ML20095F316
| ML20095F316 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 04/20/1992 |
| From: | J. J. Barton GENERAL PUBLIC UTILITIES CORP. |
| To: | |
| Shared Package | |
| ML20095F292 | List: |
| References | |
| GL-88-12, NUDOCS 9204280171 | |
| Download: ML20095F316 (9) | |
Text
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GPU NUCLEAR CORPORATION OYSTER CREEK NUCLEAR GENERATING STATION facility Operating License No. DPR-16 Technical Specification Change Request No.193 Docket No. 50-219 Applicant submits, by this Technical Specification Change Request No.193 to the Oyster Creek Nuclear Generating Station Techniral Specifications, a change to pages i, ii, 1.0-5, 3.12-1,-3.12-2, 4.12-1, 4.12-2, 6-2, 6-3, 6-4, 6-7, and 6-13.
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p By: /
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. IBo rton Vi e WP esident and Director st# Creek Sworn and Subscribed to befo methisc70 day of 1992.
N /A N a'ry Public of New Jersey JUDITH M.CROWE Notary Pubile of New My Comndssion Entres
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9204280171 920420 DR ADOCK 05000219 PDR
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION IN THE MATTER OF
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DOCKET N0. 50-219 GPU NUCLEAR CORPORATION
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CERTIFICATE OF SERVICE This is to certify that a copy of Technical Specification Change Request No.
193 for the Oyster Creek Nuclear Generating Station Technical Specifications, filed with the U.S. Nuclear Regulatory Commission on April 20,
- 1992, has this day of April 20, 1992, been served on the Mayor of Lacey Township, Ocean County, New Jersey by deposit in the United States inail, addressed as follows:
Mayor of Lacey Tt+nship 818 West Lacey Road Forked River, NJ 08731
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By:
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O. J./ Barton Vin President and Director WsdrCreek
0YSTER CREEK NUCLEAR GENERATING STATION FACILITY OPERATING LICENSE NO. OPR-16 DOCKET N0. 50 219 TECHNICAL SPECIFICATION CHANGE REQUEST NO. 193 The licensee, GPU Nuclear Corporation, hereby requests the Commission tc change Appendix A to the license for the Oyster Creek Nuclear Generating Station as described below.
Pursuant te 10 CFR 50.91, an analysis concerning the determination of no sP;nificant hazards considerations is also presented:
1.
Sgetions to be Chanaed Table of Contents Section 1, Technical Specifications Sections 1, 3.12, 4.12, 6.2, 6.4, 6.5, 6.8 and 6.9.
II.
Extent of Chanagg First, the NRC approved Fire Protection Program (FPP) was incorporated into Oyster Creek's Final Safety Analysis Report as requested by NRC Generic Letter 86-10.
Second, the operability and surveillance requirements for fire detection systems, fire suppression systems, fire barriers, and fire brigade staffing requirements as defined in the current Technical Specifications (TS) were in:orporated into the FPP.
Third, the standard fire protection license condition as described in Generic Letter 86-10 was incorporated into the operating license when the Full Term Operating License (FTOL) was issued for Oyster Creek.
Finally, we are requesting a change to the fire protection TS in accordance with NRC Generic Letter G8-12 to delete the operability and surveillance requirements and fire brigade staffing requirements that are now included in the FPP. This last step will complete the actions necessary to comply with the recommendations of Generic Letters 86-10 and 88-12.
We are also requesting four minor administrative changes to the remaining fire protection TS, as discussed below.
III.
Chanaes Reauested The changes requested are indicated on the attached revised TS pages i, ii, 1.0-5, 3.12-1, 3.12-2, 4.12-1, 4.12-2, 6-2, 6-3, 6-7, 6-10 and 6-13.
IV.
Discussion NRC Generic letter 86-10, " Implementation of Fire Protection Requirements", requested that licensees incorporate the NRC approved FPP in their Final Safety Analysis Reports (FSAR).
In this manner, the FPP, including the systems, the administrative and technical controls, the
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Page 2 of 7 organization, and other plant features associatea with fire protection-would be on a consistent status with other plant features described in the FSAR. Generic Letter 86-10 encouraged licensees, spon completion of this effort, to apply for an amendment to their operating license (1) to replace current license conditions regarding fire protection with a new standard condition and (2) to remave unnecessary fire protection TS.
The purpose of the standard license condition, which requires compliance with the provisions of the FPP as described in the FSAR, is to ensure uniform enforcement-of fire protection requirements.
GPUN has incorporated the FPP into the Updated FSAR and the standard fire protection license condition was incorporated into the license when the FTOL was issued for Oyster Creek. Accordingly, we are now applying for an amendment to remove the unnecessary fire protection iS.
This chance request is in accordance with NRC Generic Letter 88-12,
" Removal of Fire Protection Requirements from Technical Specifications",
which provides guidance for the relocation of fire protection requirements from the TS to the FPP.
This change removes flie protection requirements _from the TS in four major areas: fire detection systems, fire tuppression systems, fire barriers, and fire brigade staffing requirements.
The existing administrative control requirements related to fire.,rotection audits and all requirements for alternate shutdown monitoring instrumentation are-retained in the TS.
