ML20249B979
| ML20249B979 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 06/24/1998 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML17159A408 | List: |
| References | |
| GL-86-10, GL-88-12, NUDOCS 9806250135 | |
| Download: ML20249B979 (6) | |
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UNITED STATES g
g NUCLEAR REGULATORY COMMISSION WASHINGTON, D.c. acess-coot
- see SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO.177 TO FACILITY OPERATING LICENSE NO. NPF-14 AMENDMENT NO.150 TO FACILITY OPERATING LICENSE NO. NPF-22 PENNSYLVANIA POWER & LIGHT COMPANY Att FGHENY ELECTRIC COOPERATIVE INC.
SUSQUEHANNA STEAM ELECTRIC STATION. UNITS 1 AND 2 DOCKET NOS. 50-387 AND 388 1.0 l INTRODUCTION Section 50.48, "F;re protection." of Part 50 of Title 10 of the Code of Federal Regulations (10 CFR Part 50) requires that r,ach operating nuclear power plant have a fire protection plan that satisfies General Design Cnterion 3 (GDC 3), " Fire protection," of Appendix A to 10 CFR Part 50.
I 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 May 12,1998, the Pennsylvania Power and Light Company (the licensee) requested amendments to the Technical Specifications (TSs) appended to Facility Operating License Nos. NPF-14 and NPF-22 for the Susquehanna Steam Electric Station (SSES), 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.g (Monitoring Instrumentation - Fire Detection Instrumentation), TS Section 3/4.7.6 (Plant Systems - Fire Suppression System?), TS Section 3/4.7.7 (Plant Systems - Fire Rated Assemblies), and TS Section 6.2.2e (Fire Brigade Staffing),
from the TSs to the Fire Protection Program (consisting of the Updated Final Safety Analysis Report (UFSAR), station procedures, and SSES Technical Requirements Manual). 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.
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2-GL 8610 and GL 88-12 referred to removing fire protection requirements from the TSs. License amendments that relocate fire protection requirements to the Final Safety Analysis Report (FSAR) in accordance with GL 8610 and GL 88-12 do not revise the requirements for fire protection operability, testing, or inspections. Such amendments simply replace the fire protection TSs sections with the standard fire protection license condition. The license condition implements and maintains the NRC-spproved fire protection program, including the fire protection requirements previously specified in the TSs, in accordance with 10 CFR 50.48.
Therefore, such amendments, include the ones proposed by the licensee, are administrative in nature and have no effect on public health and safety.
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2.0 BACKGROUND
Section 182a of the Atomic Energy Act (Act) requires applicants for nuclear power plant i
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 operation; (3) surveillance requirements; (4) design features; and (5) administrative controls.
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 Technical Specifications improvements for Nuclear Power Reactors" (Final Policy Statement),
58 FR 39132 (July 22,1993), in which the Commission indicated that compliance with the Final
~ Policy Statement satisfies Section 182a of the Act, in psrticular, the Commission indicated that certain items could be relocated from the TSs to licensee-controlled documents, consistent with the standard enunciated in Portland General Electric Co. (Trojan Nuclear Plant), ALAB-531,9 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 36953).
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 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 i
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,. Commission stated that, with the requir 4 '::..s, licensees may request an amendment to delete the fire protection TSs that wow 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.
3.0 PROPOSED CHANGE
S The specific changes proposed by the licensee are as follows:
1.
Replace License Condition 2.C.(6) for Unit 1 and License Condition 2.C.(3) for Unit 2 with the standard fire protection license condition as stated in GL 86-10.
2.
Delete TS 3/4.3.7.9 (MONITORING INSTRUMENTATION - FIRE DETECTION INSTRUMENTATION) and relocate the limiting conditions for operation (LCOs), surveillance requirements (SRs), and the associated bases to the licensee controlled SSES Technical Requirements Manual (TRM). The TRM will be incorporated by reference into the SSES UFSAR.
3.
Delete TS 3/4.7.6 (PLANT SYSTEMS - FIRE SUPPRESSION SYSTEMS) and relocate the LCOs, SRs, and the associated bases to the TRM which will be incorporated by reference into the SSES UFSAR.
4.
Delete TS 3/4.7 7 (PLANT SYSTEMS-FIRE RATED ASSEMBLIES) and relocate the LCOs, SRs, and the associated bases to the TRM which will be incorporated by reference into the SSES UFSAR.
5.
Delete TS 6.2.2e fire brigade staffing, and relocate the requirements to the TRM which will be incorporated by reference into the SSES UFSAR. Also, delete the words "and Fire Brigade composition" from the footnote (*). In addition, re-letter TS 6.2.2f and g to TS 6.2.2e and f, respectively, to reflect the deletion of TS 6.2.2.e.
