NRC-90-0040, Application for Amend to License NPF-43,removing Fire Protection Requirements from Tech Specs,Per Generic Ltr 88-12
| ML20012F347 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 03/26/1990 |
| From: | Sylvia B DETROIT EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20012F348 | List: |
| References | |
| CON-NRC-90-0040, CON-NRC-90-40 GL-88-12, NUDOCS 9004110194 | |
| Download: ML20012F347 (9) | |
Text
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B. Ralph SyVJ og
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Detroit Edison
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r March 26,1990 NRC-90-0040 U. S. Nuclear Regulatory Commission Attn Document Control Desk Washington, D. C.
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References:
- 1) Fermi 2 NRC Docket No. 50-341 NRC License No. NPF-43
- 2) NRC Generic Letter 88-12. " Removal of Fire Protection Requirements from Technical Specifications", dated August 2,1988
Subject:
Proposed Technical Specification Change (License Amendment) - Relocation of Fire Protection Requirements Pursuant to 10CFR50.90. Detroit Edison Company hereby proposes to amend Operating License NPF-43 for the Fermi 2 plant by incorporating the enclosed changes into the Plant Technical Specifications and Operating License Conditions. The proposed change implements the guidance of NRC Generic Letter 88-12 (Reference 2) for removal of fire protection requirements from Technical Specifications.
Detroit Edison has evaluated the proposed Technical Specifications against the criteria of 10CFR50.92 and determined that no'significant I
hazards consideration is involved.
The Fermi 2.Onsite Review l
Organization has approved and the Nuclear Safety Review Group has reviewed the proposed Technical Specifications and concurs with the enclosed determinations.
In accordance with 10CFR50.91. Detroit l
Edison has provided a copy of this letter to the State of Michigan.
1 In order to allow sufficient. time for implementation of these changes.
Detroit Edison requests that the requested amendment be effective 60 i
days after issuance.
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9004110194 900326 O
PDR ADOCK 03000341 P
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if USNRC March 26. 1990 NRC-90-0040 Page 2 If you have any questions. please contact Mr. Glen Ohlemacher at (313) 586-4275.
Sincerely.
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Enclosure cci A. B. Davis R. C. Knop W. G. Rogers '
J. F. Stang Supervisor. Electric Operators. Michigan' Public Service Commission - J. Padgett l
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e USNRC March 26, 1990 NRC-90-0040 Page 3 I, B. RALPH SYLVIA, do hereby affirm that the foregoing statements are based on facts and circumstances which are true and accurate to the best of a:y knowledge and belief.
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II. RA1.Pfi Sy(President IA Senior Vice On this day of
- AS 1990, before me personally appeared B. Ralph Sylvia \\ being first duly sworn and says that he executed the foregoing as his free act and deed.
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_N(tary Public DOGNJE A./METTA Notmy Pub!:c Memoo Ccunty, MI MyCommissionExpkosJon.11,1992 l
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Enclosure to l
NRC-90-0040 Page l' INTRODUCTION to Generic Letter 88-12 provided guidance for removal of fire protection requitanents f rom Technical Specifications (TS). The Generic Letter addressed five elements that should be included in a license amendment request to remove fire protection requirements f rom TS.
Each of these elements is addressed individually with respect to the attached proposed changed Technical Specifications and Operating License Conditions in the evaluation below.
EVALUATION GENERIC LETTER 88-12:
First, the NRC-approved Fire Protection Program must be incorporated into the FSAR and submitted with the certification required by 10 CFR 50.71 (e)(2), as requested by Generic Letter 86-10. The FSAR update includes the incorporation of the Fire Protection Program. Including the fire hazards analysis and major commitments that form the basis for the NRC-approved Fire Protection Program. This may be accomplished by referencing the documents which define the licensee's Fire protection l
Program as identified in the NRC's Safety Evaluation Reports.
The NRC-approved Fire Protection Program includes the fire protection and post-fire safe shutdown systems necessary to satisfy NRC guidelines and requirements; administrative and technical controls; the fire brigade and fire protection related technical staf f and other related plant features which have been described by the licensee in the FSAR.
fire hazards analysis, responses to staff requests for additional information, comparisons of plant designs to applicable NRC fire protection guidelines and requirements, and descriptions of the methodology for assuring safe plant shutdown following a fire.
DETROIT EDISON POSITION:
The required information has been incorporated in the Ferini 2 UFSAR in Section 9.5 and Appendix 9A.
l GENERIC LETTLR 88-12:
l Second, the Limiting Conditions for Operation (LCO) and Surveillance Requirements associated with fire detection systems, fire suppression l
systems, fire barriers, and the administrative controls that address fire brigade staffing would be relocated f rom the TS.
An index of I
these specifications is provided in Enclosure 2.
The existing administrative controls related to fire protection audits are to be retained in TS.
Also, any specifications related to the capability for
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Enclosure to NRC-90-0040 Page 2 t
I safe shutdown following a fire, e.g..
seo Item 8(j) in Enclosure 1 to Generic Letter 81-12, are to be retained in TS.
DETROIT EDISON POSITION:
The t.ttached proposci includes the relocation of the specifications listed in Enclosure 2 of the Generic Letter. Fire protection audit requirements have been retained in the administrative controls. Fe rmi 2 TS currently do not contain TS requirements concerning the capability for safe shutdown following a fire, i
GENERIG LETTER 88-12:
Third, 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.
