ML20079M702
| ML20079M702 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 11/01/1991 |
| From: | Shelton D CENTERIOR ENERGY |
| To: | |
| Shared Package | |
| ML20079M696 | List: |
| References | |
| GL-86-10, GL-88-12, NUDOCS 9111080342 | |
| Download: ML20079M702 (10) | |
Text
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Docket Number 50-346 License Number NPF-3 Serial Number 1789 Enclosure Page 1 Application for Amendment To Facility Operating License Number NPF-3 For Davis-Besse Nuclear Power Station Unit Number 1 Enclosed are proposed changes to the Davis-Besse Nuclear Power Station, Unit Num'oer 1, Facility Operating License Number NPF-3.
Also included are the Safety Assessment and Significsnt Hazards Consideration.
The ptoposed changes (submitted under cover letter Serial Number 1789) concern:
TS 3/4.3.3.8, Fire Detection Instrumentation and its Bases Table 3.3-14, Fire Detection Instruments TS 3/4.7.9.1, Fire Suppression Vater System and its Bases TS 3/4.7.9.2, Spray And/or Sprinkler Systems and its Bases TS 3/4.7.9.3, Fire Hose Stations and its Bases Table 3.7-4, Fire Hose Stations TS 3/4.7.10, Fire Barriers and its Bases TS 6.2.2.f, Fire Brigade Staffing TS 6.4.2, Fire Brigade Training TS 6.5.1.6, Station Review Board Responsibilities TS 6.9.2, Special Reports License Condition 2.C.(4)
By:
D. C. Shelton, Vice President, l
Nuclear - Davis-Besse Sworn and subscribed before me this 1st day of November, 1991.
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_Motary Publfe, State of Ohio EVELYNL DRESS NOT/R.'PUOUC,STATEOF OHlO MyC;10h5.giresEy28,19li4 9111080342 911101 PDR ADOCK 03000346 p
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Docket Number 50-346 License Number NPF-3 Serial Number 1789 Enclosure Page 2 The following information is provided to support issuance of the requested changes to tne Davis-Besse Nuclear Power Station, Unit Number 1, Operating License Number NPF-3 and Appendix A, Technical Specifications (TS 3/4.3.3.8, Fire Detection Instrumentation and its Bases; Table 3.3-14, Fire Detection Instruments; TS 3/4.7.9.1, Fire Suppression Vater System and its Bases; TS 3/4.7.9.2, Spray And/0r Sprinkler Systems and its Bases; TS 3/4.7.9.3, Fire llose Stations and its Bases, Table 3.7-4, Fire llose Stations; TS 3/4.7.10, Fire Barriers and its Bases; TS 6.2.2.f, Fire Brigade Staffing; TS 6.4.2, Fire Brigade Training; TS 6,5.1.6, Station Review Board Responsibilities; TS 6.9.2, Special Reports; and License Condition 2.C.(4)).
A.
Time Required to Implement:
This change is tc, be implemented within 60 days after the NRC issuance of the License Amendment.
B.
Reason for Change (License Amendment Request Number 90-0013):
Relocation of the Fire Protection Program requirements from the Technical Specifications to the Updated Safety Anelysis 2eport per Generic Letters 86-10 and 88-12 vill allow for Fire Protection Progran, Tnges to be made under the provisions of 10 CFR 50.59.
C.
Safety Assessment and Significant llazards Consideration:
See
Docket Number 50-346 License Number NPF-3 Serial Number 1789 Page 1 SAFETY ASSESSMENT AND SIGNIFICANT HAZARDS CONSIDERATION FOR LICENSE AMENDMENT REQUEST NUMBER 90-0013 TITLE:
Removal of Fire Protection Technical Specifications DESCRIPTION:
This License Amendment Request (LAR) proposes the removal of the Fire Protection requirements from the Davis-Besse Nuclear Power Station Unit Number 1 Operating License NPF-3,. Appendix A, Technical Specifications (TS) based upon the guidance of Nuclear Regulatory Commission (NRC)
Generic Letter 86s10, " Implementation of Fire Protection Requirements",
dated April 24, 1986, (Toledo Edison letter Log Number 1983) and Generic Letter 88-12, " Removal of Fire Protection Requirements from Technical Specifications", dated August 2, 1988 (Toledo Edison letter Log Number 2665). These requirements have been relocated to the Fire Hazards Analysis Report (FHAR) as indicated below.
