ML20211M637
| ML20211M637 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek, Callaway, 05000000 |
| Issue date: | 02/19/1987 |
| From: | Schnell D UNION ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20211M644 | List: |
| References | |
| GL-86-10, ULNRC-1447, NUDOCS 8702270331 | |
| Download: ML20211M637 (16) | |
Text
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1901 Gratiot Street. St. Louis Donald F. Schnell Vice President February 19, 1987 U.S. Nuclear Regulatory Commission ATTN:
Document Control Desk Washington, D.C. 20555 Gentlemen:
ULNRC-1447 DOCKET NUMBER 50-483 CALLAWAY PLANT FIRE PROTECTION TECHNICAL SPECIFICATION AMENDMENT REQUEST
References:
- 1. Generic Letter 86-10, dated April 24, 1986, Implementation of Fire Protection Requirements
- 2. NRC (D.G. Eisenhut) letter to AIF (A.C. Passwater),
dated May 5, 1986
- 3. OG 87-1, dated January 9, 1987, Westinghouse owners Group (WOG) Short Term Improvement to Plant Technical Specifications Deletion of Fire Protection Requirements Union Electric Company, in conjunction with Wolf Creek Nuclear Operating Corporation (WCNOC), herewith transmits one original and 37 conformed copies of an application for amendment to Facility Operating Licenses NPF-30, for the Callaway Plant, and NPF-42, for the Wolf Creek Generating Station.
This change revises fire protection license conditions 2.C.(5)(c), (d), and (e) for Callaway and 2.C.(5)(a), (b), and (c) for Wolf Creek in accordance with Reference'1; deletes fire protection Technical Specifications 3.3.3.7 for Callaway (3.3.3.8 for Wolf Creek), 3.7.10.1, 3.7.10.2, 3.7.10.3, 3.7.10.4, 3.7.11, and 6.2.2.e; and changes Technical Specifications 6.5.1.6, 6.5.1.7, and 6.8.1 in order to remove fire protection requirements from the Technical Specifications and place them in plant. procedures under the control of the plant's unit review group (On-Site Review Committee (ORC) for Callaway and Plant Safety Review Committee (PSRC) for Wolf Creek) and in the FSAR.
The changes are similar to those previously approved on another docket.
The Safety Evaluation and Significant Hazards Evaluation for the above changes are generic to both Callaway and Wolf Creek and are included herewith as Attachment 1.
Attachments 2 and 3 are marked up Technical Specifications and License Conditions for Callaway and Wolf Creek, respectively.
Also included for additional supporting information are marked up FSAR pages showing how the removed Technical Specification requirements would be incorporated into this 8702270331 B70219 PDR ADOCK 05000482 g
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g Mailing Address: P.O. Box 149. St. Louis. MO 63166 k
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- f> document (Attachment 4'for Callaway and Attachment 5 for Wolf Creek).
The revised FSAR pages will be included in upcoming FSAR updates for each plant.
Compliance with fire protection requirements shall in no way be degraded by maintaining them in appropriate plant procedures and the FSAR.
The proposed changes provide additional
' flexibility for modifying requirements under the provisions of.
The changes are also consistent with the NRC and industry. effort to simplify the Technical Specifications.
The submittal is being made with the endorsement of the Westinghouse Owners Groups (WOG) under the lead plant concept proposed by the NRC in Reference 2.
The NRC was notified by the WOG of this submittal, in accordance with the lead plant concept procedure, in Reference 3.
The requested changes will be implemented upon NRC approval and after the necessary procedural revisions have been incorporated.
Enclosed is a check for the $150.00 application fee (Attachment 6), for Union Electric, as required by 10 CFR 170.21.
The application fee and affirmation on behalf of WCNOC will be forwarded under separate cover.
