ML20236H982
| ML20236H982 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek |
| 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.' '
' 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
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'.
4.-
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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