ML20249A731
| ML20249A731 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 06/10/1998 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20249A730 | List: |
| References | |
| NUDOCS 9806180154 | |
| Download: ML20249A731 (5) | |
Text
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g NUCLEAR REGULATORY COMMIS810N WASHINeToN. D.C. 30006 0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO.127 TO FACILITY OPERATING LICENSE NO. NPF-11 AND AMENDMENT NO.112 TO FACILl'Y OPERATING LICENSE NO. NPF-18 COMMONWEALTH EDISON COMPANY LASAI I F COUNTY STATION. UNITS 1 AND 2 DOCKET NOS. 50 373 AND 50-374
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1.0 INTRODUCTION
Section 50.48, " Fire protection," of Part 50 of Title 10 of the Code of Federal Regulations (10 CFR Part 50) requires that each operating nuclear power plant have a fire protection plan that satisfies General Design Criterion 3 (GDC 3), " Fire protection," of Appendix A to 10 CFR Part 50.
The fire protection plan must describe the overall fire protection program for the facility, outline the plans for fire protection, fire detection, and fire suppression capability, and limitations of fire damage. The program must also describe specific features necessary to implement the program, such as administrative controls and personnel requirements for fire prevention and manual fire suppression activities, automatic and manually operated fire detection and suppression systems, and the means to limit fire damage to structures, systems, or components important to safety so that the capability to safely shut down the plant is ensured.
By letter dated July 15,1996, as supplemented on June 19,1997, and February 2,1998, the Commonwealth Edison Company (Comed, the licensee) requested amendments to the Technical Specifications (TSs) appended to Facility Operating License Nos. NPF-11 and NPF-18 for the LaSalle County Station, Units 1 and 2. The proposed amendments relocate certain fire protection requirements from the TSs to the Fire Protection Program in accordance with the guidance 'provided in Generic Letter (GL) 86-10, " implementation of Fire Protection Requirements," and GL 88-12, " Removal of Fire Protection Requirements from Technical Specifications." Specifically, the licensee proposed to relocate the fire protection requirements of TS Section 3/4.3.7.9 (Instrumentation - Fire Detection Instrumentation), TS Section 3/4.7.5
. (Plant Systems - Fire Suppression Systems), TS Section 3/4.7.6 (Plant Systems - Fire Rated Assemblies), and TS Section 6.1.C.4 (Organization),- from the TSs to the Fire Protection Program (consisting of the Updated Final Safety Analysis Report (UFSAR), station procedures, and station Administrative Technical Requirements). In addition, the licensee proposed to revise the operating licenses to include the NRC's standard fire protection license condition as specified in GL 86-10. The June 19,1997, and February 2,1998, supplements clarified the license conditions by providing specific approval dates for previous fire protection safety evaluations.
This information was within the scope of the original application and did not change the staffs initial proposed no significant hazards consideration determination.
GL 86-10 and GL 88-12 referred to removing fire protection requirements from TSs. License amendments that relocate fire protection requirements to the Final Safety Analysis Report (FSAR) in accordance with GL 86-10 and GL 88-12 do not revise the requirements for fire protection operability, testing, or inspections. Such amendments simply replace the fire 9906190154 990610 PDR ADOCK 05000373 P
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~ protection TS sections with the standard fire proaction license condition. The license condition implements and maintains the NRC-approved fire protection program, including the fire protection requirements previously specified in the Ms, Cri accordance with 10 CFR 50.48.
Therefore, such amendments, including the ones propsed by the licensee, are administrative in nature and have no effect on public health and safety,
2.0 BACKGROUND
Section 182a of the Atomic Energy Act (Act) requires applicants for nuclear power plant operating licenses to state TSs to be included as part of the license. The Commission's regulatory requirements related to the content of TSs are set forth in 10 CFR 50.36. That regulation requires that the TSs include items in five specific categories, including (1) safety limits, limiting safety system settings and limiting control settings; (2) limiting conditions for j
operation; (3) surveillance requirements; (4) design features; and (5) administrative controls.
l However, the regulation does not specify the particular requirements to be included in a plant's
.TSs.
The Commission has provided guidance for the contents of TSs in its " Final Policy Statement on l
Technical Specifications improvements for Nuclear Power Reactors" (Final Policy Statement), 58 FR 3g132 (July 22,1903), in which the Commission indicated that compliance with the Final Policy Statement satisfies Section 182a of the Act. In particular, the Commission indicated that certain items could be relocated from the TSs to licensee-controlled documents, consistent with the standard enunciated in Portland Geners/ Electric Co. (Trojan Nuclear Plant), ALAB-531, g NRC 263,273 (1979). In that case, the Atomic Safety and Licensing Appeal Board indicated that " technical specifications are to be reserved for those matters as to which the imposition of rigid conditions or limitations upon reactor operation is deemed necessary to obviate the possibility of an abnormal situation or event giving rise to an immediate threat to the public health and safety." The criteria set forth in the Final Policy Statement have been incorporated into 10
~ CFR 50.36 (60 FR 36g53).
