ML20079G041

Application for Amends to Licenses NPF-29 & DPR-30,changing Current License Conditions Re Fire Protection W/New Tech Spec 3.12/4.12, Fire Protection Sys, Per Generic Ltrs 86-10 & 88-12

ML20079G041
Person / Time
Site:	Quad Cities
Issue date:	09/30/1991
From:	Stols R COMMONWEALTH EDISON CO.
To:	Murley T NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), Office of Nuclear Reactor Regulation
Shared Package
ML20079G045	List: ML20079G041 ML20079G049
References
GL-86-10, GL-88-12, NUDOCS 9110080383
Download: ML20079G041 (17)

Text

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D C:mm:nwealth Edk5uit

. C ) 1430 Opus Place i

( Downers Grove. Ulinois 60$15 September 30,1991 Dr. Thomas E. Murley, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20505 Attn: Document Control Desk

Subject:

Quad Cities Nuclear Power Station Units 1 and 2 Application for Amendment to Facility Operating Licenses DPR 29 and DPR 30 and Appendix A. Technical Specifications Technical NBC_DochetSpeelfication Nosm50 25 Land Upgrado 50:20 Prohram EJar Dr. Murley:

in 1990, Quad Cities Station Initiated a formal program to enhance the Station's performance in various aspects of plant operation. The Performance Enhancement Program (PEP; ros developed by assessing existin0 mprovement i alans, identifying potential weannesses and prioritizing improvement actions.

9ecessary improvements to the Technical Specificatiot.s were identified as one of the Station's top priority issues. Details of the goal and methodology for the Technical Specification Upgrade Program are provided in the Exo::utive Summary section of the proposed amenc ment. The program has been previously discussed with members of the NRR staff.

( Pursuarit to 10 CFR 50.90, Commonwealth Edison proposes to amend Facility Operating Licenses DPR 29 and DPR 30 and Appendix A, Technical Specifications. In accordance with Generic Letters 0610 and 8812, the proposed amendment replaces current license conditions regarding fire protection with a new standard license condition and deletes existing Technical Specification Section l 3.12/4.12,

• Fire Protection Systems". Existing administrative control requirements l related to fire protection audits are retained and additional programrnatic requ! rem 9nts have been included in the administrative controls to aodress the Fire Protection Program, consistent with the rec uirements for other programs. In accordance with the atovisions of Generic Letter 86 ' 0, the NRC approved Fire Protecticn Program will be ncorporated into the FSAR. The appropriate changes will be included in the 1991 update which will be filed in accordanco with 10 CFR 50.71(e) (2) no later than June 30,1992.

The proposed amendment request for this Technical Specification section is l- provided as follows:

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1. Amerided fire protection license condition;

2. An Executive Summary of the Tachnical Specification Upgrade Program and the proposed amendment;

3. A summary of the changes:

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Dr. T.E. Murley Sept:mb:r 30,1991

4. A detailed description of the chan0es;

5. The existing Technical Specification pages for DPR 29;

6. Commonwealth Edison's evaluation pursuant to 10 CFR 50.92(c) and 51.21; and,

7. The technical differences between the existing Unit 1 and Unit 2 Technical Specifications.

The proposed amendment has been reviewed and approved by Commonwealth Edison's on site and off site review in accordance with Company procedures.

The Technical Specification Upgrade Program proposes changes to each section of the existing Technical Specifications. As such, Commonwealth Edison roc uests that the proposed amendments be approved and issued as cne document rat 1er than as Individual sections. Commonwealth Edison respectfully requests the NRC's approval of the upgraded Technical Specification by July 1,1992.

To the best of my knowledge and bollef, the statements contained are true and correct. In some respects, these statements are not based on my personal knowledge but obtained information furnished by other Commonwealth Edison employees and consultants. Such information has been revlswed in accordance with Company practice and I believe it to be reliable.

Commonwealth Edison is notifying the State of Illinois of this application for amendment by transmitting a copy of this letter and its attachments to the designated State Official.

