ML20011D392
| ML20011D392 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 12/15/1989 |
| From: | Cockfield D PORTLAND GENERAL ELECTRIC CO. |
| To: | |
| Shared Package | |
| ML20011D389 | List: |
| References | |
| NUDOCS 8912270114 | |
| Download: ML20011D392 (7) | |
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N PORTLAND GEWERAL ELECTRIC COMPANY EUGENE WATER & ELECTRIC BOARD AND PACIFIC POWER & LIGHT COMPANY Operating License NPF-1 Docket 50-344 License Change Application 151, Revision 1 This License Change Application requests modifications to Operating License NPF-1 for the Trojan Nuclear Plant to remove those portions of the Trojan Technical Specifications that are related to the fire protection program and relocates them to Topical Report PCE-1012. Volume I, " Trojan Nuclear Plant Fire Protection Plan - Program Description",
i PORTLAND GENERAL ELECTRIC COMPANY By D.W. Coed) dent 41d Vice Presi Nuclear Subscribed and sworn to before me this 15th day of December 1989.
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Notary Public of Oreg6n My Commission Expires:
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8912270114 091215 PDR ADOCK 05000344 P
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of
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PORTLAND CENERAL ELECTRIC COMPANY,
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Docket 50-344 THE CITY OF EUGENE, OREGON, AND
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Operating License NPF-1 PACIFIC POWER & LICHT COMPANY
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(TROJAN NUCLEAR PLANT)
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CERTIFICATE OF SERVICE I hereby certify that copies of License Change Application 151 Revision 1, to the Operating License for Trojan Nuclear Plant, dated December.l.5,1989, have been served on the following by hand delivery or by deposit in the United States mail, first class, this lith day of December 1989:
Mr. David Stewart-Smith State of Oregon Department of Energy 625 Marion St NE Salem OR 97310 Mr. Michael J. Sykes Chairman of County Commissioners Columbia County Courthouse St. Helens OR 97051
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"S. A. Bauer,' Manager Nuclear Regulation Branch Nuclear Safety & Regulation Subscribed and sworn to before me this 15t h day of December 1989.
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LCA 151, Rev. 1 Page 1 of 5 Description of Change This proposed change removes those portions of the Trojan Technical Specifications (TTS) which are related to the fire protection program from the TTS and relocates them to PGE-1012. " Trojan Nuclear Plant Fire Protection Plan - Program Description". Amendment 3 to PCE-1012, included the relocated operating specifications for the fire protection program, and was submitted to the NRC on June 30, 1987. Amendment 5 to PGE-1012, which was submitted to the NRC on July 31, 1989, provided for the updating of the operating specifications to be consistent with this LCA. The relocated TTS sections are identified as follows:
PGE-1012 TTS Section Subj ec t Section 3/4.3.3.7 Fire Protection Instrumentation 8.1 Table 3.3-10 Fire Detection Instruments Table 8-1 l
3/4.7.8.1 Fire Suppression Water System 8.2 3/4.7.8.2 Spray, Sprinkler, and/or Deluge 8.3 Systems 3/4.7.8.3 Fire Hose Stations 8.4 Table 3.7-4 Fire Hose Stations Table 8-2 3/4.7.9 Penetration Fire Barriers 8.5 B3/4.3.3.7 Fire Detection instrumentation Bases 8.1.3 B3/4.7.8 Fire Suppressior. Systems Bases 8.2.3 B3/4.7.9 penetration Fire Barriers Bases 8.5.3 6.2.2.f Facility Staff (Fire Brigade) 8.6 l
6.4.2 Training (Fire Brigade) 8.6 An administrative control requiring Plant Review Board review of changes to the Fire Protection Plan is added to TTS 6.5.1.6.
In addition, the second paragraph of TTS 4.0.4 is deleted since it is no longer applicable.
The special reporting requirements in TTS Section 6.9.2 applicable to '!1re protection are also deleted. The reporting requirements of Title 10. Code of Federal Regulations, Part 50 Sections 12 and 73 (10 CFR 50.72 and 50.73) will govern as required by Section E of NRC Generic Letter 86-10 (April 24, 1986).
