ML20127D896

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Safety Evaluation Supporting Amends 96 & 88 to Licenses NPF-2 & NPF-8,respectively
ML20127D896
Person / Time
Site: Farley  Southern Nuclear icon.png
Issue date: 01/12/1993
From:
Office of Nuclear Reactor Regulation
To:
Shared Package
ML20127D884 List:
References
GL-86-10, GL-88-12, NUDOCS 9301190077
Download: ML20127D896 (5)


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SAFETY EVALVATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 96 TO FACILITY OPERATING LICENSE NO. NPF-2 AND AMENDMENT NO. 88 TO FAClllTY OPERATING LICENSE NO. NPF-8 SOUTHERN NUCLEAR OPERATING COMPANY. INC.

JOSEPH M. FARLEY NUCLEAR PLANT. UNITS 1 AND 2 DOCKET NOS. 50-343 AND 50-361 i

1.0 MlE0 DUCTION By letter dated February 26, 1991, Alabama Power Company submitted a request for changes to the Joseph M. Farley Nuclear Plant (Farley), Units 1 and 2, Technical Specifications (TSs). The requested changes would remove requirements for the fire detection systems, fire suppression systems, fire barriers, and fire brigade staffing requirements as recommended by Generic Letter (GL) 86-10.

Guidance on these proposed TS changes was provided to all power reactor licensees and applicants by GL 88-12, dated August 2, 1988.

Subsequent to the February 26, 1991, submittal, Alabama Power Company requested in a May 6, 1991, letter, that Scuthern Nuclear Operating Company, Inc., (Southern Nuclear) become the licensed operator of Farley, Units 1 and 2.

The May 6, 1991, letter requested that the license conditions proposed in the February 26, 1991, letter be amended to reflect Southern Nuclear as the operator once the change in licensed operators was implemented. Amendment Nos. 90 and 83 to facility Operating Licenses NPF-2 and 8, respectively, were issued authorizing Southern Nuclear (the licensee) to become the licensed operator.

This change was implemented on December 23, 1991.

Therefore, the May 6, 1991, letter did not affect the initial proposed no significant hazards consideration determination, in the letter dated February 26, 1991, the licensee also requested that the staff review proposed revisions to the Safety Evaluations supporting issuance of Exemption Request Nos. 1-38 and 2-35 to the requirements of 10 CFR Part 50, Appendix R, and issue corrected Safety Evaluations.

The revisions were proposed to correct the Safety Evaluations to reflect the as-built condition of the plant.

2,0 fnGGROUND Following the fire at the Browns Ferry Nuclear 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 exter.sive modification 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, the 9301190077 930112 DR ADOCK 0500 0

t 2-licensees were requested by GL 86-10 to incorporate the final NRC-approved fire Protection Program into their Final Safety Analysis Reports (FSARs).

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 with that of other plant features described in the FSAR.

In addition, the Commission concluded that a standard license condition, requiring compliance with the provisions of the Fire Protection Program as described in-the FSAR, should be used to ensure uniform enforcement of fire protection requirements.

Finally, the Commission stated that with the requested actions, llcensees may-request an amendment to delete the fire protection TSs that would now be unnecessary.

The licensees for the Callaway and Wolf Creek plants submitted lead-plant.

proposals to remove fire protection requirements from their TSs.

This-action i

was an industry effort to obtain NRC guidance on an acceptable format for i

license amendment requests to remove fire protection requirements from the TSs.

Additionally, in the licensing review of new plants, the staff has approved applicant requests to remove fire protection requirements-from TSs issued with-the operating license.

Thus, on the basis of the lead-plant proposals and the staff's experience with TSs for new licenses, GL 88-12 was issued to provide guidance on removing fire protection requirements from the TSs.

3.0 EVALUATION l

The proposed changes were reviewed against the guidance provided in GLs 86-10 and 88-12.

GL 86-10 recommended the removal of fire protection t

requirements from the TSs.

Although a comprehensive Fire Protection Program is essential to plant safety, the basis for this recommendation is that many details of this program that are currently addressed in the TSs can be modified without affecting nuclear safety.

Such modifications can be made provided that there are suitable administrative controls over-these changes.

These details, that are presently included in the TSs and which are removed by-this amendment, do.not constitute performance requirements necessary to ensure i

safe operation of the facility and, therefore, do not warrant being. included in the TSs. 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 TSs, 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 conditibn on implementation of, and subsequent changes 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 FSAR.

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! The proposed TS changes include the following:

1.

