ML20237C032
| ML20237C032 | |
| Person / Time | |
|---|---|
| Site: | Fort Saint Vrain  |
| Issue date: | 12/15/1987 |
| From: | Robert Williams PUBLIC SERVICE CO. OF COLORADO |
| To: | Calvo J NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM), Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20237C034 | List: |
| References | |
| GL-86-10, P-87422, TAC-65241, TAC-66508, NUDOCS 8712180081 | |
| Download: ML20237C032 (5) | |
Text
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Public Service ~
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P.o. Box 840 2420 W. 26th Avenue, Suite 1000, Denver, Colorado 80211 conver. co so201.oB40 R.O. WILLIAMS, JR.
VICE PRESIDENT NUCLEAR OPERATIONS December 15, 1987 Fort St. Vrain i
Unit No. 1 l
P-87422 I
U. S. Nuclear Regulatory Commission ATTN:
Document Control Desk Washington, D.C.
20555 Attention: Mr. Jose A. Calvo Director, Project Directorate IV Docket No. 50-257
SUBJECT:
FIRE PROTECTION PROGRAM PLAN SUBMITTAL
REFERENCE:
(See Attached List)
Dear Mr. Calvo:
Public Service Company of Colorado (PSC) is hereby submitting the Fort St. Vrain (FSV) Fire Protection Program Plan as committed in Reference 1 for NRC approval.
Generic Letter 86-10 (Reference 2), issued by the NRC on April 25, 1986, requires licensees to submit a Fire Protection Program Plan (FPPP).
Portions of the FSV FPPP have previously been approved by the NRC through Safety Evaluations or by an NRC-approved exemption (as noted in FPPP Section FP.S.6), while other portions have not been em l
reviewed or remain the subject of an NRC draft Safety Evaluation (which has not been issued in its final form).
(3 The FSV Fire Protection Program has evolved over a period of years to i
meet increasingly stringent fire protection regulatory guidance. The on. i FSV FPPP contains many substantial fire protection improvements in a 38 >
concise, coordinated manner.
It clarifies or resolves conflicting Nn statements made during this period of evolution, and consolidates FSV fire protection commitments into a single document. Therefore, it is g
PSC's intent that the FSV FPPP supersede all previous FSV fire gk protection commitments.
m<
y PSC considers that this Fire Protection Program represents the best am means of protecting the health and safety of the public in the area of FSV fire protection. Therefore, in an effort to most effectively utilize this program, PSC is proceeding to progressively implement b
D the FSV FPPP, on an interim basis, pending the issuance of the ho remaining outstanding NRC safety evaluations.
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P-87422' December-15, 1987' Page 2.
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~The following is a brief review of recent NRC and PSC correspondence related to. fire protection:
On -April-25,.1986, the NRC published Generic Letter 86-10 which specified that:
'"...each licensee should include, in the FSAR ' update required by 10CFR50.71(e) that will fall due -more than 6
. months after the date of this letter, the incorporation of the fire protection program that has been approved by the NRC..."
On November 18, 1986, the NRC sent a draft copy of the NRC's FSV-Appendix R Fire Protection Safety Evaluation (Reference 3) to PSC for comment.
PSC reviewed this draft Safety Evaluation and submitted comments to the NRC on January 16, 1987 (Reference 4).
However, as of this date, the final FSV Appendix R Safety Evaluation has not been issued by the NRC.
On May 15, 1987, 'PSC submitted revised FSV Fire Protection Shutdown /Cooldown models (Reference 5) for NRC review.
On June 1, -1987, PSC requested an exemption from 10CFR50, Appendix R (except Sections III.G and III.J)
(Reference 6),
noting the prior NRC approvals of the FSV Fire Protection 1
Program. The NRC agreed that only Sections III.G and III.J of Appendix R ~are applicable to Fort St. Vrain (Reference 7).
On October 15, 1987, PSC requested (Reference 8) that the FSV i
fire protection Technical Specifications be deleted and replaced
-by the _ Fire Protection Operability Requirements (FPOP,'s), which are included in the Fire Protection Program Plan.
It was-requested that the existing fire protection related Technical Specifications be deleted and the FPOR's implemented to avoid confusion over'duplicative requirements, in accordance with prior conversations with NRC officials.
On November 12,
- 1987, the NRC rejected (Reference 9) PSC's request to delete fire protection Technical Specifications on the basis that the request was premature pending approval of the FSV Fire Protection Program.
Therefore, in accordance with References 1 and 9, PSC is submitting this FSV Fire Protection Program Plan for NRC approval.
