ML20236E532
| ML20236E532 | |
| Person / Time | |
|---|---|
| Site: | McGuire, Mcguire  |
| Issue date: | 06/06/1989 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20236E530 | List: |
| References | |
| NUDOCS 8906150025 | |
| Download: ML20236E532 (5) | |
Text
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%,,,,,/ SAFETE EVALUATION BY:THE'0FFICE 0F NUCLEAR REACTOR REGULATION- - RELATED TO AMENDMENT NO. 98 TO FACILITY OPERATING LICENSE NPF-9
- AND APENDMENT NO. 80 TO FACILITY OPERATING LICENSE NPF : DUKE POWER COMPANY lI l
DOCKET NOSi 50-369 AND 50-370 MCGUIRE NUCLEAR STATION, UNITS 1 AND 2 i ~ 1.0' INTRODUCTION 1 By letter dated March 9,1987, Duke Power Company (the licensee) proposed thatl. l . the existing license conditions on fireiprotection be replaced with the standard - condition noted in Generic-Letter 86-10 and also proposed changes to the Appen-i dix A Technical Specifications (TS) for McGuire Nuclear Station,' Units 1 and 2... J The proposed changes would remove requirements for fire detection systems, fire-suppression-systems, fire barriers, and fire brigade' staffing requirements as
- recommended by. Generic Letter 86-10.. The proposed changes would-also modify the.
administrative control requirements of the TS to add requirements for the Fire-1 Protection Program that are similar to requirements for. other programs 4 implemented ~ by license condition. Guidance'on these proposed changes'to:TS wasprovided to all power reactor licensees ano applicants by Generic Letter 88-12',' dated August 2,. 1988. Supplemental information addressing GL 88-12 and:in further support of1 the request, was provided by the licensee on March 20 and May'19 and.23,:1989. Specifically, the requested changes would revise Unit 1 License Condition 2.C.(4) and corresponding Unit 2 License Condition 2.C.(7) " Fire-Protection Program" to substitute a standard condition that states: Duke Power Company :shall implement and maintain in effect all: provisions of the approved fire protection program as described in the Final Safety Analysis Report,. as updated, for the facility through'the-1989 annual FSAR update and as approved in the' SER dated March 1978 and Supplements 2 l 5 and 6 dated March 1979, April 1981, and February 1983, respectively,'and the safety evaluation dated May 15, 1989, subject to the following provision: q The licensee'may make changes to the approved fire protection program l 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. ./ The proposed amendments would delete TS 3/4 3.3.7, referenced TS Table' 3.3-11 I and corresponding Bases, each titled " Fire Protection Instrumentation;" 1 t-TS 3/4.7.10 " Fire Suppression Systems" including all subsections, referenced l 15 Table 3.7-5 " Fire Hose Stations," and associated Bases; TS 3/4.7.11'" Fire 1 i K P l
,s. . Barrier Penetrations" and its corresponding Bases; and TS 6.2.2.e which addresses staffing requirements for the site Fire Brigade. Additionally, reference to the " Fire Brigade" composition within the footnote referenced by TS 6.2.2.e would be removed. The TS Index would be revised to reflect these deletions. The proposed amendments would supplement the administrative controls requirements of TS 6.5.1 " Review and Audit-Technical Review and Control Activities" to require that the Station Manager ensure the performance of a review by a qualified individual / organization of the Fire Protection Program and implementing procedures and submittal of reconrnended changes to the Nuclear Safety Review Board. The amendments would also supplement TS 6.8.1 " Procedures and Programs" to add the following to the existing activities requiring written procedures: "h. Fire Protection Program implementation" and "1. Commitments contained in FSAR Chapter 16.0."
2.0 BACKGROUND
Following the fire at the Browns Ferry Nuclear Power Plant on March 22, 1975, 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 and alterations occurred in these programs over the years. Consequently, on April 24, 1986, licensees were requested by Generic Letter 86-10 to incorporate the final NRC-a Reports (FSARs)pproved Fire Protection Program in their Final Safety Analysis In this manner, the Fire Protection Program -- including the systems, the administrative and technical controls, the organization, and other plant features associated with fire protection -- would have a status consistent with that of other plant features described in the FSAR. In addition, the Commission concluded that a standard license condition, requiring compliance with the provisions of the Fire Protection Program as described in the FSAR, should be used to ensure uniform enforcement of fire protection requirements. Finally, the Commission stated that with the requested actions, licensees may request an amendment to delete the fire protection TS that would now be unnecessary. The licensees for the Callaway and Wolf Creek plants submitted lead-plant pro-posals to remove fire protection requirements from their TS. This action was an industry effort to obtain NRC guidance on an acceptable format for license amendment requests to remove fire protection requirements from TS. Additionally, in the licensing review of new plants, the staff has approved applicant requests to remove fire protection requirements from TS issued with the operating license. Thus, on the basis of the lead-plant proposals and the staff's experience with TS for new licenses, Generic letter 88-12 was issued to provide guidance on removing fire protection requirements from TS. By letters dated March 20 and May 19 and 23, 1989, the' licensee responded to Generic Letter 88-12. The original amendment request was deemed to be in accordance with the generic l 1etter. However, the proposed license condition was changed to be more in j accordance with the standard license condition. Additionally, revised FSAR pages were included in the May 19, 1989 letters to incorporate, by reference, the approved fire protection program as well as the operational conditions, remedial actions and test requirements for fire protection systems and the fire brigade staffing requirements that had formerly been included in the plant technical specificaticas.