The FHAR has been incorporated by reference into the Updated Safety Analysis Report (USAR).
NRC approval of this LAR will allow changes to the Fire Protection Program to be made in accordanca with the provisions of 10 CFR 50.59, " Changes, Tests, and Experiments", and 10 CFR 50.71(e),
" Maintenance of Records. Making of Reports" (submittal of USAR changes), rather than by a license amendment.
The existing Operating License, ?.ppendix A, TS does not completely reflect all of the fire protection system components that are used to comply with the requirements of NRC Branch Technical Position (BTP)
APCSB 9.5-1, Appendix A, " Guidelines for Fire Protection for Nuclear Power Plants Docketed Prior to July 1, 1976" and the applicable portions of 10 CFR 50, Appendix R, " Fire Protection' Program for Nuclear Power Facilities Operating Prior to January, 1979".
For example, although the plant surveillance procedures list all of the required fire detection zones, TS Table 3.3-14, " Fire Detection Instruments",
does not.
Similar discrepancies exist in TS Table 3.7-4, " Fire Hose Stations". These discrepancies were resolved during the incorporation of the TS into the FHAR. Other enhancements made during the incorporation of the TS Into the'FHAR included: identification cf which fire protection system compenents are used to comply with either BTP APCSB 9.5-1, Appendix A or 10 CFR 50, Appendix R; addition of compensatory measures for the fire detection and barrier surveillances in the containment and annulus areas; increasing the electric and diesel fire pump-flow and head requirements to meet current analysis requirements; and increasing the diesel fire pump run time testing to meet National Fire Protection Association (NFPA) Code recommendations.
The changes made through the incorpuration of the TS into FHAR did not reduce the Fire Protection Program requirements of the Davis-Besse Nuclear Power Station (DBNPS).
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Docket Number 50-346 License Number NPF-3 Serial Number 1789 Page 2 The TS sections that are being removed and their proposed corresponding FHAR locations are:
IS Section Subject FHAR Section 3/4.3.3.8 Fire Detection Instrumentation 8.1.1 and 8.2.1 Bases 3/4.3.3.8 and Bases j
Table 3.3-14 Fire Detection Instruments Tables 8-1 and 8.3 3/4.7.9.1 Fire Suppression Vater System 8.1.2 Bases 3/4.7.9 and Bases 3/4.7.9.2 Spray and/or Sprinkler Systems 8.1.3 and 8.2.2 Bases 3/4.7.9 and Basec 3/4.7.9.3 Fire Hose Stations 8.2.3 and 8.2.4 Bases 3/4.7.9 and Bases Table 3.7-4 Fire Hose Stations Tables 8-5 and 8-6 3/4.7.10 Fire Barriers 8.1.4 and 8.2.5 i
Bases 3/4.7.10 and Bases 6.2.2.f Fire Brigade Staffing 8.3 6.4.2 Fire Brigade Training 8.3 The TS Table of Contents is also proposed for revision administrative 1y to reflect the above removal of TS.
Additionally, a requirement for the Station Review Board (SRB) to review Fire Protection Program changes vill be added to TS-6.5.1.6, "[ Station Review Board]
Responsibilities". The wording of-this particular requirement vili oe consistent with other program reviews conducted by the SRB, such as TS-6.5.1.6.1 (Security Plan) and TS 6.5.1.6.j (Emergency Plan).. The reporting requirements in TS 5.9.2, "Special Reports",'for Specifications 3.3.3.8, 3.7.9.1 and 3.7.9.2 vill be-remcved in that the reporting requirements of 10 C7R 50.72 and,10 CFR 50.73 prevail. The current TS 6.8.1, " Procedures and. Programs", already' includes a requirement (TS 6.8.1.f) for written Fire Protection Program procedures to be established, implemented and maintained.
Refer to Pages 9-through 35 of Attachment 1 for the marked-up Technical Specifications.
This LAR proposes-revision of License Condition 2.C.(4). consistent with.
the standard license condition proposed in Generic Letter 86-10.
