ML17333A364
| ML17333A364 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 03/11/1996 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML17333A362 | List: |
| References | |
| NUDOCS 9603210374 | |
| Download: ML17333A364 (12) | |
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 205554001 SAFETY EVALUATION BY THE OFFIC OF NUC EAR REACTOR R GULAT ON ELATED TO AMENDMENT NO. 208 TO FACILITY OPERATING LICE SE NO.
DPR-58 ND AM NDMENT NO. 192 TO FACILITY OPERATING LICENSE NO.
DPR-74 INDIANA MICHIGAN POWER COMPANY DONALD C.
COOK NUCLEAR PLANT UNIT NOS.
1 AND 2 DOCKET NOS.
50-315 AND 50-316
1.0 INTRODUCTION
Section 50.48, "Fire protection," of Part 50 of Title 10 of the Code of Federal Re ulations (10 CFR Part
- 50) requires that each operating nuclear power plant have a fire protection plan that satisfies Criterion 3
(GDC 3),
"Fire protection," of Appendix A to 10 CFR Part 3III The fire protection plan must describe the overall fire protection program for the facility, outline the plans for fire protection, fire detection, and fire suppression capability, and limitations of fire damage.
The program must also describe specific features necessary to implement the program, such as administrative controls and personnel requirements for fire prevention and manual fire suppression activities, automatic and manually operated fire detection and suppression
- systems, and the means to limit fire damage to structures,
- systems, or components important to safety so that the capability to safely shut down the plant is ensured.
The U.S. Nuclear Regulatory Commission (NRC) staff approved the Donald C.
Cook Nuclear Plant, Unit Nos.
1 and 2, (D.C.
Cook) fire protection program in a Safety Evaluation Report dated June 4;
1979.
By letter dated June 20,
- 1995, and supplemented December 19, 1995, the Indiana Michigan Power Company (the licensee) requested aIIIer4nents, to the Techni,cal.
Specifications (TS) appended to Facility Operating LIicense Nos.
DPR-58 and DPR-74 for the Donald C.
Cook Nuclear Plant, Unit Kes.
1 and 2.
The proposed amendments would change the fire protection program in accordance with the guidance provided in Generic Letter (GL) 86-10, "Implementation of Fire Protection Requirements,"
and GL 88-12, "Removal of Fire Protection Requirements from Technical Specifications."
Specifically, the licensee proposed to incorporate the NRC-approved fire protection program and major commitments, including the fire hazard analysis, into the Updated Final Safety Analysis Report (UFSAR),
and to revise the operating licenses to include the NRC's standard fire protection license condition.
In addition, the licensee proposed to relocate the fire protection requirements of TS Section 3/4.3.3.7 (Fire Detection - Instrumentation),
TS Section 3/4.7.9 (Fire Suppression Systems),
TS Section 3/4.7. 10 (Fire Rated Assemblies),
TS Section 6.2 (Administrative Controls Organization),
and TS Section 6.8 (Administrative Controls Procedures and Programs) from the TS to the revised fire protection program.
The December 19,
- 1995, supplement clarified the license conditions 96032i0374 9603ii PDR ADCICK 050003iS P
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by'providing specific approval dates for previous fire protection safety evaluations.
This information was within the scope of the original app*lication and did not change the staff's initial proposed no significant hazards consideration determination.
GL 86-10 and GL 88-12 referred to removing fire protection requirements from TS.
License amendments that relocate the fire protection requirements to the Final Safety Analysis Report (FSAR) in accordance with GL 86-10 and GL 88-12 do not revise the requirements for fire protection operability, testing, or inspections.
Such amendments simply replace the fire protection TS sections with the standard fire protection license condition.
The license condition implements and maintains the NRC-approved fire protection program, including the fire protection requirements previously specified in the TS, in accordance with 10 CFR 50.48.
Therefore, such amendments, including the one proposed by the licensee, are administrative in nature and have no effect on the public health and safety.
2.0 BACKGROUND
Section 182a of the Atomic Energy Act (the "Act") requires applicants for nuclear power plant operating licenses to state TS to be included as part of the license.
The Commission's regulatory requirements related to the content of TS are set forth in 10 CFR 50.36.
That regulation requires that the TS include items in five specific categories, including (1) safety limits, limiting safety system settings and limiting control settings; (2) limiting conditions for operation;,
(3) surveillance requirements; (4) design features; and (5) administrative controls.
However, the regulation does not specify the particular requirements to be included in a plant's TS.
The Commission has provided guidance for the contents of TS in its "Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors"
("Final Policy Statement" ),
58 FR 39132 (July 22, 1993), in which the Commission indicated that compliance with the Final Policy Statement satisfies Section 182a of the Act.
In particular, the Commission indicated that certain items could be relocated from the TS to licensee-controlled documents, consistent with the standard enunciated
.in Portland General Electric Co.'(Trojan Nuclear Plant),
ALAB-531, 9 NRC 263, 273 (1979).
