IR 05000410/1987013
| ML17054C167 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 06/01/1987 |
| From: | Anderson C, Krasopoulos A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17054C166 | List: |
| References | |
| 50-410-87-13, GL-86-10, NUDOCS 8706100185 | |
| Download: ML17054C167 (12) | |
Text
Report No.
87-13 Docket No.
50-410 U
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NUCLEAR REGULATORY COMMISSION
REGION I
License No.
NPF 54 Pri ority Licensee:
Nia ara Mohawk Power Cor oration 301 Plainfield Road Category B
S racuse New York 13212 Facility Name:
Nine Mile Point
C Inspection At:
S racuse New York Inspection Conducted:
A ri 1 20-21 1987 Inspectors:
A. Krasopoulos, Re ctor Engineer ate Approved by:
Q C.
. Anderson, Chief Plant Systems Section DRS date Ins ection Summar
Ins ection conducted on A ril 20-21 1987 Re ort No.
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related to a licensee request to incorporate the Fire Protection sections of the Technical Specifications (TS) into the Final Safety Analysis Report (FSAR)
and to delete these fire protection sections from the TS in accordance with the guidance contained in Generic Letter (GL) 86-10.
Results:
The licensee's request is consistent with the guidance contained in G.L. 86"10.
No unacceptable conditions were identified.
8706100185 870604 PDR ADOCK 05000410 PDR
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0ETA1LS 1.0 Persons Contacted
'ia ara Mohawk Power Cor oration M. Brause, Lead Compliance and Verification Engineer M. Kammer, Site Fire Protection Supervisor M. Korcz, Special Projects - Nuclear Engineer M. Mosier, Lead Engineer - Safety Analysis 2.0 Pur ose and Scope This inspection was conducted to evaluate the licensee's request to incorporate into the FSAR the fire protection sections of the T.S.
and delete these sections from the T.S.
The evaluation consisted of a comparison between the T.S.
versus the FSAR Fire Protection requirements to assure that the level of safety will not be decreased with the deletion of the Fire Protection from the T.S.
3.0
~Back round The NRC in Generic Letter 86-10 stated that licensee's should add the Fire Protection Program into the FSAR.
With the inclusion of the fire protection program into the FSAR and the inclusion of a Standard Fire Protection License Condition in the license the Fire Protection sections of the T.S.
are unnecessary and may be deleted.
The bases for the inclusion of the fire protection program into the FSAR and the use of a standard Fire Protection License Condition is described in GL 86-10
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The licensee via letters dated December 9,
1986 and April 10, 1987 requested a license amendment to remove the Fire Protection sections from the Technical Specifications and informed the NRC that the fire protection requirements contained in the Technical Specifications will be incorporated into the FSAR consistent with the guidance contained in Generic Letter 86-10.
4.0 Ins ection of the Fire Protection Pro ram in su ort of a Licensin Action related to the deletion of the Fire Protection Technical S ecifications The inspection included a review of the incorporation of the Fire Protection Program into the FSAR, a review of the fire protection TS sections to be deleted, a review of the equivalent administrative and technical controls, and a review of the proposed T.
S. revision to include the administrative controls and reporting requirements of the Fire Protection Program.
The licensee's existing Fire Protection Program consists of the FSAR Section 9.5. 1, FSAR Appendix 9A, the Fire Protection sections of the T.S.
the Operational guality Assurance Manual and the implementing Administrative, Maintenance and Surveillance procedure The licensee proposed to delete the following T.S. sections containing the Fire Protection elements and include the applicable requirements into the FSAR, Appendix 9A as follows:
Fire Protection T.S. Section to be deleted Title FSAR Section that the Fire Protection will a
ear in 3/4.7.8 3 '.7.8 3/4.7.7 3.7.7.1 3.7.7.6 3.7.7.2 3.7.7.5 3.7.7.4 3.7.7.3 Fire Barriers Fire Oetection Fire Protection Water Supply System Fire Pumps Outside Hose Stations Sprinkler and Water Spray System Manual Hose Installa-tions Halon 1301 Suppression CO Suppression System 9A.3.5.1.1 9A.3.6.1 9A.3.6.2 9A.3.6.2.6 9A.3.6.2.7 9A.3.6.3.3 9A.3.6.3.4 9A.3.6.4 9A.3.6.5 The deletion of these T.S.
requirements is permissible under the guidance of Generic Letter 86-10 provided that they are described or referenced in the FSAR and equivalent controls are established.