Furthermore, License Condition 2.c.(8) is deleted and replaced by the model license condition cited in NRC Generic Letter 86-10.
Proposed replacement pages for the TTS and the Trojan Operating License are provided as Attachments 1 and 2,.respectively. Attachment 3 is an excerpt from the Trojan Nuclear Plant FSAR.
It includes FSAR Section 9.5.1, which references Topical Report PGE-1012 for a description of the Trojan Nuclear Plant Fire Protection Program.
Also provided as is a copy of Section 8 from PGE-1012. " Trojan Nuclear Plant Fire Protection Plan - Program Description".
These changes to the Trojan Technical Specifications have been reviewed by a mult1 disciplinary group of responsible, technical supervisory and management personnel, including the Plant Review Board and the Trojan Nuclear Operations Board (refer to TTS Sections 6.5.12 and 6.5.2.2, respectively).
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LCA 151. Rev. 1 Page 2 of 5 Reason for Change NRC Generic Letter 86-10. " Implementation of Fire Protection Require-ments", April 24, 1986, Section F. " Addition of Fire Protection Program into FSAR", mentions several problems for licensees and NRC inspectors in identifying the operative and enforceable fire protection requirements at each licensed facility.
The NRC has attributed these problems to vari-ations in license conditions added by amendments before the effective date of 10 CFR 50.48 and Appendix R and to the many submittals which typically constitute the fire protection " programs" for each plant.
Among the problems discussed is the difficulty in making changes to the approved fire protection program without first requesting a license amendment. As the NRC staff stated:
f the fire protection program committed to by the licensee is required by a specific license condition or is not part of the FSAR for the facility, the provisions of 10 CFR 50.59 may not be applied to make changes without prior NRC approval.
Thus, licencees may be required to submit amendment requests even for relatively minor changes to the fire protection program."
The Plant operating staff is required to be very familisr with the contents of the technical specifications and are required to demonstrate that knowledge to pass qualification /requalification examinations. The fire protection-related portions contain little, if any, information which the operators actually need to have memorized to be able to operate the reactor safely.
Even if such information is not memorized, it occu-pies considerable cpace in the TTS document, thereby hampering the operator's ability to find other useful information rapidly.
Removing the fire protection elements from the TTS, then, will help to ease the training and operating burden of the Plant Staff.
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The NRC, in Generic Letter 86-10, states:
...[E]ach licensee should include, in the FSAR update required by 10 CFR 50.71(e) that will fall due more than 6 months after the date
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of this letter, the incorporation of the fire protection program l
that has been approved by the NRC, including the fire hazards l
analysis and major commitments that form the basis for the fire I
protection program... At the same time the licensee may request an-amendment to delete the technical specification that will now be j
unnecessary." (Pages 4 and 5) l Similar license amendments / Technical Specification changes have been' approved for the Perry, Hope Creek, Hatch and Palo Verde nuclear plants (References 1 through 4) and have been proposed in submittals to the NRC from the following plants that are similar to the Trojan design:
- Byron /Braidwood on August 29, 1986,
- Wolf Creek /Callaway on February 19, 1987, l
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LCA 151. Rev. 1 page 3 of 5
+ V. C. Summer on March 31, 1987, and
+ Joseph p. Farley on July 16, 1987.
Generic Letter 88-12. " Removal of Fire protection Requirements from Technical Specifications," August 2,1988, provided further guidance for the implementation of Generic Letter 86-10.
This included suggestions for the removal of fire protection requirements from TS in four major areas:
fire detection systems, fire suppression systems, fire barriers, and fire brigade staffing requirements.
It also contained suggestions for other changes to administrative control requirements related to the fire protection program to ensure the program consistency with requirements of other programs.
Significant Hazards Consideration Determination The proposed change does not involve a significant hazards consideration because operation of the Trojan Nuclear plant in accordance with this change would not:
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Involve a significant increase in the probability or the consequences of an accident previously evaluated.