In that
- case, the Atomic Safety and Licensing Appeal Board indicated. that "technical specifications are to be reserved for those matters as to which the imposition of rigid conditions or limitations upon reactor operation is deemed necessary to obviate the possibility of an abnormal situation or event giving rise to an immediate threat to the public health and safety."
The criteria set forth in the policy statement have been incorporated into 10 CFR 50.36 (60 FR 36953).
Following the fire at the Browns Ferry Nuclear Power Plant on March 22,
- 1975, the Commission undertook a number of actions to ensure that improvements were implemented in the fire protection programs for all power reactor facilities.
Because of the extensive modification of fire protection programs and the number of open issues resulting from staff evaluations, a number of revisions and alterations occurred in these programs over the years.
Consequently, licensees were requested by GL 86-10 to incorporate the final NRC-approved fire protection program in their FSARs.
In this manner, the fire protection
program, including the systems, certain administrative and technical controls, the organization, and other plant features associated with fire protection, would have a status consistent with that of other plant features described in the FSAR.
In addition, the Commission concluded that a standard license condition, requiring compliance with the provisions of the fire protection program as described in the FSAR, should be used to ensure uniform enforcement of the fire protection requirements.
Finally, the Commission stated that with the required actions, licensees may request an amendment to delete the fire protection TS that would now be unnecessary.
Subsequently, the NRC issued GL 88-12 to give guidance for the preparation of the license amendment request to implement GL 86-10.
3.3 ER I EEE IIAE I The specific TS changes proposed by the licensee are as follows:
1.
Revise License Condition 2.C.(4) for Unit 1 and License Condition 2.C.(3)(o) for Unit 2 as follows:
Indiana Michigan Power Company shall implement and maintain, in effect, all provisions of the approved Fire Protection Program as described in the Updated Final Safety Analysis Report for the facility and as approved in the SERs dated December 12, 1977, July 31,
- 1979, January 30,
- 1981, February 7,
- 1983, November 22,
- 1983, December 23,
- 1983, March 16,
- 1984, August 27,
- 1985, June 30, 1986, January 28,
- 1987, May 26,
- 1987, June 16,
- 1988, June 17,
- 1988, June 7,
- 1989, February 1,
- 1990, February 9,
- 1990, March 26, 1990, April 26,
- 1990, March 31, 1993, April 8,
- 1993, December 14,
- 1994, January 24, 1995, April 19,
- 1995, June 8,
- 1995, and [the date of this safety evaluation],
subject to the following provision:
The licensee 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 fire.
2.
Delete TS 3/4.3.3.7 (Instrumentation Fire Detection instrumentation) and their associated bases and table and incorporate
- them, by reference to the Fire Protection
- Program, into the D.C.
Cook UFSAR.
3.
Delete TS 3/4.7.9 (Plant Systems Fire Suppression Systems) and their associated bases and tables, including 3/4.7.9. 1 (Fire Suppression Water System),
3/4.7.9.2 (Spray and/or Sprinkler Systems),
3/4.7.9.3 (Low Pressure C02 Systems),
3/4.7.9.4 (Halon Systems),
and 3/4.7.9.5 (Fire Hose Stations),
and incorporate
- them, by reference to the Fire Protection
- Program, into the D.C.
Cook UFSAR.
4.
Delete TS 3/4.7. 10 (Plant Systems Fire Rated Assemblies) and their associated bases and incorporate
- them, by reference to the Fire Protection
- Program, into the D.C.
Cook UFSAR.
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5.
Delete TS 6.2.2.e.,
L'ire brigade staffing, and the related portion of the associated
- footnote, and incorporate
- them, by reference to the Fire Protection
- Program, into the D.C.
Cook UFSAR.
6.
Create TS 6.8. 1.g. to add "Fire Protection Program implementation" to the list of activities for which written procedures shall be established, implemented and maintained.
7.
Revise the Index to reflect the TS changes.
- 4. 0 EVALUATION The NRC staff reviewed the license amendment requests for D. C.
Cook against the guidance provided in GLs 86-10 and 88-12.
GL 86-10 requested that the licensee incorporate the NRC-approved fire protection program in its UFSAR for the facility and specified a standard fire protection license condition.
GL 88-12 addressed the elements a licensee should include in a license amendment request to remove the fire protection requirements from the plant TS.
These elements are (1) the NRC-approved fire protection program must be incorporated into the UFSAR; (2) the Limiting Conditions for Operation (LCOs) and Surveillance Requirements associated with fire detection systems, fire suppression systems, fire barriers, and the administrative controls that address fire brigade staffing would be relocated from the TS (the existing administrative controls associated with fire protection audits and specifications related to the capability for safe shutdown following a fire would be retained);
(3) all operational conditions, remedial
- actions, and test requirements presently included in the TS for these
- systems, as well as the fire brigade staffing requirements, shall be incorporated into the fire protection program; (4) the standard fire protection license condition specified in GL 86-10 must be included in the facility operating license; (5) the Plant Nuclear Safety Review Committee (Onsite Review Group) shall be given responsibility for the review of the fire protection program and implementing procedures and for the submittal of recommended changes to the Nuclear Safety and Design Review Committee (Offsite or Corporate Review Group);
and (6) fire protection program implementation shall be added to the list of elements for which written procedures shall be established, implemented, and maintained.
