ML20237G917
| ML20237G917 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 08/28/1987 |
| From: | Tucker H DUKE POWER CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| Shared Package | |
| ML20237G919 | List: |
| References | |
| TAC-66053, TAC-66054, NUDOCS 8709030031 | |
| Download: ML20237G917 (8) | |
Text
DUKE POWER Coxym
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P.O. Dox 33180 011AltLOTTE. N.O. 28242 TELEPHONE HAL IL TUCKER (704) 373-4531 vmr ymmument Mt:0 LEAR PapptTCTION August 28, 1987 U. S. Nuclear Regulatory Commission Attention: Document Control Desk l
Washington, D. C. 20555 l
Re:
Catawba Nuclear Station, Units 1 and 2 Docket Nos. 50-413 and 50-414 Proposed Technical Specification Amendment Relocation of Fire Protection Requirements l
To the Catawba FSAR i
l Gentlemen:
Attached are proposed license amendments to Facility Operating Licenses NPF-35 and NPF-52 for Catawba Nuclear Station, Units 1 and 2, respectively. These proposed changes seek to relocate all Fire Protection related requirements from Technic =1 Specifications to the Catawba FSAR while adding the Fire Protection program to those items included in Specifications 6.5.1 and 6.8.1.
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The following is a summary of the attachments to this letter:
1 o Attschaent 1 providee a justification for the proposed change and analysis of significant hazards consideration. provides the proposed revision to the Catawba Technical o
Specif1 cations and Bases. provides the proposed revision to the Catawba FSAR.
o 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 n-' c plant. At the present time, Duke has not sought and does not plan to seek endorsement by the Westinghouse Owners Group to be a lead plant on this subject.
@o Duke is aware that the Westinghouse Owners Group has endorsed an application of No SNUPPS o:. behalf of KG&E and Union Electric (reference WOG letter OG-87-1 dated OO January 9, 1987 to H. Denton).
Duke believes that our submittal is consistent M
with the above proposed Technical Specification. Duke will monitor the results gg of NRC review of the lead plant submittal, and if necessary, modify our submittal n<
to gain approval.
o 0*ox This request involves one amendment request to Catawba's Technical Specifications.
S$ct Accordingly, pursuant to 10 CFR 170.21 & check for $150.00 is encicsed.
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U. S. Nuclear Regulatory Commission August 28, 1987 Page Two Pursuant to 10 CFR 50.91 (b) (1) the appropriate South Carolina State Official is being provided a copy of this amendment request.
Very truly yours, 4%dC I
Hal B. Tucker l
RWO/110/sbn Attachment xc:
Dr. J. Nelson Grace, Regional Administrator U. S. Nuclear Regulatory Commission Region II i
101 Marietta Ftreet, NW, Suite 2900 l
Atlanta, Georgia 30323 1
Mr. Heyward Shealy, Chief l
Bureau of Radiological Health South Carolina Department of Health &
Environmental Control 2600 Bull Street Columbia, South Carolina 29201 i
American Nuclear Insurers c/o Dottie Sherman, ANI Library i
The Exchange, Suite 245 l
270 Farmington Avenue Farmington, CT 06032 M&M Nuclear Consultants 1221 Avenue of the Americas New York, New York 10020 INPO Records Center Suite 1500 1100 Circle '5 Parkway Atlanta, Georgia 30339 Mr. P. K. Van Doorn NRC Resident Inspector Catawba Nuclear Station
U. S. Nuclear Regulatory Commission August 28, 1987 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 revision to the Catawba Nuclear Station Technical.', specifications, Appendix A to License Nos. NPF-35 and NPF-52; and that all statements and matters set forth therein are true and correct to the best of
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his knowledge.
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i fW j-Hal B. Tucker, Vice President Subscribed and sworn to before me this 28th day of August, 1987.
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i ATTACHMENT 1 JUSTIFICATION FOR PROPOSED CHANGE ANALYSIS AND SIGNIFICANT HAZARDS CONSIDERATION 4
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JUSTIFICATION FOR PROPOSED CHANGE By letter dated April 24, 1986, NRC issued Generic Letter 86-10, " Implementation of Fire Protection Requirements". A response to this Generic Letter was provided for Catawba by letter dated August 12, 1986. The Generic Letter, in part, directed the incorporation of the fire protection program into the FSAR for each facility. This amendment request is in response to this particular point contained in the Generic Letter.
Following implementation of this proposed change, a significant reduction in the content of the fire protection related Technical Specifications will be achieved.
