ML20108D146
| ML20108D146 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 04/29/1996 |
| From: | Link B WISCONSIN ELECTRIC POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20108D149 | List: |
| References | |
| A00L-960429, AL-960429, GL-88-12, VPNPD-96-025, VPNPD-96-25, NUDOCS 9605070296 | |
| Download: ML20108D146 (6) | |
Text
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- e Wisconsin i
Electnc
- POWER COMPANY 231 W Michegon. PO Box 2046. Wwoukee. WI 53201-2046 (4141221-2345 I VPNPD-96-025 April 29.1996 Document Control Desk 1 US NUCLEAR REGULATORY COMMISSION I Mail Station PI-137 Washington, DC 20555 !
Gentlemen:
DOCKETS 50-266 AND 50-301 TECIINICAL SPECIFICATIONS CHANGE REOUEST 173 REMOVAL OF FIRE PROTECTION REOUIREMEN_TS l FROM THE TECHNICAL SPECIFICATIONS POINT BEACH NUCLEAR PLANT. UNITS 1 AND 2 l
l In accordance with the requirements of 10 CFR 50.4 and 50.90, Wisconsin Electric Power Company (Licensee) hereby requests amendments to Facility Operating Licenses DPR-24 and DPR-27 for Point Beach Nuclear Plant, Units I and 2 respectively, to incorporate changes to the plant Technical Specifications. The proposed revisions will remove fire !
l protection requirements from the Technical Specifications and incorporate them in Point Beach Nuclear Plant's Fire l Protection Evaluation Report (FPER) in accordance with the guidance contained in NRC Generic Letter 88-12. Marked-up Technical Specifications pages, marked-up license, applicable FPER pages, a safety evaluation, and the no significant hazards consideration are enclosed.
DESCRIPTION OF CURRENT LICENSE CONDITION i Section 15.3.14 of the Point Beach Technical Specifications specifies the requirements for fire protection systems and components which would be employed to mitigate the consequences of fires which could affect equipment required for safe i plant shutdown. The requirements for the following systenis and components are contained in this section: !
Fire Main Loop Water Supply Water Sprinkler System Fire Hose Stations Halon Gascous Suppression Systems Fire Detection Systems Fire Barrier Penetration Seals Section 15.3.14 also contains a table that details the type of fire protection systems provided for the various safe shutdown areas at Point Beach Nuclear Plant.
l Technical Specification 15.4.15 specifies the required frequency for inspecting and testing the fire protection equipment
! listed in Section 15.3.14.
Technical Specification (TS) 15.6.2.2.f delineates the stafiin', requirements of the Point Beach fire brigade, with TS 15.6.4.2 detailing the training program requinments for the fire brigade. TS 15.6.5.1.8.h delineates the Manager's Supervisory Staff review requirements for the facility's fire protection program. TS 15.6.5.3 describes the inspection and 96050'7di96 PDR 960429 l P ADOCK 05000266 p9g 95. py, p b/ 5 Asawmaursxasm wwcoww
Document Control Desk April 29,1996 Page 2 audit requirernents associated with the fire protection program. TS 15.6.9.2.F describes reporting requirements should degradation of fire protection systems or components take place. Finally, TS 15.6.8.1.8 states that approved procedures shall be required for fire protection program implementation.
The Facility Operating License for Wisconsin Electric Power Company also contains requirements associated with the fire protection program. Section 3.H of the license states the following:
"The licensee may proceed with [andj is required to complete the modifications identified in Paragraphs 3.1.1 through 3.1.33 of the NRC's Fire Protection Safety Evaluation Report (SER) for the facility dated August 2,1979. These modifications shall be completed as specified in Table 3.1 of the SER or supplements thereto.
The licensee is required to implement and maintain the administrative controls identified in Section 6 of the NRC's Fire Protection Safety Evaluation Report on the Facility dated August 2,1979 and supplements thereto."
l Paragraphs 3.1.1 through 3.1.33 of the NRC's Fire Protection SER identify required modifications in the following areas:
Emergency Breathing Apparatus Ventilation Flow Monitoring Smoke Exhaust Portable Fire Extinguishers Fire Hose Stations Hydrant Gate Valves ,
Fixed Water Suppression Systems Interior Hose Station Nozzles !
Water Damage Protection Water Supply - Fire Department Pumper Connection )
Waterproofing Carbon Dioxide Hose Reel Nozzles 1 Drain System Diesel Generator Air Intake Structure Access for Manual Fire Suppression Ventilation Duct Penetration Seals Fire Barriers Auxiliary Building Cable Tray Penetration Seals Ventilation Dampers Containment Building Fire Stops Curbs and Barriers Service Building Penetration Seals Fire Detectors Cable Tray Penetration Seal Qualification Portable Handlights Communication System Cable Separation Emergency Diesel Generators - Remote Panel Ventilation System Control Cables Fire Hydrant Inspections Hydrant House Hose Equipment Control Room Light Fixtures Hydrogen Hazard Fire Protection The administratis e controls identified in Section 6 of the NRC's Fire Protection SER are as follows:
Organization Fire Brigade Training Control of Combustibles Control ofIgnition Sources Fire Fighting Procedures Quality Assurance l
In accordance with NRC Generic Letter 86-10, the FPER has been incorporated into the PBNP FSAR by reference.
