ML20127H240
| ML20127H240 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 01/13/1993 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20127H220 | List: |
| References | |
| GL-86-10, NUDOCS 9301220261 | |
| Download: ML20127H240 (8) | |
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UNITED STATES 3
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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULAT10tj REL ATED TO AMENDMENI fiO. 75 TO FACILITY OPERAT11(G LICENSE NO. DPR-80 AND AMENDMBH No. 74 TO FACILITY OPERATING LICENSE NO. DPR-02 PACIFIC GAS AND ELECTRIC COMPANY DlMl0 CANYON NUCLEAR POWER PLANT. UNIT NOS.1 AND 2 DOCKET NOS. 50-275 AND 50-323 1.0 INTRODVCTION By letter dated November 15, 1990, as supplemented by letters dated May 19, 1992 and October 8, 1992, Pacific Gas and Electric Company (PGLE or the licensee) requested amendments to Facility Operating Licenses DPR-80 and DPR-82 for Diablo Canyon Units 1 and 2, respectively.
The amendment application is designated License Amendment Request LAR 90-11.
The amendments change the combined Diablo Canyon technical specifications (TS) to:
(1) revise the fire protection license condition (2.C.(5)) and the reporting license condition (2.G.), (2) relocate the fire protection TS and associated bases to plant procedures and the Updated Final Safety Analysis Report (UFSAR), (3) augment the administrative TS to define the fire protection program controls, and (4) revise the condensate storage tank TS and associated bases to clarify the requirement for watcr sources used by the auxiliary feedwater system.
The PG&E letter of May 19, 1992, provided additional information on the specific fire protection sections that will be included in the next FSAR update.
This documents in the FSAR the major commitments for the basis of the Diablo Canyon fire protection program, in accordance with the recommendations of GL 86-10.
The PG&E letter of October 8,1992, proposed that the fire protection license conditions not be relocated in the licenses, contrary to what had been proposed in the PG&E letter of November 15, 1990.
This is an administrative change.
The information provided by the 1992 submittals is within the scope of the initial notice and did not affect the Commission's initial determination.
2.0 RA10ATION A
Pacific Gas and Electric Company has proposed changes to the operating licenses and the technical specifications for Diablo Canyon Units 1 and 2.
The changes proposed by the licensee are discussed below.
9301220261 930113 DR ADOCK 0500 5
l A.
Fire Protection Chanaes t
The licensee has recuested that the fire protection TS be relocated to plant procedures anc the UFSAR in accordance with the guidance of the NRC's Generic Letter (GL) 86-10. " Implementation of Fire Protection Requirements," and GL 88-12 " Removal of Fire Protection Requirements from Technical Specifications." The staff's contractor, Science Applications International Corporation (SAIC), reviewed the licensee's submittals.and t
found it acceptable. The SAIC Technical Evaluation Report (TER)-
documenting its review is enclosed.
The NRC staff has reviewed the.SAIC-TER and agrees with its conclusions.
B.
Clarification of Water Source Reauirements for the Auxiliary Feedwater I
Eulem (AFW)
In its november 15, 1990, letter, PGLE proposed that the TS for the condensate storage tank be modified to clarify the requirements for-water
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sources for the auxiliary feedwater system (AFW).
Specifically, the following changes to TS 3/4.7.1.3 were proposed:
(1)
The title of TS 3/4.7.1.3 is changed from " Condensate Storage Tank" to
" Auxiliary Feedwater Source."
(2)
The Limiting Condition for Operation-(LCO) is changed to require that a useable volume of water of 164,678 gallons be maintained in the ti condensate storage tank (CST) with an open flow path to the-AFW pump.
suction.
In addition, the LCO requires that a useable volume of water be maintained in the-fire water storage tank (FWST) of 57,922 gallons when one unit is in operation and 115,844 gallons when two units are in operation, with a flow path capable of being aligned to the AFW-pump suction.
The previous TS required that the CST have a contained volume of 178,000 gallons. The previous TS had no LC0 on the FWST, but allowed the FWST to serve as a backup AFW supply source when the CST is inoperable, with a surveillance requirement that required.
demonstrating once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.that'the FWST contained at least
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270,000 gallons when it is the supply source for the AFW pumps.
