ML20066C774

Application for Amends to Licenses DPR-62 & DPR-71,replacing Current License Condition Re Fire Protection W/Std Condition

ML20066C774
Person / Time
Site:	Brunswick
Issue date:	01/04/1991
From:	Vaughn G CAROLINA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20066C776	List: ML20066C774 ML20066C785
References
GL-86-10, GL-88-12, NLS-90-237, NUDOCS 9101110204
Download: ML20066C774 (8)

Text

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Carolina Powsr & Light Company P_O Box 155) e Ra6eigh, N C. 27602 '

fe X,^ene"," JAbl 041991 SERrAt: NtS 90 237 Nucieer sernes Depariment 10 CPR 50.90 TSC 87TSB04 United States Nuclear Regulatory Commission ATTENTION: Document Control Desk Washington, DC 20555 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS 1 AND 2 DOCKET NOS. 50 325 6 50 324/ LICENSE NOS. DPR 71 6 DPR 62 REQUEST FOR LICENSE AMENDMENT FIRE PROTECTION TECllNICAL SPECIFICATIONS AND LICENSE CONDITION Gentlemen:

In accordance with the Code of Federal Regulations, Title 10, Parts 50.90 and 2.101, Carolina Power & Light Company (CP&L) requests a revision to the Operating Licenses and Technical Specifications for the Brunswick Steam Electric Plant, Units 1 6 2. (BSEP 1 & 2).

The proposed change would replace the current license condition regarding itre protection with a standard condition and delete the Technical Specifications that will become unnecessary. The proposed change is consistent with the guidance and provisions of Generic Lettera 86 10 and 88 12.

Enclosure 1 provides a descrf ption of the proposed change and the basis for the change.

Enclosure 2 provides the basis for the Company's determination that the proposed changes do not involve a significant hazards consideration.

Enclosure 3 and 4 provide the proposed pages of the license condition and Technical Specifications for each unit.

In order to allow time for procedure revision and orderly incorporation into copies of the Technical Specifications, CP&L requests that the proposed amendments, once approved, be issued with an effective date to be no later than 60 days from the issuance of the amendment.

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9101110204 910104 PDR ADOCK 05000324 h P PDR L

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SERIAL: NLS 90 237 10 CFR 50.90 TSC 87TSB04 i

Please refer any questions regarding this submittal to Mr. M. R. Oates at (919) 546 6063.

Yours very truly, I

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G. E. Vaughn C, E. Vaughn, having been first duly sworn, dic' depose and say that the information contained herein is true and corre c to the best of his information, knowledge and belief; and the sources of his information are officers, employees, contractors, and agents of Carolina Power & Light Company.

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Enclosures i f l

% ..............y o ,d COUN ise,,,nio6o 'p cc: Mr. Dayne Brawn Mr. S. D. Ebneter Mr. N. B. Le Mr. R. L. Provatte

l ENCLOSURE 1

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BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2 ,

NRC DOCKETS 50 325 6 50-324 OPERATINC LICENSES DPR 71 & DPR 62 REQUEST IOR LICENSE AMENDMENT FIRE PROTECTION TECHNICAL SPECIFICATIONS 6 LICENSE CONDITION DISCUSSION AND BASIS FOR CHANGE REOUEST The NRC issued Generic Letter (CL) 86 10 " Implementation of Fire Protection Requirements" on April 24, 1986, which described problems associated with inclusion of the fire protection program in the Technical Specifications (TS).

It stated that the Commission believes that the best way to resolve these problems is to incorporate the fire protection program at.d major commitments, including the fire haeards analysis, by reference, into the Final Safety Analysis Report (FSAR). In this manner, che fire protection program, including the systems, the administrative and technical controls, the organization, and other plant features associated with fire protection would

'= on a consistent status with other plant features described in the FSAR.

Also, the provisions of 10 CFR 50.$9 would then apply directly for changes made to the fire protection program that would not adversely affect the ability to achieve and maintain safe shutdown.