Please direct any questions concerning this proposed amendment to J. Schrage at 708/515 7283.

Very truly yours, Rita Stols Nuclear Licensing Administrator Enclosure (A): Proposed Amendment to Technical Specification Section 3.12/4.12, N re Protection Systems" including amended license condition regarding fire protection.

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cc: A.Bert Davis, Replonal Administrator-Rill L.N. Olshan, Pr ect Manager NRR 3cm; NNfc. NIA

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QUAD CITIES NUCLEAR POWER STATION f

TECHNICAL SPECIFICATION UPGRADE PROGRAM PROPOSED AMENDMENT SECTION 3.12/4.12 " Fire Piotection Systems" l [_ _ _ .:

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4 FIRE PROTECTION AMENDED LICENSE CONDITION

4 QUAD CITIES UNITS 1 & 2 DPR-29 & DPR-30 INSERT To FACILITY OPERATING LICENSE PAGE 4 F. Fire ProtectiRD commonwealth Edison Company shall implement and maintain in

• effect all provisions of the approved fire protection program as described in the Updated Final Safety Analysis Report for the facility and as approved in the safety Evaluation Reports dated July 27,-1979 with supplements dated November 5, 1980 and February 12, 1981; December 30, 1982; December 1, 1987 with supplement dated April 20, 1988; December 11, 1987 with supplement dated July 21, 1988; and February 25, 1991, 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 raintain safe shu,tdown in the event of a fire.

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l EXECUTIVE

SUMMARY

Proposed Deletion of TS 3.12/4.12

' FIRE PROTECTION SYSTEMS' l

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4 RKECUTIVE 8UKRARY QUAD CITIES TECHNICAL BPECIFICATION UPGRADE PROGRAM The Quad cities Technical Specification Upgrade Program was conceptualized in response to lessons learned from the Dresden Diagnostic Evaluation Team inspection and the frequent need for Technical Specification interpretations. A comparison of the existing Quad Cities Technical Specification and, Standard Technical Specifications and later operating plants' Technical Specification provisions was conducted to identify potential improvements in clarifying r2quirements and to identify requirements which are no longer consistent with current industry practices. The comparison review identified approximately one-hundred and fifty suggested improvements. The Technical Specification Upgrade Program was not intended to be a complete adoption of the Standard Technical specifications. Overall, the Quad Cities custom Technical specifications provide for a safe operation of the plant and, therefore, only an upgrade was deemed appropriate.

The comparison study revealed a mix of recommended upgrades which included the relaxation of certain existing Technical Specification requirements, the addition of surveillances, the removal of allowances which would no longer be allowed under new plant licensing, and better definition of appropriate action requirements in the event a Limiting Condition for operation cannot be met. The Technical Specification Upgrade Program also implements NRC recommended line item improvements to the Technical Specifications which were issued under Generic Letters.

In response to an NRC recommendation, the Unit 1 and Unit 2 Technical Specifications are combined into one document. To accomplish the combination of the Units' Technical Specifications, a comparison of the Unit 1 and 2 Technical Specifications was performed to identify any technical differences. The technical differences are identified in the proposed amendment package for each section.

The Technical Specification Upgrade Program was identified as a Station top priority during the development of Quad Cities Station's Performance Enhancement Prcgram ( ?EP) . The Technical Specification Upgrade Program's goal is to provide a better tool to Station personnel to implement their responsibilities and to ensure Quad Cities Station is operated in accordance with current industry practices. The upgraded cpecifications provide for more safe and reliable operation of the plant. The program improves the operator's ability to use the Technic?1 Specifications by more clearly defining Limiting Conditions for Operations and required actions. The most significant improvement to the specifications is-the addition of equipment operability requirements during shutdown conditions.

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SUMMARY

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Proposed Changes to Technical Specification Section 3.12/4.12, " Fire Protection Systems" Prtacnt License Condition 3.F .4s replaced with the standard Fire Protection License Condition contained in Generic Letter 88-12,

" Removal of Fire Protection Requirements From Technical Specifications".