(3) The Action-Statements, Surveillance Requirements, and Bases for the-
.3 revised TS 3/4.7.1.3 were changed to be-consistent with the revised-LCO.
The NRC' staff has reviewed the proposed changes and' finds them acceptable because they make no physical alteration to the water source-or the AFW system, nor is there a change in the method by which the AFW system performs its functions.
Further, the changes-provide assurance that there will be a sufficient quantity of water-supplied to the AFW pumps to remove heat from the reactor coolant system in the
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event of a loss of normal feedwater to the steam generators.
Specifically, the revised TS requires that 222,690 gallons (164,768 4
plus 57,922) be avellable when one unit is in operation, or 280,612 (164,768 plus 115,844) gallons of water be available when both units are in operation.
These volumes are sufficient to allow plant cooldown under the accident conditions postulated by Generic Letter 81-21. " Natural Circulation Cooldown," which was committed to by PG&E by letter dated December 7, 1981.
Based on the above, the NRC staff finds the proposed changes to TS 3/4.7.1.3 to be acceptable.
3.0 STATE C0!fSVLTATION in accordance with the Commission's regulations, the Ca11tornia State official was notified of the proposed issuance of the amendments.
The State official had no comments.
4.0 LtiyRQ!iMf14TAL _ CONSIDERATION These amendments involve changes with resWci to the installation or use of a facility component located within the restricted area as defined in 10 CFR part 20 and change surveillance requirements.
The staff has determined that the amendments involve no significant increase in the amounts, and-no signifi-cant 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 amendments involve no significant hazards consideration and there has been no public comment on such finding (56 FP.11784). Accordingly, these amendments meet 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-these amendments.
5.0 [0!!EWS1Qfti The Commission has concluded, based on the considerations discussed above, 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 regulations, and (3) the issuance of these amendments will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributors:
J. Singh, RIV H. Rood, NRR Dated:
January 13, 1993
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TECHNICAL EVALUA'110N REPORT FIRE PROTECHON 1.JCENSE AMENDMENT REQUEST DIABLO CANYON UNTIS 1 AND 2 TAC Nos. M79423 and M79424 SA/C Sciance Applications knametiord Corpondbon An EmployceDwned Company July 23,1992 Prepared for:
U.S. Nuclear Regulatory Commission Washington, DC 20555 Contract NRC 03 87 029 Task Order No. 97 I
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1,0 INTRODUCTION This Technical Evaluation Report (TER) documents in independnt review of Ucense Amendment Request 9011 submitted for Diablo Canyon Units 1 and 2 by Pacific Gas and Electric Company, the licensee. The request was submitted to the NRC by letter dated November 15, 1990. A plant visit was made on February 6 and 7,1992 following a preliminary review of the submittal. As a result of the plant visit and a subsequent conference call with the licensee on February 27,1992 it was determined that additional infennation was needed from the licensee. The licensee prmided this information to the NRC by letter dated May 19,1992.
2.0 DISCUSSION The licensee has requested an amendment to the Unit I and Unit 2 Operating Ucense,_
which would revise the fire protection license condition and relocate fire protection technical specifications to plant operating procedures. This amendment was requested in accordance with guidance provided in NRC Generic Letter 8610, The proposed changes to the Technical specifications are as follows:
1.
The requirements of TS 3/4.3.3.8 (Fire Detection Instrumentation),3/4.7.9.1 (Fire Suppression Water System),3/4,7.9.2 (Spray and/or Sprinkler systems),3/4.7.9.3 (CO2 system), 3/4.7.10 (Fire Barrier Penetrations) would be relocated to plant administrative procedure controls and to the FSAR Update..
2.
The requirements of TS 6.2.2.e (Plant Staff Fire Brigade Composition) are currently in the FSAR Update and also would be relocated to plant procedures.
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3.
T3 6.5.2.6 and 6.5.2.7 (Plant Safety Review Committee (PSRC) Responsibilities) would be revised to require PSRC review of the plant Fire Protection Program and its revisions and recommend approval to the Plant Manager.
4.