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 J
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 GL 86-10 to incorporate their final NRC-approved fire protection programs in their FSARs. In this manner, the fire protection program, including the systems, certain
. 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 the fire protection requirements. Finally, the Commission stated that, with the required actions, licensees may request an amendment to delete the fire protection TSs that would now be unnecessary. Subsequently, the NRC issued GL 88-12 to give guidance for the preparation of the license amendment request to implement GL 86-10.
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3.0 PROPOSED CHANGE
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The specific changes proposed by the licensee are as follows:
1.
Replace License Condition 2.C.(25) for Unit 1 and License Condition 2.C.(15) for Unit 2 with the standard fire protection license condition as stated in GL 86-10. In addition, delete Sections E and F of Attachment 1 to Facility Operating License NPF-18 which specified items to be completed for the Fire Protection Program prior to exceeding 5 percent of rated full power and prior to startup from the first refueling outage.
2.
Delete TS 3/4.3.7.9 (INSTRUMENTATION - FIRE DETECTION INSTRUMENTATION) and -
relocate the limiting conditions for operation (LCOs), surveillance requirements (SRs), and the associated bases to Administrative Technical Requirements (ATRs). The ATRs will be incorporated by reference into the LaSalle UFSAR.
3.
Delete TS 3/4.7.5 (PL. ANT SYSTEMS - FIRE SUPPRESSION SYSTEMS) and relocate the LCOs, SRs, and the associated bases to an ATR which will be incorporated by reference into the LaSalle UFSAR.
l 4.
Delete TS 3/4.7.6 (PLANT SYSTEMS - FIRE RATED ASSEMBLIES) and relocate the LCOs, SRs, and the associated bases to an ATR which will be incorporated by reference into the LaSalle UFSAR.
5.
Delete TS 6.1.C.4, fire brigade staffing, and relocate the requirements to an ATR which will be incorporated by reference into the LaSalle UFSAR. Also, delete the words "and Fire Brigade composition" from the footnote (*) to TSs 6.1.C.2 and 6.1.C.4.
4.0 EVALUATION
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The NRC staff reviewed the license amendment request against the guidance provided in GLs 86-10 and 88-12; GL 8610 stated that the licensee should incorporate its NRC-approved fire l
protection program in its UFSAR and specified a standard fire protection license condition that the licensee may use to replace current license conditions once the fire protection program is incorporated into the UFSAR.
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GL 88-12 addressed the elements a licensee should include in a license amendment request to remove fire protection requirements from the plant TSs. These elements are (1) the NRC-l approved fire protection program must be incorporated into the UFSAR; (2) the LCOs and SRs_
associated with fire detection systems, fire suppression systems, fire barriers, and the
~ administrative controls that address fire brigade staffing would be relocated from the TSs (the existing administrative controls associated with fire protection audits and specifications related to the capability for safe shutdown following a fire would be retained); (3) all operational conditions, remedial actions,' and test requirements presently included in the TSs for these systems, as well as the fire brigade staffing requirements, shall be incorporated into the fire protection program; (4) the standard fire protection license condition specified in GL 86-10 must be included in the facility operating license; (5) the Administrative Controls section of the TSs shall provide that the Onsite Review Group shall be given responsibility for the review of the program and implementing procedures and for the submittal of recommended changes tu the Offsite or Corporate Review Group; and (6) the Administrative Controls section of the TSs shall provide
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., that implementation of the program shall be added to the list of elements for which written procedures shall be established, implemented, and maintained.
The staff's analysis of the license amendment request is set forth below.
1.
LaSalle's Fire Protechon System is presented in UFSAR Section 9.5.1 and the Fire Hazards Analysis, including the Safe Shutdown Analysis, is incorporated in Appendix H of the UFSAR. Therefore, the licensee has satisfied Element 1 of GL 88-12.
2.
In its submittal dated July 15,1996, the licensee stated that it will incorporate the current TS LCOs and SRs for the fire detection systems, fire suppression systems, fire barriers, and the administrative controls that address fire brigade staffing into a LaSalle ATR document.
In its letter dated February 2,1998, the licensee stated that the above mentioned TS requirements will be included in the Fire Protection Program by reference to the ATR.
