ML20148G090
| ML20148G090 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 01/13/1988 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20148G074 | List: |
| References | |
| GL-86-10, NUDOCS 8801260405 | |
| Download: ML20148G090 (4) | |
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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION SUPPORTING AMENDMENT NO 30 TO FACILITY OPERATING LICENSE NO. NPF-_30 UNION ELECTRIC COMPANY CALLAWAY PLANT DOCKET NO. 50-483
1.0 INTRODUCTION
In Generic Letter 86-10, the staff recommended that licensees incorporate the approved fire protection program into the Final Safety Evaluation P.eport (FSAR).
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 tne FSAR and staff safety evaluation reports.
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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 letter dated February 19, 1987, Union Electric Company (the licensee) submitted a request to revise the Callaway technical specifications and amend the operating license in accordance with the above-refer 0 aced staff guidance. The information in these submittals included proposed FSAR revisions.
The staff reviewed this information and identified a number of questions / concerns with the licensee's proposals. By letter dated October 30, 1987, the licensee responded to those questions / concerns. The staff's evaluation of thic infoma-tion is as follows:
2.0 DISCUSSION The licensee proposed to delete the following fire protection Technical Specifications:
3.3.3.7.
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, 3.7.10.4.
Fire Hose Stations, 3.7.11.
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. The following fire protection Technical Specifications will remain as is:
3.3.3.5, Remote Shutdown Instrumentatien 6.2.2.e.
Site Fire Brigade d.5.2.8.e.
Fire Protection Audits and f.
The licensee also proposed to revise Technical Specifications 6.5.1.6 and 6.5.1.7, On-Site Review Comittee (ORC)/ Plant Safety Review Comittee (PSRC) responsibilities to provide specific reference to the requirement to review the plant fire protection program and 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 contained in 10 CFR 50.72, 10 CFR 50.73 and 10 CFR Part 21.
3.0 EVALUATION i
TP,c staff had several conce.ns with the licensee's proposals, which nece:.sitated additional written clarification. The first was that in removing certain tech-nical specifications and relying upon the Fire Protection Program and procedures, 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 specificatinns or the Standard Technical Specifications. However, the information submitted in suppert of the amendirent affinns that the operating restrictions and surveillances added to the Fire Protection Program and procedures are equivalent to those which were in the technical specifications. On this basis, the staff's concern has been resolved.
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The staff was also concerned that all of the fire protection features which are necessary to satisfy staff fire protection guidelines and requirements i
and which were encompassed by the original technical specifications would
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not be adequately surveilled. While it was initially clur that the licensee intended to surveil 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 scope of fire protection fetures to be surveilled 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 shetdown and alternate shutdown systems would not be conducted as stipulcted in Generic letter 81-12. The licensee responded that the existing technical specifications are comprehensive with regard to post-fire shutdown systens and will remain unchanged. On this basis, the staff's concern is resolved.
. The licensee had originally proposed to delete the shutdown requirement of Specification 3.7.10.1 Action b.
The staff's position is that the loss of the normal fire protection water supply and the inability to establish a back-up fire suppression water system within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> warrant plant shutdown.
The licensee responded that the requirements of Specification 3.7.10.1 Action b.
will be added to the FSAR with commitment that no modifications to these require-ments will be made without prior approval from NRC. The staff considers this response to be acceptable.
The staff was concerned that significant degradations of fire protection would not be reported to the staff. The licensee comitted to report such degradations as described in the Discussion section above. The staff is currently reviewing 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 FSAR. The FSAR presently contains information such as the fire hazards analysis, responses to staff questions, fire protection comit-ments, comparisons of plant design to Appendix A to BTP APCSB, and the method-ology for assuring conformance with Appendix R to 10 CFR Part 50, Sections III.G, III.J., III.L. and 111.0. The staff evaluated this infortation and found it
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acceptable as documented in the SER and in Supplements Nos. 3 and 4.
The licensee has revised the FSAR to incorporate the fire protection feature operating restrictions and.eurveillances which have been removed from the technical specifications. This conforms with the guidance issued in Generic Letter 86-10 and therefore is acceptable.
Based on the above evaluation, the staff concludes that the licensee's proposed amendment conforms with the guidance issued in Generic Letter 86-10. The staff has also verified that the updated FSAR contains the complete Callaway Fire Protection Program.
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4.0 ENVIRONMENTAL CONSIDERATION
This amendment involves a change in the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 or changes an inspection or surveillance requirement. The staff has detennined 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 occupa-tional radiation exposure. The Comission has previously published a proposed finding that this amendment involves no significant hazards consideration and there has been no public coment on such finding. Accordingly, this amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 651.22(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 this amendrrent.
5.0 CONCLUSION
The staff has concluded, based on the considerations discussed above, that:
(1) there is reasonable assurance that the health and safety of the will not be endangered by operation in the proposed manner; and (2) public such activitie: will be conducted in compliance with the Commission's regulations and the issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributors:
D. Kubicki, ECEB T. Alexion, PDIII-3 Dated: January 13, 1988 I
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