ML20128P887
| ML20128P887 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 02/18/1993 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20128P884 | List: |
| References | |
| GL-86-10, GL-88-12, NUDOCS 9302250176 | |
| Download: ML20128P887 (5) | |
Text
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SAFETY EVALUATION DV itL 91FICE OF NUCLEAR REACTOR REGULATION BELATED TO AMENDMENT N0,161 10 FAClllTY OPERATING LICENSE NO. DPR-16 GPU NV.01f# l0RPORATIQN AND dERSEY CENTRAL P_0WER & LIGHT COMPANY Q111fJLCREEK N'). CLEAR GEREMIING stall 0R DOCKET NO. 50-21%
l.0 JBIRQD.Vfil0B By letter dated April 20, 1992, GPU Nuclear Corporation (the licensee) submitted a request for changes to the Oyster Creek Nuclear Generating Station (OCN3S) Technical Specifications (TS).
The requested changes would delete the fire protection TS and t'1eir associated bases and definittuis from the TS.
The delated requirements have been relocated to the OCNGS Fire Protection Plan.
The proposed amendment would augrent the Administrative Controls Section of the TS to require:
(1) that written procedures be established; implemented and maintainea for activities involving implementation of the Fire Protection Program, (2) periodic review of the Fire Protection Program and im)1ementirg procedures by a qualified individual / organization, and (3) suamittal of recommcoded changes to the Fire Protection Program cod implementing procedures to the Safety Review and Audit Board, Conforming changes would also be made to the TS.
License Condition 2.C(3) has been previously revised to:
(1) require the licensee to implement and maintain in-effect all provisions of the approved Fire Protection Program as described in the updated Final Safety Analysis Report (UFSAR) as approved in the Fire Protectica Safety Evtluation Report dated March 3, 1978, and supplements, and (2) permit the licensee to make changes to the approved Fire Protection Program without prior approval of the NRC, only if tho:0 changos would not adversely affect the ability to achieve and maintain safe sh'Jtdown-in the cvent of a fire. The proposed changes are in accordance with the guidance-provided in NRC Generic letters 88-12, " Removal of Fire Protection Requirements from Technical Specifications," dated August 2, ISd8 and 86-10,
" Implementation of Fire Protection Requirements," dated April 24, 1986.
2.0 MCKGRQM!{Q 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 facilitier.
Because of the extensive modtfication 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-9002250176 930218 PDR ADOCK O$000219 P
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approved Fire Protection Program in their Final Safety Analysis Resorts (FSARs).
In this manner, the Fire Protection Program, including tie systems, the administrative and technical controls, the organization, and other plant features assod ated with fire protection, would have a status consistent with thtt of other plant features described in the FSAR.
In.
addition, the Commission concluded that standard license condition, requiring compliance with the arovisions of the Fire Protection Program as described in the FSAR, should se 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, 1
The licensees for the Callaway and Woif Creek plants sutunitted lead-plant -
proposals to remove fire protection requirements from their TS.
This action was an industry effort to obtain NRC guidance'on e.n acceptable format for license amendment requests to remove fire protection requirements from TS.
Additionally, in the licensing review of new plants, the staff had ap) roved requests to remove fire protection requirements from TS issued with t1e operating license.
Thus, on the basis of the lead-plant proposals an:' 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.
3.0 QLECMili_Off Tne licensee has requested an amendment to its operating license which would relocate fire protection Technical Specifications to the Updated Final Safety Analysis Report (VFSAR).
The TS changes proposed by the licensee are as follows:
1.
Deletion of TS Section 3.12 for Fire Detection Instramentation Fire Suppression Water Systems, Spray and/or Sprinkler Systems, Fire Huse Stations, Halon Systems and Fire Garrier Penetration Fire Seals and associated bases.
These TS requirements would be relocated to plant administrative procedures controls and to the Fire Protection Plan.
2.
De ilon of the minimum fire brigade staffing requirements TS G.2.2g.
TS 6.5.N2a currently states, "An independent protection and loss 3.
prevention program inspection and audit shall be performed annually utilizing;either qualified offsite _ licensee personnel, or an outside firo protection firm." The licensee requested that the word: "offsite" be deleted from the 15.
l 4.
TS Table 3.12-6 (which wuuld be renamed new Table 3.12-1), ' Alternate Shutdown Monitoring Instrumentation," be revised to identify "Rx2's, near V-15-30" as the readout location for control rod drive system flow.
5.
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.
6.
TS Table 3.12 6 (which would become Table 3.12-1) incorrectly identifies instrument rack "RK05" as the readout location for shutdown cooling system flow.