Revision of the fire protection License Conditions 2.C.(4) for Unit I and 2.C.(6) ion license condition contained in GL 86-10.for Unit 2 to provide consistency with the sta protect 2.

Deletion of Unit I and Unit 2 fire protection TS 3/4.3.3.9 (Fire Detection Instrumentation), 3/4.7.11 (Fire Suppression Systems), 3/4.7.12 (Fire Barrier Penetrations), and associated Bases sections.

3.

Deletion of the minimum fire brigade staffing requirement, TS 6.2.2.e, for both units.

The proposed license conditions for Units 1 and 2 are as follows:

Southern Nuclear shall implement and maintain in effect all provisions of the approved fire protection program as described in the Final Safety Analysis Report for the facility and as approved in the Fire Protection Safety Evaluation Reports dated February 12, 1979 August _.24, 1983, December 30, 1983, November 19, 1985, Se?tember 10, 1986, and December 29,-1986.

Southern Nuclear-may make clanges to the approved fire protection program without prior approval ol' the Commission only if those changes would not adversely affect the ability to achieve and maintain safe shutdown.

The licensee incorporated their fire Protection Program into the July 1987 FSAR update as Appendix 98. Attachment C to Appendix 9B contains operability and surveillance requirements for the fire protection equipment and systems that currently exist in the plant's TSs.

Fire brigade staffing requirements are also included in Appendix 98. Appendix 9B also contains a list of implementing procedures by number and title, which implement the Fire Protection Program as described-in the FSAR. Many of these procedures are currently based on requirements in the TSs.

TheIicenseestatesintheir February 26, 1991, submittal that these procedures will be modified to reflect the FSAR tased Fire Protection Program within 90 days of NRC approval by which time the TS changes will be implemented.

The list of implementing procedures along with their identified performance frequencies were compared with existing TSs and found to be consistent.

Therefore eliminating TSs would not reduce the level of safety and is consistent with guidance in GLs 86-10 and 88-12.

In addition, current TS 6.5.1.6(b) requires that the Plant Operations Review Committee (PORC) review the safety evaluations for all programs required by Specification 6.8 and changes thereto.

Specification 6.8.l(f) requires that written procedures be established, im)lemented, and maintained covering-Fire Protection Program implementation. Tierefore, the guidance in GL 88-12 calling for the addition of these sections into the TSs has been met, The licensee also states in their February 26, 1991, submittal that they will relocate, to administrative procedures, the requirement that currently exists in TS 3/4.7.11.1 to shutdown the reactor in the event of loss of all fire water for' greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Maintaining this requirement is consistent

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4 with guidance provided in GL 88-12.

The proposed license condition was also found to be consistent with_the license condition provided in GL 86-10 and is considered acceptable.

By letter dated February 26, 1991, the licensee stated that Safety Evaluations for Exemption Request Nos. 1-38 and 2-35 to the requirements of 10 CFR Part 50, Appendix R, required revision to reflect the actual plant condition at the time of the requests. The exemption requests and the supporting Safety Evaluations were issued in staff letters dated September 10 and December 29, 1986, respectively.

Specifically, the licensee identified that the room cooler for the Train A motor driven auxiliary feedwater pump room was located outside of the pump room instead of inside the room as stated in the original submittal to the NRC.

The location change for the room cooler does not change the staff's conclusion which states that a fire in this area will leave auxiliary feedwater flow to at least one steam generator.

4.0

SUMMARY

Based on the review of the february 26, 1991, submittal, as supplemented on May 6, 1991, requesting changes to the operating license and fire protection portions of the -TSs for Farley, Units 1 and 2, it is concluded that the licensee has followed the guidance provided in GLs 86-10 and 88-12.

Therefore, the proposed changes are acceptable.

Additionally, the change in the indicated location for the room cooler does not affect the original exemptions as granted.

5.0 STATE CONSULTATION

in accordance with the Commission's regulations, the State of Alabama official was notified of the proposed issuance of the amendment.

The State official had no comments.

6.0 ENVIRONMENTAL CONSIDERATION

The amendment changes a-requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and changes to the surveillance requirements The amendment also relates to changes in recordkeeping, reporting, or administrative procedures or requirements.

The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents 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 the amendment involves no significant hazards consideration, and there has been no public comment on such finding (56 FR 20026). Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

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7.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that:

(1) there is reasonable assurance that the health and stfety 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 regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

4 Principal Contributors:

S. Hoffman j

A. Singh Date: January 12, 1993 e

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