5 2.0. EVALUATION Generic Letter 86-10 recommended the removal of fire protection requirements from the TS. Although a comprehensive Fire Protection Program is essential to plant safety, the basis for this recommendation is.that many details of this program that are currently addressed in TS can.be modified without affecting nuclear safety. Such modifications can be made provided that there are suitable administrative controls over these changes. These details, that are-presently included in TS and which are removed by these amendments, do not constitute-performance requirements necessary to ensure safe operation of-the facility and, therefore, do not warrant being included in TS. At the same time, suitable administrative controls ensure that there will be careful review and analysis by competent individuals of any changes in the Fire Protection Program including' those technical and administrative requirements removed from the TS to ensure that nuclear safety is not adversely affected. These controls include: (1) the TS administrative controls that are applicable to the Fire Protection Program; (2) the license condition on implementation of, and subsequent changes to the Fire Protection Program; and (3) the 10 CFR 50.59 criteria for evaluating changes to the Fire Protection Program as described in the FSAR. The specific details relating to fire protection requirements removed from TS by' these amendments include those specifications for fire detection systems, fire suppression systems, fire barriers, and fire brigade staffing' requirements. The-administrative control requirements have been modified to include Fire Protection Program implementation as an element for which written procedures must be established, implemented, and maintained..These TS changes proposed by the licensee are in accordance with the guidance provided by Generic Letter 88-12. Generic Letters 86-10 and 88-12 also include administrative control requirements to ensure that periodic audits are performed regarding fire protection program-matic controls and program implementation. In this respect, the staff notes that existing McGuire TS 6.5.2.9 already contains the following provisions and no change is needed by these amendments: " Audits of unit activities shall be performed under the cognizance of of the NSRB [ Nuclear Safety Review Board]. These' audits shall encompass: g. The Facility Fire Protection programmatic controls including the i implementing procedures at least once per 24 months by qualified i licensee QA personnel; h. The fire protection equipment and program implementation at least once per 12 months utilizing either a qualified offsite licensee fire protection engineer or an outside independent fire protection i consultant. An outside independent fire protection censultant shall be used at least every third year;" As required by Generic Letter 86-10, the licensee confirmed that the NRC-approved Fire Protection Program will be incorporated into Section 9.5.1 of the FSAR. Also, the licensec has proposed that the existing license condition on the i Fire Protection Program be replaced with the standard condition noted in Generic Letter 86-10. 1
. The licensee confirmed that the operational conditions, remedial actions, and test requirements associated w(th the removed fire protection TS have been included in the Fire Protection Program which will be incorporated into the FSAR. This is in accordance with the guidance of Generic Letter 88-12. We find that the incorporation of the Fire Protection Program, and the former TS requirements by reference to the procedures implementing these requirements, into the FSAR and the use of the standard license condition on fire protection establishes the Fire Protection Program, including the systems, the administra-1 tive and technical controls, the organization, and the other plant features associated with fire protection on a consistent status H th other plant features described in the FSAR. Also, the provisions of 10 CFR R 59 apply directly for subsequent changes the licensee desires to make in the Fire Protection Program. In this context, the determination of the involvement of an unreviewed safety question defined in 10 CFR 50.59(a)(2) will be made based on the " accident... previously evaluated" being the postulated fire in the fire hazards analysis for I the fire area affected by the change. Hence, the proposed license condition establishes an adequate basis for defining the scope of changes to the Fire j Protection Program which can be made without prior Comission approval, i.e., without introduction of an unreviewed safety question. On the basis of its review of the above items, the staff concludes that the i licensee has met the guidance of Generic Letters 86-10 and 88-12. Accordingly, l the staff finds the proposed changes have no adverse impact on s-fety and are, l therefore, acceptable.
3.0 ENVIRONMENTAL CONSIDERATION
These amendments involve changes to the use of facility components located within the restricted area as defined in 10 CFR Part 20. The staff has determined 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 exposure. The staff has determined that the amendments involve no significant hazards consideration, and there has been no public coment on such finding. Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(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 these amendments.
4.0 CONCLUSION
The Comission made a proposed determination that the amendments-involve no significant hazards consideration which was published in the Federal Register (54 FR 19266) on May 4, 1989. The licensee's subsequent submittals of May 19 and 23, 1989 provided supplemental information or minor changes requested by the staff to improve consistency with Generic Letter 88-12 and did not change the intent of this initial request and does not alter our finding of no significant I hazards consideration. The Commission consulted with the state of North Carolina. No public comments were received, and the state of North Carolina did not have any coments.
-5. On the basis of the considerations discussed above', the staff concludes that: (1) there is reasonable assurance that the health and safet not be endangered by operation in the proposed manner, (2) y of the public will such activities will be conducted in compliance with the Commission's regulations, and.(3) the issuance of these amendments will not be inimical to the common defense and security or to the health and safety of the public. s '1 Principal Contributors: Dennis J. Kubicki, SPLB/ DEST l Thomas G. Dunning, OTSB/D0EA D. Hood, PD#11-3/DRP-1/II. ] Dated: June 6, 1989 ] 1 i i i .l l I i --__-__}}