ML20118B554
| ML20118B554 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 09/22/1992 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20118B552 | List: |
| References | |
| NUDOCS 9210050079 | |
| Download: ML20118B554 (4) | |
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SAFETY EVALVATION BY THE OfflCE OF NUCLEAR REACTOR REGULAT1.0)B REtATED TO AMENDMEf1T NO. 174 TO FAClllTY OPERATING LICENSE NO. NPF-3 TOLEDO EDISON COMPAfE CENTER 10R SERVICE COMPANY hhD THE CLEVELAND ELECTRIC ILLUMINATING COMPANY DAVIS-BESSE NUCLEAR POWER STATION. UNIT NO 1
{l0CKET NO. 50-346 1.0 INTPf$UCTION By letter dated November 1, 1991 and supplemented December 26, 1991, and June 1, 1992 the Toledo Edison Company (the licensee) proposed that the existing license condition on fire protection be replaced with the standard condition noted in Generic letter 86-10, and also proposed changes to the Appendix A Technical Specifications (15) for Davis-Besse.
The proposed changes would remove detailed requirements for fire detection systems, fire suppression systems, fire barriers, and fire brigade staffing requirements as recommended by Generic Letter 86-10.
The proposed change would also modify the administrative control requirements of the TS to add requirements for the Fire Protection Program that are similar to requirements for other programs implemented by license conditions.
Guidance on these proposed changes to TS was provided to all power reactor licensees and applicants by Generic Letter 88-12, dated August 2, 1988.
The supplemental letter confirmed the installation of fire detection equipment and requested a 90 day implemertation period and did not alter the proposed action or affect the deternination published December 11, 1991, 2.0 EVALUATION following the fire at the Browns Ferry Nt. clear Power Plant on March 22, 1975, the Commission undertook a number of actions to ensure that improvements were implemented in the Fire Protection Programs for all power reactor facilities.
Because of the extensive modifications of Fire Protection Programs and the number of open issues resulting from staff evaluations, a number of revisions and alterations occurred in these programs over the years.
Consequently, licensees were requested by Generic letter 86-10 to incorporate the final NRC-approved Fire Protection Program in their Updated Safety Analysis Reports (USAR).
In this manner, the Fire Protection Program -- including the systems, the administrative and technical controls, the organization, and other plant features associated with fire protection -- would have a status consistent 9210050079 920922 POR ADOCK 05000346 p-PDR
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with that of other plant features described in the USAR.
In. addition, the Commission concluded that a standard license condition, requiring compliance with the provisions of the Fire Protection Program as described-in the USAR, should be used-to ensure uniform enforcement of fire protection requirements.
Finally, the Commission stated that, with the requested actions, licensees may request an amendment to delete the fire protection TS that would now be unnecessary.
The licensees for the Callaway and Wolf Creek plants submitted lead-plant proposals to remove fire protectior, requirements from their_TS.
This action was an industry effort to obtain NRC guidance on an acceptable format for license amendment requests to remove fire protection requirements from TS.
Additionally, in the licensing review of new plants, the staff has approved applicant requests to remove fire protection requirements from TS issued with the operating license.
Thus, on the basis of the lead-plant proposals and the staff's experience with TS for new licenses, Generic Letter 88-12 was issued to provide guidance on removing fire protection requirements from TS.
Generic Letter 86-10 recommended the removal of fire protection requirements-from the TS.
Although a comprehensive Fire Protection Program is essential to-plant safety, the basis for this recommendation is that many detail: of this.
pregram that are currently addressed in TS can be modified without affecting nuclear safety.
Such modification can be made provided that there are suitable administrative controls over these changes.
These details, which are presently included in TS and that are removed by this amendment, do not constitute performance requirements necessary to ensure safe operation of the-facility and, therefore, do not warrant being included in TS. At the same time, suitable administrative controls ensure that there will be careful review and analysis by competent individuals of any changes in the-Fire Protection Program including those technical and administrative requirements removed from the TS to ensure that nuclear safety is not adversely affected.
These controls include:
(1) the TS administrative controls that are applicable to the fire Protection Program; (2) the license condition on implementation of, and subsequent change to, the Fire Protection Program; and
-(3) the 10 CFR 50.59 criteria for evaluating changes to the Fire Protection Program as described in the USAR. The Davis-Besse Fire Hazards Analysis Report (FHAR) has been incorporated by reference into_the USAR, Section 9,5.1,
" Fire Protection System," and the Fire Protection Program requirements have been incorporated into the FHAR Section'8.0, " Operating Specifications."
l-The specific details relatino to fire protection _ requirements _ remcVed from TS by this amendment include tPcse specifications for fire _ detection systems, fire suppression systems, fire barriers, and fire brigade staffing.
requirements.