Therefore, the licensee has satisfied Elements 2 and 3 of GL 88-12.
3.
The licensee proposed to incorporate the standard fire protection license condition specified in GL 86-10 for LaSalle. The licensee has, therefore, satisfied Element 4 of GL 88-12, 4.
With respect to Element 5 of GL 88-12, the licensee's existing or proposed TSs do not include a requirement in the Administrative Controls section that the Onsite Review Group have responsibility for review of the fire protection program and implementing procedures, and for the submittal of recommended changes to the Offsite or Corporate Review Group.
All TSs requirements related to responsibilities of the Onsite Review Group, including its responsibility for review of the fire protection program, were relocated from the TSs to the Comed Quality Assurance Topical Report, CE-1-A, by a license amendment dated October 20,1995. The licensee implements its Quality Assurance (QA) program in accordance with the requirements of 10 CFR Part 50, Appendix B. Changes to the QA program that constitute a reduction in commitment require NRC review and approval pursuant to 10 CFR 50.54(a). Tiie staff has determined that in light of the regulatory controls thet exist under 10 CFR 50.54 to adequately control future modifications to the QA program, the underlying objective of Element 5 of GL 88-12 has been met.
5.
The TSs currently contain a requirement (TS 6.2.A.g) that written procedures be established, implemented, and maintained for implementation: of the fire protection program.
Therefore, the licensee has satisfied Element 6 of GL 88-12.
l' In summary, the licensee has proposed to incorporate the existing TS fire protection l
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requirements as stated above into the fire protection program which is, by reference, l
L incorporated into the UFSAR. This conforms to staff guidance in GL 86-10, " implementation of l
Fire Protection Requirements," and GL 88-12 " Removal of Fire Protection Requirements from l
Technical Specifications," for removing unnecessary fire protection TSs in four major areas: fire detection systems, fire suppression systems, fire barriers, and fire brigade staffing requirements.
The proposed TSs are consistent with NUREG-1434, " Standard Technical Specifications,
' General Electric Plants." In addition, incorporating these requirements into the UFSAR is consistent with 10 CFR 50.36, as amended, because these TSs do not impact reactor operations, do not identify a parameter which is an initial condition assumption for a design-basis accident or transient, do not identify a significant abnormal degradation of the reactor coolant pressure boundary, and do not provide any mitigation of a design-basis event.
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e u e The fire protection plan required by 10 CFR 50.48, as implemented and maintained by the fire protection license condition, provides reasonable assurance that fires will not give rise to an l
immediate threat to public health and safety. Although there are aspects of the fire detection and mitigation functions that have been determined to be risk significant, such that Criterion 4 of 10 CFR 50.36 would otherwise seem to apply, the minimum requirements for those functions were established in General Design Criterion 3 and 10 CFR 50.48, and further controls are not necessary since the licensee must comply with these minimum requirements regardless of whether they are restated in the TSs or not.
The licensee's fire protection program is required by 10 CFR 50.48, and any changes to that program are govemed by 10 CFR 50.48 and license conditions 2.C.(25) (Unit 1) and 2.C.(15)
(Unit 2). Therefore, the requirements relocated to the UFSAR may be controlled in accordance with 10 CFR 50.59.
These relocated requirements relating to fire protection features are not required to be in the TSs under 10 CFR 50.36 or other regulations, or by Section 182a of the Atomic Energy Act, and are not required to obviate the possibility of an abnormal situation or event giving rise to an immediate threat to public health and safety. In addition, the staff finds that sufficient regulatory controls exist under 10 CFR 50.48 and 10 CFR 50.59 to addrass future changes to these requirements. Accordingly, the staff has concluded that these requirements may be relocated from the TSs to the licensee's UFSAR, and that the proposed amendments are acceptable.
5.0 STATE CONSULTATION
l' In accordance with the Commission's regulations, the Illinois State official was notified of the proposed issuance of the amendments. The State official had no comments.
6.0 ENVIRONMENTAL CONSIDERATION
The amendments change administrative requirements, or change a requirement with respect to j-the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and change SRs. The NRC 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 radiation exposure. The Commission has previously issued a proposed finding that l
the amendments involve no significant hazards consideration, and there has been no public ccmment on such finding (61 FR 50340 ). Accordingly, the amendments meet the eligibility _
criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9) and (c)(10). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in i
connection with the issuance of the amendments.
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7.0 CONCLUSION
The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendments wiH not t'e inimical to the common defense and security or to the health and safety of the public.
Principal Contributors: L. W. Rostbach
~ Date: June 10,1998