License Condition 2.C.(4) was issued on July 26, 1979 as part of License Amendment Number 18 and was subsequently amended on April 22, 1980 in License Amendment Number 24.
By reference,' License Condition 2.C.(4) incorporates Table 1 of the NRC Fire Protection SER dated July 26, 1979, which was issued as part of License Amendment
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Docket Number 50-346 License Number NPP-3 Serial Number 1729 Page 3 Number 18.
The SER Table 1 summarized commitments made by Toledo Edison to implement various modifications in order to achieve compliance with NRC requirements.
SYSTEMS, COMPONENTS, AND ACTIVITIES AFFECTED:
The various fire protection features installed throughout the plant for 10 CFR 50, Appendix R and BTP APCSB 9.5-1 Appendix A compliance, including fire detection instrumentation, fire suppression vater systems (sprinkler and deluge systems, fire-hose stations / connections, hydrants and hydrant hose houses), and fire barriers, are not affected b) the proposed changes. The effect of these changes does not physically modify the systems and components but instead enhances and relocates the requirements for verification of operability and compensatory actions from the TS to.the USAR by reference to the FHAR.
The relocated TS vere clarified as to which components comply with either BTP APC8P 9.5-1, Appendix A or-1-0 CPR 50, Appendix R.
The Fire Datection Instrumentation ensures that adequate warning capability is available for the prompt detection of fires. This capability is required in order to detect and locate-fires in their early stages to reduce the potential for damage to safe shutdown equipment. The nroposed changes do not affect the Fire Detection Instrumentation.
The Fire Suppression Systems ensure that adequate fire suppression capability is available to confine and extinguish-fires occurring in any portion of the facility where safe shutdown equipment is located.
The Fire Suppression Systems consist of the water-system',-sprinkler and deluge systems, fire hose stations / connections, hydrants and hydrant hose houses. The collective capability of the Fire Suppression Systems is adequate to minimize potential damage.to safe shutdown equipment.
The proposed changes-do not affect the Fire Suppression Systems.
The Fire Barriers ensure that fires will be confined or adequately retarded from spreading to adjacent fire areas or to portions of redundant safe shutdown systems required in the event of a-fire within the fire area. This passive design feature minimizes the possibility of a single fire rapidly involving several fire areas of the facility prior to detection and extinguishment. -The equipment-that provides active protection, such as a fire detection activated door or a deluge system was added to the appropriate. relocated specifications. The proposed changes do not affect the Fire Barriers.
SAFETY FUNCTIONS OF THE AFFECTED SYSTEMS, COMPONENTS, AND ACTIVITIES:
As described above, the safety functions of fire protection systems and components are not affected by these proposed changes. The activities affected by:these changes are the administrative processes for implementing Fire Protection Program aspects, including maintaining operability limitations, performance of surveillances, compensatory _
actions, Fire Brigade staffing and training, requiring Station Revieu Loard (SRB) review of Fire Protection Program' changes, and the
Docket Number 50-346 License Number NPF-3 Serial Number 1789 Page 4 submittal of Special Reports to the NRC.
The function of these activities is to ensure that the Fire Protection Program requirements are maintained to ensure plant safety and protect the public health and safety.
EFFECTS ON SAFETY:
The removal o'. the TS requirements for fire protection systems based upon their iacorporation into the USAR by reference to the FHAk is consistent with the guidance and considerations of Generic Letters 86-10 and 88-12, thereby maintair;ing the Fire Protection Program aspects intact. This is further ensured by the revised license condition ar ' TS adrainistrative controls which requite the program to a
be maintained ur he provisions of 10 CFR 50.59 and 10 CFR 50.71(e),
and provider review of changes to the Fire Protection Program.
The changes ough the incorporation of the TS into the FHAR di6 not reduce the Firt. Protection Program requirements of the DBNPS.
Therefore, there are no negative effects on safety introduced by the removal of the Fire Protection TS requirements.
Subsequent to issuance of the SER for License Amendment Number 18, alternate methods of compliance vere identified by Toledo Edison, and in other cases, analyses or code compliance reviews were performed to demonstrate the acceptability of the original configuration. These alternative methods of compliance and analyses / reviews vere submitted in Toledo Edison letter Serial Numiser 1783, dated March 22, 1990. This letter was reviewed in NRC Region III Inspection Report 50-346/90007 (DRS), (Toleco Edison letter Log Number 1-2345, dated August 22, 1990).
