ML20210J595
| ML20210J595 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 08/12/1997 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20210J590 | List: |
| References | |
| NUDOCS 9708180154 | |
| Download: ML20210J595 (6) | |
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,j NUCLEAR REGULATORY COMMISSION UNITED STATES p
a WASHINGTON, D.C. M5664001 49.....
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 227 TO FACILITY OPERATING LICENSE NO. DPR-77 II l
AND AMENDMENT NO. 218 TO FACILITY OPERATING LICENSE NO. DPR-79 TENNESSEE VALLEY AUTHORITY SE000YAH NUCLEAR PLANT. UNITS 1 AND 2 DOCKET NOS. 50 327 AND 50-328
1.0 INTRODUCTION
Section 50.48. " Fire protection " Part 50. Title 10 of the Code of Federa?
Regulatfons (10 CFR Part 50) requires that each operating nuclear power pient have a fire protection plan that satisfies General Design Criterion (GDC) 3.
" Fire protection." of Appendix A. 10 CFR Part 50. The fire protection plan must describe the overall fire protection program for the facility, outline the plans for fire protection, fire detection, and fire suppression capability, and limitations of fire damage.
The program must also describe specific features necessary to implement the program, such as administrative controls and personnel requirements for fire prevention and manual fire suppression activities, automatic and manually operated fire detection and suppression systems, and the means to limit fire damage to structures, systems, or components important to safety so that the capability to safely shut down the plant is ensured. The U.S. Nuclear Regulatory Commission (NRC) staff a) proved the Sequoyah Nuclear Plant (SON) fire protection program in Safety Evaluation Reports contained in NUREG-0011. Supplements 1, 2. and 5.
NUREG-1232. Volume 2. and NRC letters dated May 29 and October 6, 1986.
In a submittal dated September 26, 1996, as supplemented on August 12. 1997, the Tennessee Valley Authority (TVA), the licensee for SON, Units 1 and 2.
proposed to change the SON Technical Specifications (TS) related to fire protection and revise the fire protection license condition for each unit.
The proposed amendments would inglement the guidance provided in Generic Letter (GL) 86-10. " Implementation of Fire Protection Requirements." and GL 88-12. " Removal of Fire Protection Requirements from Technical Specifications." Specifically, the licensee has incorporated the NRC-approved fire protection 3rogram and major commitments. including the fire hazard analysis, into tie Updated Final Safety Analysis Report (UFSAR) by reference to the Fire Protection Report (FPR) which was issued on August 30, 1996.
Updates to the FPR will be made, as appropriate, in a manner similar to UFSAR updates. The >roposed amendments would remove the fire protection program
. details from tie TS and would revise the operating licenses to include the NRC's standard fire protection license condition.
Specifically. the amendments would revise TS Sections 3/4.3.3 (Monitoring Instrumentation).
3/4.7.11 (Fire Detection Systems). 3/4.7.12 (Fire Barrier Penetrations). 6.2.2 (Facility Staff), and Index pages V. IX. and XIV.
In addition the amendments EDR k
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would revise the Operating Licenses to-include the NRC's. standard fire protection license condition (License Condition 2.C(16) for Unit 1. License
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Condition 2.C(13) for Unit 2).
l GLs 8610 and 88-12 referred to removing fire protection requirements from the TS.
License amendments that relocate the fire protection requirements to the UFSAR in accordance with GLs 8610 and 88-12 do not revise the requirements for fire protection operability, testing, or inspections.
Such amendments
. simply replace the fire protection TS sections with the standard fire protection license condition.
The license condition implements and maintains the NRC approved fire protection program, including the fire protection requirements previously specified in the TS. in accordance with 10 CFR 50.48.
Therefore, such amendments, including the one proposed by the licensee, are administrative in nature and have no effect on the public health and safety.
The August 12. 1997, submittal provided a minor addition to the revised license conditions, at the NRC staff's request, but did not change the scope of the September 26, 1996, application and the initial proposed no significant hazards consideration determination.
2.0 BACKGROUND
Section 182a of the Atomic Energy Act (the "Act") requires applicar.ts for nuclearpowerplantoperatinglicensestostateTStobeincludedaspart-of the license.
The Commission s regulatory requirements related to the content i
of TS are set _forth in 10 CFR 50.36.
That regulation re include items in five specific categories. including (1) quires that the TS limits.
. limiting safety system settings and limiting control settings: safety (2) limiting L
conditicos-for operation: (3) surveillance requirements: (4) design features:
and (5) administrative controls.
However, the regulation does not specify the L
particular requirements to be included in a plant s TS.
The Commission has provided guidance for the contents of TS in its " Final Policy Statement on Technical Specifications Improvements for Nuclear. Power l
Reactors" (" Final Policy Statement"). 58 FR 39132 (July 22. 1993). in which t
the Commission indicated that compliance with the Final Policy Statement satisfies Section 182a of the Act.
