 3/4.9.5 C0MMUNICATIDNS..............................-............. 8 3/4 9-2 3/4.9.6 MANIPULATOR CRANE."........................................- 8 3/4 9-2 3/4.9.7 CRANE TRAVEL - SPENT FUEL STORAGE POOL BUILDING. . . . . . . . . 8 . . 3/4 9-2 3/4.9.8 RESIDUAL NEAT REMOVAL AND COOLANT CIRCULATION. . . . . . . . . .8. .3/4 . 9-2 )
3/4.9.9 and 3/4. 9.10 WATER LEVEL - REACTOR VESSEL and STORAGE P00L............................................ S 3/4 9-3 XVIII ~
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