Toledo Edison has revieved the requirements of Table 1 of the License Amendment Number 18 SER, and concluded that it has addressed the requirements of License Amendment Number 18 SER, Table 1 either by completion of the stipulated requirements or by the alternativa compliance methods (see Attachment 2) vith one exception.
This exception is with regards to providing additional area type detection in the fuel handling area (Room 300).
However, Toledo Edison has committed in its letter Serial Number 1757, dated February 16, 1990, to complete the detector installation in the fuel handling area by the end of the Seventh Refueling Outage. Based on this review and commitment, Toledo Edison has determined that the present License Condition 2.(C).4 should be removed in its entirety and replaced with a license condition consistent with that proposed in Generic Letter 86-10.
Furthermore, based on this review and commitment, there are no negative effects on safety introduced by this revised License Condition.
SIGNIFICANT HAZARDS CONSIDERATION:
The NRC has provided standards in 10 CFR 50.92(c) for determining whether a significant hazard exists due to a proposed amendment to an Operating License for a facility. A proposed amendment involves no significant hazards consideration if operation of the facility in accordance with the proposed changes would:
(1) Not involve a significant increase in the probability or consequences of an accident previcusly evaluated; (2) Not create the possibility of a new or
Docket Number 50-346 License Number NPP-3 Serial Number 1789 Page 5 different kind of accident frou any accident previously evaluated; or (3) Not involve a significant reduction in a margin of safety. Toledo Edison has reviewed the proposed changes and determined that a significant hazards consideration does not exist because operation of the Davis-Besse Nuclear Power Station, Unit Number 1, in accordance with these changes vould la.
Not involve a significant increase in the probability of an accident previously evaluated because although the changes remove the Fire Protection requirements from the TS, the requirements vero incorporated'into the USAR which is controlled under the 10 CFR 50.59 process. The changes made through the incorporation of the TS into the FHAR did not reduce the Fire Protection Program requirements of the DBNPS.
Operating limitations vill continue to be imposed, and required surveillances vill continue to be performed in accordance with the approved vritten procedures.
As such, fire protection systems are not affected and therefore, no accident scenarios are impacted _by the proposed changes.
Including a specific reference in the TS for SRB review of the Fire Protection Program and revisions thereto vill not involve 4
a significant increase in the probability of an accident previously evaluated because this is an administrative change with no accident impli ations.
Toledo Edison's review of the License Amendment Number 18 SER requirements concluded that those requirements are either met, met with a commitment, or met with alternative approaches, The proposed change to License Condition 2.C.(4), which would replace the present license condition with a standard license-condition consistent with that proposed in Generic Letter 86-10, would not involve a significant increase in the probability of a:r accident _previously evaluated because the d.ange does not reduce the existing Fire Protection Program nor does it rcsult in a degradation of control of the Fire Protection Program process.
. Future changes to the Fire Protection Program vill be processed under-the existing provisions of 10 CFR 50.59.
Ib.
Not involve a significant increase in the consequences of an accident previously evaluated-because although the' changes remove the Fire Protection requirements from the TS. the requirements were incorporated into the USAR which is controlled under-the 10 CFR 50.59 process. The changes made through the incorporation of'the TS into the FHAR_did not reduce the Fire Protectior. Program requirements of the DBNPS.
Operating limitations vill cor.tinue to be imposed, and required surveillances vill continue to be performed la accordance with approved written procedures.
As such, the proposed changes have no radiological impact and therefore, no accident consequences are impacted.
Docket Number 50-346 License Number NPF-3 Serial Number 1789 Page 6 Including a specific reference in the TS for SRB reviev of the Fire Protection Program and revisions thereto vill not involve a significant increase in the consequences of an accident previously evaluated because this is an administrative change with no accident implications.
Toledo Edison's review of the License.mendment Number 18 SER requiremen+- concluded that those requirements are either met, met with a commitment, or met with alternative approaches.
The proposed change to License Condition 2.C.(4), which would replace _the present license condition with a standard license condition consistent with that proposed in Generic Letter 86-10, would not involve a significant increase in the consequences of an accident previously evaluated because the change does not reduce the existing Fire Protection Program nor does it result in a degradation of control-of the Fire Protection Program process.
