ML20005G998
| ML20005G998 | |
| Person / Time | |
|---|---|
| Site: | Fort Saint Vrain  |
| Issue date: | 01/11/1990 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20005G992 | List: |
| References | |
| GL-88-12, NUDOCS 9001240022 | |
| Download: ML20005G998 (3) | |
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- NUCLEAR RESULATORY COMMISSION 1" $ 1-wAsumeToN, D, C. 20586 p 4...,f{
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- SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION w
LRELATED TO AMENDMENT NO 76?TO FACILITY OPERATING LICENSE NO. DPR-34 PUBLIC' SERVICE COMPANY OF. COLORADO
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FORT ST. VRAIN NUCLEAR GENERATING STATION (a
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1.0 INTRODUCTION
p, By letter dated September 14, 1989, Public Service Company of Colorado (the licensee) proposed changes to the Appendix A. Technical _ Specifications (TS) for y'
Fort St. Vrain (FSV). The proposed changes would remove requirements for fire detection systems, fire suppression systems, fire barriers, and fire brigade
' staffing requirements as recomended by Generic Letter 86-10. The proposed changes would 'also modify the administrative control requirements of the TS to add requirements for the Fire Protection Program'that are similar to require-ments for other programs implemented by license condition. Guidance on these
- proposed chuges to TS was provided to all power reactor licensees and applicants by Generic Letter 88-12, dated August 2,1988.
2.0 ' BACKGROUND 1
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
[1 alterations occurred in these programs over the years. Consequently, licensees L
were requested by Generic Letter 86-10 to incorporate the final NRC-approved j
Fire Protection Program in their Final Safety Analysis Reports (FSARs).
In this l
manner, the Fire Protection Program -- including the systems, the administrative and technical controls, the organization, and other plant features associated l
I; 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 L
- standard license condition, requiring compliance with the provisions of the Fire p
Protection Program as described in the FSAR, should be used to ensure uniform enforcement of fire protection requirements.
Finally, the Commission stated that with the requested actions, licensees may request an amendment to delete the fire protection TS that would now be unnecessary.
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The licencees for the Callaway and Wolf Creek plant submitted lead-plant L
proposals to remove fire protection requirements from their TS. This action was an industry effort to obtain NRC guidance on an acceptable format for license u
amendment requests to remove fire protection requirements from TS.
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-Additionally, in the licensing review of new plants, the staff has approved applicant requests to remove fire protection requirements from TS issued with the operating license. Thus, on the basis of the lead-plant proposals and the j
staff's experience with TS for new licenses, Generic Letter 88-12 was issued to provide guidance on removing fire protection requirements from TS.
3.0 -EVALUATION
- Generic Letter 86-10 recomended the removal of fire protection requirements
_from the TS. Although a comprehensive Fire Protection Program is essential to plant safety, the basis for this recomendation is that many details of this 1
program-that are currently addressed in TS can be modified without affecting nuclear safety. Such modifications can be made provided that there are suitable administrative controls over these changes. These details, that are presently included in TS and which are removed by this amendment, do not constitute performance requirements necessary to ensure safe operation of the facility and, therefore, do not warrant'being included in TS. At the same time, suitable administrative controls ensure that there will be careful review and analysis by competent individuals of any changes in the Fire Protection Program including those technical and administrative requirements removed from the TS to ensure that nuclear safety is not adversely affected. These controls include:
(1) the TS administrative controls that are applicable to the Fire Protection Program; (2) the license condition on implementation of, and subsequent changes to, the
-Fire Protection Program; and (3) the 10 CFR 50.59 criteria for evaluating
-changes to the Fire Protection Program as described in the FSAR.
The specific details relating to fire protection requirements removed from TS by this amendment include those specifications for fire detection systems, fire
. suppression systems, fire barriers, and fire brigade staffing requirements. The administrative control requirements have been modi'ied to include Fire
-Protection Program implementation as an element for which written procedures must be established, implemented, and maintained.
In addition, the audit responsibilities of the Nuclear Facility Safety Comittee were expanded to include the review of the Fire Protection Program and implementing procedures and submittal of recomended changes to the Plant Operations Review Comittee.
The TS changes proposed by the licensee are in accordance with the guidance provided by Generic Letter 88-12, as addressed in the items below, o
L (1) Specification AC 7.1.2, was revised to add the review of the fire
-protection program implementation and the submittal of recomended change:,
to the Plant Operations Review Comittee.
(2) Specification AC 7.4, concerning procedures and programs, was revised to add Fire Protection Program implementation to those programs for which written procedures shall be established, implemented, and maintained.
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(3) Specifications LCO 4.10 and SR 5.10, Fire Detection Instrumentation, Fire Suppression Systems, Fire Barriers, its associated Surveillance Require-ments, and Bases were removed.
(4) Specification AC 7.1.1 on fire brigade staffing requirements was removed.
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As requ' red by Generic Letter 86-10, the licensee' confirmed that the NRC-approved Fire Protection Program has been incorporated into the FSAR. Also, the licensee has proposed the standard license condition noted in Generic Letter 86-10.
The licensee confirmed that the operational conditions, remedial actions, and
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-test requirements associated with the removed fire protection TS have been
. included in the Fire Protection Program incorporated into the FSAR. This is in
- accordance with the, guidance of Generic Letter 88-12.
On the basis of its review of the above items, the staff concludes that the licensee has met the guidance of Generic Letter 88-12. Therefore, the staff finds the proposed changes acceptable.
4.0 ENVIRONMENTAL CONSIDERATION
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This amendment involves changes to requirements with respect to the use of the facility components located within the restricted area as defined in 10 CFR Part 20 and changes to surveillance and administrative procedures or require-ments. The staff has determined that the amendment involves 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 M
increase in individual or cumulative occupational radiation exposures. The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration and there has been no public coment on such finding. Accordingly, the amendment meets the eligibilit categorical exclusion set forth in 10 CFR Section 51.22(c)(9) y criteria for and(c)(10).
Pursuantto10CFR51.22(b),noenvironmentalimpactstatementorenvironmental assessment need be prepared in connection with the issuance of this amendment.
5.0 CONCLUSION
The Commission made proposed determinations that the amendment involves no significant hazards consideration, which were published in the Federal Register (54 FR 49138) on November 29, 1989. The Commission consulted with the State of Colorado. No public comments were received, and the State of Colorado did not have any comments.
On the basis of the considerations discussed above, the staff concludes that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, and (2) such activities will be conducted in compliance with the Commission's regulations, and the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributors: Dennis J. Kubicki, SPLB/ DEST Thomas G. Dunning, OTSB/D0EA Kenneth L. Heitner, PDNP/DRSP Peter B. Erickson, PDNP/DRSP Dated: January 11, 1990