The licensee incorporated the NRC-approved fire protection program by reference into the D.C.
Cook UFSAR in July 1994.
The licensee has, therefore, satisfied Element 1 of GL 88-12.
The licensee stated in its submittal of June 20, 1995, that it will incorporate the current TS LCOs and surveillance requirements for the fire detection systems, fire suppression
- systems, and the TS requirements related to fire brigade staffing into the D.C.
Cook Fire Protection Program.
Therefore, the licensee will have satisfied Elements 2 and 3 of GL 88-12.
The licensee proposed incorporating the standard fire protection license condition specified in GL 86-10 for D.C. Cook.
The licensee has, therefore, satisfied Element 4 of GL 88-12.
To satisfy Element 5 of GL 88-12, the licensee addressed changes to the administrative controls sections of the TS.
The licensee will require the
~ t ai I
Plant Nuclear Safety Review Committee and Nuclear Safety and Design Review Committee to review the fire protection program and implementing procedures as well as recommended changes as an additional responsibility.
The licensee
- has, therefore',
satisfied Element 5 of GL 88-12.
Element 6 of GL 88-12 specified that the licensee add fire protection program implementation to the administrative controls Section of the TS.
This change is made to the list of elements for which written procedures, shall be established, implemented, and maintained.
The licensee has added TS 6.8. l.h.
(a TS 6.8. 1."g" was added by a previous amendment) which addresses the fire protection program; therefore, the proposal has satisfied Element 6 of GL 88-12.
The licensee's proposed TS amendments for D.C.
Cook are in accordance with NRC staff guidance provided in GLs 86-10 and 88-12.
In summary, the licensee has proposed to incorporate the existing TS fire protection requirements as stated above into the fire protection program which is, by reference, incorporated into the UFSAR.
This conforms to staff guidance in GL 86-10, "Implementation of Fire Protection Requirements,"
and GL 88-12, "Removal of Fire Protection Requirements from Technical Specifications," for removing unnecessary fire protection TS in four major areas:
fire detection systems, fire suppression systems, fire barriers, and fire brigade staffing requirements.
In addition, incorporating these requirements into the UFSAR is consistent with NUREG-1431, "Standard Technical Specifications, Mestinghouse Plants and 10 CFR 50.36, as
- amended, because these TS do not impact reactor operations, do not identify a parameter which is an initial condition assumption for a design-basis accident or transient, do not identify a significant abnormal degradation of the reactor coolant pressure
- boundary, and do not provide any mitigation of a design-basis event.
The fire protection plan required by 10 CFR 50.48, as implemented and maintained by the fire protection license condition, provides reasonable assurance that fires will not give rise to an immediate threat to public health and safety.
Although there are aspects of the fire detection and mitigation functions that have been determined to be risk significant,'uch that Criterion 4 of 10 CFR 50.36 would otherwise seem to apply, the minimum requirements for those functions were established in GDC 3 and 10 CFR 50.48, and further controls are not necessary since the licensee must comply with these minimum requirements regardless of whether they are restated in the TS ol not.
The licensee's fire protection program is required by 10 CFR 50.48, and any changes to that program are governed by 10 CFR 50.48 and license conditions 2.C.(4) (Unit 1) and 2.C.(3)(o) (Unit 2), set forth above.
Therefore, the requirements relocated to the UFSAR may be controlled in accordance with 10 CFR 50.59.
These relocated requirements relating to fire protection features are not required to be in the TS under 10 CFR 50.36 or other regulations, or by Section 182a of the Atomic Energy Act, and are not required to obviate the possibility of an abnormal situation or event giving rise to an immediate
V p1
6 threat to the public health and safety.
In addition, the staff finds that sufficient regulatory controls exist under 10 CFR 50.48 and 10 CFR 50.59 to address future changes to these requirements.
Accordingly, the staff has concluded that these requirements may be relocated from the TS to the licensee's UFSAR.
5.0 STATE CONSULTATION
In accordance with the Commission's regulations, the Michigan State official was notified of the proposed issuance of the amendments'he State official had no comments.
- 6. 0 NVIRONMENTAL CONSIDERATION The amendments change the requirements with respect to the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and change surveillance requirements'he staff has determined that the amendments involve no significant increase in the amounts, and no significant change in the types, of any effluents that may be released
- offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure.
The Commission has previously issued a
proposed finding that the amendments involve no significant hazards consideration and there has been no public comment on such finding (60 FR 47620).
Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9)
~
Pursuant to 10 CFR 51.22(b),
no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments'.0 CONCLUSION The staff has concluded, based on the considerations discussed above, that (1) there is reasonable assurance that the health and safety of the public
'ill not be endangered by operation in the proposed
- manner, (2) such activities will be conducted in compliance with the Commission's regulations and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public Principal Contributor C.
R.
Thomas (By precedent)
K. S.
West (By precedent)
J.
B. Hickman Date:
March 11, 1996
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