BVY-96-155, Application for Amend to License DPR-28,requesting Rev to TS to Relocate Fire Protection Requirements
| ML20132B570 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 12/10/1996 |
| From: | Reid D VERMONT YANKEE NUCLEAR POWER CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20132B575 | List: |
| References | |
| BVY-96-155, GL-86-10, GL-88-11, NUDOCS 9612170301 | |
| Download: ML20132B570 (5) | |
Text
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Y VERMONT YANKEE NUCLEAR -POWER CORPORATION Ferry Road, Brattleboro, VT 05301-7002 ENGINEERING OFFICE 580 MAIN STREET a
8OLTON, MA 01740 (508)779-6711 December 10,1996 BVY 96155 United States Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 i
References:
(a)
License No. DPR 28 (Docket No. 50-271)
(b)
NRC Generic Letter 86-10, " Implementation of Fire Protection Requiremerns",
dated 4/24/86.
(ci NRC Generic Letter 88-12, " Removal of Fire Protection Requirements from the Technical Specifications", dated 8/2/88
Subject:
Proposed Change No.189 - Relocation of Fire Protection Requirements from Technical Specifications l
Pursuant to Section 50.90 of the Commission's Rules and Regulations, Vermont Yankee Nuclear Power Corporation hereby proposes the following change to Appendix A of the Facility Operating License
[ Reference (a)].
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Proposed Chanae:
This proposed change revises the Facility Operating License (FOL) and Technical Specifications (TS) to relocate fire protection requirements to the Vermont Yankee Fire Protection Plan and FSAR in accordance with References (b) and (c).
Specifically, the changes proposed are as follows:
(1)
Facility Operating License page 7, replace paragraph 3.F with the following:
" Vermont Yankee shall implement and maintain in effect all provisions of the approved Fire a
Protection Program as described in the Final Safety Analysis Report for the facility and as
)f approved in the SER dated January 13,1978, and supplemental SERs, subject to th,e following
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provision:
Vermont Yankee 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 1
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achieve and maintain safe shutdown in the event of a fire."
9612170301 961210 PDR ADOCK 05000271 P
PDR l
U.S. Nuclear Rrgulatary C:mmission VERMONT YANKEE NUCLEAR POWER CORPORATION December 10,1996 Page 2 q
(2)
TS Table of Contents page (v), substitute the word ' DELETED' in section 3.13.
(3)
TS Definitions, page 4, replace definition 'AA', Vital Fire Water Suppression System with the word ' DELETED'.
(4)
TS Section 3.10, page 216, delete fire watch requirement.
(5)
TS Sections 3.13/4.13, Fire Protection, pages 240 through 252, replace each page with a new page with the words 'This page has been deleted'.
(6)
TS Section 6, Administrative Controls:
l Page 256, delete paragraph 6.1.E and the note at bottom of page.
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l Page 259, add new paragraph 6.2.A.6.h, which says " Review of the Fire Protection program and implementing procedures".
q Page 262, modify paragraph 6.5.A.7 such that only the words " Fire protection program implementation" remain.
Page 275, delete paragraph 6.7.C.2.f.
Reason / Basis for Chanoe:
The purpose for these proposed changes is to move fire protection requirements from the Vermont l
Yankee Technical Specifications to the Fire Protection Plan and the FSAR, in accordance with the guidance in NRC Generic Letters 86-10 and 88-12.
Nuclear Regulatory Commission (NRC) Gener'c Letter 86-10 (Reference (b)) Section F, " Addition of l
Fire Protection Program into UFSAR", describes several problems for licensees and NRC inspectors in identifying the operative and enforceable fire protection requirements at each licensed facility. The NRC has concluded that the best way to resolve these problems, is to incorporate the fire protection I
program and major commitments, including fire hazards analysis, by reference into the Final Safety Analysis Report (FSAR) for the facility, in so doing, the plant features associated with the fire protection program would be on a consistent status with other plant features described in the FSAR.
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In addition, the provisions of 10CFR50.59 will apply for changes made in the Fire Protection Plan to assure that any changes would not involve an unreviewed safety question.
Generic Letter 88-12 (Reference (c)) provided further guidance for the preparation of a license amendment to implement Generic Letter 86-10. Generic Letter 88-12 suggests that the amendment remove the fire protection requirements from Technical Specifications in four major areas: fire detection systems, fire suppression systems, fire barriers and fire brigade staffing requirements. It also states that fire protection audit administrative controls be retained in the Technical Specifications and that specific review requirements be added in the Plant Operations Review Committee (PORC) responsibilities.
