ML20247H382

Provides Addl Info Re 870309 & 890320 Applications for Amends to Licenses NPF-9 & NPF-17,relocating Fire Protection Requirements to FSAR Per Generic Ltrs 86-10 & 88-12,in Response to 890427 Telcon

ML20247H382
Person / Time
Site:	McGuire, Mcguire
Issue date:	05/19/1989
From:	Tucker H DUKE POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20247H389	List: ML20247H382 ML20247H392
References
GL-86-10, GL-88-12, NUDOCS 8905310225
Download: ML20247H382 (6)

Text

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DUKE POWER GOMPANYL P.O. Box 33189 7- .

. CHAMLOTTE, N.C. 28242

.HALH.TUCKEH TELEPHO!rE -

ma enemment (704) 073-4rb31 anotsam emooverson .

May 19, 1989

'U..S. Nuclear Regulatory Commission Document Control Desk-Washington, D.C. 20555

Subject:

McGuire Nuclear Station Docket Nos. 50-369 and 50-370 NRC Generic Letter Nos. 86-10 and 88-12 Relocation of Fire Protection Requirements to the McGuire FSAR-Proposed Technical Specification / License Condition /FSAR SLC Changes (T.S.'s 3/4.3.3.7/3/4.7.10.1 thru 4/3/4.7.11/6.2.2/6.5.1/6.8.1// '

Lic. Cond. 2.C.(4)/2.C.(7)//SLC's 16.9-1 thru 7/16.13-1)

Revision / Supplement My letter of March 9, 1987, as revised by my. letter of March 20, 1989, submitted

-proposed license amendments (pursuant to 10CFR 50.4 and 50.90) to Facili+.y 1 Operating Licenses NPF-9 and NPF-17 for McGuire Nuclear Station Units 1 and 2, respectively, along with' attendant proposed revisions to the McGuire Nuclear

~ Station Final Safety Analysis Report (FSAR). The proposed amendments / revisions-are based on NRC Generic Letters Nos. 86-10 and 88-12 and seek to relocate all fire protection related requirements from McGuire Technical Specifications to the FSAR while adding'the fire protection program to those items included in Tech.

Specs. 6.5.1 and 6.8.1. Additionally, revisions to the appropriate fire protection' program license conditions were proposed. The " Notice of Consideration of Issuance of Amcndmants to Facility Operating Licenses and Proposed No Significant Hazards Consideration' Determination and Opportunity for Hearing" related to the proposed -amendments was published in the Federal Register on May 4, 1989.

The' proposed amendments / revisions were discussed in a Telecon on April 27, 1989 between~P. B. Nardoci, H. D. Brandes (DPC), D. S. Hood, and D. J. Kubicki of your staff. It was determined during this Telecon that based on NRC's review of the proposed amendments / revisions certain changes need to be made to the proposal.

These changes involved more directly/ completely incorporating the McGuire Fire Protection Review and Supplements into the FSAR (Section 9.5.1), and revising the

- proposed Fire Protection Program license conditions to more closely adhere to the standard version provided in Generic Letter 86-10. In addition, another copy of the McGuire Fire Protection Review Manual was requested to replace.one that was

.previously submitted but misplaced. Accordingly, this letter provides the subject changes and manual.

8905310225 890519 'm p

DR ADOCK 05000369 PNV k(

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' 1)ocument Control Desk '

. May 19, 1989

, Pap,e 2 Attachment 1 is the proposed revision to McGuire FSAR Section 9.5.1. While Duke felt that adequate incorporation (by reference) oi the McGuire Nuclear Statien Fire Protection Review into the FSAR had been handled by the 1985 update to the FSAR (as discussed in the March 9, 1987 submittal) and revisions proposed in the March 20, 1989 submittal, the NRC felt that a stronger reference similar to that.

contained in a n@ 3 April 18, 1988 Catawba Nuclear Station submittal was needed. The p % m m revision, which summarizes all fire protection related correspondence ana commitments submitted to the NRC for the McGuire Nuclear

. Station, meets that guidance. This proposed revision supplements the FSAR revisions proposed in the March 9, 1987 and March 20, 1989 submittals, and will be incorporated into the FSAR in the next applicable annual FSAR updr.te, (1989 update which will be submitted in 1990).

Attachment 2 is the prcposed revisions to McGuire Nuclear Station Facility Operating Licenses NPF-9 (Unit 1) Condition 2.C.(4) and NPF-17 (Unit 2) Condition 2.C.(7), " Fire Protection Program." '"he License conditions Duke proposed in the March 9, 1987 submittal were hybrids of the standard fire protection license condition contained in Generic Letter 86-10 and specific conditions for Fire Protection Plan requirements contained in the currently applicable license conditions, deleting certain aspects of the currently applicable license conditions (requiring modifications be completed by a certain date) that are ,

unnecessary. This was done due to Duke's bclief that the standard license }

condition would not address all of the plant specific provisions of the currently applicable license conditions since the entire McGuire Fire Protection Program has not yet received formal NRC approval (as discussed in the March 20, 1989 Jetter). However, in the April 27th Telecon we vera instructed (in accordance with the guidance in the Generic Letters) to propose only the standard Heense condition contained in Generic Letter l'6-10, letting it completely replace the currently applicable license conditions. This should be acceptable since the NRC i intends to wait until approval of the entire Fire Protection Program (e.g.

including the two upcoming SER's discussed below) before issuing the Fire  !

Protection Relocation Amendment (the two SER's will be added to the proposed

" Standard" License Condition by the NRC follming agreement by Duke).

Consequently, the attached proposed license conditions supersede those previously proposed in t5,e March 9, 1987 submittal in their entirety.