In this manner, the former TS Requirements will become an integral part of the Fire Protection Program and changes subsequent to this amendment will be subject to the standard license condition. These remedial actions include shutdowns currently required by TS 3.0.3 when an LCO and its associated Action Requirements cannot be met.
An example of such a requirement is the shutdown required for the loss of the fire suppression water system and failure to establish a backup water supply within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
DETROIT EDISON POSITION:
The Fermi 2 Fire Protection Program (as described in UFSAR Appendix 9A) has incorporated the TS requirements for the systems proposed to be relocated including TS 3.0.3 requirements.
GENERIC LETTER 88-12:
Fourth, the standard fire protection license condition in Generic Letter 86-10 must be included in the license. Any other current fire protection license conditions shall be removed. This license condition precludes changes to the npproved Fire Protection Program without prior Commission approval if those changes would adversely af fect the ability to achieve and maintain safe shutdown conditions in the event of a fire.
DETROIT EDISON POSITION:
The attached proposal replaces the current Fermi 2 fire protection license condition with the stendard license condition from Generic Letter 86-10.
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Enclosur6 to NRC-90-0040 Page 3 GENERIC LFITER 88-12:
Finally, the Administrative Controls section of the TS chall be augmented to support the Fire Protection Program. This shall be accomplished by additions to two specifications.
First, the Unit Review Group (Onsite Review Group) shall be given responsibility for the review of the Fire Protection Program and implementing procedures and the submittal of recommended changes to the Company Nuclear Review and Audit Group (Offsite or Corporate Review Group).
Second. Fire Protection Program inplementation shall be added to the list of elements for which written procedures shall be established, implemented, and maintained.
The Emergency Plan and the Security Plan were used 'as models to determine the appropriate administrative control for the Fire Protection Program. These additions will provide administrative controls for the Fire Protection Program that are equivalent to those for other programs that are implemented by license condition. The enclosed marked pages of the Westinghouse Standard Technical Specifications (STS) serve as a model for. the changes to the administrative controls. If the plant's TS dif fer f rom the STS.
additions to the administrative controls for the Fire Protection Program should be proposed that are consistent with the administrative controls for the Emergency and Security Plans.
DETROIT EDISON POSITION:
The Fermi 2 TS vary from the STS in that the administrative controls i
include provisions for technical review and control for implementing procedures. These provisions are separate from the activities of the On-site Review Organization (OSRO). The attached proposal has added administrative controls for the Fire Protection Program consistent with the administrative controls for the Emergency and Security Plans. Fire l
Protection Program implementation is currently an element for which TS l
6.8.1 requires written procedures be established, implemented, and main t ained.
The Technical Specification provisions for Nuclear Safety Review Group oversight by audit of the Fire Protection Program implementation are re tained. This is also consistent with the provisions for the Emergency and Security Plans.
i SIGNIFICANT HAZARDS CONSIDERATION l
l In accordance with 10CFRSO.92. Detroit Edison has made a determination that the proposed amendment involves no significant hazards considerations. To make this determination. Detroit Edison must l
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Enclocuro to NRC-90-0040 Fage 4 establish that operation in accordance with the proposed amendment would not:
- 1) involve a significant increase in the probability or consequences of an accident previously evaluated, or 2) create the possibility of a new or different kind of accident from any accident previously evaluated, or 3) involve a significant reduction in a aargin of safety.
1.
The proposed change to remove the fire protection Technical Specifications does not involve a significant increase in the probability or consequences of an accident previously evaluated because the change does not involve a physical modification to the plant, a change to any safety system or a change to any setpoint. The administrative concept of concurrently removing the fire protection requirements from the Technical Specifications and
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incorporating these elements into the UFSAR does not affect the safety analysis presented in the Fermi 2 7
UFSAR. The change will not af fect the functioning of the fire protection program, which will be maintained pursuant l
to the operating license.
No changes will be made to the program that' conflict with the requirements of the license.
2.
The proposed change to remove the fire protection Technical Specification does not create the possibility of a new or different kind of accident from any accident previously evaluated because the change is purely administrative in nature and does not af fect the accident analysis or the operation or function of any safety-related equipment.
The ' fire protection program requirements will continue to be maintained. No new modes of operation are being introduced.
t 3.
The proposed change to remove the fire protection Technical Specification does not involve a significant reduction in the margin of safety because the incorporation of the fire protection requirements into the UFSAR does not change the level of fire protection in the plant. Additionally, the 10CFR50.59 criteria and the standard license condition will ensure future changes are properly evaluated.
Based on the above. Detroit Edison has determined that the proposed amendment does not involve a significant hazards consideration.
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Enclosure to NRC-90-0040 Page 5 EWIROleGufTAL IMPACT Detroit Edison has reviewed the proposed Technical Specification changes against the criteria of 10CFR51.22 for environmental considerations. The proposed change does not involve a significant hacarde consideration, nor significantly change the types or significantly increase the amounts of ef fluents that may be released of fsite, nor significantly increase individual or cumulative occupational radiation exposures. Based on the foregoing, Detroit Edison concludes that the proposed Technical Specifications do neet the criteria given in 10CFR$1.22(c)(9) for a categorical exclusion from the requirements for an Environmental Impact Statement.
CONCLUSION Baned on the evaluation above:
- 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 proposed amendments will not be inimical to the common defence and security or to the health and safety of the public.
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