Very truly yours, A Dona Schnell JMC/ lad Attachments : 1. Generic Safety Evaluation and Significant Hazards Evaluation
- 2. Callaway Revised Technical Specifications and License Conditions
- 3. Wolf Creek Revised Technical Specifications and License Conditions
- 4. Callaway Proposed FSAR Changes
- 5. Wolf Creek Proposed FSAR Changes
- 6. Application Fee t
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- STATE OF MISSO'UR'I -)
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S.S-
- CITY:OF ST. LOUIS '. ).
. Ro'bert J. Schukai, of. lawful age, being first-duly. sworn
.upon oath says that:he is General Manager-Engineering (Nuclear) -for
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- Union Electric-Company; that~ he: has, read :the. foregoing document and knows the content:thereof;.that he.has executed the same for and.on-behalf of.said company with full. power and_ authority to do sor and
'that-the' facts therein stated are true and correct to the.best of his knowledge, information and belief.
r-By Robe J.
chukai Gener ager-Engineering Nuclear SUBSCRIBED and sworn to before me this /f day.of
, 198f -
0 BARBARA J. PFAFF, -
NOTARY PUBUC, STATE OF t.uSSOUR) -
MY COMMISSION EXP1RES APRIL 22,1989 ST. LOUIS COUNTY.
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a sp cc:
Gerald Charnoff, Esq.
Shaw, Pittman, Potts & Trowbridge 1800 M.
Street, N.W.
Washington, D.C.
20036 Dr.
J. O. Cermak CFA, Inc.
3356 Tanterra Circle Brookeville, MD 20833 W. L.
Forney Division of Projects and Resident Programs, Chief, Section lA U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137 Bruce Little Callaway Resident Office U.S. Nuclear Regulatory Commission RR#1 Steedman, Missouri 65077 Paul O'Connor (2)
Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 316 7920 Norfolk Avenue Bethesda, MD 20014 Ron Kucera, Deputy Director Department of Natural Resources P.O. Box 176 Jefferson City, MO 65102 Manager, Electric Department Missouri Public Service Commission P.O. Box 360 Jef ferson City, MO 65102 E. H. Johnson, Director Division of Reactor Safety and Projects U.S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011 J.
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Cummins Wolf Creek Resident Office U.S. Nuclear Regulatory Commission Box 411 Burlington, KS 66839
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Schnell J."E.
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P. Neuhalfen R. J. Schukai
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E. Miltenberger D.'E. Shain
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Passwater W. R. Campbell R. P. Wendling D.
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D. J. Walker
.O. Maynard (KG&E)
N. P. Goel (Bechtel)
.G56.37 (CA-460) j Compliance (J. E. Davis)
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,+1 ATTACHMENT 1 ULNRC-1447
_'y, GENERIC SAFETY EVALUATION AND s
SIGNIFICANT HAZARDS EVALUATION N.
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SAFPLY EVAIDATION
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- his amendment reque t deletes Technical Specifications 3/4.3,3.7 for y{Osl3/4.7.10.4,7QCallaway(3/4.3.3.8forWolfCrwk), 3/4.7.10.'1,3/4.7.10.
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3/4.7.11) 6.2.2.e, and,the corresponding section 3/4 Bases, pl;da d revices; Technical' Specifications 6.5.1.6, 6.5.1.7, and 6.8.1 and o'
licenre conditions 2.C. (5) (c),.(d)Md (e) for Callaway and 2.C. (5) (a),
5 Q'd(b), 5nd '(c) for iblf Creek in accotdance _with the annotated pages tt provided in Attachments 2 and 3.} hse changes and their respective safety evaluations are discussed' hereinafter.,In those cases where
.Callaway and %olf Creek Technical SpecificF.lons have different numbers,
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g99 the Wolf Creek. number is in parenthesec. 'I
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1.
Technical: Specification 3/4.3.3.7 - (3/4.3.3.8), Fire Detection;Instru- ( ( '
mentation, is deleted. The requirenents of this specification have p(
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been prhd in their entirety to plant operating procedut'es; his cW,nge Ya administrative in nature in that no requirements;are being aftered. Provisions for review of future changes to the!requirenents arfdictated by the changes to Technical Specifications 6.5.1.6, 6.5.1.7, and 6.8.1 as described below.