Also, the requested copy of the' current version of the McGuire Nuclear Station Fire Protection Review Manual has been previously provided under separate cover.

In addition, as discussed in the April 27th telecon and another en May 2, 1989, copies of the recent (1936 and 1989) revisions to this manual were provided as an aid in determining what changes have been made since the last NRC review / approval

[1985 revision-changes since then have been editorial (improving documentation, etc.) rather than technical changes to the program).

In addition to the above requested changes and manual, other matters discussed in the April 27th telecon and a follow-up telecon on May 2, 1989 included upcoming Fire Protection Frogram SFRs and the Standby Shutdown System (SSS) Technical Specification. It is our understanding that the NRC will be issuing SERs concerning our Appendix R criteria deviations submittal of August 3, 1984 and our NFPA 72D-1975 Fire Detection Code Deviations submittal of May 6, 1983. D. Hood and D. Kubicki stated that the License Amendment which will be issued to remove

Document Control Desk

. Hay 19, 1989

, Page 3 fire protection from Technical Specifications will adopt all SERs, including these two upcoming ones. Concern by the NRC reviewer (Mr. Kubicki) was raised that contrary to guidance contained in Generic letter 88-12, the March 9, 1987 and March 20, 1989 submittals did not retain the SSS specification in Technical Specifications (it was proposed as a FSAR selected license commitment (SLC)). We pointed out that as discussed in the March 20th submittal there is no formal SSS specification in the current McGuire Technical Specifications, that Duke had only been administratively implementing a proposed SSS Techni, Specification, and that the status of the proposed SSS Technical Specification which has not yet been approved by the NRC was currently uncertain for reasons outlined in the March 20th submittal. Since there is no formal SSS Technical Specification, the guidance in Generic Letter 88-12 is technically not being violated. The issue of whether the SSS Specification would eventually have to be placed in the Technical Specifications or world be allowed to become a FSAR SLC will be resolved by the NRC (e.g. It may be handled by the Technical Specification Improvement Program),

and should be treated separately in order not to hold up issuance of tha Fire Protection Relocation Amendment.

With regards to an additional matter not previously discussed with the NRC, please be advised that the entries for proposed (provided in the March 9, 1987 submittal) FSAR SLC Table 16.9-3 Fire Detection Instrumentation Detector Zone Nos. 70 and 87 are different from those in the currently applicable Technical Specification Table 3.3-11 upon which it is based. The entries for the Total No.

of Instruments for the Auxiliary Feedwater Pumps is correctly given in the proposed FSAR Table as "10(0)" for Smoke and "8(1)" for Fixed Temp. Rate of Rise, rather than the "8(2)" and "8(0)" respectively given in the current Technical Specifications. This Technical Specification discrepancy is being corrected as part of the Fire Protection Relocation Amc..dment submittal, and was inadvertently not identified as a change in the March 9, 1987 submitcal.

The March 9, 1987 submittal as revised by my letter of March 20, 1989 (Technical Specification / License Condition /FSAR Changes, along with their justifications and analysis of Significant Hazards Consideration) remains valid, except as modified by this submittal. Justification for the attached changes is included in this letter. The March 9, 1987 Analysis of Significant Hazards Consideration should bound the license conditions changes since the new conditions at< essentially a subset of those previously proposed and are in accordance with the guidance in the NRC Generic Letters, and thus does not need to be supplemented (note that ne analysis of significant hazards is necessary for changes to the FSAR).

Should there be any questions or if additional information is required, please advise.

Very truly yours,

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hh 'Y*v H. B. Tucker x

PBN/SEL/167/lcs Attachments

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l. ' pocument Control Desk l . _May.19, 1989 i i , -Page.4 xc: (w/ Attachments)

Mr. S. D. Ebneter 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 701 Barbour Drive Raleigh, North Carolina 27605 Mr. P. K. VanDoorn NRC Senior Resident Inspector McGuire Nuclear Station Mr. Darl Hood, Project Manager Division of Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Gommission Washington, D.C. 20555

pocuant control Desk  ;

.- May 19, 1989-

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l. -I ATTACHMENT 1 I PROPOSED REVISION TO McGUIRE NUCLEAR STATION FINAL SAFETY ANALYSIS REPORT SUPPLEMENT TO MARCH 9, 1987 PROPOSAL

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Document l Control. Desk

. .Mayc19, 1989

,. Pak,e7 1 ATTACHMENT 1:

~ ' Dates.'of Letters From Duke Power to NRC.Regarding McGuire Fire Protection Program pq

'-March 22,.1978.

May 1'!19783 aJ May,30, 1978' August 1,(1978

' September 1, 1978

' November 2, 1978 January 9, 1979 January 31, 1979

" November 8,11979, December 7, 1979

. December 14, 1979

- -March 31,~1980, July.10, 1980

July

17,.1980~

October 24,-:1980 January 9,11981 January 27, 1981

' October 21, 1981 July 14, 1982 August' 17,.1982 September 23, 1982 September. 30, 1982 L . October 7, 1982

' October 12,:1982

' November.1,L1982 December 14, 1982 January 5,.1983 February 22,.1983 March 31,-1983-April 14,.1983 F May_6,'1983 May 13,.198?

May 13, 1983 May 31 1983 July 12,.1983

-August 1, 1983 .

September 28, 1983 November 18,.1983-

. January 4, 1984 June 1, 1984

. August 2, 1984 August 3, 1984 Note: As per discussion with Mr. D. Hood of NRC, when the FSAR is updated to include these dates, a description of the letters content will be added to each 1ctter date.

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