ML20209A655
| ML20209A655 | |
| Person / Time | |
|---|---|
| Site: | Byron, Braidwood  |
| Issue date: | 08/29/1986 |
| From: | Miosi A COMMONWEALTH EDISON CO. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20209A660 | List: |
| References | |
| 2051K, GL-86-10, NUDOCS 8609080078 | |
| Download: ML20209A655 (8) | |
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A" - On. nm - m.z cre.oo. mms Address Hoply t; Post Omco isox 767 Cericago, Mnois 80800 0767 A'ugust 29, 1986 Mr. Harold R. Denton U.S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation Washington, DC. 20555
Subject:
Byron Station Units 1 and 2 Application for Amendment to Facility Operating License, NPF-37, Appendix A, Technical Specifications NRC Docket Nos. 50-454. 50-455. 50-456 and 50-457
Dear Mr. Denton:
Pursuant to 10 CFR 50.90, Commonwealth Edison proposes to amend one License Condition and Appendix A, Technical Specifications, of Facility Operating License NPF-37. This proposed amendment requests the revision of License Condition 2.C(6) and the removal of the Fire Protection Technical Specifications. The proposed revision to the License Condition is included in Attachment
- 1. The marked up Technical Specification pages indicating the proposed changes are enclosed in Attachment 2.
Generic Letter 86-10, Section F, provides guidance for a l
licensee to request an amendment to delete the Fire Protection Technical Specifications. This guidance requires that the fire protection program be included by reference in the FSAR and the operating license be amended to substitute the standard license condition for fire protection. Therefore, in accordance with this guidance, Commonwealth Edison proposes a revision to the Fire Protection Program License Condition 2.C(6) similar to that presented in the Generic Letter. The revised License Condition is included in Attachment 1. Regarding the second requirement, the Byron Station Final Safety Analysis Report (FSAR), Section 9.5.1 currently includes by reference to the Fire Protection Report the fire protection program and major commitments, including the fire l hazard analysis. Therefore no additional FSAR changes should be required. However, it should be noted that the FSAR reference is to the October, 1977 version of the Fire Protection Report.
Commonwealth Edison doesn't believe this reference needs tc be revised since the most current amendment of the Fire Protection Report is the controlling document. In addition, Commonwealth Edison proposes a revision the Fire Protection Program
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m administrative controls once the Technical Specifications are removed. The proposed revision is included in Attachment 3. This revision should be issued as an amendment to the Fire Protection Report when the License Amendment is issued by the NRC.
Administrative controls are currently provided through existing Station administrative procedures, operating procedures and the general surveillance program for the Fire Protection Technical Specifications. These controls will remain in effect after the proposed amendment is issued to ensure a level of fire protection consistent with the existing Technical Specification requirements is maintained. The administrative program will also require the periodic verification of the fire protection system operability. If any portion of the fire protection system becomes inoperable, the administrative program will require appropriate actions be implemented similar to those currently required by the Technical l
Specifications to restore equipment to operable status and initiate fire w6tches or alternate methods of fire protection as required.
Included in Commonwealth Edison's amendment request is the addition of the Fire Protection Program to the defined responsibilities of the Onsite Review and Investigative Function and to the procedures and programs requirements in the Administrative Controls Section 6 of the Technical Specification (pages 6-13 and 6-16). This addition reinforces the importance of the fire The changes to the protection program on plant safety.
Administrative Controls Section 6 assures that written procedures will always be maintained for the Fire Protection Program. In addition, it assure that a multi-discipline review by the Onsite Review and Investigative Function will be conducted on proposed changes to the Fire Protection Program requirements once they are removed from the Technical Specification and implemented through an administrative program. Therefore, these proposed revisions are appropriate and consistent with requirements established for similar programs such as the Station Security Plan and the Emergency Plan.
i As discussed above, License Condition 2.C(6) provides controls for maintaining and revising the approved Fire Protection Program. A 10CFR50.59 review must be completed to verify an unreviewed safety questions does not exist before implementing any changes to the program. In addition, the requirements of the Administrative Controls Section 6.0 ensures that a Station onsite review will be performed on any proposed changes including reviewing the results of the 10CFR50.59 evaluation. These controls combined with the effective General Surveillance Program utilized at the Station will ensure that the requirements of the Fire Protection Program are effectively implemented once the Fire Protection Technical Specifications are removed.