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2I'TechnicalSpeciflcation 3/4.7.10.1, Fire]Supprbssion Water Systen, is '
deleted. All of the requirements of this sp Wification, with the-i-
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- nole exception of the %1 ant shutdown and mod 9 change restriction requirements up>n determination of inoperabijity of the system-.
3dictated by act/p b, have been moved to ppit operating procedures.
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IWith the'above eKeeptEn, the changes.are purely administrative in.
nature, since no: requirerents are being altered.
S e deletion of tNeplant shutdown and mode change restriction lh requirements upon Hoss of operability of the fire suppression water
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systen is deemed acceptable for the following reasons.
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E a) 'Several meanEof fire detection and fire protection are still 3
i operable,,since they are not affected by the loss of the watier' supprhssibn'systen. Fire dettchion instrumentation is available-l _
allowing detection of a firy and response' by plant' personnel using operable fire fighting (capabilities. Plant fire barriers oviding fire isolation pf cafety-related equignent from non-l p'Spfety-related equignerit 'ar$ between trains of safety-related F
equipnent are still cperable. iIn addition, halon fire suppres-sion systens -protect certain' vital electrical equignent.
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-t b) he inoperability of the ftre suppression water system will effectively' pause loss of'coerability of spraycand dprinkler T
systems and Eire hose stations. %e ci-itical pryf ard sprinkleri systems andhe stations %ve thir own action requirements to t
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. ensure that fire protectioh is idaintain$d. %esk actions @ irt l
fof establishiffs a;fitc etch for early detectionPpnd the use [
l of portable extinguishers and a~ fire brigade as a'oackup fire j
suppression syatens 1%ese action requirements will be maintained in the plant procedures. The loss of the fire suppression water
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ler systems and b re hose stations, and therefore their required i
acgansishouldbesufficient.
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- C c). Plant s vcadures will require establishment of.a backup. fire
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suppression system within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. In order to ensure that
- actions are taken if.the backup fire suppression water systen-
.is not available, plant p6veedures will require actions designed to minimize the risk of fire... Provisions'for the review of-future changes to the requirements are dictated by the changes to Technical Specifications 6.5.1.6, 6.5.1.7, and 6.8.1 as.
described below..
3.
Technical Specifications 3/4.7.10.2 (Spray and/or Sprinkler Sys-tens), 3/4.7.10.3 (Halon Systems), 3/4.7.10.4 (Fire Hose Stations)
- and 3/4.7.11 (Fire Barrier Penetrations) are deleted. W e require-ments of these specifications have been moved in their entirety to plant operating procedures. his change is administrative in nature in that no requirements are being altered. Provisions for review of
. future changes to the requirements are dictated by the changes to Technical Specifications 6.5.1.6, 6.5.1.7, and 6.8.1 as described below..
m 4.
Te & nical Specification 6.2.2.e, Site Fire Brigade Requirements, is deleted. Se requirement of this specification has been moved in its entirety to plant operating procedures. %is change is administrative in nature in that no requirements are being altered.
Provisions for review of future changes to the requirements are dictated by the changes to Technical Specifications 6.5.1.6, 6.5.1.7, and'6.8.1 as described below.
5.
Technical Specifications C.5.1.6 and 6.5.1.7, On-Site Review Ccunnit-tee. (OfC/ Plant Safety Review Ccanittee (PSBC) Responsibilities, are being revised to provide specific reference to the requirement to review the plant Fire Protection Progran and its revisions. his change reinforces the importance of the Fire Protection Progran on plant safety and assures a multi-discipline review by the CRC of proposed changes to those requirements that are removed frcan the Technical Specifications.
6.
Technical Specification 6.8.1, Written Procedure Requirements, is revised to ~ include the Fire Protection Progran implementation.
