ML20035F681
| ML20035F681 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 04/16/1993 |
| From: | Opeka J NORTHEAST NUCLEAR ENERGY CO., NORTHEAST UTILITIES |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20035F682 | List: |
| References | |
| B14408, GL-86-10, NUDOCS 9304220167 | |
| Download: ML20035F681 (6) | |
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HARTFORD. CONNECTICUT 06141-0270 i
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J (203) 665-5000 i
l April 16,1993 Docket No. 50-245 i
B14408 Re:
10CFR50.90 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555 l
i Gentlemen:
i Millstone Nuclear Power Station, Unit No. I Proposed Revision to Technical Specifications Fire Protection l
1 Pursuant to 10CFR50.90, Northeast Nuclear Energy Company (NNECO) hereby proposes
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to amend its Operating License, DPR-21, by incorporating the changes-identified
.l in Attachments I and 2 into.the Technical Specifications of Millstone Unit No.1.
j Descriotion of Proposed Chances These changes revise Technical Specifications 1.0.A, '3.12. A, 4.12.A, 3.12.B, 4.12.B, 3.12.C, 4.12.C, 3.12.D, 4.12.D, 3.12.E, 4.12.E, 3.12.F,: 4.12.F, 6.2.2.f, 6.4.2, 6.5.1.6.j, 6.5.2.6.1, 6.9.2.d and e; and Technical Specification Tables-3.12.1, 3.12.2, and 6.2-1; and Bases 3.12 and 4.12.
Each change is' delineated below:
.l I
In accordance with Generic Letter 86-10"', Technical Specification provisions related to the Fire Protection Program are 'peing deleted and = placed in a
- technical requiraents manual (TRM) which is currently being developed and should be in place by Summer, 1993. The definition, limiting condition for operation, and surveillance requirements for fire protection equipment and the requirements for fire brigade training are being placed in the Millstone Unit No. 'l' TRM.
l Future changes to the TPJi will be reviewed to determine if. a 10CFR50.59 evaluation is required. Further, changes to Section 6, Administrative Controls, provide that any: changes to the Fire Protection Program _ and implementing procedures are reviewed by either the Plant Operations Review Committee (PORC) or the Site Operations Review Committee (SORC)- as are other changes to the Technical Specifications.
l (1).
D. G. Eisenhut letter to All Power Reactor Licensees and Applicants for-f Power Reactor Licensees, " Implementation of Fire Protection Requirements (Generic Letter 86-10)," dated April 24,'1986.
9304220167 930416 PDR ADOCK 05000245-f P
PDR I
6
i i-U.S. Nuclear Regulatory Commission B14408/Page 2 April 16, 1993 T
The following specific changes are being proposed:
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Technical Specification 1.0. A which provides the definition of the fire suppression water system will be deleted. This definition will be incorporated in the TRM. An indication that this provision has been deleted will remain.
Technical Specifications related to Fire Suppression Water System including Limiting Condition for Operation 3.12. A.1, 3.12. A.2, 3.12. A.3, 3.12. A.4, and Surveillance Requirement 4.12.A.1 will be deleted in their entirety.
The provisions of these Technical Specifications will be incorporated in the TRM.
Technical Specifications related to Spray and/or Sprinkler Systems including Limiting Condition for Operation 3.12.B.1,3.12.B.2, and Surveillance Requirement 4.12.B.1 will be deleted in their entirety. The provisions of these Technical Specifications will be incorporated in the TRM.
Technical Specifications related to Carbon Dioxide and Halon 1301 Systems including Limiting Condition for Operation 3.12.C.1, 3.12.C.2, 3.12.C.3, 3.12.C.4, and Surveillance Requirements 4.12.C.1 and 4.12.C.2 will be deleted in i
their entirety.
The provisions of these Technical Specifications will be incorporated in the TRM.
Technical Specifications related to Fire Hose Stations including Limiting Condition for Operation 3.12.D.1, 3.12.D.2, 3.12.D.3, and Surveillance Requirements 4.12.D.1, and Table 3.12.1 will be deleted in their entirety. The provisions of the. Technical Specifications will be incorporated in the TRM.
