ML17352A473
| ML17352A473 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 02/25/1994 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML17352A472 | List: |
| References | |
| GL-86-10, NUDOCS 9403100271 | |
| Download: ML17352A473 (5) | |
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON. D.C. 20555-0001 SAF TY E
UATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION R
AT D 0
AMENDMEN NO.
TO FAC LITY OPERATING LIC NS NO.
DPR-31 AND AMENDMENT NO, 153TO FACI ITY OPERATING LICENSE NO.
DPR-41 FLORIDA POW R AND LIGHT COMPANY TURKEY POINT UNIT NOS.
3 AND 4 DOCKET NOS.
50-250 AND 50-251
- 1. 0 INTRODUCTION Generic Letter (GL) 86-10, "Implementation of Fire Protection Requirements,"
dated April 24,
- 1986, recommended that licensees remove the fire protection requirements, including the fire hazards analysis and major commitments that fo'rm the basis for the Fire Protection
- Program, from the facility Technical Specifications (TS) and incorporate them in their Final Safety Analysis Reports (FSARs).
GL 88-12, "Removal of Fire Protection Requirements from Technical Specifications,"
dated August 2, 1988, provided guidance for a license amendment submittal to implement GL 86-10.
By letter dated August 17, 1993, Florida Power and Light Company (FPL or the licensee) proposed changes to the TS for the Turkey Point Plant, Units 3 and 4, to implement GL 86-10.
By letter dated January 14,- 1994, the licensee submitted clarifying information which did not change the staff's initial no significant hazards determination.
- 2. 0 DISCUSSION The TS changes proposed by the licensee are as follows:
1.
Delete. TS 3.3.3.4 (Fire Detection Instrumentation),
TS 3.7.8. 1 (Fire Suppression Water System),
TS 3.7.8.2 (Spray and/or Sprinkler Systems),
TS 3.7.8.3- (Fire Hose Stations),
TS 3.7.8.4, (Fire Hydrants and Hydrant Hose Houses),
and TS 3.7.9 (Fire Rated Assemblies) and their associated bases and surveillances, and incorporate them into the FSAR.
2.
Delete TS 6.2.2.f for site fire brigade staffing and incorporate into the FSAR.
3.
Add TS 6.5. 1.7.1 to include the review of the fire protection program and implementing procedures as an additional responsibility of the Company Nuclear Review Board (CNRB).
9403i0027i, 940225, PDR ADOCK '5000250 P
2 The licensee also proposed the following fire protection license condition:
Florida Power and Light Company 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 and as approved in the SERs dated March 21, 1979, April 3, 1980, July 9,
- 1980, Oecember 8,
- 1980, January 26,
- 1981, May 10,
- 1982, March 27,
- 1984, April 16,
- 1984, August 12,
- 1987, and February 25, 1994, respectively, 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.
Other editorial changes to the TS, to reflect the proposed
- changes, would also be made.
- 3. 0 EVALUATION GL 86-10 recommended removing fire protection requirements from the TS.
Although a comprehensive Fire Protection Program is essential to plant safety, the basis for the recommendation to relocate these requirements from the TS is that many details of this program that are currently addressed in TS do not constitute performance requirements necessary to ensure safe operation of the facility and, therefore, can be modified without affecting nuclear safety.
Such modifications can be made provided that there are suitable administrative controls over these changes to ensure that changes to the Fire Protection Program would be based on careful review and analysis by competent individuals such that nuclear safety is not adversely affected.
These controls relating to the Fire Protection Program include:
(1) the TS administrative controls; (2) the license condition on implementation of and subsequent changes; and (3) the 10 CFR 50.59 criteria for evaluating changes.
The NRC staff reviewed the license amendment request 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 FSAR 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 FSAR; (2) the Limiting Conditions of Operations and Surveillance Requirements associated with fire detection systems, fire suppression systems, fire barriers, and the administrative controls that address fire brigade staffing would be deleted from the TS (the existing administrative controls related to fire protection audits would be retained in the TS); (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 Unit Review Group (Onsite Review Group) shall be given responsibility for the review of the fire protection program and implementing procedures and for the submittal
3 of recommended changes to the Company Nuclear Review and Audit group (Off-site 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 for the facilities into its FSAR in July 1987.
The licensee has, therefore, satisfied Element I of GL 88-12.
The licensee will incorporate the current TS operability and surveillance requirements for the fire detection systems, fire suppression systems, fire rated assemblies, and the TS requirements related to fire brigade staffing into the FSAR.
Therefore, the licensee has satisfied Elements I, 2, and 3 of GL 88-12.
The licensee proposed the standard fire protection license condition specified in GL 86-10 and, therefore, satisfied Element 4 of GL 88-12.
To satisfy Elements 5 and 6 of GL 88-12, the licensee will add TS 6.5.3.8.1 to include the review of the fire protection program and implementing procedures as an additional responsibility of the CNRB.
Element 6 of GL 88-12 specified that the licensee add fire protection program implementation to the list of elements.
for which written procedures shall be established, implemented, and maintained.
TS 6.8. I.h currently addresses the fire protection program; therefore, no changes are required.
The licensee
- has, therefore, satisfied Elements 5 and 6 of GL 88-12.
The licensee also proposed to maintain TS 6.9.2, which relates to the requirement of special reports of fire detection instrumentation, fire suppression systems and fire rated assemblies.
Based on the above discussion, the licensee's proposed TS amendment is in accordance with NRC staff guidance provided in GLs 86-10 and 88-12 and therefore, acceptable.
5.0 STATE CONSULTATION
Based upon the written notice of the proposed amendments, the Florida State official had no comments.
- 4. 0 ENVIRONS T
CONS ID RATIO These amendments change a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20.
The NRC 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 (58 FR 50967).
Accordingly, these 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 these amendments.
6.0 CONC USIO Based on its evaluation in Section 2.0 above, the staff concludes that the proposed TS changes are acceptable.
The Commission has concluded, based on the considerations discussed above, that:
(1) there is reasonable assurance that the health and safety of the public will 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:
A. Singh, SPLB Date:
February 25, 1994
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