Such action is consistent with the objectives of the NRC Technical Specification Improvement Program by reducing both the size and complexity of current Technical Specifications.
Attachments 2 and 3 provide proposed revisions to the Catawba Technical Specifications, Bases, and FSAR. The following is a brief summary of these l
changes:
(1) The Limiting Conditions for Operations (LCO) and Surveillance Requirements (SR) for Specification 3/4.3.3.8 - Fire Detection Instrumentation are removed i
from Technical Specifications.
1 (2) The LCOs and SRs for Specification 3/4.7.10 - Fire Suppression Systems Spray and/or Sprinkler Systems, CO Systems and Fire Hose Stations are removed.
2 (3) The LCOs and SRs for Specification 3/4.7.11 - Fire Barrier Penetrations are removed.
(4) The LCOs and SRs for Specification 3/4.7.13 - Standby Shutdown System are removed.
I (5) Specification 6.2.2e. 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 control is added.
(7) Specification 6.8.1h. requiring the inclusion of the Fire Protection Program under Procedures and Programs controls is added.
(8) Specification 6.8.11. requiring the inclusion of the Commitments contained in FSAR Chapter 16.0 under Procedures and Programs control is added.
(9) Items in the Index and applicable Bases sections are removed.
The remedial action and Surveillance Requirements of the existing Technical Specifications on fire protection (Specifications 3/4.3.3.8, 3/4.7.10, 3/4.7.11 and 3/4.7.13) presently exist in plant procedures.
The fire brigade staffing requirements of the existing Technical SpeM fications (Specification 6.2.2e.) also presently exist in a plant procedure.
Changes to these procedures would be subject to the added Technical Specification requirements on Administrative Controls, Section 6.
As an additional aid in identifying, locating and using these requirements, Duke has elected to locate these itema in Catawba FSAR Chapter 16.0.
For the information of the Staff, Attachment 3 provides the proposed revision to the q
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Catawba FSAR which will be included in the next update.
It is our plan to locate 1
a copy of FSAR Chapter 16.0 along with the Technical Specifications in the Control Room to allow ready access by the operators.
j The addition of the fire protection program to the defined list of items requiring 4
technical review and control and to the procedures and programs requirements in
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Section 6 of the Technical Specifications on Administrative Controls reinforces tha importance of the fire protection program on plant safety. Therefore, thasa additions are appropriate and consistent with requirements established for sir i.r programs such as the security and emergency plans. The changes to the Administrative Controls in Section 6 of the Technical Specifications assures a multi-discipline review of proposed changes to those requirements which are removed from the Technical Specifications and placed in plant procedures.
ANALYSIS OF SIGNIFICANT HAZARDS CONSIDERATION As required by 10 CFR 50.91, this analysis is provided concerning whether the I
proposed amendments involve significant hazards considerations, as defined by 10 l
I CFR 50.92.
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 I
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 reloctte fire protection requirements from l
Tnchnical Specifications. This concept has been accepted by the Staff for at least l
two NTOL plants.
Further, the NRC Staf; has suggested that this item be termed a l
short-term improvement item that could be handled by the industry using the lead plant process. Duke is aware of several other utilities that either have proposed I
or will shortly propose license amendments to remove fire protection requirements from Technical Specifications.
The details of the proposed change have been previously submitted for the McGuire l
Nuclear Station (letter dated March 9, 1987). 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 rpecific license condition (license condition #8 for NPF-35 and license condition #6 for NPF-52) along with details provided in the FSAR, the fire protection review document, and the fire Protection Commitment Index.
Duke believes that this proposed change is essentially an administrative change in 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.
No changes to the existing requirements for fire protection equipment have been made.
This proposed revision to Technical Specifications relocates the existing requirements to Catawba 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).
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l l l The changes do not create the possibility of a new or different kind of accident from any accident previously evaluated. As above, the proposed changes do not alter the technical requirements; they are to be relocated from the Technical l
Specifications to the FSAR.
Plant procedures will continue to provide the specific
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instructions for implementing the LCOs, Actions and Surveillance Requirements.
There have been no relaxation of commitments and, as incorporated into the plant procedures, the changes are the same as present Technical Specifications.
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These c?.antms do not involve a significant reduction in the margin of safety.
No technical changes to the existing requirements are being proposed.
As stated 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.
Based on the preceding discussions, Duke conriders that this amendment request does not involve significant hazards consideration ns.
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ATTACHMENT 2 PROPOSED CHANGES TO TECHNICAL SPECIFICATIONS AND BASES i
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