ML20057F181
| ML20057F181 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 10/07/1993 |
| From: | Opeka J NORTHEAST NUCLEAR ENERGY CO., NORTHEAST UTILITIES |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20057F182 | List: |
| References | |
| B14624, GL-86-10, NUDOCS 9310140262 | |
| Download: ML20057F181 (5) | |
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NORTHEAST UTILETIES cenere On ces semen street, sernn. connect, cut I
5 P.O. BOX 270 H ARTFORD, CONNECTICUT 06141-0270 l[ ((72[.$C (203) 665-5000 L
L October 7, 1993 l
Docket No. 50-245 B14624 Re:
U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555 Gentlemen:
Millstone Nuclear Power Station, Unit No.1 Proposed Revision to the Operating License Fire Protection t
Pursuant to 10CFR50.90, Northeast Nuclear Energy Company (NNECO) hereby proposes to amend Operating License No. DPR-21 by incorporating the changes identified herein into the fire protection license condition.
Backaround On April 16,1993,"' NNEC0 submitted a proposed license amendment request to the NRC Staff which would modify the Millstone Unit No. 1 - Technical Specifications in accordance with Generic Letters (GL) 86-10 and 88-12.
The-GLs also requested licensees to amend their custom fire protection license condition and substitute it with the standard fire protection condition proposed in GL 86-10.
NNEC0'S "B14408, Proposed,Deleted TS 3.12 Re Fire Suppression Water Sys, Spray &/Or Sprinker Sys,Carbon Dioxide & Halon 1308 Sys,Fire Hose Stations,Fire Protection Instrumentation & Penetration [[Topic" contains a listed "[" character as part of the property label and has therefore been classified as invalid.s|April 16, 1993, letter]] did not propose to modify the Millstone Unit No.1 Fire Protection License Condition since NNEC0 believed the license condition was already consistent with the proposed standard found in GL 86-10.
Subsequent discussions with the NRC Staff have l
resulted in NNECO's decision to modify the license condition.
Description of Proposed Chances This change will modify Operating License Condition 2.C(3), " Fire Protection" by deleting the existing wording of the license condition and replacing it with the standard wording provided _in GL 86-10.
The safety evaluations cited in the revised license condition are those issued by the NRC Staff in support of NNECO's Fire Protection Program as described in the Final Safety Analysis i
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J. F. Opeka letter to the U.S. Nuclear Regulatory Commission, " Proposed 1
130@Ei n t Technical Specifications--Fire Protection," dated April 16, 9310140262 931007 9.
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U.S. Nuclear Regulatory Comission B14624/Page 2 October 7, 1993 Report (FSAR), Full-Term Operating License (FTOL) Application, safe shutdown methodology, and request for exemptions to 10CFR50, Appendix R.
Safety Assessment For plants licensed prior to January 1,1979, such as Millstone Unit No.1, the license contained a condition requiring implementation of modifications committed to by the licensee as a result of the review conducted against the Standard Review Plan, Branch Technical Position on fire protection.
This license condition was added to the Millstone Unit No. I license by an amendment issued on September 26,
- 1978, and supplemented via later 2'
amendments.
Two points should be noted in regard to these conditions issued for the l
industry:
(1) some did not explicitly cover required fire protection features where modifications to the existing plant configuration or procedures were not required, and (2) some of the provisions in these conditions may have been superseded by Sections III.G, J, and 0 of Appendix R.
These nonstandard license conditions also create difficulties because they do not clearly specify when a licensee may make changes to the approved program without requesting a license amendment.
If the fire protection program committed to by the licensee is required by a specific license condition or is not part of the FSAR for the facility, the provisions of 10CFR50.59 may not be l
applied to make changes without prior NRC approval.
Thus, licensees may be i
required to submit amendment requests even for relatively minor changes to the i
The NRC Staff stated that the aforementioned problems, in general, exist because of the many submittals that constitute the Fire Protection Program for each plant.
The NP,C believed that the best way to resolve these problems was to incorporate the Fire Protection Program and major commitments, including the fire hazards analysis, by reference into the FSAR for the facility.
Millstone Unit No. I accomplished this in our 1987 FSAR submittal.
The NRC also believed that a standard license condition, requiring licensees to comply with the provisions of tho Fire Protection Program as described in the FSAR, should be used to ensure uniform enforcement of fire protection requirements.
A standard license condition for fire protection was issued with the FTOL on October 31, 1986; however, the current license condition does not reference all the appropriate supplemental safety evaluation reports (SER) to the Fire Protection Program.
This license amendment will incorporate the NRC-endorsed standard license condition and will cite the appropriate NRC Staff SERs.