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Removing the fire protection requirements from the Technical Specifications does not affect Commonwealth Edison's commitment to adhere to the National Fire Protection Code, Branch Technical Position 9.5-1 or 10CFR 50 Appendix R as clarified in the Byron Fire Protection Report. Surveillances consistent with those currently required by the Technical Specifications will also be required to be performed to meet the requirements of the Fire Protection Program based on the proposed revision to the Fire Protection Report. Without formal Technical Specifications, the fire protection activities will continue to be implemented similar to how it is currently being done. In addition, the fire protection system is classified as reliability related and as such the Quality Assurance Department also audits the fire protection activities to ensure compliance with its commitments.
Recent activities in the NRC and Westinghouse Owner's Group have focused on a Technical Specification Improvement Program aimed at reducing the voluminous requirements of the Technical .
Specifications. The objective of the program is to remove those Technical Specifications which do not directly affect the safe operation of the plant and can be effectively maintained through an administrative program. Removing the Fire Protection Technical Specifications is consistent with the criteria established for the Technical Specificati'on Improvement Program in that these systems i are not part of Design Basis Accident mitigation as defined by the
- - program criteria. Removal of the Fire Protection Technical l Specifications will reduce the size and complexity of the current Technical Specifications which the operators must interface with daily. Removal of these Technical Specifications will not detract from Commonwealth Edison's ability to maintain the required level of fire protection. Commonwealth Edison believes that this request is consistent with the NRC's ongoing goals for Technical Specification improvements.
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If the' proposed amendment is found to be acceptable, then Edison requests that the amendment should not become effective until the Byron Station on-alte review has approved the administrative program to be implemented. This will allow Byron Station the flexibility to make all procedure revisions necessary to implement the administrative program as soon as possible after notification of the NRC's acceptance of the proposed changes. The Technical Specifications will not be removed until the Administrative Program l
is fully functional to provide a smooth transfer of requirements.
The marked up index pages have also been included to reflect the proposed changes. Commonwealth Edison requests that the actual Technical Specification numbering not be revised to reflect
- the deletion of the Fire Protection Technical Specification. The entire Surveillance Program has been established based on the existing Technical Specification numbering. Revision of the numbers for the Technical Specifications remaining or reassignment of any
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numbers for Technical Specifications deleted could result in extensive and unnecessary Station procedure changes.
Commonwealth Edison has reviewed the proposed changes and find that no unreviewed safety questions exist and our review is documented in Attachment 4, Significant Hazards Consideration.
These changes are applicable to Braidwood Stations Units 1 and 2 and should ha incorporated into the initial Braidwood Technical Specifications, if they are found acceptable.
Commonwealth Edison is notifying the State of Illinois of our application for this amendment by transmitting a copy of this letter and its attachment to the designated state official.
In accordance with 10CFR 170, a fee remittence in the amount of $150.00 ie also enclosed.
Please direct any questions you may have regarding this matter to this office.
I Three (3) signed original and thirty-seven (37) copies of this letter and its attachments are provided for your use.
Very truly yours, A. D. Osi Nuclear Licensing Administrator
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cc: Resident Inspector-Byron Resident inspector-Braidwood L. Olshan l
J. Stevens
- - M. C. Parker
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SUBSC BED and N to befor me this day of J ehM_ , 1986 1 4A ~
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-3 ATTACHMENT 1 LICENSE CONDITION CHANGE 4
NPF-37 (5) Equipment Qualification (Section 3.11. SSER #5. SSER '#6)
All electrical equipment within the scope of 10 CFR 50.49 must be environmentally qualified by. November 30, 1985.