In particular, the Commission indicated that certain items could be relocated from the TS to licensee controlled 1
document. consistent with the standard enunciated in Portland General Electric Co. (Trojan Nuclear Plant). ALAB 531, 9 NRC 263. 273 (1979).
In that case, the Atomic Safety and Licensing A) peal Board indicated that _" technical specifications are to be reserved for tiose matters as to'which the 4mposition L
of rigid conditions or limitations upon reactor operation is deemed necessary L
to obviate the possibility of an abnormal situation or event-giving rise to an
-immediate threat to the_public health and safety." The criteria set'forth in
_the policy statement have been incorporated into 10 CFR 50.36 (60 FR 36953).
~ Following the fire at the Browns Ferry Nuclear Power Plant on March 22. 1975.
I the Commission undertook a number of actions:to ensure that improvements were implemented in the fire protection programs for all power reactor facilities.
Because of the extensive modification of fire protection programs and the number of open issues resulting from staff evaluations, a number of revisions j
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and alterations occurred in these programs over the years.
Consequently.
licensees were requested by GL 8610 to incorporate the final NRC approved fire protection program in their UFSARs.
In this manner, the fire protection program, including the systems, certain administrative and technical controls, the organization, and other_ plant features associated with fire protection, would have a status consistent with that of other )lant features utscribed in the FSAR, in addition, the Commission concluded tlat a standard license condition, requiring compliance with the provisions of the fire protection
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program as described in the UFSAR, should be used to ensure uniform enforcement of the fire protection requirements.
Finally, the Commission stated that, with the required actions, licensees may request an amendment to delete the fire 3rotection TS that would now be unnecessary.
Subsequently,
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the NRC issued G. 8812 to give guidance for the preparation of the license amendment request to implement GL 8610.
3.0 PROPOSED CHANGE
S The specific License Condition change proposed by the licensee is as follows:
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'1.
Revise License Condition 2.C.(16) for Unit 1 and License Condition 2.C.(13) for Unit 2 as follows:
TVA shall implement and maintain in effect all provisions of the approved fire protection program referenced in Sequoyah Nuclear i
Plant's Final Safety Analysis Re) ort and as approved in NRC Safety
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Evaluation Repuri.s coni.sinad in 4UREG 0011, Supplements 1. 2.
i and 5. NUREG 1232, Volume 2. NRC letters dated May 29 and 1
October 6, 1986, and the Sa Lty Evaluation issued on August 12, 1997, for License Amendment Nos, 227/218. subject to the following provision:
j TVA may make changes to the approved fire protection program i
without-prior approval of-the Commission only if those changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire.
2.
The following TS sections have been incorporated, by reference to the SON Fire Protection Program, into Section 9.5.1 of the UFSAR. As proposed by the licensee, the sections would be deleted from the TS in their entirety:
A.
TS 3/4.3.3.3.8, " Monitoring Instrumentation Fire Detection Instrumentation," as well as Table 3.3-11. " Fire Detection Instruments," and the associated bases.
D.
TS 3/4.7.11. " Fire Suppression Systems "-as well as Table 3.7-5,
" Fire Hose Stations," and the associated bases.
C.
TS 3/4.7.12. " Fire Barrier Penetrations," and the associated bases.
D.
TS 6.2.2.e. " Facility Staff," pertaining to fire brigade composition, and the fire brigade portion of the footnote on p. 6-2, 3,-
Index pages V. IX, and XIV would be revised to reflect the changes discussed above.
4 4.0
-EVALUATIQN 1he NRC staff reviewed the license amendment requests for SON against the guidance provided in GLs 86 10 and 88-12.
GL 86 10 requested that the licensee incorporate the NRC-approved fire protection program in its UFSAR for-the facility and specified a standard fire protection license condition.
GL 8812 addressed the elements a licensee should-include in a license amendment request to remove the fire protection requirements from the plant 15.
These elements are (1) the NRC-a) proved fire protection )rogram must be
-incorporated into the UFSAR: (2) the imiting Conditions for Operation (LCOs) and Surveillance Requirements associated with fire detection systems, fire suppression systems, fire barriers, and the administrative controls that address fire brigade staffing would be relocated from the TS (the existing administrative controls associated with fire protection audits and-specifications related to the capability for safe shutdown following a fire (3) all operational conditions, remedial actions, and test
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would be retained):
requirements presently included in the TS for these systems, as well as the fire brigade staffing requirements, shall be incorporated into the fire protection program: (4) the standard fire protection license condition-specified in GL 86-10 must be included in the facility operating license:
(5) the Plant Nuclear Safety Review Committee (0nsite Review Group) shall be given responsibility for the review of the fire protection program and implementing procedures and for the submittal of recommended changes to the l
Nuclear Safety and Design Review Committee (Offsite or Cor orate Review l
i Group): and (6) fire protection program implementation sha 1 be added to the list of elements for which written procedures shall be established, implemented, and maintained.
The licensee submitted its FPR for SON On August.30, 1996 in accordance with GL 86-10. This report details the SON Fire Protection Program, which was incorporated by reference into the SON UFSAR on December 6, 1996.