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l U.S. Nuclerr Rigulatory Ccmmissi:n VERMONT YANKEE NUCLEAR POWER CORPORATION Dec:mber 10,1996 Page 3 Safety Considerations:
There are no safety implications associated w'ith these proposed changes because:
(a)
No fire protection requirements have been deleted, just relocated (b)
The effectiveness of,the program will be assured by the revised License Condition which is the standard license condition provided in Generic Letter 86-10 (c)
PORC review of the Fire Protection Program, implementing procedures and proposed changes, assure no loss of effectiveness (d)
The provisions of 10 CFR 50.59 apply to changes made in the Fire Protection Program to assure that any changes do not involve an unreviewed safety question This proposed amendment relocates fire protection requirements from Technical Specifications to the I
W Fire Protection Plan and to the FSAR. Operating limitations will continue to be imposed and required surveillances will continue to be performed in accordance with written procedures and instructions auditable by the NRC. Although future changes to the fire protection program elements will no longer be controlled by 10 CFR 50.36, " Technical Specifications", proposed changes will be evaluated in accordance with the new License Condition,10 CFR 50.59 and plant procedures.
These changes are consistent with the guidance provided in Generic Letters 86-10 and 88-12 and will not reduce the effectiveness of the Fire Protection Program. Since no changes have been made to the technical content, the relocation is primarily administrative in nature.
This proposed change has been reviewed by the Vermont Yankee Plant Operations Review Committee and the Nuclear Safety Audit and Review Committee.
Slanificant Hazards Considerations:
The standards used to determine that a regast for amendment involves no significant hazards are included in 10CFR50.92 of the Commission's rules and regulations. These standards state that operation of the facility in accordance with the proposed amendment will not: (1) involve a significant increase in the probability or consequences of an accident previously evaluated, (2) create the possibility of a new or different kind of accident from any accident previously evaluated, or (3) involve a significant reduction in a margin of safety. The discussion below addresses each of these criteria and demonstrates that the proposed amendment does not constitute a significant hazard.
1.
The proposed amendment will not involve a slanificant increase in the probability or consecuences of an accident orevious!v evaluated:
The proposed changes are administrative in nature and are consistent with the guldance provided in NRC Generic Letters 86-10 and 88-12. These changes do not affect the Initial conditions or precursors assumed in the FSAR safety analyses. These proposed changes also j
do not decrease the effectiveness of equipment relied upon to mitigate the previously evaluated accidents. Programmatic controls will continue to assure that fire protection program changes do not reduce the effectiveness of the program to achieve and maintain safe shutdown in the j
event of a fire.
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l U.S. Nuclear R0gulatory Commission VERMONT YANKEE NUCLEAR POWER CORPORATION
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December 10,1996 Page 4 i
i 2.
The prooosed amendment will not create the possibility of a new or different kind of accident from an accident oreviousiv eva'uated.
The proposed changes do not modify any plant equipment, there is no reduction in fire protection requirements, there is no change in operating procedure and surveillance requirements and.r,o reduction in administrative control or equipment reliability. Therefore, 4
Implementation of the proposed change will not affect the design function or configuration of any component, introduce any new operating scenarios, failure modes or accident initiators.
3.
The proposed amendmert will not involve a slanificant reduction In a marain of safety:
The proposed amendment does not involve a reduction to the Fire Protection Program. The fire protection requirements are simply being relocated to other controlled documents. There are no equipment modifications being proposed, only the location of fire protection j
requirements, which is administrative in nature.
. Based on the above discussion, we have determined that this proposed license amendment does not constitute a significant hazard as defined in 10CFR50.92.
9 Environmental imoact Consideration:
Vermont Yankee has reviewed this request against the criteria of 10 CFR 51.22 for categorical l
exclusion from environmental impact considerations. The proposed changes do not involve a j
significant hazards consideration or significantly increase the amounts or change the types of effluents that may be released offsite, nor do they significantly increase individual or cumulative occupational a
radiation exposure. Based on the foregoing, Vermont Yankee concludes that the proposed change meets the criteria given In 10 CFR 51.22(c)(9) for categorical exclusion from the requirement for an Environmental impact Statement.
Schedule of Chance:
The proposed change will be incorporated into the Vermont Yankee Technical Specifications as soon as practicable following receipt of your approval.
We trust that the information provided adequately supports our request, however, should you have any questions regarding this matter, please do not hesitate to contact this office, Sincerely, VERMONT YANKEE NUCLEAR POWER CORPORATION A
Donald A. Meld Vice President, Operations
U.S, Nuclair Reguatory Commission VERMONT YANKEE NUCLEAR POWER CORPORATION I
December 10,1996 Page 5 Enclosure A: Affected Technical Specification pages Enclosure B: New Technical Specification pages 4 > N '!Cg g,
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USNRC Region 1 Administrator USNRC Resident inspector - WNPS USNRC Project Mant.ger - WNPS gg7Agy }t p
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STATE OF VERMONT
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Then personally appeared before me, Donald A. Reid, who, being duly sworn, did state thaYe $s Vice President, 3
Operations, of Vermont Yankee Nuclear Power Corporation, that he is duty authorized to execute and file the foregoing document in the name and on the behalf of Vermont Yankee Nuclear Power Corporation, and that the statements therein are true to the best of his knowledge and belief.
1 Sally A.@andstrum, Notary Public j
My Commission expires February 10,1999 4
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