(6) Fire Protection Program (Section 9.5.1. SER. SSER #3. SSER #5.
SSER #6) implemc+ and (a) The licensee shall A maintain in effect all provisions of the approved fire protection program as described in the Fire Protection Report for the facility through Amendment B
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Oct;t;; 11,100 ; . . Cet:ter 15.-196+, and as approved in the SER through Supplement 6, subject to provisions b & c below.
Font if those c s b) The licensee may make no changerto the approved fire tocold not adverJe l Protection program -d.i;h x:21d d;;res;; th: 11;:1 cf fies offed the abili to d h OC Mod prbr aprwal d de och; eye d M tain .
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features of the approved (c) The licensee may fire protection program ;;hich J. ..- J. .- .:: it; i;;;.1 ;f-fin r. etecti .. il; --- r izr "551:2 -r--- i Provided:
(i) Such changes do not otherwise involve a change in a '
license condition or Technical Specification or result in a unreviewed safety question (see 10 CFR 50.59), and j
(ii) such changes do not result in failure to complete the fire protection program approved by the Commission,pris. iu 12 u . . .. . 1 a . . .. . . .
As with other change.s impleinented under to CFA50.5'lj ghe licensee shall maintain, in an auditable form, a current record of all such changes, including an analysis of the effects of the changes on the fire protection program, and shall make such records available to NRC inspectors upon request. All changes to the approved program ::f: rith: t rrier C_.._i==i=n = m vv.1- shall be reported annually to the Director of the Office of Nuclear Reactor Regulation, te,,.;;... wlL;. ..,,,,. 61... :::ly;;; .olonj with the F3AR revisiens reguired by to Crg.sa. 71(c).
9416N Tempotory Cllanyes to . spec (Fic. fitv-. ptoFecHch /ea h>res un;zh may be necessary lo accomplisb nuainlenarice. ov' modi RcaNcn.s arc acceptable. provided in ivrim campensafory menores are implement-ed.
P NPF-37
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, (d) Prior 1985, the licensee.=k-li J-plete .
Installation and tes continuous thermistors in the Auxiliary ng ventilat stem charcoal filter l
plenu, ending completion of this w the licensee conduct an hourly fire watch patrol to et the charcoal filters in the Auxiliary Building. ,
(7) Control Room Human Factors (Section 18.2.-SSER #4)
Unless the staff determines that the test results do not support the change, the licensee shall, prior to startup following the first refueling outage, move the range and volume controls for the SOURCE RANGE nuclear instrument on Unit 1 from the nuclear instrumentation cabinet IPM07J to the main control board IPM05J.
(8) TMI Item II.F.1. Iodine / Particulate Samplint (Section 11.5. SSER
. 151
- Prior to startup following the first refueling outage, the licensee shall demonstrate that the operating iodine / particulate sampling system will perform its intended function.
(9) Emergency Response Capability (NUREG-0737. Supplement #1)
The licensee shall complete the emergency response capabilities as required by Attachment 2 to this license, which is incorporated into this license.
(10) Reliability of Diesel-Generators (Section 9.5.4.1. SER. SSER #5)*
Prior to startup following the first refueling outage the controls and monitoring instrumentation on the local control panels shall be dynamically qualified for their location or shall be installed on a free standing floor mounted panel in such a manner (including the use of vibration isolation mounts as necessary) that there is reasonable assurance that any induced vibrations will not result in cyclic fatigue failure for the expected life of the instrument.
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(11) Generic Letter 83-28 (Required Actions Based on Generic Implications of Salen ATWS Events)
The licensee shall submit responses to and implement the requirements of Generic Letter 83-28 on a schedule which is consistent with that given in its letters dated November 5, 1983, February 29, 1984, June 1, 1984, and October 10, 1984.
- Requires exemption; see Paragraph 2.D 9416N
F N ATTACHMENT 2 TECHNICAL SPECIFICATION PAGE CHANGES l
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