After the NRC draft FSV Fire Protection Safety Evaluation (Reference 3) and the SER for the BTP 9.5-1 Appendix A measures are finalized and received, PSC will submit an amendment request to the FSV Operating License in accordance with NRC Generic Letter 86-10 and will resubmit the amendment request to delete the unnecessary fire protection Technical Specifications and implement the FSV Fire Protection Operability Requirements.
Pending these activities, PSC will continue to meet the existing FSV fi re protection Technical Specification Limiting Conditions for
P-87422 December 15, 1987 Page 3 Operation and Surveillance Requirements, until they are replaced by the FPORs.
In addition, it is PSC's intent to implement the additional requirements of the FPORs as resources permit.
Attachment I to this letter is the proposed wording that PSC plans to include in the updated Final Safety Analysis Report (UFSAR),
to be submitted to the NRC after receipt of the final NRC FSV fire protection safety evaluations, reflecting the implementation of the FSV Fire Protection Program Plan. The Fire Protection Plan affords equal or better fire protection to Fort St. Vrain compared with the commitments made in the updated FSAR, Rev 5, Section 9.12.
PSC will notify the NRC in writing of any changes to the commitments contained in the FPPP, until the plan is approved and plan changes fall within the 10CFR50.59 regulatory criteria denoted in Generic Letter 86-10.
PSC requests issuance of the NRC FSV Fire Protection Safety Evaluations as soon as possible, and requests NRC concurrence with the FSV Fire Protection Program Plan to permit complete implementation.
Very truly yours, s
R.0. Williams, Jr.
Vice President Nuclear Operations R0W/CB:jw Attachments cc:
Regional Administrator, Region IV
)
ATTN: Mr. T.F. Westerman, Chief Projects Section B Mr. Robert Farrell Senior Resident Inspector Fort St. Vrain I
P-87422 December 15, 1987 Page 4 9
REFERENCES 1.
PSC letter, Williams to Calvo, dated June 2, 1987 (P-87208) 2.
NRC letter, Eisenhut to Division Directors, dated April-25, 1986 (G-86228) 3.
NRC letter, Heitner to Williams, dated November 18, 1986 (G-86607) 4.
PSC letter, Williams to Berkow, dated January 16, 1987 (P-87013) 5.
PSC letter, Warembourg to Calvo, dated May 15, 1987 (P-87167) 6.
PSC letter, Williams to Calvo, dated June 1, 1987 (P-87202) 7.
NRC letter, Crutchfield to Williams, dated August 3, 1987 (G-87263).
- 8..PSC letter, Williams to Calvo, dated October 15, 1987 (P-87347) 9.
NRC letter, Heitner to Williams, dated November 12, 1987 (G-87405)
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ATTACHMENT 1 i
9.12 FIRE PROTECTION 9.12.1 Fire Protection Program Plan The FSV Fire Protection Program Plan is a single source for all FSV fire protection commitments, which is hereby incorporated by reference into the FSV Updated FSAR, in accordance with Generic Letter 86-10.
It describes how FSV complies with the applicable regulatory guidance given in 10 CFR 50, Appendix R and BTP 9.5-1, Rev. 1, Appendix A, and contains information on the Fort St. Vrain:
Fire protection organization and responsibilities Fire detection, protection and supporting systems Fire Protection Shutdown /Cooldown models Alternate Cooling Method Applicable NRC regulatory requirements Conformance with regulatory requirements, including exemptions Conformance with NFPA Codes, including exceptions NRC fire protection safety evaluations Fire Protection Quality Assurance requirements Fire consequences Fire protection model and system Operability and Periodic Testing Requirements In accordance with Generic Letter 86-10, this Fire Protection Program Plan may be changed without prior approval of the NRC only if those changes would not otherwise involve a change in a license condition or technical specification or result in an unreviewed safety question, as determined under 10 CFR 50.59 evaluation. All changes to this program shall be reported at least annually to the Director of the Office of Nuclear Reactor Regulation, along with the FSAR revisions required by 10 CFR 50.71 (e).
The FSV Fire Protection Program provides assurance, through a defense in depth design, that a fire in the plant will not prevent either the a
Fire Protection Shutdown /Cooldown Trains or the Alternate Cooling Method from performing their assigned shutdown /cooldown functions and will not significantly increase the risk of radioactive releases to the environment.
To accomplish this, the FSV Fire Protection Program is directed towards fire prevention, detection, suppression and an orderly shutdown /cooldown of the reactor.
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