This change-reinforces the importance of the Fire Protection Progran on plant safety and is consistent with the requirements established for similar programs, such as the security plan.
7.
License conditions 2.C. (5) (c),(d), and (e) (2.C. (5) (a), (b), and (c)), dealing with changes to the Fire Protection-Progran, are revised in accordance with the guidance Erovided in section F of Generic Letter 86-10, Implementation of Fire Protection Requirenents.
%e changes provided in Generic, Letter 86-10 establish requirements for control of the Fire Protection Progran.
Pursuant to the above information, this inicidient request does not adversely affect or endanger the health or safety of the general public and does not involve an unreviewed safety question.
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.t SIGNIFICANT HAZARD EVAIDATION Wis mendment request consists of deletions of Technical Speci-fications 3/4.3.3.7 for Callaway (3/4.3.3.8 for Wolf Creek), 3/4.7.10.1, 3/4.7.10.2, 3/4.7.10.3, 3/4.7.10.4, 3/4.7.11, and 6.2.2.e, the correspon-ding Section 3/4 Bases, and revisions to Tednical Specifications 6.5.1.6, 6.5.1.7 6.8.1, and license conditions 2.C.(5) (c), (d), and (e) for Callaway and 2.C.(5) (a), (b), and (c) for Wolf Creek as discussed in the Safety Evaluation. he following discus sions address these changes md their corresponding significant hazard evaluations in the sme order as discussed in the Safety Evaluation. In those cases where Callaway and Wolf Creek Technical Specifications have different numbers, the Wolf Creek number is in parentheses.
1.
Technical Specification 3/4.3.3.7 (3/4.3.3.8) (Fire Detection Instrumentation) is deleted, and the requirements contained therein have been transferred to the FSAR and plant operating procedures.
a) his change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
No changes to the requirements have been made. This change simply renoves the fire detection instrumentation requirments frm the Technical Specifications and places them into plant procedures and the FSAR without altering them. Review of the Fire Protection Progr a and its revisions will be the responsi-bility of the On-Site Review Comittee (ORC) for Callaway and the Plant Safety Review Ccmnittee (PSRC) for Wolf Creek, just as it has always been the responsibility of these groups to review danges to fire protection requirements when they were part of the Technical Specifications.
b) This change does not create the pom. aility of a new or different kind of accident frm any previously evaluated. The propose 3 change does not alter the requirements; it just moves then frcm the Technical Specifications to the FSAR. Plant procedures will continue to provide the specific instructions for implementing the ICO, action, and surveillance requirements. W ere has been no reduction in comitments and, as incorporated into the plant procedures, this change meets the requirements of the existing Technical Specifications.
c) %is change does nat involve a significant reduction in the margin of safety. No change is being proposed for the require-ments themselves. Technical Specification 3/4.3.3.7 (3/4.3.3.8) is being deleted, and the requirements contained therein are being incorporated into the FSAR. Plant procedures will continue to provide the specific instructions necessary for the implemen-tation of the requirements, just as when the requirements resided in the Technical Specifications. Fire Protection Progrm ccmnitments, reporting requirenents, and mendments will oy this process be transferred from the jurisdiction of 10 CFR 50.73 and 10 CFR 50.90 to 10 CFR 50.59 and 10 CFR 50.71(e).
(1)
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2.
Te&nici.1 Specific. tion 3/4.7.10.1 (Fira Suppression Water Syste) is. deleted.. All of the requirements contained therein, with the.
exception of the plant shutdown md mode dange restriction k
requirements dictated by action b, have been transferred to the'-
R FSAR and plant operating procedures.
a) Bis change does not ' involve a significant increase in the gobability ore consequences of an accident previously evaluated.
In the: accident ' analysis it _is asstmed that a design basis
- accident does not occur simultaneously with a fire, and'the fire hazards analysis does not rely _ solely on autmatic~ fire suppre sion systems.