4.0 EVALUATION The license mendment request for OCNGS was reviewed against guidtnco provided in NRC Generic Letters 86-10 and 88-12.
In addition, an assassment was made against the guidance provided in Geaeric Letter 81-12 which establishes the need to provide T3 requirements for alternate shutdown equipment which was not previously contained in plant TS.
The licensee incorporated their fire proteccion program into Oyster Creek's Final Safety Analysis Report in January 1991.
The operability and surveillance requirements for the detection systems, fire suppression systems, fire barriers and fire brigade staffing requirements as defined in the current TS were incorporated into the fire protection program.
In addition, current TS 6.5.3.2a states, "An independent fire protection and loss prevention program inspection and audit shall be parformed-annually utilizing either qualified onsito licensee personnel or an outside fire protection firm." The licensee requested to delete the word "offsite" from the TS.
Generic Letter 82-21 states that the annual audits may be performed by qualified utility personnel who are not directly responsible for the site fire protection program or by an outside independent fire protection consultart. The liceiisee had estabitshed procedures to enst.re that the independence and effectiveness of the audit team by defining the comoosition of the audit team.
The entposition of the aud:t team will include either qualified utility personnel or an outside fire protection consultant. Based on the procedural controls and the composition of the audit team, this change would not reduce the quality or effectiveness of the annual audit and the cuidancepro{ldedinGenericLetter82-21hasbeenmet.
The licensee requested TS Table 3.12-6 (which would be renamed Table 3.12-1),
" Alternate Shutoown Monitoring Instrumentation" be revised to identify "Rx23 near V-15-30" as the readout location for control rod drive-system flow.
The licensee has stated that new flow indicator was installed near Valve V-15-30 is the new readout location.
Further, the existing surveillance-requirements of TS 4.12.1, which apply to the alternate shutdown monitoring instrumentation, would ensure the new flow indicator is capable of performing its intended' function.
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The licensee requested TS Tables 3.12-G (which would become Table 3.12-1) and 4.12-1 be revlu d to delete the operability and surveillance requirement for the condensate transfer pump discharge pressure indicctor.
This proposed change would be consistert with the guidance provided in Generic Letter 86-10.
The surveillance requirements would be relccated in the Plant Administrative procedures.
TS Table 3.12-6 Shich would become Table 3.12-1) incorrectly identifies instrument rack "RK05" as the readout location for shutdown cooling system flow.
The correct readout location is located on the 51 foot elevation of the reactor building near the reactor building closed cooling water heat exchangers.
Accordingly, TS Table 3.12-6 (3.12-1) would be revised to identify " local" as the readout location for this parameter.
The licensee has stated in the April 20, 1992, submittal that the existing TS for the alternate shutdown monitoring instrumentation would be retained in the existing TS and do not propose the removal of the alternate shutdown instrumentation from the TS. This is consistent with the Generic Letters 81-12 and 88-12 guidance and is therefore acceptable.
Based on the review of the April 20, 1992, request for changes to the license and fire protection sortion of the TS for OCNGS, the staff concluded that GPU Nuclear Corporation las followed the guidance provided by the NRC in Generic Letters 86-10 and 88-12 and the requested changes should be approved.
5.0 STATE CONSI)LTATION in accordance with the Commission's regulations, the New Jersey State official was notified of the proposed is;,uance of the amendment.
The Statu official had no comments.
6.0 ENVIRONMENTAL (pMlpERATlW The amendment changes a requirement with respect te installation or use of a facility component located within the rer,tricted area as defined in 10 CFR Part 20 and changes surveillance requirements.
The amendment also relates to changes in recordkeeping, reporting, or administrative procedures or requirements. The NRC staff his determined that the amendment invo!ves no significant. increase in the amounts, and no significant enor.2e in the types, of any effluents that may be released offsite, and that there is no.
- significant' increase in inolvidual 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 (57 FR 20511). Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9) and (10).
Pursuant to 10 CFR Sl.22(b) no environmental impact statement or environmental arsessment need be pre;:ared in connection with the issuance of the amendment.
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7.0 CONCLU110H' The Commission has concluded based c (1)thereisreasonableassurr.theconsiderationsEdiscussedabove.
that:
nce that the health and safety of the
.f public will not be endangered by operation in the proposed manner, (2) such.
4, activities will be conducted in compliance with the Commission's reguistions, and (3) the f ssuance of the amendment will not be inimical to the common-defense and security cr to the health and safety of the public.
Principal Contributor:
A. Singh Date:
February 18, 1993 k
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