ML20236H982

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Forwards Responses to Six NRC Comments Re 870417 Rev to Application for Amend to License NPF-42,modifying Fire Protection Requirements in Plant Procedures & Updated SAR Instead of Tech Specs.Revised Tech Specs Encl
ML20236H982
Person / Time
Site: Wolf Creek Wolf Creek Nuclear Operating Corporation icon.png
Issue date: 10/30/1987
From: Withers B
WOLF CREEK NUCLEAR OPERATING CORP.
To:
NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
Shared Package
ML20236H986 List:
References
WM-87-0300, NUDOCS 8711050074
Download: ML20236H982 (6)


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WSLF CREEK NUCLEAR OPERATING CORPORATION w

' President and October 30,'1987-sert o. wanert ca.m.cutwo otre.' '

WM 87-0300

' O.. S.: Nuclear Regulatory Commission -

ATTN Document. Control Desk-Washington, D. C. 20555

Reference:

'1).ULNRC-1447, dat'ed February 19, 1987, from' l

D. - F. ' Schnell, - Union Electric,. to NRC

2) KM 87-0068,- dated. March 2, 1987,-from B. D.-Withers, WCHOC.to NRC
3) ET 87-0155,~ dated April 17, 1987, from J. A. Bailey, WCNOC,'to NRC C

Subject:

Docket No. 50-482:

Response to Comments Concerning Fire Protection Technical. Specification Amendment Roquest l

Gentlemen:

Re ferenc e ' 3. transmitted a revision to a request. for amendment to Facility Operating License NPF-42 for Wolf Creek Generating Station.

The amendment request proposed. modifying existing license conditions regarding fire protection and placing fire protection requirements in~ plant procedures, and the Updated Safety Analysis Report instead of Technical Specifications.

During. discussions with members of the Nuclear Regulatory Commission staff,

six comments were mede concerning the proposed amendment request.

The responses to these comments are provided as Attachment I to this letter.

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Revised. portions of. the original ~ submittal are provided as Attachment II.

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The conclusions of the complete Safety Evaluation and Significant Hazards 1

Consideration transmitted by. Reference 1 as endorsed by Reference 2 remain

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valid.

If you have,any questions concerning this matter, please contact me or Mr.

j O. L. Maynard of my staff.

Very truly yours,

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Bart D. Withers 1

President and BDW/jad Chief Executive Officer

-Attachments: -I)

NRC Comments Concerning Fire Protection Technical l

Specification Amendment Request 1

II) Revised Marked-up Pages cc:

G. Allen (KDHE), w/a J. E. Cummins (NhC), w/a 0 [fl R. D. Martin (NRC), w/a 0p P. W. O'Connor -(NRC), 2 w/a 3

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P.O. Box 411/ Burlington, KS 66839 / Phone: (316) 364 8831 8711050074 871030 M Equal opportunity Ernployer MF,HCNET PDR ADOCK 05000482 P

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COUNIT OF COPFEY

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I Bart D.' Withers,, of-lawful age, being first duly sworn upon oath says.that he is President and Chief Executive : Officer of Wolf Creek Nuclear Operating l

Corporation; that he has read the foregoing docunent and knows the ccntent thereof; that he has executed. that : same for and ;on. behalf '~of said

' Corporation with full power' and authority to do so; and that;the facts

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. therein stated are true and correct to the' best.of his knowledge, information and belief.

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gy Bart D. Withers-l President and Chief Executive Offi xr i

SUBSCRIBED and sworn to before me this 30- day of M 1987.

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1 ATTACHMENT I 4

NRC COMMENTS CONCERNING FIRE PROTECTION TECHNICAL SPECIFICATION AMENDHENT REQUEST l

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AtEachment,to'I WMl87-0300 Page 1 of 2 i

October'30, 1987-NRC COMMENTS CONCERNING'

- FIRE PROTECTION TECHNICAL SPECIFICATION AMENDMENT REQUEST 1.

Confirm,that ' deletion,of-the fire protection technical specifications will not affect commitments to. Branch Technical ' Position APCSB.

9.5-1,'

Appendix'A and 10 CFR 50,. Appendix-R.

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Response

-The commitments: to Branch Technical Position APCSB 9.5-1,.

Appendix A^

and 10.CFR 50, Appendix R are~ not. changed as a-result 'of this change s

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request to-remove fire

. protection item s '. from the'ctechnical

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' speci fications.

l These documents are addressed in FSAR'(USAR. for. ' Wolf H

Creek) Appendixes 9.5 A and 9.5' E which are only being revised to -

include' items' which are being removed from~ the-specifications., ' Future' changes to these sections will' be made under the requirements 'of 10 CFR f

50.59.

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2.

The shutdown requirement of-Specification 3.7.10.1 ACTION b ' 'should be-retained in an appropriate commitment document.

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Response

A As part of 5 implementing'. the proposed revisions to-the Technical Speci fications, the requirements of Specification 3.7.10.1 Action b n

'will' be retained and will not be modified without prior approval from-1 the-Nuclear Regulatory Commission.(NRC).

. The requirements lo f.

1 Specification. 3.7.10.1. Action b'will be added to FSAR (USAR for Wolf Creek) Table.9.5.1-2 with a statement that no modi fications to these requirements will be made without prior approval from the NRC.

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. 3.

The. site Fire. Brigade requirement under the Unit Staff listing of

'Section 6.2.2.e should remain in the Technical Specifications.

Response

The site. Fire Brigade requirement will be retained in Section 6.2.2.e..

I of the Technical Specifications'.

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How will deviations from the fire protection program be handled with -

regard to deportability?.

Response

4 After the relocation of' fire protection system requirements from the

-Technical Speci fications,

events which may be potentially reportable i

will. still be evaluated relative to the criteria of 10 CFR 50.72, 10 CFR 50.73 and 10 CFR 21 on an individual basis.

A deportability determination will be made based on this evaluation process.

Events 1nvolving signi ficant degradation of the fire protection system would -

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be reportable.

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' Attachment I to WM.87-0300 Page 2 of:-2 October 30,x1987" s

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Is.your~ post-fire. alternate. shutdown capabilit'y covered by Technical Specifications and therefore in conformance with Generic Letter. 81-12.

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< Technical Specification 3.3.3.5 requires that. specific remote. shutdown monitoring. instrumentation channels and the auxiliary shutdown panel p

l controls shall~be OPERABLE with readouts displayed external to the i

l' control room.

The ' Bases for this1 Technical Specification states that, "The 0PERABILITY of the Remote Shutdown System ensures 'that sufficient capability; is available to permit shutdown and maintenance of HOT SHUTDOWN of the facility from locations outside the control ' room and that: a-fire.will not preclude achieving sa fe shutdown."

Since Technical Specification 3.3.3.5 covers instrumentation in addition; to that required for safe shutdown in the event of,a control room fire, no modification has been proposed to this Technical Specification or-its associated bases..

6.

Confirm the accuracy.of proposed FSAR (USAR for Wolf Creek) Table l

9.5.1-2.

Response

The proposed. FSAR (USAR for Wolf Creek) Table 9.5.1-2 was provided for in formation with lthe proposed Technical Specification = changes.

This table will be finalized to accurately and completely address all current Technical Specification requirements as part of the normal FSAR (USAR for Wolf Creek) revision process.

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i ATTACHMENT II REVISED HARKED-UP PAGES j

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