Technical Specifications related to Fire Detection Instrumentation including Limiting Condition for Operation 3.12.E.1 and 3.12.E.2, Surveillance Requirements 4.12.E.1 and 4.12.E.2, and Table 3.12.2 will be deleted in their entirety. The provisions of these Technical Specifications will be incorporated in the TRM.
t-Technical Specifications related to Penetration Fire Barriers, including Limiting Condition for Operation 3.12.F.1 and 3.12.F.2, and Surveillance Requirements 4.12.F.1 will be deleted in their entirety.
The provisions of the Technical Specifications will be incorporated in the TRM.
These deletions discussed above will result in the complete removal of Sections 3.12 and 4.12.
One page will be inserted which will state these sections have been intentionally deleted per the guidance provided in Generic.
Letters 86-10 and 88-12.<2' The corresponding Bases Section 3.12 and 4.12, Fire
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Protection Systems, will be deleted and so indicated on page B 3/412-1.
(2)
Frank T. Miraglia letter to All Power Reactor Licensees and Applicants,
" Removal of Fire Protection Requirements from Technical Specifications (Generic Letter 88-12)," dated August 2, 1988.
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U.S. Nuclear Regulatory Commission B14408/Page 3 i
April 16, 1993 i
I Technical Specification 6.2.2.f, relating to the site Fire Brigade, will be deleted and incorporated in the TRM.
The existing Technical Specification 6.2.2.g will be renumbered as 6.2.2.f.
The deletion will be noted on page 6-2.
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Technical Specification Table 6.2-1 will be modified to delete minimum shift crew requirement for the Fire Brigade and will be incorporated in the TRM.
l Technical Specification 6.4.2, related to a training program for the Fire Brigade, will be deleted in its entirety.
The provisions of these Technical j
Specifications will be incorporated in the TRM.
Two additions will be made to Technical Specification 6.0:
Technical Specifi-cation 6.5.1.6.j will be added to include the review of the Fire Protection Program and implementing procedures as an additional responsibility of the PORC, and Technical Specification 6.5.2.6.1 will be added to include the responsibility i
for review of the common site Fire Protection Program and implementing procedures by the SORC.
Two additional deletions will be made to Section 6.9.2.d and 6.9.2.e, whereby reference to Fire protection requirements will be deleted.
The remaining paragraphs will be renumbered accordingly. The existing requirement to provide special reports will be deleted as is allowed by the current standard technical specifications.
Safety Assessment l
The requirements of the deleted Technical Specifications will be moved in their entirety to the TRM. Future changes to a fire protection requirement in the TRM will require a 10CFR50.59 evaluation to be performed.
The current fire protection license condition is consistent with the standard wording recommended in GL 88-12.
The license condition allows changes to the fire protection program only if those changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire.
The changes proposed herein are consistent with the current fire protection license condition.
The modifications to Technical Specification 6.5.1.6 provides specifically that the PORC is responsible for review of the unit's Fire Protection Program and implementing procedures. Similarly the modifications to Technical Specification 6.5.2.6 provides specifically that the 50RC is responsible for review of t> ;
common site Fire Protection Program and implementing procedures not reviewed by PORC.
These changes are administrative in nature in that no current Fire Protection Program requirements are being altered aside from the deletion of the requirement to provide special reports. The requirements are being placed in documents other than the Technical Specifications and License in accordance with Generic Letters 86-10 and 88-12.
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U.S. Nuclear Regulatory Commission B14408/Page 4 April 16, 1993 Sionificant Hazards Consideration In accordance with 10CFR50.92, NNEC0 has reviewed the attached proposed changes and has concluded that they do not involve a significant hazards consideration.
The bases for this conclusion is that the three criteria of 10CFR50.92(c) are not compromised.
The proposed changes do not involve a significant hazards consideration because the changes would not:
1.
Involve a significant increase in the probability or consequences of an accident previously evaluated.
The proposed changes simply remove the provisions of the Fire Protection Program that are contained in the Technical Specifications and places them in the TRM. No current requirements are being added or deleted aside from removal of the special reports section.
Review of the Fire Protection Program and its revisions will be the responsibility of the PORC and SORC, just as it has always been the responsibility of these groups to review changes to fire protection Limiting Condition for Operation and Surveillance Requirements when they were part of the. Technical Specifications.
