ML20245J096
| ML20245J096 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 02/17/1989 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20245J086 | List: |
| References | |
| GL-86-10, GL-88-12, NUDOCS 8903060164 | |
| Download: ML20245J096 (4) | |
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1 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 136 TO FACILITY OPERATING LICENSE NO. DPR-66, DUQUESNE LIGHT COMPANY OHIO EDISON COMPANY PENNSYLVANIA POWER COMPANY BEAVER VALLEY POWER STATION, UNIT NO. 1 DOCKET NO. 50-334 INTRODUCTION By letter dated November 1, 1988, revising and supplementing a previous letter dated April 7, 1987, Duquesne Light Company (the licensee, acting as agent for the above utilities) proposed that the existing license condition on fire-protection be replaced with the standard condition noted in Generic Letter 86-10 and also proposed changes to the Technical Specifications (TS) for the J unit. 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 protection program that are similar to requirements for other programs implemented.by license condition. Guidance on these proposed changes to TS was provided to all power reactor licensees and applicants by Generic Letter 88-12, dated August 2,1988.
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, licensees were requested by Oeneric Letter 86-10 to incorporate the final NRC-approved fire protection program in their Final Safety Analysis Reports (FSARs).
In this manner, the fire 3rotection program -- including the systems the administrative and tec1nical controls, the organization, and other piant 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 4
8903060164 890217 PDR ADOCK 05000334 P
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' 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 propostis to remove fire protection requirements from their TS. This action was an industry effort to obtain NRC guidance on an acceptable format for l
license amendment requests to remove fire protection requirements from plant TS.
Additionally, in the licensing review of new plants (e.g. Beaver Valley Unit 2), the staff has approved applicant requests to remove fire protection requirements from the 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 the TS.
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 the 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 currently included in the TS and which are removed by this amendment, do not constitute performance requirements necessary to ensure safe operation of the facility and, therefore, do not warrant being included in the 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 Updated FSAR.
The specific details relating to fire protection requirements removed from the TS by this amendment include those specifications for fire detection systems, fire suppression systems, fire barriers, and fire brigade staffing requirements. Currently, the administrative control requirement (6.8.1.f) already includes fire protection program implementation as an element for which written procedures must be established, implemented, and tr.aintained.
In addition, the audit responsibilities of the Offsite Review Committee continue to include the review of the Fire Protection Program and implementing
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procedures (6.5.2.8.h).
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. The TS changes proposed by.the licensee are in accordance with the guidance 3
provided by Generic Letter 88-12, as addressed in the items below.
(1) Specification 3.3.3.6, Fire Detection Instrumentation, its associated--
surveillance requirements, and bases were removed.
(2) Specifications 3.7.14'.1 through 3.7.14.5, Fire Suppression Systems, their associated surveillance requirements, and bases were removed.
(3) Specification 3.7.15, Fire Barriers, and its associated. surveillance requirements were removed.
(4) Specification 6.2.2.f and 6.4.2 on fire brigade staffing requirements were removed.
As required by Generic Letter 86-10, the licensee confirmed that the NRC-approved fire protection program has been incorporated into the Updated FSAR.
Also,.the. licensee has proposed that the existing licensing condition on the
' fire protection program be replaced with the standard condition noted in
The licensee confirmed that the operational conditions, remedial actions, and test requirements associated with the removed fire protection TS have been included in the Fire Protection Program by incorporation into the station administrative procedures _(SAP 9D, Rev. 5), which is referenesi by the Updated
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FSAR. This is in accordance with the guidance of Generic Letter 88-12.
Currently, the administrative controls requirement (Section 6.8) already includes fire protection program implementation as an element for which written procedures must be established, implemented and maintained. The 11censee's'Onsite Safety Committee is currently required by Section 6.5.1.6 to be responsible for review of all procedures required by Section 6.8.-
The licensee's Offsite Review Connittee is currently required by Section 6.5.2.8 to audit the fire protection program and associated implementing procedures.
These requirements are similar to those imposed on the licensee's Facility Security Plan and Facility Emergency Plan, and are consistent with the guidance of Generic Letter 88-12.
On the basis of its review of the above items, the staff concludes that the licensee has met the guidance of Generic Letter 88-12. Therefore, the staff finds the proposed changes acceptable.
ENVIRONMEN_TAL CONSIDERATION This amendment changes reqmnents with respect to the installation or use of facility components located within the restricted area as defined in 10 CFR Part 20, and changes surveillance requirements. The staff has determined that the amendment involves no significant increase in the amounts and no significant i
change in the types of any effluents that may be released off-site, and that there is no significant increase in individual or cumulative occupational radiation exposure. The staff previously issued a proposal finding that this amendment involves no significant hazards consideration and there has been no
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. public comment on such finding. Accordingly, the amendment meets 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 the amendment.
CONCLUSION We have concluded, based on the considerations discussed above, that:
(1) there is reasonable assurance that the health and safet be endangered by operation in the proposed manner, (2) y of. the public will not 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:
Peter S. Tam Dated:
February 17, 1989 9
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