The inspector reviewed the licensee's proposal and determined that when th'is proposal is implemented the applicable T.S.
Requirements, Action Statements and Surveillance Requirements will be incorporated entirely into the FSAR.
The implementing Administrative Maintenance and Surveillance Procedures of the Fire Protection Program will remain in effect.
In addition, the licensee stated that the proposed Facility Operating License will include the Standard Fire Protection Condition found in GL 86-10 appropriately ammended to include the name of the licensee and the applicable SER dates.
This license condition is included as Attachment 1 of this report.
The licensee also proposed to include in section 6.8.4 of the T.
S. the following condition:
6.8.4.d Fire Protection Pro ram The Fire Protection Program is a program to implement and maintain in effect all provisions of the approved fire protection program as described in the Final Safety Analysis Report as amended and as approved in the Safety Evaluation Report (NUREG"1047) dated February 1985 as supplemented.
The noncompliances with the above Fire Protection Program that affect the abil.ity to achieve and maintain safe shutdown in the event of a fire shall be reported in accordance with
.the requirements of 10 CFR 50.7 '
The inclusion of this condition in the T.S. will assure that equivalent controls of the fire protection program are maintained and any program violations are reported in accordance with the requirements of )0 CFR 50.73.
The licensee actions described above are consistent with the guidance of Generic Letter 86-10.
The inspector did not identify any unacceptable conditions.
5.0 Conclusion Based on the above, the inspector determined that:
1.
The existing FSAR sections of the fire protection program (FPP) together with the proposed revision satisfy the guidance in Generic Letter 86-10 for incorporating the FPP into the FSAR
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2.
The deletion of the TS sections is in accordance with the guidance in Generic Letter 86-10.
3.
The existing fire protection T.S.
requirements are incorporated entirely into the FSAR and administrative controls exist to implement and control these activities.
4.
The existing License Condition 2.c(7) is in accordance with the Standard License Condition in Generic Letter 86-10 which allows the Licensee to make changes to the approved FPP under the Revisions of
CFR 50.59.
Adequate administrative controls exist to determine if a proposed FPP change would adversely affect the ability to achieve and maintain safe shutdown in the event of a fire.
Based on the above, he inspector concluded that the licensee's request to delete the Fire Protection elements from the Technical Specifications when the full power license is issued, meets the guidance in Generic Letter 86-10 and there is reasonable assurance that the health and safety of the public will not be endangered by operation in this manner and such activities will be conducted in compliance with the Commission's regulations and the approval of these actions by the Commission will not be inimical to the common defense and security or to the health and safety of the public.
The inspector met with licensee management representatives (see Section 1.0 for attendees)
at the conclusion of the inspection on April 21, 1987.
The inspector summarized the scope and findings of the inspection at that tim i4
The inspector and the licensee discussed the contents of this inspection report to ascertain that it did not contain any proprietary information.
The licensee agreed that the inspection report may be placed in the Public Document Room without prior licensee review for proprietary information (10 CFR 2.790).
At no time during this inspection was written material provided to the licensee by the inspecto ATTACHMENT 1 FACILITY OPERATING LICENSE STANDARO LICENSE CONOITION FIRE PROTECTION (7)
Fire Protection Section 9.5. 1 SER SSER Nos.
4 and
Niagara Mohawk Power Corporation shall implement 'and maintain in effect all provisions of the approved fire protection program as described in the Final Safety Analysis Report for the facility through Amendment No.
27 and as described in submittals dated March 25, May 7 and 9, June 10 and 25, July ll and 16, August 19 and 22, September 5,
12, and 23, October 10, 21, and 22, 1986, and as approved in the SER dated February 1985 (and Supplements 1 through 5) subject to the following provision:
Niagara Mohawk Power Corporation 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 fir '