The administrative controls requirements have been modified to include Fire Protection Program implementation as an element for which written-procedures must lnr established, implemented, and m:intained. 'In addition,=the review responsibilities of the Station' Review Board were expanded to include the review of the Fire Protection Program and changes thereto.
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The TS changes proposed by the licensee are in accordance with the guidance provided by Generic Letter 88-12, as addressed in the items below.
(1)
Specification 6.5.1.6, " Station Review Board Responsibilities," was revised to add the review of the fire Protection Program and changes thereto.
(2)
Specification 6.8, " Procedures and Programs," already includes the i
requirement-for written fire Protection Program proceduret to be established, implemented, and maintained, s
(3)
Specification 3.3.3.8, "Fira Detection Instrumentation," its associated Surveillance Requirements, and Bases were removed.
(4)
Specification 3/4.7.9, " Fire Suppression Systems," the associated Surveillance Requirements, and Bases were removed.
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_(5)
Specification 3/4.7.10, " Fire-Barriers," its associated Surveillance Requirements, and Bases were removed.
(6)
Specification 6.2.2.7 on fire brigade staffing requirements was removed.
As required by Generic Letter 86-10, the licensee confirmed that the NRC-approved fire Pretection Program has been incorporated into the USAR Section 9.5.1.
Also, the 1 tensee_has proposed that the existing licensing condition 2.C.(4) on the Fire Protection Program be replaced with the standard condition noted in Generic Letter 86-10.
in the letter dated November 1, 1991, the licensee committed to inform the NRC when the installation of additional area-type detection in the fuel handling area (Room 300).was complete.
The installation of additional area-type detection in Room 300 has been comp 1cted and the procedures have been revised to reflect the installation of new detectors. The fHAR, which is now part of the USAR, will_ be revised during the 1992 annual update to reflect the installation of the new detectors.
According to the guidance of Generic Letter 88-12, fire protection TS related to safe shutdown following a fire should not be included in the removal of detailed fire protection requirements from TS.
The licensee's submittal met this guidance, only in that:there were no existing TS related to safe shutdown following a fire, following discussions with the NRC staff, the licensee, by letter dated July 28, 1992, committed to include testing of transfer switches used to meet 10 CFR Part 50 Appendix R safe shutdown requirements, and will
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submit a license amendment application to include the transfer switch testing in the TS.
The licensee has committed to submit the application by December 31, 1992. The NRC staff. finds this to be an appropriate action.
The licensee confirmed that the operational conditions, remedial actions, and~
4 test requirements associated with the removed fire protection TS have been
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This is in accordance with the guidance of Generic Letter 88-12.
Un the basis of its review of the above items, the staf f concludes that the licensee has met the guidance of Generic Letter 88-12.
Therefore, the staff finds the proposed changes acceptable.
3.0 ST AT E CONSU_LT AT 10N in accordance with the Coms nn's regulations, the Ohio State official was notified of the proposed issuance of the amendment.
The State official had no comments.
4.0 ENVIRONMENT Al (04SEf PAT 1(lN This amendment involves a change to a requirement with respect to the instal-lation or use of a f acility component located within the restricted area as defined in 10 CFR Part ?0 or a change to a surveillance requirement. The staff has determined that the amendment involves no significant increasa in the amounts, and no significant change in the types, of any ef fluents that may be released offsite and that there is no significant increase in individual or cumulative occupational radiation exposure.
The Commission has previously issued a proposed finding that this amendment involves no significant hazards consideration and there has been no public comment on such finding (56 FR 64662).
Accordingly, this amerent meets the eligibility criteria for categorical exclusion set forth 4. 10 CFR Sl.22(c)(9).
This amendment also 3
involves changes in recordkeeping, reporting or administrative procedures or requirements.
Accordingly, with respect to these items, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 551.22(c)(10).
Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of this amendment.
5.0 CONClVS;JN On the basis of the considerations discussed above, the staff concludes that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulutions, and (3) the issuance of this amendnent will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributors:
T. Dunning J. Lombardo Date:
Septanber 22, 1992
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