The generic letter also stated _that the Commission believes that a standard license condition, requiring the licensee to comply with the provisions of the fire protection progra:n as described in the FSAR, should be used to ensure untform enforcement of fire protection requirements. Once the program is incorporated into the FSAR, "the licensee may apply for an amendment to the operating license which cmends any current license conditions regarding fire protection... and substitute a standard condition as described in CL 8610.

At the same :Ime, the licensee may request an amendment to delete the TS that w1!1 now be unnecessary.

The fire protection program was incorporatad in the Updated FSAR at BSEP via the Annual Update submitted on June 1,1987 The Fire Hazards Analysis is being restructured to be consistent with the Safe Shutdown Analysis. The FSAR will be revised to reflect these changes in the next update scheduled to be submitted in June 1991.

The following proposed changes are consistent with the_ changes identified in CL 88 12. Administrative controls to support the Fire Protection Program

, adequately exist in the TS.

Proposed Change No. 1:

Replace the existing license condition.2.B(6) for BSEP_1 & 2 with the standard ,

license condition in Ceneric Letter 86-10. ,

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Page 2 of 2 Proposed Changs No. 2:

Delete Unit 1 6 2 Fire Protection Technical Specifications 3/4,3.5.7, 3/4.7.7.1, 3/4.7.7.2, 3/4 7.7.3, 3/4.7.7.4, 3/4.7.7.5, 3/4.7.8 and associated bases.

Proposed Change No. 3:

Delete Unit 1 6 P minimum Fire Brigade staffing requirement in Technical Specification 6.2.2 8.

Proposed Change No. 4:

Delete Unit 1 6 2 Special Report requirements in Technient Specifications 6.9.2 d, g, and h.

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I ENCLOSURE 2 l

BRUNSWICK STEAM ELECTRIC PIANT, UNITS 1 AND 2 NRC DOCKETS 50 325 6 50 324 ,

, OPERATING LICENSES DPR 71 6 DPR 62 REQUEST FOR LICENSE AMENDMENT '

i FIRE PROTECTION TECHNICAL SPECIFICATIONS 6 LICENSE CONDITION 1

10CPR50.92 INALUATION s

J The Commission has provided standards in 10CPR50.92(c) for determining whether a significant hazards consideration exists. A proposed amendment to an '

operating license for a facility involves no si nificant hazards consideration 6

if operation of the facility in accordance with the proposed amendment would e not: (1) involve a significant increase in the probability.or consequences of an accident previously evaluated, (2) create the possibility of a new or different kind of accident from any accident previously evaluated, or (3) a involve a significant reduction in a margin of safety. Carolina Power & Light Company has reviewed this proposed license amendment request and determined that its adoption would not involve a significant hazards consideration. The bases for this determination are as follows:

Pronored Chnnre No. 1:

Replace the existing license condition 2.B(6) with the standard license I condition in Generic Letter 86 10, Bas.i s The change does not involve a significant hazards consideration for the following reasons:

1. The proposed amendment does not involve a significant increase in the probability _ or . consequences of an accident previously evaluated. The r existing license condition requires that the licensee comply with the l

provisions of the November 22, 1977 Fire Protection Safety Evaluation Report and supplements thereto. The new license ~ condition will require all provisions of.the fire protection program to be maintained in effect, and that changes to the program may be made in'accordance with the provisions of 10 CFR 50.59. the overall objective of the Fire Protection Program and License Conditions is to ensure safe shutdown of the plant in the event of a fire. The provisions of 10 CFR 50.59 preserve the ability to achieve and maintain safe shutdown of the plant.-

Therefore, the new license condition is consistent with the objective of the existing license condition and Generic Letter 86-10. Consequently this change will not increase the probability or consequences of an accident previously evaluated.