In. addition, backup manual fire suppression capabilities are available. Other than the deletion of the t
plant shutdown and mode change restrictions dictated by action b, no & anges to requirements have been made. h is d ange-for the most-part sinply removes the fire suppression water system requirements frm the Technical Specifications and places them into the plant procedures-and the FSAR without altering them.
e Review of the Fire Protection Progra and its revisions will be the responsibility of the ORC /PSRC, just as it has always been the responsibility of these groups to review changes to fire protection requirements when they were part of the Technical Specifications.
b) his dange ck>es not create the possibility of a new or different kind of accident fra any previously evaluated since, in the accident analysis, it is not assumed that a design basis accident
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occurs simultaneously with a fire and the fire hazards analysis does not rely solely on autmatic fire suppression ' systems.
Plant procedures will require establisinent of. a backup fire 1
suppression-system within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
In order to ensure that actions are taken if the backup fire suppression water system is not available, plant gocedures will require actions designed to minimize the risk of fire. Provisions for the review of future changes to the requirments are dictated by the.danges-to Technical Specifications 6.5.1.6, 6.5.1.7, and 6.8.1 as described below.
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' %e inoperability of the fire suppression water system will effectively cause loss of operability of spray and sprinkler systems and fire hose stations. %e critical spray and sprinkler systems and hose stations have their own action' requirements to ensure that fire protection is maintained. These actions consist of establishing a fire watch for early detection and the use of portable extinguishers and a fire brigade as a berkup
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fire suppression system. % ese action requirements will be maintained in the plant gocedures. % e loss of the fire
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suppression' water system will cause the inoperability of only i
the spray and sprinkler systems and fire hose stations, and l
therefore their required actions, in addition to those actions retained in the plant procedures frm Specification 3/4.7.10.1 (which includes all the Technical Specification actions except the plant shutdown and node dange restrictions), should be sufficient.
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. e c) his change does not involve a significant reduction in the margin of safety since fires are not assumed to occur simultane-ously with a design basis accident. In addition, several means of fire detection and fire protection are still operable, since they are not affected by the loss of the water suppression systen. Fire detection instrumentation is available allowing detection of a fire and response by plant personnel using cper-able fire fighting capabilities. Plant fire barriers goviding fire isolation of safety-related equipment frm non-safety-related equipment and between trains of safety-related equignent are still operable. Also,.halon fire surpression systans protect certain vital electrical equipnent.
Plant procedures will continue to provide the specific instruc-tions necessary for the inplementation of all of the requirements frm Specification 3/4.7.10.1, with the exception of action b (plant shutdown and node change restrictions upon complete loss of fire suppression system capability), which will be cmpensated for by actions designed to minimize the risk of fire.
Fire Protection Program commitments, reporting requirements, and anendments will by this gocess be transferred frcxn the jurisdiction of 10 CFR 50.73 and 10 CFR 50.90 to 10 CFR 50.59 and 10 CFR 50.71(e).
In sununary, loss of the mrmal fire suppression water system does mt affeet the probability of having an accident. If the backup suppres-sion system is not available, additional empensatory actions will te -
taken as discussed above and, therefore, shutdown of the unit is rot warranted. Additionally, unit power level or changes in operating node will not affect the remaining suppression or backup suppression capability to handle a fire; therefore, the application of Technical Specification 3.0.4 is not warranted.
3.
Technical Specifications 3/4.7.10.2 (Spray and/or Sprinkler Systems, 3/4.7.10.3 (Halon Systems), 3/4.7.10.4 (Fire Hose Stations), and 3/4.7.11 (Fire Barrier Penetrations) are deleted, and the require-ments contained therein have been transferred to the plant opera-ting procedures.
a) his change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
No cilanges to the requirements have been made. This change simply removes the spray and/or sprinkler system, halon system, l
fire hose station, and fire barrier penetration requirenents frcun the Technical Specifications and places them into plant procedures and the FSAR without altering them. Review of the Fire Protection Progran and its revisions will be the responsi-bility of the On-Site Review Cmmittee (ORC) for Callaway and the Plant Safety Review Carunittee (FSRC) for Wolf Creek, just as it has always been the responsibility of these groups to review changes to fire protection requirements when they wre part of the Technical Specifications.