The administrative controls proposed for the FPP are consistert with the administrative controls for the Emergency and. Security Plans.
The standard fire protection license condition precludes changes to the NRC. approved FPP without prior NRC approval if those changes would adversely affect the ability to auileve and maintain safe shutdown conditions--in. the event of a fire. According to Generic Letter 86-10, GPUN may alter specific features of the approved FPP provided such changes-do not otherwise involve.a change in a license condition or TS or result in an unreviewed safety question as defined in 10 CFR 50.59.
Further, temporary changes to specific fire protection features which i
may be necessary to accomplish maintenance or modifications are acceptable provided interim compensatory measures are implemented.
The special reporting requirements in the current fire protection TS are being eliminated with this change. Any future deficiencies in the FPP would be reported in accordance with 10 CFR 50.72 and 10 CFR 50.73.
This is'in accordance with the guidance in Generic Letter 86-10. Other conditions which represent deficiencies in the FPP and are not encompassed by the-above reporting criteria will be evaluated'to l
determine appropriate corrective action.
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In addition to the changes requested in accordance with Generic Letter 88-12, GPUN is also requesting additional administrative changes to the l
fire-protection TS. These changes, which do not reduce the effectiveness of the fire protection TS, are described belw.
Page 3 of 7 A.
TS 6.5.3.2.a currently states, "An independent fire protection and loss prevention program-inspection and audit shall be performed annually utilizing either qualified offsite_ licensee personnel or an outside fire protection firm". GPUN requests the word l
"offsite" be deleted from the TS.
Limiting the inspection and audit team members to qualified "offsite" personnel'is overly restrictive and is not necessary to ensure independence of the audit team.
It prohibits the use of qualified, independent persennel who are located onsite.
The purpose of the annual audit, as stated in NRC Generic-Letter 82-21, Enclosure 1, is to assess the plant fire protecticn equipment and program imolementation in depth to verify continued compliance with NRC requirements,-the SAR commitments, and the
-license conditions. The generic letter further states that the annual audits may be performed by qualified utility personnel who are not directly responsible for the site FPP or by an outside independent fire protection consultant. The Standard Technical Specifications specify offsite licensee personnel, however there is no requirement in the generic letter that the audit team be comprised of-offsite personnel. of the generic letter supports an annual audit team compristd of personnel not i
responsible for the subject being audited.
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.GPUN' procedures ensure the independence and effectiveness of the audit team by specifying that the audit team composition include:
1.
A le:d auditor from our-QA organization,
- 2. _
A fire protection engineer who is not directly responsible for-the FPP at the site being audited and, 3.
An engineer not directly responsible for the subject under 1
audit-(knowledgeable in safety systems, operating procedures, and emergency procedures).
Thus the independence of the-audit team is established without restricting members to_those stationed offsite, and a
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comprehensive and conscientious audit program as described in Generic Letter'82-21.can be performed utilizing members located either-offsite or.onsite. The annual audit will continue to satisfy the overall programmatic requirements contained-in 10 CFR 50.48(a) and the guideline positions in BTP 9.5-1.
Based-on-the above procedural controls defining the composition of the audit
. team, this change will not reduce the quality or effectiveness of
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the annual audit.
I 3.
GPUN requests TS Table 3.12-6 (which would become Table 3.12-1),
" Alternate Shutdown Monitoring Instrumentation", be revised to identify "Rx 23', near V-15-30" as the readout location for control rod drive system flow.
l Page 4 of 7 Safe shutdown in the event of a fire in the control room requires alternate shutdown which utilizes the control rod drive (CRD) system bypass line for reactor water makeup.
This includes manual operation of valve V-15-30 in the CRD bypass line. Since CRD flcw monitoring in the control room is considered damaged by the fire, the alternate shutdown method relies on local flow indication to monitor CRD system performance.
The local flow indication at reactor building elevation 51', below instrument rack RK02 was utilized for this purpose which is remote from valve V-15-30 (elevation ?3') and required an operator at the valve, an operator at the flow Indicator, and intercommunication.
A new flow indicator was installed and located to be easily read from valve V-15-30.
The new flow indicator allows the operator at valve V-15-30 to be aware of flow indication without support from j
an additional operator. This change reduces the burden on plant operators during alternate shutdown in the event of a fire.
The existing surveillance requirements of TS 4.12.1 which apply to the alternate shutdown monitoring instrumentation will ensure the new flow indicator is capable of performing it's intended function.
C.
GPUN requests TS Tables 3.12-6 (which would become Table 3.12-1) and 4.12-1 be revised to delete the operability and surveillance requirement for the condensate transfer pump discharge pressure indicator.
This change will make the TS consistent with the current revision of the Fire Hazards Analysis Report. The alternate shutdown path relies on the "B" isolation condenser (IC-B) to remove decay heat from th reactor. Makeup water to the shell side of IC-B can be supplied by either the condensate transfer or fire water systems.
IC-B shell water level is used to monitor operation of both makeup systems N is sufficient for this purpose. The condensate transfer pump discharge pressure indicator (PI-21) is no longer used. The IC-B shell water level indicator is located on the remote shutdown panel and is already included in TS Tables 3.12-6 (which would become Table 3.12-1) and 4.12-1.
