ML20147C964
| ML20147C964 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 02/24/1988 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20147C950 | List: |
| References | |
| NUDOCS 8803030201 | |
| Download: ML20147C964 (4) | |
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o UNITED STATES
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NUCLEAR REGULATORY COMMISSION o
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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION Sl'PPORTING AMENDMENT NO.15 TO FACILITY OPERATING LICENSE NO. NPF-42 KANSAS GAS & ELECTRIC COMPANY KANSAS CITY POWER AND LIGHT COMPANY KANSAS ELECTRIC POWER COOPERATIVE, INC.
WOLF CREEK GENERATING STATION DOCKET NO. 50-482
1.0 INTRODUCTION
In Generic Letter 86-10, the staff recommended that licensces incorporate the approved fire protection program into the Final Safety Evaluation Report (Updated Safety Evaluation Report, (USAR) for Wolf Creek). This program includes the fire protection and post-fire safe shutdown systems necessary to satisfy staff guidelines and requirements, administrative and technical controls and procedures, the fire brigade and fire protection technical staff, and other plant features described in the USAR and staff safety evaluation reports.
Upon completion of this effort, including the certification required by 10 CFR 50.71(e)(2), licensees may then apply for an amendment to the operating license to substitute the standard fire protection license condition delineated in the generic letter. At the same time, licensees may request an amendment to delete the fire protection-related technical specifications which would be considered unnecessary.
By letters dated February 19 March 2 and April 17, 1987, the licensee submitted a request to amend the technical specifications and operating license in accor-dance with the above-referenced staff guidance. The information in these sub-mittals included proposed USAR revisions. The staf f reviewed this infonna-tion and identified a number of questions / concerns with the licensee's proposals.
By letter dated October 30, 1987, the licensee responded to those questions / con-cerns. The staff's evaluation of this information is as follows:
2.0 DISCUSSION The licensee proposed to delete the following fire protection technical specifications:
3.3.3.8.
Fire Detection Instrumentation, 3.7.10.1.
Fire Suppression Water System, 3.7.10.2.
Spray and/or Sprinkler Systems, 3.7.10.3.
Halon Systems, x
3.7.10.4.
Fire Hose Stations, 3.7.11.,
Fire Barrier Penetrations, eso3030201 080224 PDR ADOCK 0500 2
O The following fire protection technical specification will remain as is:
3.3.5.
Remote Shutdown Instrumentation 6.2.2.a.
Site Fire Brigade 6.5.2.8.e. and f.
Fire Protection Audits The licensee also proposed to revise Technical specifications 6.5.1.6 and 6.5.1.7, Plant Safety Review Ccm ittee (PSRC) res)onsibilities to provide specific reference to the requirement to review tie plant fire protection program 6nd submit recomended changes to the Nuclear Safety Review Committee. Technical Specification 6.8.1, Written Procedure Requirements, is revised to include the Fire Protection Program implementation.
In addition, although not specifically included in the technical specifications, the licensee comitted in the October 30, 1987 letter to report significant degradations of fire protection features in accordance with the criteria con-tained in 10 CFR 50.72, 10 CFR 50.73 and 10 CFR Part 21.
3.0 Ey,AL,U_ATION The staff had several concerns with the licensee's proposals, which necessi-tated additional written clarification.
The first was that in removing certain technical specifications and relying upon the Fire Protection Program and pro-cedures, the operating restrictions and surveillances for the fire protection features would be changed so as to be less conservative than either the original plant technical specifications or the Standard Technical Specifications.
However, staff review of the information submitted in support of the amendment confirms that the operating restrictions and surveillances added to the Fire Protection Program and precedures are equivalent to those which were in the technical specifications. On this basis, the staff's concern has been resolved.
The staff was also concerned that all of the fire protection features which are necessary to satisfy staff fire protection guidelines and requirerents and which were encompassed by the original technical specifications might not receive adequate surveillance. While it was initially clear that the licensee intended to carry out surveille.nce on features protecting safe-shutdown systems, it was not clear that all of the technical specification operating restrictions and surveillances for the relocated fire protection features would be included in the Fire Protection Program and procedures. The licensee responded that their comitments to surveil all fire protection features required to satisfy Appendix A to BTP APCSB 9.5-1 and Appendix R to 10 CFR Part 50 are not being changed in conjunction with the removal of certain fire protection technical specifications. The staff concludes that the scope of fire protection features to receive surveillance has not been reduced. On this basis, the staff's concern has been resolved.
The staff was also concerned that surveillance of all post-fire safe shutdown and alternate shutdown systems would not be conducted as stipulated in Generic 1.etter 81-12. The licensee has shown to the staff that the existing technical specifications are comprehensive with regard to post-fire shutdown systems and will remain unchanged. On this basis the staff's concern is resolved.
3 The licensee proposed to delete the shutdown requirement of specification 3.7.10.1 Action b.
By letter dated October 30, 1987 the licensee stated that the requirenents of specification 3.7.10.1 Action b., will be added to the USAR. The staff considers comitments made in the October 30, 1987 letter to be ai:ceptable.
The staff was concerned that significant degradations of fire protection would not be reported to the staff. The licensee connitted to report such degrada-tions as described in the Discussion section above. The staff is currently re-viewing the need for additional guidance and requirements concerning the reporting of fire protection deficiencies.
Finally, the staff was concerned that the entire fire protection program would not be included in the USAR. The USAR presently contains information such as the fire hazards analysis, responses to staff questions, fire protection conn.it-rents, coniparisons of plant design to Appendix A to BTP APCSB, and the methcdo-logy for assuring conformance with Appendix R to 10 CFR 50, sections III.G.
III.J., III.L. and III.O. The staff evaluated this information and found it acceptable as documented in the SER and in Supplements Nos. 3 and 4 The licen-see has revised the USAR to incorporate the fire protection feature operating restrictions and surveillances which have been removed from the technical specifications. This conforms with the guidance issued in Generic Letter 26-10 and therefore is acceptable.
Based on the above evaluation the staff concludes that the licensee's proposed anendnent conforms with the guidance issued in Generic Letter 86-10. The staff has also verified that the USAR contains the conplete Wolf Creek Fire Protection Program.
4.0 ENVIRONMENTAL CONSIDERATION
The amendment involves a change in the installation or use of a facility com-ponent located within the restricted area as defined in 10 CFR Part 20 or in a surveillance requirement. The staff has determined that the an.endnent 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 curulative occupational radiation exposures. The Com-mission has previously issued a proposed finding that the amendn.ent involves no significant hazards consideration and there has been no public comnent on such finding. Accordingly, the amendment reets the eli rical exclusion set forth in 10 CFP Section 51.22(gibility criteria for catego-c)(9). Pursuant to 10 CFR 51.??(b), no environmental impact statement or environmental assessnent need be prepared in connection with the issuance of the amendment.
5.0 CONCLUSIOj!
The staff has concluded, based on the considerations discussed above, that:
(1) there is reasonable assurance that the health and safety of the public will
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not be endangered by operation in the proposed manner, and (2) such activities will be conducted in compliance with the Comission's regulations, and the issuance of the amendment will not be inimical to the conson defense and secu-t rity or to the health and safety of the public, Date:
February 24, 1988 Principal Contributors: Dennis Kubicki, Paul W. O'Connor 1
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