Future changes to the Fire Protection Program will be evaluated by NNECO to verify that the proposed (2)
D. L. Ziemann letter to W. G. Council, " Provisional Operating License No. DPR-21, Amendment 53," dated September 26, 1978.
U.S. Nuclear Regulatory Commission B14624/Page 3 October 7, 1993 change does not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire. Any issue which does not meet this criterion will be submitted to the NRC Staff for prior review and approval.
Sionificant Hazards Consideration NNECO has reviewed the proposed changes in accordance with 10CFR50.92 and has concluded that the changes do not involve a significant hazards consideration (SHC).
The basis for this conclusion is that the three criteria of 10CFR50.92(c) are not compromised. The proposed changes do not involve an SHC because the changes would not:
1.
Involve a significant increase in the probability or consequences of an accident previously analyzed.
The NRC issued GL 86-10 to assist utilities in the relocation of technical specifications that relate to fire protection and to i
incorporate a consistent license condition.
The relocation of the technical specification was addressed via NNEC0's letter of April 16, 1993.
The incorperation of the GL 86-10 standard license condition, via this letter, will have no impact on the probability or consequences of an accident or malfunction previously evaluated.
The new condition will ensure uniform application of fire protection methodology / criteria by 1
clearly defining the licensing basis as it exists for Millstone Unit No. 1.
2.
Create the possibility of a new or different kind of accident from any 3
previously evaluated.
1 The incorporation of the standard license condition wording has no affect on plant operation, and will not result in the plant being operated differently than previously.
Therefore, there is no new or different kind of accident that can be created by this revised license condition.
3.
Involve a significant reduction in a margin of safety.
The Fire Protection Program will continue to be reviewed and controlled under existing regulations and procedures.
This change will ensure that the regulations are uniformly applied.
This license condition change does not add any new requirements, nor does it delete any requirement that NNECO is already committed to.
This license condition change consolidates these commitments.
Thus, there is no significant reduction in a margin of safety.
Moreover, the Commission has provided guidance concerning the application of 1
standards in 10CFR50.92 by providing certain examples (51FR7751, March 6, 1986) of amendments that are considered not likely to involve an SHC.
Although the proposed change is not enveloped by a specific example, the proposed change does not involve a significant increase in the probability or consequences of an accident previously analyzed.
As previously stated in our
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U.S. Nuclear Regulatory Commission B14624/Page 4 October 7, 1993 "B14408, Proposed,Deleted TS 3.12 Re Fire Suppression Water Sys, Spray &/Or Sprinker Sys,Carbon Dioxide & Halon 1308 Sys,Fire Hose Stations,Fire Protection Instrumentation & Penetration [[Topic" contains a listed "[" character as part of the property label and has therefore been classified as invalid.s|April 16, 1993, letter]], the removal of the fire protection limiting conditions i
for operation and surveillance requirements from the technical specifications i
has no adverse impact upon plant operation or safety. Any changes to the Fire Protection Program requirements will be made in ac::ordance with the provisions of 10CFR50.59 and the fire protection license condition.
NNECO has reviewed the proposed license amendment against the criteria of 10CFR51.22 for environmental considerations.
The proposed changes do not involve an SHC, nor increase the types and amounts of effluents that may be released off site, nor significantly increase individual or cumulative occupational radiation exposures.
Based on the foregoing, NNECO concludes that the proposed change meets the criteria delineated in 10CFR51.22(c)(9) for a categorical exclusion from the requirements for an environmental impact statement.
Attachment I presents the marked-up copy of the license condition. The retype l
of the proposed change to the license condition is included in Attachment 2.
The Millstone Unit No. I _ Nuclear Review Board has reviewed this proposed amendment and concurs with the above determination.
In accordance with 10CFR50.91(b), we are providing the State of Connecticut with a copy of this proposed amendment.
I Regarding our proposed schedule for this amendment, we request issuance at your earliest convenience with the amendment effective as of the date of issuance, to be implemented within 30 days of issuance.
Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY h FAL J. F'.-Op'eka
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Executive Vice President j
cc: See Page 5 I
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l U.S. Nuclear Regulatory Commission El%29/Page 5 October 7, 1993 cc:
T. T. Martin, Region I Administrator J. W. Andersen, NRC Acting Project Manager, Millstone Unit No.1 P. D. Swetland, Senior Resident Inspector, Millstone Unit Nos.1, 2, and 3 Mr. Kevin T.A. McCarthy, Director Monitoring and Radiation Division Department of Environmental Protection 79 Elm Street P.O. Box 5066 Hartford, CT 06102-5066 Subscribed and sworn to before me this N day of ((? M /C %, 1993 And.
kkenNc' Date Commissio Expires: 3 2/ [
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