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j Document Control Desk April 29,1996 Page 3 D.ESCRIPTION OF PROPOSED CHANGES In accordance with guidance provided in NRC Generic Letter 88-12, we propose to remove Section 15.3.14 and Section 15.4.15, " Fire Protection System", from the Technical Specifications and locate the associated require-ments into Point Beach's Fire Protection Evaluation Report (FPER) Section 7.2. Specifications 15.6.2.2.f and 15.6.4.2, concerning fire brigade stafling and training requirements, will also be located into Point Beach's FPER.
A copy of the applicable FPER section is enclosed for your resiew.
Additionally, in accordance with the guidance provided in NRC Generic Letters 86-10 and 88-12, we propose that the existing conditions concerning fire protection within our facility operating license be replaced with the following condition:
" Wisconsin Electric shall implement and maintain in effect all provisions of the approved fire protection program as described in the Final Safety Analysis Report for the facility and as approved in the SER dated August 2,1979 (and Supplements dated October 21,1980, January 22,1981, and July 27,1988), subject to the following provision:
The licensee may make changes to the approved fire protection program 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."
BASIS AND JUSTIFICATION The basis andjustification for the proposed changes are contained in the attached safety evaluation and no significant hazards consideration.
It has been determined that the proposed amendments do not involve a significant hazards consideration, authorize a significant clumge in the types or total amounts of any efliuent release, or result in any significant increase in individual or cumulative occupational exposure. Therefore, we conclude that the proposed amendments meet the requirements of 10 CFR 51.22(c)(9) and that an emironmental impact statement or negative declaration and ,
environmental impact appraisal need not be prepared.
Please contact us if there are any questions. I Sincerely,
%l Bob Link Vice President 1 Nuclear Power ,
1 GDA/kmc Enclosures cc: NRC Regional Administrator !
NRC Resident inspector Public Senice Commission of Wisconsin I
TECHNICAL SPECIFICATIONS CHANGE REOUEST 173 SAFETY EVALUATION INTRODUCTION Wisconsin Electric Power Company (Licensee) is applying for amendments to Facility Operating Licenses DPR-24 and DPR-27 for Point Beach Nuclear Plant, Units 1 and 2. The amendments propose to remove fire protection requirements from the Technical Specifications and incorporate them in Point Beach Nuclear Plant's Fire Protection Evaluation Report (FPER) in accordance with the guidance contained in NRC Generic Letter 88-12.
NRC Generic Letter 86-10, " Implementation of Fire Protection Requirements," requested that licensees incorporate the NRC approved fire protection program into their FSAR. Subsequently, NRC Generic Letter (GL) 88-12, " Removal of Fire Protection Requirements From Technical Specifications," was issued, providing guidance for the preparation of a license amendment to implement GL 86-10. GL 88-12 identifies five elements that a licensee must include in such a license amen 2 ment request. These five elements are discussed in the evaluation below.
EVALUATION First, GL 88-12 requires that the NRC-approved fire protection program be incorporated into the FSAR and submitted with the certification required by 10 CFR 50.71(c)(2). In June 1987, Wisconsin Electric modified the FSAR to incorporate the NRC-approved Fire Protection Plan into the FSAR, by reference. This change was certified as required by 10 CFR 50.71(c)(2).
Second, the generic letter requires that the Limiting Conditions for Operation (LCO) and Surveillance Requirements associated with the fire protection program be relocated from the Technical Specifications. We intend to relocate Technical Specifications 15.3.14 and 15.4.15, in their entirety, to FPER Section 7.2. Specification 15.3.14 consists of Limiting Conditions of Operation (LCOs), and Section 15.4.15 consists of surveillance requirements in the following areas:
Fire Main Loop Water Supply 4 Water Sprinkler System 4 Fire Hose Stations 1 Halon Gaseous Suppression Systems j Fire Detection Systems i Fire Barrier Penetration Seals Additionally, Generic Letter 88-12 requires that the administrative controls that address fire brigade staffing be relocated from the Technical Specifications. Therefor =, we intend to relocate Specifications 15.6.2.2.f and 15.6.4.2 to FPER Section 7.2. These two specifications delineate fire brigade staffing and training requirements.