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Page 2 of 4

2. The proposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated. The new license condition will ensure that the ability to achieve and maintain safe shutdown in the event of a fire is preserved. Since this new license condition is consistent with the objective of the old license condition, this change will not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. The proposed amendment does not involve a significant. reduction in the margin of safety. The requirements contained in the existing license condition 2.B(6) are also contained-in a " Commitment Document" incorporated by reference into the FSAR. Removal of the existing license condition provides consistency with Generic Letter 8610. The fire protection program, which docuneents compliance to 10 CFR 50, Appendix R in accordance with the requirements of 10 CFR 50.48 has been incorporated into the updated FSAR by letter dated June 1, 1987.. As discussed in item 1 above, the new license condition is consistent with the intent of the existing license condition. Accordingly, this proposed change will not involve a reduction in the margin of safety.

Eronosed Change No. 2:

Delete Unit 1 & 2 Fire Protection Technical Specifications 3/4.3.5.7, ,

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3/4.7.7.1, 3/4,7.7.2, 3/4 7.7.3, 3/4.7.7.4, 3/4.7.7.5, 3/4.7.8 and associated bases.

llahili The change does not involve a significant hazards consideration for the following reasons:

1. The proposed amendment door not involve a significant increase in the probability or consequences of an accident previously evaluated. .This is because the operability requirements of the fire protection features and surveillance requirements are not changing. Their control will be maintained in the Updated FSAR where changes must be evaluated in accordance with 10 CFR 50.59. Since this is a programmatic change there will not be an increase in the probability.or consequences of an.

accident previously evaluated.

2. The proposed amendment does not create the possibility of a new or.

different kind of accident from any accident previously evaluated. The requirement to maintain operability of the fire protection features and to perform surveillance requirements will be controlled in the Updated FSAR. Since this is an administrative type change, the possibility of a new or different kind of accident from any accident previously evaluated will not be occated.

3. The proposed amendment does not involve a significant reduction in the l

margin of safety. Since the change is-programmatic and administrative in nature and operability'or surveillance requirements are not changing, .

this proposed change will not involve a reduction in the margin of '

safety. '

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page 3 of 4 i Proposed Chance No. 3:

Delete Unit 1 6 2 minimum Fire Brigade staffing requirement in Technical Specification 6.2.2g.

Basis The change does not involve a significant har.ards consideration for the following reasons:

1. The proposed amendment does not involve a significant increase in the probability or consequence of an accident previously evaluated. The current fire brigade staffing requirements will be administrative 1y controlled and maintained in the Updated FSAR. Therefore, the deletion of Technical Specification 6.2.2.g and the placement of the same requirement into the Updated FSAR will not increase the probability or consequences of an accident previously evaluated.

2. 1he proposed amendment does not create the possibility of a new or different kind of accident previously evaluated. The requirement to maintain the miniawn staffing requirements will be retained ia the Updated FSAR instead of the Technical Specifications. Since this is an administrative type change, the possibility of a new or different kind of accident from any accident previously evaluated will not be created by this change.

3. The proposed amendment does not involve a significant reduction in the margin of safety. Since the staffing levels of the current requirements for the fire brigade are not being reduced, the proposed change will not involve a reduction in the margin of safety, froposed Chanre No. 4:

Delete Unit 1 & 2 Special Report requirements in Technical Specifications, 6.9,2 d, g, and h.

Basis The change does not involve a significane hazards consideration for the "

following reasons:

1. The proposed amendrcent does not-involve a significant increase in the probability or consequence of an accident previously' evaluated. The reportin5 requirements proposed for deletion do not affect the operation i of the facility. Existing compensatory action associated with the component specific action statements are being maintained in effect so the level of fire protection is unchanged. Therefore, this change 9111 not increase the probability or consequences of an accident. ,

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2. The proposed amendment does not create the possibility of a new or different kind of accident previously evaluated. As stated in item 1 above, deletion of these special reports does not affect the operation of the facility. Consequently, the possibility of a new or different kind of accident previously evaluated will not be created by this 4

change.

3. The proposed amendment does not involve a significant reduction in the margin of safety. As stated in item 1 above, existing compensacory action associated with the component specific action statements are being maintained in effect so the level of fire protection 16 unchanged.

Additionally, 10 CFR 50.72 and 10 CFR 50.73 provide criteria, that if met as a result of fire protection deficiencies, would require notification to NRC. Accordingly, this proposed change will not involve a reduction in the margin of safety.

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