ML18054A876

Application for Amend to License DPR-20,revising License Condition 3.E & Relocating Fire Protection Tech Specs to Updated Fsar,Per Generic Ltrs 86-10 & 88-12

ML18054A876
Person / Time
Site:	Palisades
Issue date:	07/31/1989
From:	Hoffman D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:
Shared Package
ML18054A875	List: ML18054A874 ML18054A876 ML18054A877
References
GL-86-10, GL-88-12, NUDOCS 8908030248
Download: ML18054A876 (5)

Text

1 CONSUMERS POWER COMPANY Docket 50-255 Request for Change to the Technical Specifications License DPR-20 For the reasons hereinafter set forth, it is requested that the License conditions and the Technical Specificatins contained in the Provisional Operating License DPR-20, Docket 50-255, issued to Consumers Power Company on October 16, 1972, for the Palisades Plant be changed as described in Section I below:

I. Changes A. Section 3E of the license is changed completely to conform with the guidance of Generic Letter 86-10.

B. Table of Contents, pages ii and iii Delete section 3.22 FIRE PROTECTION SYSTEM C. Table of Contents, page v Delete section 4.17 FIRE PROTECTION SYSTEM D. Section 3.22, FIRE PROTECTION SYSTEM, pages 3-96 through 3-102 Delete entire section To be incorporated into FSAR section 9.6.7.1 E. Table 4.2.2, Minimum Frequencies for Equipment Tests, page 4-15 Delete item 7, renumber remaining items To be incorporated into FSAR section 9.6.7.2.2 F. Section 4.17, FIRE PROTECTION SYSTEM, pages 4-75 through 4-80 Delete entire section to be incorporated into FSAR section 9.6.7.2 G. Section 6.2.2, PLANT STAFF, page 6-1 Delete section e To be incorporated into FSAR section 9.6.7.3.

H. Footnote at the bottom of page 6-1 Delete the words "and the Fire Brigade" I. Section 6.4, TRAINING, page 6-5 Delete section 6.4.2 To be incorporated into FSAR section 9.6.7.4 OC0789-0001-NL02

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2 J. Section 6.5.2.8.1, REVIEW, Page 6-9 A4d the following item:

h. Fire Protection Program and Implementing Procedure Changes II. Discussion Generic Letters 86-10 and 88-12 provide guidance for the proposed license condition change and the removal of certain Fire Protection requirements from the Technical Specifications. Consumers Power has adopted this guidance and is incorporating the Fire Protection Program and major commitments, including the Fire Hazards Analysis, by reference into the Final Safety Analysis Report (FSAR) for the facility.

In this manner the Fire Protection Program, will be on a consistent status with other plant features described in the FSAR.

The requirements that are to be removed from the Technical Specifications and incorporated into the FSAR are the Limiting Conditions for Operation (LCO) and Surveillance Requirements associated with fire detection systems, fire suppression systems and fire barriers, and the administrative controls that address the fire brigade staffing. In addition, the administrative controls section of the Technical Specifications are augmented to support the Fire Protection Program. This is accomplished by PRC review of the Fire Protection Program and implementing procedures and the submittal of recommended changes to the Nuclear Safety Services Department (NSSD).

Since the various requirements are not being eliminated and are only being relocated, there is no negative effect on the Fire Protection Program. In fact there is reason to believe overall plant safety will be enhanced by only placing high priority safety requirements within the Technical Specification.

III. Analysis of No Significant Hazards Consideration Consumers Power Company finds that activities associated with this change request involve no significant hazards and, accordingly, a no significant hazards determination per 10CFR50.92(c) is justified, The following evaluation supports that finding.

The proposed amendment involves two changes that must be evaluated for no significant hazards considerations. These changes are:

1. Revision of license condition 3.E to the standard license condition presented in Generic Letters 86-10 and 88-12 *

• 2. Removal of the Fire Protection Technical Specifications and the addition of Fire protection program requirements to the Final Safety Analysis Report (FSAR).

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3 Evaluation

1. Involve a-significant-increase-in-the-probability or-consequences of-an-accident previously--evaluated.

The proposed change to the license condition is in accordance with the guidance provided in Generic Letters 86-10 and 88-12. The proposed license condition is similar to recommended license condition with minimal changes. The revision is consistent with the NRC goal of standardizing the Fire Protection Program license conditions to ensure uniform enforcement of fire protection requirements. The change requested to the license condition provides guidelines for maintaining and making changes to the Plant Fire Protection Program and is not a change affecting the design or function of a particular feature of the fire protection system. The proposed license condition wording is virtually the same as the recommended change and does not involve an increase in the probability or consequences of an accident previously evaluated, since the license condition requires that a 10CFRS0.59 evaluation for identification_of unreviewed safety questions be performed for each proposed change. With the proposed license condition, as with the existing license condition, each change to the fire protection program will be evaluated for its impact on the fire hazards analysis and the margin of safety.

The second change requests the relocation of the Fire Protection requirements from the Technical Specifications to the FSAR. Relocating the Fire Protection Technical Specifications does not increase the probability or consequences of an accident previously evaluated since it does not change the material condition or operating requirements of the plant. Relocating the Technical Specifications does not alter the results of the fire hazards analysis. The proposed change does not remove or degrade Palisades Plant requirements for maintaining an adequate level of fire protection. The present fire protection requirements to demonstrate operability or take remedial actions will be maintained through the Palisades FSAR and plant procedures. The level of fire protection consistent with that currently existing will remain unchanged.

2. Create the possibility-of-a-new or different-kind of accident from-any-accident previously evaluated A new or different kind of accident from those previously evaluated is not created. The proposed changes only involve a transfer of the requirements for the fire protection from the Technical Specifications to Palisades FSAR. The proposed Fire Protection Program license condition and the proposed changes to Technical Specifications require adequate control for evaluation of proposed changes to the Fire Protection Program. Therefore, individual changes will continue to be evaluated for their impact on safety.

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• 3. Involve a-significant reduction in a margin of safety These proposed changes are administrative in nature and do not involve a particular change to the fire hazards analysis previously documented. Therefore, it does not involve a reduction fn the margin of safety. Each future change will continue to be evaluated for any impact on the margin of safety as described in the Technical Specification bases. The proposed changes will ensure that adequate review of propo$ed changes to the Fire Protection Program continues to be performed.

IV. Conclusion The Palisades Plant Review Committee has reviewed this License and Technical Specification Change Request and has determined that these changes do not involve an unreviewed safety question and therefore involves no significant hazards consideration. These changes have been reviewed by the Nuclear Safety Board. A copy of the.License and Technical Specification Change Request has been sent to the State of Michigan official designated to receive such Amendments to the Operating License.

CONSUMERS POWER COMPANY To the best of my knowledge, inform~tion and belief, the contents of this submittal are truthful and complete.

By ~~~~~:...:..:!:=:!~~~'.'.:::::::;:=:~

David P Hoffman, esident Nuclear Operations Sworn and subscribed to before me this 31st day of July, 1989.

E aine E Buehre , Notary Public Jackson County, Michigan My commission expires October 31, 1989

• OC0789-0001-NL02

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ATTACHMENT 1 Consumers Power Company Palisades Plant Docket 50-255 PROPOSED CHANGE TO LICENSE REGARDING

• FIRE PROTECTION July 31, 1989

• OC0789-0001-NL02 4 Pages