This change merely relocates the fire protection program elements from the TTS to Section 9.5.1 of the FSAR by. reference to pGE-1012.
No change is being made to the approved fire protection program.
All operating limitations will continue to be imposed, and all required surveillances will continue to be performed in accordance with written procedures and instructions auditable by the NRC.
Although proposed future changes to the fire protection program elements heretofore located in the TTS will no longer be controlled l
by 10 CFR 50.90, the jurisdiction of 10 CFR 50.59 will apply and j
thereby assure that future revisions and/or changes to the program are properly reviewed and approved.
In addition, the requirements of l
10 CFR 50.71(e) will assure proper NRC staff notification when revi-sions are made to the program.
Thus, programmatic controls will continue to assure that this change will not have the effect of permitting future proposed fire protec-tion program changes to create an unreviewed safety question.
Since 10 CFR 50.59 requires an evaluation of whether the probability or consequences of an accident previously evaluated may be increased, it is concluded that this change does not involve a significant increase in the probability or consequences of an accident previously l
evaluated.
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Create the possibility of a new or different kind of accident from l
any previously evaluated, l
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LCA 151, Rev. 1 page 4 of 5 PGE-1912, incorporated by reference in Trojan FSAR Section 9.5.1, I
already contains the fire hazards analysis.
Since this change merely relocatos the fire protection program elements from the TTS to PCE-1012, such that no substantive change to the fire protection program is being made, it is evident that this change does not affect the ability of the Trojan Nuclear Plant to achieve and maintain safe shutdown in the event of a fire. As noted in Para-graph 1 above, the provisions of 10 CFR 50.59 will continue to assure that future fire protection program changes will not create the possibility of an accident different from any previously evaluated in the FSAR.
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Involve a significant reduction in the margin of safety.
As noted above, this change does not involve a reduction to the approved fire protection program; thus, there is no effect on the margin of safety.
In the April 6,1983 Federal Retister, the NRC provided certain examples of amendments that are considered not likely to involve significant hazards considerations.
Example (i) is a purely administrative change to technical specifications:
for example, a change to achieve consistency throughout the technical specifications, correction of an error, or a change in nomenclature.
Example (vii) is a change to conform a license to changes in the regulations, where the license change results in very minor changes to facility operations clearly in keeping with the regulations.
In this case, the proposed change is similar to both example (1) and to example (v11) in that relocation of fire protection program elements from the TTS to the FSAR is a purely administrative change which conforms the license to the NRC's recommendations in Generic Letters 86-10 and 88-12.
I Since the fire protection program elements of the TTS are merely being' relocated to the FSAR and other documents referenced therein, there is no relaxation of the Limiting Conditions for Operation or Surveillance Requirements. Removal of the fire protection program elements from the TTS can also be viewed as an effort to achieve consistency throughout the technical specifications, since this change is part of an overall industry technical specification improvement effort aimed at eliminating material which will reduce the size and complexity of technical specifications.
For these reasons, this change is considered purely administrative.
I Therefore, based on the above discussion, this change has been determined not to involve a significant hazards consideration.
References i
1.
W. R. Butler (NRC) to M. E. Edelman (Cleveland Electric Illuminating
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Co.), November 29, 1985.
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LCA 151, Rev. 1 Page 5 of 5 2.
Safety Evaluation Report Related to the Operation of Hope Creek Generating Station, NUREG-1048, Supplement No. 6. July 1986, j
(Section 9.5.1).
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C. W. Rivenbark (NRC) to J. T. Beckham (Georgia Power Co.),
November 24, 1986.
4.
G. W. Knighton (NRC) to E. E. Van Brunt, Jr. (Arizona Public Service Co.), April 8, 1987.
Safety / Environmental Eveluation Summary Safety and environmental evaluations were performed as required by 10 CFR 50 and the TTS.
This review determined that the proposed changes do not create an unreviewed safety question since Plant operations remain consistent with the FSAR, adequate surveillance is maintained, and there is no significant adverse impact on the environment.
Schedule consideration it is requested that the effective date of this amendment be 30 days after the date of issuance by the NRC.
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