-Future changes to the Fire Protection Program vill be processed under the existing provisions of 10 CFR 50.59.
2a.
Not create the possibility of a new kind of accident from any accident previously evaluated because the Fire Protection requirements were incorporated into the USAR. The changes made through the incorporation of the TS into the FHAR did not I
reduce the Fire Protection Program requirements of the DBNPS.
No changes are being made to.the existing ability of DBNPS to achieve and maintain safe shutdown in the event of a fire.
This is an administrative action to relocate the Fire Protection-Program requirements from the TS to the USAR by reference to the FHAR. Thus, no new accident scenarios have been created, lncluding a specific reference in the TS for SRB review of the Fire Protection Program and revisions thereto does not create the possibility of.a new kind of-accident from any previously evaluated because_there are no changes to the Fire Protection program requirements as a' result of this TS revision. The-formal _ requirement for the' SRB to reviev the Fire Protection Program and its revisions is an' administrative action that does not create a new accident-scenario.
Toledo Edison's review of the License Amendment Number 18 SER requirements concluded.that these requirements are either met, met with a_ commitment, or met with alternative approaches.
The proposed change to License Condition 2.C.(4), which vould replace the present license condition _vith a standard license condition consistent with.that proposed in Generic Letter-86-10, vould not create a'new accident scenario because the-change does not reduce the existing Fire Protection Program j
nor does it result in a degradation of-control of the Fire l
Protection Program-process.
Future changes to the Fire Protection Program vill be processed under the. existing provisions cf 10 CFR 50.59.
3
Docket Number 50-346 License Number NPF-3 Serial Number 1789 Page 7 2b.
Not create the possibility of a different kind of accident from any accident previously evaluated because the Fire-Protection requirements were incorporated into the USAR.
The changes made through the incorporation of the TS into the FHAR did not reduce the Fire Protection Program requirements of the DBNPS. No changes are being made to the existing ability of DBNPS to achieve and maintain safe shutdown in the event of a fire. This is an administrative action to reloctte the Fire Protection Program requirements from the TS to the USAR.
Thus, fire protection systems are not affected and different accident scenarios have not been created.
Including a specific reference in the TS for SRB review of the Fire Protection Prograr.. and revisions thereto does not create the possibility of a different kind of accident from any previously evaluated because there are no changes to the Fire Protection Program requirements as a result of this TS revision. The formal requirement for the SRB to review the Fice Protection Program and its revisions is an administrative action that does not create a different accident scenario.-
Toledo Edison's review of the License Amendment Number 18 SER requirements concluded that those requirements are either met, met with a commitment, or met with alternative approaches.
The proposed change to License Condition 2.C.(4), rhich would replace the present license condition with--a standard license condition consistent with that proposed in Generic Letter 86-10, does not create a different accident scenario because the change does not reduce the existing Fire Protection Program nor does it result in a degradation of control of the Fire Protection Program process.
Future changes to the Fire Protection Program vil_ be processed under the existins provisions of 10 CFR 50.59, 3.
Not involve a significant reduction in a margin of safety because as noted above, the changes made through the incorporation of the TS into the FHAR did not reduce the Fire Prctection Program requirements of the DBNPS.
The requirement for the SRB to review the Fire Protection Program and revisions thereto is an addition to the TS and as such does not involve a significant reduction in the margin of safety.
The replacement of-the existing License Condition 2.C.(4) with a standard condition consistent with that proposed in Generic Letter 86-10 does not involve a significant reduction in a margin of safety because, the requirements of the existing License Condition have either been met, met with_a specific commitment, or met vi h acceptable alternative approaches.
Docket Number 50-346 License Number NPF-3 Serial Number 1789 Page 8 CONCLUSION:
On the basis of the above, Toledo Edison has determined that this License Amendmer:* Request does not involve a significant hazards consideration.
As this License Amendment Request concerns proposed _
-u changes to an Operating License Condition and to the Technical Specifications that must be reviewed by the Nuclear Regulatory Commission, this License Amendment Request does not constitute an unreviewed safety question.
ATTACHMENT:
Attached are the proposed marked up changes to the operating License and Technical Specifications.
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