Third, the generic letter requires that all operational conditions, remedial actions, and test requirements presently included in the Technical Specifications for fire detection systems, fire suppression systems, fire barriers, and fire brigade staffing requirements be incorporated into the fire protection program. Since we intend to relocate all of Technical Specification (TS) 15.3.14, TS 15.4.15, TS 15.6.2.2.f, and TS 15.6.4.2 to FPER Section 7.2, the operational conditions, remedial actions and test requirements will be maintained in the FPER. Additionally, we intend to relocate the Unique Reporting Requirement of TS 15.6.9.2.F to FPER Section 7.2. This article requires submittal of a report within 30 days of a fire protection system becoming inoperable.
Fourth, the generic letter requires that the standard fire protection license condition in Generic Letter 86-10 replace the existing fire protection license condition in Point Beach's operating license. Our proposed license condition meets the requirements in GL 86-10 and will preclude changes to the approved fire protection program without prior NRC approval if the changes would adversely affect the ability to achieve and maintain safe shutdown conditions in the event of a fire.
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4 Finally, the generic letter requires that two specifications be added to the Point Beach Technical Specifications. Tbc first specification shall identify the Manage /s Supervisory Staff (MSS) as the group responsible for the resiew of the fire protection program and implementing procedures, and the submittal of any recommended changes to the Off Site Review Committee (OSRC). The second specification requires that fire protection implementation be added to the list of elements for which written procedures shall be established, implemented, and maintained. Such specifications already exist in the current Technical Specifications and are thus not being included in this change package. TS 15.6.5.1.8.h requires that the MSS review the fire protection program every 24 months to ensure the program meets established commitments and requirements. TS 15.6,8.1.8 requires that approved procedures be used for fire protection program implementation.
In conclusion, we believe that the proposed changes meet the guidelines in Generic Lc ters 86-10 and 88-12. Operation of the Point Beach Nuclear Plant in accordance with the proposed specifications will meet all regulatory requirements and maintain established Icvels of safety.
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! TECHNICAL SPECIFICATION CHANGE REOUEST 173 l NO SIGNIFICANT HAZARDS CONSIDERATION In accordance with the requirements of 10 CFR 50.91(a), Wisconsin Electric Power Company (Licensee) has evaluated the proposed changes against the standards of 10 CFR 50.92 and has determined that the operation of Point Beach Nuclear Plant, Units 1 and 2 in accordance with the proposed amendments does not present a significant hazard. The analysis of the requirements of 10 CFR 50.92 and the basis for this conclusion are as follows:
! 1. Operation of this facility under the proposed Technical Specifications change will not increase tie probability or l consequences of an accident previously evaluated.
This change request proposes to remove certain fire protection program requirements from the Point Beach l Technical Specifications and incorporate them into the Final Safety Analysis Report (FSAR) and the Fire Protection Evaluation Report (FPER). No requirements are eliminated, modified, or de-emphasized by this l change. The proposed amendment ensures that any future changes to the fire protection program will be subject to
!' an apprcpriate evaluation in accordance with NRC regulations to ensure that there are no unreviewed safety questions.
Therefore, these proposed changes are administrative in nature. There are no proposed changes to the physical f
plant or the pr== which ensure the plant's capability to mitigate fires and achieve safe shutdown. Therefore, there is no potential effect on the probability or consequences of previously evaluated accidents.
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, 2. Operation of this facility under the proposed Technical Specifications change will not create the possibility of a l
new or different kind of accident from any accident previously evaluated.
New or different accidents can only be created by new or different accident initiators or sequences. Because there are no proposed changes to the physical plant or the processes which ensure the plant's fire protection capability, new or different kinds of accident initiators will not be introduced by this change. The proposed changes are administrative in nature.
( 3. Operation of this facility under the proposed Technical Specifications change will not create a significant reduction in a margin of safety.-
- The margins of safety for Point Beach are based on the design and operation of the reactor and containment and
! the safety systems that provide their protection. Because there are no proposed changes to the physical plant or the processes which ensure the plant's fire protection capability, there will be no effect on the reactor, reactor containment, or the safety systems which provide their protection. Therefore, the proposed changes will not create a reduction in a margin of safety. The proposed changes are administrative in nature.
Additionally, the proposed revision to Point Beach's operating license will not allow Wisconsin Electric to make changes to the approved fire protection program without prior approval of the Nuclear Regulatory Commission l should these proposed changes adversely affect the ability to achieve and maintain safe shutdown in the event of a l
' fire. In accordance with NRC Generic Letter 86-10, any proposed change to the approved fire protection program requires the performance of a 10 CFR 50.59 evaluation and a fire hazards analysis. Should these evaluations l
indicate that the ability to reach and maintain safe shutdown has been adversely affected, prior NRC review and approval will be obtained prior to effecting the changes. Thus, a significant reduction in a margin of safety cannot occur.
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