The nicensee has, therefore, satisfied Element 1 of GL 88-12, The licensee stated in its license amendment request submittal of September 26, 1996, that it will incorporate the current TS LCOs and surveillance requirements for the fire detection systems (instrumentation),
fire suppression systems, fire barrier )enetrations, and the TS requirements related to fire brigade staffing into tie SON Fire Protection Plan, which is aart of the FPR submitted on August 30, 1996, In fact, these requirements lave already been incorporated into Part 14 of the plan, with-a note s)ecifying that implementation of Part 14 is on hold pending NRC approval of 4
tie subject TS amendment. Therefore, the licensee has satisfied Elements 2 and 3 of GL 88-12.
The licensee proposed incorporating the standard fire protection license condition specified in GL 86-10 for SON.
The licensee has, therefore.
satistled Element 4 of GL 88-12.
To satisfy Elements 5'and 6 of GL 88 12. the licensee addressed changes to the administrative controls sections of the TS.
The SON TS already support the Fire Protection Program, inluding TS 6.8.1.f. which re procedures for Fire Protection Program implementation. quires written The current administrative controls for fire protection are consistent with the administrative controls for,the emergency and security plans. The licensee
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already requires the Plant Operations Review Committee, with overview by the Nuclear Safety Review Board, to review changes to the Fire Protection Program.
This requirement is in Part 8.1 of the Fire Protection Plan submitted on August 30. 1996.
The licensee has, therefore, satisfied Elements 5 and 6 of GL 88-12.
Therefore, the licensee's proposed TS amendments for SON are in accordance with NRC staff guidance provided in GLs 86-10 and 88-12.
In summary, the licensee has proposed to incor> orate the existing TS fire protection requirements as stated above into tle Fire Protection Program, which is..by reference incorporated into the UFSAR.
This conforms to staff guidance in GL 86-10. " Implementation of Fire Protection Requirements." and i
GL 88-12. " Removal of Fire Protection Requirements from Technical Specifications." for removing unnecessary fire protection TS in four major 3
areas:
fire detection systems, fire suppression systems fire barriers, and fire brigade staffing requirements.
In addition. incorporating these 5)quirements into the UFSAR is consistent with NUREG-1431. " Standard Technical re ecifications.-Westinghouse Plants" and 10 CFR 50.36. as amended, because tiese TS do not impact reactor operations, do not identify a parameter which I-is an initial condition assumption for a design-basis accident or transient, do not identify a significant abnormal degradation of the reactor coolant pressure boundary and do not provide any mitigation of a design basis event.
The fire protection plan required by 10 CFR 50.48, as implemented and maintained by the fire protection license condition, provides reasonable assurance that fires will not give rise to an immediate threat to public health and safety. Although there are aspects of the fire detection and mitigation functions that have been determined to be risk significant, such that Criterion 4 of 10 CFR 50.36 would otherwise seem to apply, the minimum requirements for those functions were established in GDC 3 and 10 CFR 50.48, and further controls are not necessary since the licensee must comply with these minimum requirements regardless of whether they are restated in the TS or not.
The licensee's fire protection program is required by 10 CFR 50.48, and any chan 2.C.ges to that program are governed by 10 CFR 50.48 and license conditions (16) (Unit 1) and 2.C.(13) (Unit 2), set forth above. Therefore, changes to the reguirements relocated to the UFSAR will be controlled in accordance with 10 CFR 50.59.
These relocated requirements relating to fire protection features are not-required to be in the TS under 10 CFR 50.36 or other regulations, or by Section 182a of the Atomic Energy Act, and are not required to obviate the possibility of an abnormal situation or event giving rise to an immediate threat to the public health and safety, in addition, the staff finds that sufficient regulatory controls exist under 10 CFR 50.48 and 10 CFR 50.59 to address future changes to these requirements.
Accordingly, the staff has concluded that these requirements may be relocated from the TS to the licensee's UFSAR.
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5.0 STATE CONSULTATION
in accordance with the Commission's regulations, the Tennessee State official was notified of the proposed issuance of the amendments. The State official had no comments.
6.0 ENVIRONMENTAL CONSIDERATION
j The amendments change the requirements with respect to the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and change surveillance requirements.
The staff has determined i
that the amendments involve 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 occupational radiation exposure. The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration and there has been no public comment on such finding (62 FR 35843). The amendments also change administrative procedures or
-reporting requirements. Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9) and (c)(10).
Pursuant to 10 CFR 51.22(b). no environmental impact statement or i
environmental assessment need be prepared in connection with the issuance of l
the amendments.
7.0 CONCLUSION
The Coreission has concluded. based on the considerations discussed above, that:
(1) there is reasonable assurance that the health and safet public will not be endangered by operation in the proposed manner.y of the-(2) such activities will be conducted in compliance with the Commission's regulations.
and (3) the issuance of the amendment will not be inimical to the common defense and_ security or to the health and safety of the public.
Principal Contributor:
R. Hernan Dated: August 12, 1997 t
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