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- b); 'his change does not create the possibility'of a new or different
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- kind of accident _ from any previously evaluated. % e proposed change.does not alter.the requirments; it just moves the from the 4
Technical' Specifications to the FSAR. Plant procedures.will continue to provide the specific instructions for;implenenting the LOD, action, and surveillance requirements. W ere has been no reduction in:conmitments and, as incorporated into the plant procedures, this change meets the requirements of the existing Technical Specifications.
c)
This change does not involve _ a significant reduction in the margin
'of safety.r No change is being proposed for. the requirements themselves. Technical Specifications 3/4.7.10.2,3/4.7.10.3, 3/4.7.10.4, and 3/4.7.11 are being deleted and the requirements contained therein are being incorp> rated into the FSAR. Plant procedures will continue to provide the specific instructions 1
necessary for the implementation of. the requirenents, just as when the requirements resided'in-the Technical Specifications.
t
~ Fire Protection Program comitments, reporting requirements,. and mendnents will by this process be transferred from the' jurisdiction of 10 CFR 50.73 and 10 CFR 50.90 to 10 CFR'50.59 and 10 CPR 50.71(e).
4.
Technical Specification'6.2.2.e, Site Fire Brigade Requirements, is deleted, and the requirements contained therein have been transferred:
to the plant operating procedures.
a)-
W is change does not involve a significant increase in the probability or consequences of an accident previously e' valuated.
~No changes to the requirements have-been made. This change simply renoves the site fire brigade requirements from the' Technical.
Specifications and places then into plant procedures and the PSAR without altering them.. Review of the Fire Protection Progran and its revisions will be the responsibility of the On-Site Review Conmittee (ORC) for Callaway and the Plant Safety Review Omnittee I
~ (PSRC) for Wolf Creek, just as it has always been the responsibility of these groups to review dianges to fire 3
protection requirements when they were part of the Technical Specifications.
f.
j b) his change does not create the possibility of a new or different kind of accident frm any previously evaluated. The proposed change does not alter the requirements; it just moves them frm the l
Technical Specifications to the FSAR. Plant procedures will continue to provide the specific instructions for implementing the l
Technical Specifications administrative requirements. There has been-no reduction in commitments and, as incorporated into the plant procedures, this change meets the requirements of the existing Technical Specifications.
p c)
Wis change does not involve a significant reduc' 7 in the margin of safety. No change is being proposed for the t irements i
themselves. Technical Specification 6.2.2.e is be deleted, and 5
c the requirements contained therein are being incorpv sted into the F
PSAR or plant procedures. Plant procedures will co.inue to provide the specific instructions necessary for the implementation of the requirements, just as when c
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- the~ requirements resided in the Technical Specific
- tions. Fira Protection Progra comitments; reporting requirenents,' and amendments will by this' process be transferred fr m the juris-diction of 10 CFR 50.73 and 10 CFR'50.90 to 10 CFR 50.59 and 10 CFR'50.71(e).
f 5.
Technical. Specifications 6.5.1.6 and 6.5.1.7, On-Site Review Comittee -(OE)/ Plant Safety Review Ccamittee' (PSRC) Responsi-bilities, are being revised.to provide specific reference to the-LORC's (PSRC's) requirement to review the plant Fire Protection.
Progr a and its revisions.-
a) mis' change does not ' involve a significant increase (in the probabilty or consequences of an accident'previously evaluated.
%e-dange does not involve a reduction in requirements.