D.
TS Table 3.12-6 (which would become Table 3.12-1) incorrectly identifies instrument rock "P.K05" as the readout location for shutdown cooling system flow. This flow can only be read locally on tha 51' elevation of the reactor building near the-reactor building closed cooling water heat exchangers.
Accordingly, GPUN requests TS Table 3.12-6 (Table 3.12-1) be revised to identify
" Local" as the readout location for this parameter.
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'V.
Determination GPUN has determined that operation of the Oyster Creek Nuclear Generating Station in accordance with the proposed TS does not involve a significant hazards consideration as defined in 10 CFR 50.92.
A.
The proposed changes to the TS do not involve a significant increase in the probability or consequences of an accident previously evaluated.
1.
The proposed changes to the TS made in accordance with Generic Letter 88-12 do not alter GPUN's existing commitments on fire protection. These existing commitments have been reviewed and approved by the NRC. The probability and consequences of accidents has been evaluated for the existing approved FPP in NRC Safety Evaluation dated March l
3, 1978 and supplerant; thereto.
l License condition 2.C(3) requires any changes made to the
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FPP be evaluated under the provisions of 10 CFR 50.59 and allows only those changes that would not adversely affect the_ ability to achieve and maintain safe shutdown in the event of a fire.
2.
The proposed change to TS 6.5.3.2.a does not effect previously evaluated accidents.
Based on existing procedural controls which define the composition of the audit team, this change does not reduce the quality or effectiveness of the annual audit. The annual audit b;;'.
continue to adequately assess plant fire protection equipment and program implementation.
3.
The proposed change to TS tables 3.12-6 and 4.12-1 to reflect the installation of a new flow indicator for CRD system flow does not effect previously evaluated accidents.
The use of the new flow indicator in the event of a fire
-does not alter the previous considerations.
4.
The proposeo change to TS tables 3.12-6 and 4.12-1 to delete the operability and surveillance requirement for the condensate transfer pump discharge pressure indicator does not effect previously evaluated accidents.
The Appendix R strategy will not be affected since an existing Appendix R component is used to determine the operability of IC shell side water makeup systems.
5.
The proposed change to TS table 3.12-6 to correct the readout location for shutdown cooling system flow is an administrative channe only and does not effect previously.
evaluated accidents.
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l Page 6 of 7 B.
The proposed changes to the TS do not create the possibility of a new or different kind of accident from any accident previously evaluated.
1.
The proposed changes to the TS made in accordance with Generic Letter 88-12 do not alter GPUN's existing previous evaluations of possible accidents.
Further, license condition 2.C(3) requires that any changes to the FPP be evaluated via the 50.59 process to determine if the possibility of a new or different kind of accident would be created.
2.
The proposed change to TS 6.5.3.2.a removes the requirement that offsite parsonnel shall be used to perform the annual fire protection and loss prevention program inspection and audit, and is unrelated to the possibility of creating a new or different kind of accident.
3.
The proposed change to TS tables 3.12-6 and 4.12-1 to reflect the installstion of a new flow indicator for CRD system flow does not create the possibility of a new or different kind of accident.
The use of the new flow indicator in the event of a fire does not alter the previous evaluation.
4.
The proposed change to TS tables 3.12-6 and 4.12-1 to delete the operability and surveillance requirement for the condensate transfer pump discharge pressure indicator does not create the possibility of an accident or malfunction of a type different from any previously identified since it's Appendix R function is performed by another existing Appendix R component.
5.
The proposed change to TS table 3.12-6 to correct the readout location for shutdown cooling system flow is an adni:nistrative change only and does not create the possibility of a new or different kind of accident.
C.
The proposed changes to the TS do not involve a significant reduction in a margin of safety.
1.
The proposed changes to the TS made in accordance with Generic Letter 08-12 will maintain the existing margin of safety by trar,.erral of the FPP provisions from the TS to the FSAR.
Since the provisions of 10 CFR 50.59 allow for evaluation of any reduction in the margin of safety and allow for cnanges to the FPP without prior NRC approval after 50.59 evaluation, the proposed changes will not involve a reduction in a margin of safety.
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4 Page 7 of 7 2.
The proposed change to TS 6.5.3.2.a does not reduce the quality or effectiveness of-the annual audit.
Therefore there-is no reduction in a margin of safety.
3.
The proposed change to TS tables 3.12-6 and 4.12-1 to reflect the installation of a new flow indicator for CRD system flow does not reduce any margin of safety. The new flow indicator enhances the operator's ability to monitor CRD system flow during a fire and was installed for this purpose.
4.
The proposed change to TS tables 3.12-6 and 4.12-1 to delete the operability and surveillance requirement for the condensate transfer pump discharge pressure indicator does not reduce any margin of safety.
Existing Appendix instrumentation will be used to determine the operability of IC shell side water makeup systems during a fire.
5.
The proposed change to TS table 3.12-6 to correct the readout location for shutdown cooling system flow is an ad.inistrative change only and does not reduce any margin of safety.
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