TS 6.8.1 (Written Procedure Requirements) would be revised to include the Fire Protection Program Implementation.
The proposed license condition for Unit i reads as follows:
PG&E shall implement and maintain in effect all provisions of the approved fire protection plan as discussed in its Final Safety Analysis Report Update,in PG&E's December 6,1984, Appendix R Report, and in the NRC staffs Fire Protection Evaluation in Supplement 8,9,
- 13. 23, and 27 to the Diablo Canyon Safety Evaluation Report, subject to provision b below.
Provision b:
PG&E may make changes to the approved fire protection program without prior approval of the Commission only if those changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire.
The proposed Unit 2 license condition reads exacdy the same as Unit 1 except Supplement 31 is added to the list of Safety Evaluation Reports.
3.0 EVALUATION The license amendment request for Diablo Canyon was reviewed against guidance provided in NRC Generic 12tters 86-10 and 8812. A site visit war made on February 5-6,1992 to review current arid proposed plant implementing procedures, in addition, an assessment was made against the guidance in Generic Letter 8112 which establishes the need to provide 2
whnical specification requirements for alternate shutdown equipment which was not previemly contained in plant technical specifications, ne plant proposes to relocate tne current fire protection technical specification requirernents identified in Section 2 of this TER, to plant Equipment Control Guidelines t
(ECGS). This type of procedure was (stablished by the licertsee to address those operating renuirements that did not erir, 'n plant technical specifications but existed in other !! censing documents such as the FSAR He proposed fire protection ECGS were reviewed to ensure that all :spects cf thc Art protection program which were be!ng deleted from technical speciDeations, would be r, dressed in plant procedures. Although F e fire protection ECOs were not approved at the time of review, the draft procedures presented, did cover all technical specification items.
The FSAR update was reviewed to verify that all aspects of the fire protection program had,.
been incorporated as defined in Generic Letter 86-10. The licensee had modified the FSAR Update in Revision 3 to include most aspects of the fine protection program. This Revision was submitted by letter dated September 16,1987 and contained the certification per 10 CFR 50.71(e) as required by Generic letter 86-10. Thia revision did not contain however, the operating requirements and surveillance requirements for fire protection equipment which is currently contained in plant technical specifications. The licensee stated that they intend to include this in'armation in the next FSAR Update submittal which is scheduled for September 1992. This is not in accordance with Generic Letter 8610 which states that the licensee must first include major commitments which form the basis of the fire protection program in the FSAR directly or by reference prior to removing technical specification requireme its. By letter dated May 19,1992 the licensee submitted a revision l
to the FSAR which included the operability and surveillance requirements proposed to be l
removed from technical specificatforu His FSAR revision was reviewed and found to provide the equivalent information that currently exists in the plant's technical specifications and is therefore acceptable.
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This review determined that :he licensee's proposal does properly modify the existing technical specifications to require the Plant Safety Review Committee to review changes to the fire protection program and that the technical specifications require that written procedures exist to govern the fire protection program implementation.
The proposed license conditions were also discussed with the licensee. Although they were determined to be consistent with Generic letter 8610, a concern arose regarding the reference to Supplement 31 to the Safety Evaluation Report, only in the Unit 2 condition.
Upon initial review, it was not clear whether this supplement had any impact on the Unit I fire protection prcgram. Because of this, the licensee agreed to review this supplement j
to determine if it should be added to the Unit 1 license condition. As a result of this review, the licensee informed the NRC by telephone call on February 27,1992 that the proposed license conditions did reference the appropriate safety evaluations and therefore l
did not need to be changed.
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' Die existence of technical specifications for alternate shutdown equipment was discussed with the licensee. The licensee stated that as a result of findings in NRC Region V Inspection Report 9101, a review of safe shutdown equipment was being conducted to determine if operability procedures were necessary. The 11eensee stated they did not intend to include any new operability requirements in technical specifications, however, they did intend to modify plant ECOs as appropriate. The licensee stated in their May 19,1992 letter that ECGS for alternate shutdown equipment not covered by existing technical specifications will be implemented by May 5,1993. The lack of technical specifications for alternate shutdown equipment does not conform to NRC guidance in Generic Letter 81 12.
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