ML20246C856
| ML20246C856 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 06/30/1989 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20246C854 | List: |
| References | |
| GL-86-10, GL-88-12, NUDOCS 8907110167 | |
| Download: ML20246C856 (4) | |
Text
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. jo UNITED STATES Q-NUCLEAR REGULATORY COMMISSION j
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SAFETY EVALUATION SY THE OFFICE OF NUCLEAR REACTOR REGULATION l
SUPPORTING AMENDMENT NO.106 TO PROVISIONAL OPERATING LICENSE NO. DPR-19 i
- AND AMENDMENT NO.101 TO FACILITY OPERATING LICENSE NO. DPR-25 l
COMMONWEALTH EDISON COMPANY l
DRESDEN' NUCLEAR POWER STATION, UNIT NOS. 2 AND 3 DOCKET NOS. 50-237 AND 50-249
1.0 INTRODUCTION
Dy letter dated February 22, 1989, Coirmonwealth Edison Company (the licensee) proposed that.the existing license conditions on fire protection be replaced with the standard condition noted in Generic Letter 86-10 and also proposed changes to the Appendix A Technical Specifications (TS) for Dresden Units 2 and-3. The proposed changes would remove requirements for fire detection systems, fire suppression systems, fire barriers, and fire brigace' staffing requirements as recommenced 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 provicea to all power reactor licensee and epplicants by Generic Letter 88-12, dated August 2, 1988.
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 f acilities.
Because of the extensive modification of Fire Protection Programs and the i
number of open issues resulting from staff evaluations, a number of revisions j
and alterations occurred in these programs over the years. Consequently, licensees were requested by Generic Letter 86-10 to incorporate the final NRC dpproved Fire Protection Program in their Final Safety Analysis Reports (FSARs).
In this manner, the Fire Protection Program -- including the systems, the administrative and technical controls, the organization, and other plant features associcted with fire protection -- would have a status consistent with that of other plant features described in the FSAR.
In addition, the Comission concluded that a standard license condition, i
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 Comission stated that with the requested actions, licensees may request an amendii.ent to delete the fire protection TS that would now be unnecessary.
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The licensees for the Callaway and Wolf Creek plants submitted lead-plant proposals 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.
3.0 QALUATION 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 this amendment, 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.evalutting changes to the Fire Protection l
Program as described in the FSAR.
The specific details relating to fire protection requirements removed from TS by this amenoment 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.
In addition, the audit responsibilities of the On-Site Review and Investigative Function were expanded to include the review of the Fire Protection Program and implementing procedures and submittal of recommended changes to the Off-Site Review and Investigative Function.
The TS changes proposed by the licensee are in accordance with the guidance provided by Generic Letter 88-12, as addressed in the items below.
(1) Specification 6.1.G.2.a.13, On-Site Review and Investigative Function, was revised to add the review of the fire protection program implementation and Specification 6.1.G.I.a was revised to include the review of recommended changes by the Off-Site Review and Investigative Function.
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(2) With the inclusion of Specification 6.1.G.1.a(11), Fire Protection Program implementation has been added to those programs for which written procedures are required. Specification 6.1.H, which was approved in a previous amendment, contains an inspection and audit requirement for the Fire Protection Program.
(3) Specifications 3.12 and 4.12, Fire Suppression Systems, their associated Surveillance Requirements, and Bases (including Fire Barriers and Fire Detection Instrumentation, and their associated Surveillance Requirements and Bases) were removed.
(4) Specification 6.2.C on fire brigade staffing requirements was removed.
As required by Generic Letter 86-10, the licensee by letter dated June 20, 1989 confirmed that the NRC approved Fire Protection Program has been incorporated into the FSAR and stated that any other references determined to be appropriate would be included in the 1989 calendar year FSAR update. Also, the licensee has proposed that the existing licensing conditions on the Fire Protection Program be replaced with the standard condition noted in Generic Letter 86-10.
The licensee confirmed that the operational conditions, remedial actions, and test requirements associated with the fire protection TS will be approved prior to removal from the TS and within 60 days from the approval date of this safety evaluation and included in the fire Protection Program incorporated into the UFSAR. This satisfies the guidance of Generic Letter 88-12.
On the basis of its review of the above items, the staff concludes that the licensee has ret the guidance of Generic Letter 88-12. Therefore, the staff finds the proposed changes acceptable.
4.0 ENVIRONMENTAL CONSIDERATION
These amendments involve changes to the use of the 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 off site, 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 comment on such finding. Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuantto10CFR51.22(b)noenvironmentalimpactstatementor environmental assessment need be prepared in connection with the issuance of these amendments.
5.0 CONCLUSION
The Commission made proposed determinations that the am ndments involve no -
significant hazards consideration, which were published in the Federal Register (54 FR 13762) on April 5, 1989. The Commission consulted with the l
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- State of Illinois. No public comments were received, and the state of Illinois did not have any connents.
On the basis of the considerations discussed above, the staff concludes that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed inanner, (2) such activities will be conducted in compliance with the Comission's regulations, dnd (3) the issuance of these amendments will not be inimical to the comon defense and security or to the health and safety of the public.
Principal Contributors: Dennis J. Kubicki, SPLB/ DEST Thomas G. Dunning, OTSB/D0EA Byron L. Siegel, NRR/DRSP Dated:
June 30, 1989
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