4.0 EVALUATION The NRC staff reviewed the license amendment request against the guidance provided in GLs 86-10 and 8812. GL 86-10 stated that licensees should incorporate the NRC-approved fire protection program in its UFSAR and specified a standard fire protection license condition that licensees may use to replace current license conditions once the fire protection program is incorporated into the UFSAR.
GL 8812 eddressed the elements a lic.ansow should include in a license amendment request to remove fire protection requirements from the piant TSs. These elements are (1) the NRC-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 recently included in the TSs for these systems, as well as the fire brigade staffing requirements, shall be incorporated into the fire protection program;
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(4) the standard fire protection license condition specified in GL 8610 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 to the Offsite or Corporate Review Group; and (6) the Administrative Controls section of the TSs shall provide that implementation of the program shall be added to the list of elements for which written procedures shall be established, implemented, and maintained. The licensee has met each of these elements as discussed below.
1.
SSES's Fire Protection System is presorded in UFSAR Section 9.5.1 by reference to the.
licensee's Fire Protection Review Report (FPRR) which includes the Fire Hazards Analysis and the Safe Shutdown Analysis. Therefore, the licensee has satisfied Element 1 of GL 88-12.
l 2.
In its submittal dated May 12,1998, the licensee proposed to incorporate the current TSs LCOs and SRs for the fire detection system, fire suppression systems, fire barriers, and the administrative controls that address fire brigade staffing into the SSES TRM document. The licensee also stated that the above mentioned TS requirements were included in the Fire Protection Program by reference to the TRM. Therefore, the licensee has satisfied Elements 2 and 3 of GL 8812.
. 3.
The licensee proposed to incorporate the standard fire protection license condition specified in GL 8610 for SSES, Units 1 and 2. The licensee's proposed license conditions identified all of the staff's safety evaluations of the approved Fire Protection Program, except the safety evaluation that evaluates this amendment. Therefore, for completeness, the staff
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has also referenced this safety evaluation in the license conditions for SSES, Units 1 and 2.
The licensee has, therefore, satisfied Element 4 of GL 88-12.
4.
The audit requirements for the Fire Protection Program (TS 6.5.2.8) are being retained in j
the TSs. In addition, the licenses has proposed to incorporate in the TSs that the Plant Operations Review (onsite review group) Cominittee is responsible for reviewing the fire protection programmatic controls and implementing procedures, and that submittal of recommended changes is made to the corporate Susquehanna Review Committee.
I Therefore, the licensee has satisfied Element 5 of GL 88-12.
l 5.
The TSs currently provide that written procedures shall be established, implemented, and maintained for implementation of the Fire Protection Program (TS 6.8.1f). In its submittal dated May 12,1998, the licensee proposed to incorporate into the TSs a requirement (TS 6.8.1j) that written procedures be established, implemented, and maintained for implementation of the Technical Requirements Program. Therefore, the licensee has satisfied Element 6 of GL 88-12.
- In summary, the licensee has proposed to incorporate the existing TSs fire protection l
requirements as stated above into the fire protection program which is, by reference, Incorporated into the UFSAR. This conforms to staff guidance in GL 86-10. "; implementation of Fire Protection Requirements," and GL 88-12, " Removal of Fire Protection Requirements from Technical Specifications," for removing unnecessary fire protection TSs in four major areas: fire 3
detection systems, fire suppression systems, file barriers, and fire brigade staffing requirements.
J In addition, incorporating these requirements into the UFSAR is consistent with NUREG-1431,
" Standard Technical Specifications, Westinghouse Plants and 10 CFR 50.36, as amended, A
5 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.
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 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.(6) (Unit 1) and 2.C.(3)
(Unit 2). Therefore, the requirements relocated to the UFSAR may be controlled in accordance with 10 CFR 50.5g.
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 50.5g to address 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.
3.0 STATE CONSULTATION
in accordance with the Commission's regulations, the Pennsylvania State official was notified of the proposed issuance of the amendments. The State official had no comments.
4.0 ENVIRONMENTAL CONSIDERATION
The amendments change a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and change the surveillance requirements. 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 the amendments involve no significant hazards consideration, and there has been no public comment on such finding (63 FR 28010). The amendments also relate to changes in recordkeeping, reporting, or administrative procedures or requirements. Accordingly, the amendments meet eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(g)and (c)(10). Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.
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5.0 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 will not be inimical to the common defense and security or to the health and safety of the public.
PrincipalContributor. V. Norses Date: June 24, 1998 i
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