In addition, no design basis accidents are affected by this change, nor are safety systems adversely affected by the changes.
Therefore, these is no impact on the probability of occurrence or the consequences of any design basis accidents.
2.
Create the possibility of a new or different kind of accident-from any previously evaluated.
The proposed changes simply remove the provisions of the Fire Protection Program that are contained in-the Technical Specifications and places them in the TRM. No current requirements are being added or deleted aside from removal of the special reports section.
There are no new failure modes associated with the proposed changes.
Since the plant will continue to operate as designed, the proposed changes will not modify the plant response to the point where it can be considered a new accident.
3.
Involve a significant reduction in a margin of safety.
No change is being proposed for the Fire Protection Program requirements themselves. The relevant Technical Specifications are being deleted, and the requirements contained therein are being incorporated into the TRM.
Plant procedures will continue to provide the specific instructions necessary for the implementation of the requirements, just as when the requirements resided in the Technical Specifications.
Fire Protection Program changes will be governed by the provisions of 10CFR50.59 and the current fire protection license condition.
As such, the changes do not directly affect any protective boundaries nor does it impact the safety limits for the boundary.
Thus, there are no adverse impacts on the protective boundaries, safety limits, or margin of safety.
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i U.S. Nuclear Regulatory Commission B14408/Page 5 April 16, 1993 Moreover, the Commission has provided guidance concerning the application of standards in 10CFR50.92 by providing certain examples (51FR7751, March 6,1986) of amendments that are considered not likely to involve a significant hazards consideration.
Although the proposed changes are not enveloped by a specific example, the proposed changes would not involve a significant increase in the probability or consequences of an accident previously analyzed. As previously stated, the removal of the Fire Protection-related Technical Specifications from the Technical Specifications has no adverse impact upon plant operation or safety.
Since operability and surveillance requirements will remain in a controlled document, the changes do not reduce the effectiveness of Technical 1
Specification requirements.
In addition, the Fire Protection Program i
requirements will be maintained in a TRM. Any changes to the Fire Protection Program requirements will be made in accordance with the provisions of 10CFR50.59 and the fire protection license condition.
NNECO has reviewed the proposed license amendment against the criteria of l
10CFR51.22 for environmental considerations. The proposed changes do not involve a significant hazards consideration, nor increase the types and amounts of i
effluents that may be released offsite, nor significantly increase individual or j
cumulative occupational radiation exposures.
Based on the foregoing, NNECO concludes that the proposed changes meet the criteria delineated in 10CFR51.22(c)(9) for a categorical exclusion from the requirements for an environmental impact statement.
Attachment 1
presents the marked-up copy of the affected Technical Specifications. The retype of the proposed changes to Technical Specifications i
are included in Attachment 2 and reflect the currently issued version of Technical Specifications. Pending Technical Specification Changes, or Technical Specification changes issued subsequent to this submittal, are not reflected in the enclosed retype. The enclosed retype should be checked for continuity with Technical Specifications prior to issuance.
Revision bars are provided in the right hand margin to indicate a revision to the text.
No revision bars are utilized when the page ' is changed solely to accommodate the shifting of text due to additions or deletions.
The Millstone Unit No. I Nuclear Review Board as well as the Site Nuclear Review Board have reviewed and approved this proposed amendment and concur with the above determination.
In accordance with 10CFR50.91(b), we are providing the State of Connecticut'with a copy of this proposed amendment.
U.S. Nuclear Regulatory Commission B14408/Page 6 April 16, 1993 Regarding our proposed schedule for this amendment, we request issuance at your t
earliest convenience with amendment effective as of the date of issuance, to be implemented within 30 days of issuance.
Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY l
h. IC 0tJL J.-fkDpeka U
Executive Vice President t
cc:
T. T. Martin, Region I Administrator J
W. Andersen, NRC Acting Project Manager, Millstone Unit No. 1 P. 6 Swetland, Senior Resident Inspector, Millstone Unit Nos. 1 2,
and 3 Mr. Kevin McCarthy, Director Radiation Control Unit Department of Environmental Protection Hartford, Connecticut 06116 Subscribed and sworn to before me this [' day of[2hA//;,
1993
'da 1bCA,uk Nqfa'ry Public 4
Date Commission Expires:
.3/ 98 t
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