%e ORC /PSRC has always been responsible for reviewing proposed 3
L changes.to the Technical Specifications and is'now responsible for reviewing danges to the Fire Protection Progrm, idlich t
has been created fra the former Technical Specifications and i
other requirements.
b)- Wis dange dc:es' not create the' possibility.of a new or different kind of accident from any geviously evaluated. %ere has-been no dange in requirements as a result' of this Technical p
i Specification revision. In fact, the a3dition to Specification 6.5.1.6 is an addition to the previously identified ORC /PSRC-responsibilities in that previously the ORC /PSRC did not have a specific Technical Specification requirement to review the Fire i
Protection Progrm.
c) - Wis dange does mt involve a significant reduction in the margin of safety. % e change to ORC /PSRC responsibilities as delineated in sections 6.5.1.6 and 6.5.1.7 involves an increase in requirements. We former Technical Specifications
~
are a subset of the' entire Fire Protection Progra, and the
. ORC /PSRC is now responsible for reviewing the entire program,
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whereas formerly the CRC /PSBC responsibilities for review in this area included only the Technical Specifications. Their responsibility for procedural review renains unchanged.
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6.
Technical Specification 6.8.1, Written Procedure Requirements, is revised to include the Fire Protection Progra inplementation.
a)- his change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
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We addition of the Fire Protection Progr a to the' list of required written procedures constitutes an additional control 1P not presently included in the Technical Specifications.
I b) his dange does not create the possibility of a new or different kind of accident from any geviously evaluated.
Ib requirements have been reduced by the addition of Specification 6.8.1.1 (6.8.1.h for Wolf Creek) ; instead, the darge creates an additional requirement.
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~ c) _ Sis change does not involve a significant reduction in the margin of shfety. The addition of the Fire Protection Progran to the listN f required written procedures constitutes an-additional control not presently included in the Technical Specifications.
- 7. License conditions 2.C. (5) (c), (d), and (e) (2.C. (5) (a), (b), and
. (c)), dealing with changes to the Fire Protection Progra, are revised in accordance with the guidance provided in section F of Generic Letter 86-10,' Implementation of Fire Protection Require-ments.
a) This change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
he change in license conditions fran those previously incorpo-rated into the license to the one presented in Generic Ietter 86-10 does not result in any loss of control of the change process.-
Previously, changes to the Fire Protection Progran that decreased the level of fire protection in the plant could only be made with prior Counission approval utilizing the license anendment process (10 CFR 50.90). %e new license condition also requires prior Comnission approval but utilizes the 10 'CFR 50.59 process.
%e old license condition also required that the licensee maintain an auditable record of all changes made to the Fire Protection Progran that do not require prior Ccunission approval.
%e new license condition does not specifically levy this re-l quirement; but, since the Fire Protection Progran and the former Tech Specs are now incorporated into the FSAR, their changes fall under 10 cm 50.59, and section 10 CFR 50.59(b) contains the same record keeping requirement.
Finally, the old license condition required an annual report to the Carunission on all changes to the Fire Protection Program made without i
prior approval. % e sane' annual reporting requirements is levied by 10 CFR 50.59(b) and 10 CFR 50.71(e).
b) his change does not create the possibility of a new or different kind of accident fran any previously evaluated. The proposed license conditions do not involve any significant change in requirements and are recommended by the PRC in Ceneric Letter 86-10.
c) This change does not involve a significant reduction in the margin of safety. The proposed license condition does not involve any significant change in requirements and was recom-mended by the PRC in Generic Letter,86-10.
Fire Protection Progran otanitments, reporting requirements, and anendments will by this process be transferred fran the jurisdiction of 10 CFR 50.73 and 10 CFR 50.90 to 10 CFR 50.59 and 10 CFR 50.71(e).
j (6)
SLM4ARY Based on the previous-discussions, this amendment request does
.not involve a significant increase in the probability or consequences of an accident previously evaluated; nor create the pssibility of a new or different kind of accident from any accident previously evaluat-ed; nor involve a reduction in the required margin of safety. Based on the foregoing, the requested amendment does not present a significant hazard.
(7)
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- 't ATTACHMENT 2 ULNRC-1447 CALLAWAY REVISED TECHNICAL SPECIFICATIONS AND LICENSE CONDITIONS
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