All the Fire Protection Systems Technical Specifications contained in present Section 3.12/4.12 are deleted in accordance with the provisions of Generic Letter 88-12

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SUMMARY

OF CHANGES Proposed Deletion of TS 3.12/4.12

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MMMARY RE CRhMER )

l Proposed Deletion of Specification 3.12/4.12 Firo Protection SysJoms This amendment package is one in a series of proposals that will provide improvements to the prosent Quad Cities Technical Specifications. The specific changes to the Facility operating Licenso and for Section 3.12/4.12 are summarized below.

Item 1:

Eaqq it Facility Onoratina License DPR-29 Present License Condition 3.F is replaced with cho standard Fire Protection License Condition contained in Generic Letter 88- A2.

The present License condition requires implementation of the tiRC's Fire Protection Safoty Evaluation dated July 27, 1979.

Item 2 EaERE 3.12/4.12-1 tnrouch 3.12/4.12-13. DPR-29 All the Fire Protection Systems Technical Specifications contained in present Section 3.12/4.12 are doloted in accordance with the provisions of Generic letter 88 _2.

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l DESCRIPTION OF CHANGES Proposed Deletion of TS 3.12/4.12

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l DESCRIPTIOM QZ PROPORD AREERREEE REQHET  ;

Proposed Deletion of Specification 3.12/4.12 Fire Protection Systems The changes proposed in this amendment request are made to implement the provisions of Generic Letters 88-12 and 86-10. An item by item description of the proposed changes requested is-provided below. The Summary of Changes section can be referred to in order to reference back to a given change and its affected page.

'Itgma 1 and 2 Generic Letter 86-10 recommended the removal of fire protection requirements from the technical specifications. Although a comprehensive' Fire Protection Program is essential to plant safety, the basis for this recommendation is that many details of this program that are currently addressed in the technical specifications can be modified without affecting nuclear safety.

Such modifications can be made provided that there are suitable administrative controls over these-changes. These details, that are precei.tly= included in the technical specifications and which are remc:ved by this amendment request, do not constitute performance requirements necessary to ensure safe operation of the facility and, therefore do not warrant being included in the technical specifications,. At the same time, suitable ,

administrative controls ensure that there will be careful review and analysis.by competent individuals of any changes in the Fire Protection Program including those technical and administrative requirements removed from the-technical specifications to ensure that nuclear safety-is not adversely affected. These controls include:-(1) the technical specification administrative controls that are applicable to the Fire Protection' Program; (2) the-license condition or implementation of, and subsequent changes to the Fire Protection Program; and (3) the 10 CFR 50.59 criteria for evaluating changes-to-the. Fire Protection Program as described in

-the UFSAR.

This proposed amendment removes the Fire Protection Systems and fire brigade staffing requirements from the technical specifications, and adds administrative controls to support the Fire Protection. Program. Enclosure 1 to GL 88-12 provides the

-guidance-for removal of fire protection requirements from the-technical specifications. The Generic Letter addresses five elements that should be included in a license amendment request.

-These five elements and-Quad Cities implementation methods are discussed below.

1) GENERIC LETTER 88-121- The NRC Fire Protection FJugram must be incorporated into the FSAR and submitted with the certification required by 10 CFR 50.71(e) (2), as requested by-

GL 86-10. The FSAR update includes the incorporation of the Fire Protection Program, including the fire hazards analysis and major commitments that f rm the basis for the NRC-approved Fire Protection Program. This may be accomplished by referencing the documents wh.4ch define the licensee's Fire Protection Progran as identified in the NRC's Safety Evaluation Reports.

QUAD CITIEE POSITIONt The required information has been incorporated into UFSAR Section 10.6 for Quad Cities Units 1 and 2.

2) GENERIC LETTER 88-12: The Limiting conditions for Operation (LCO) and surveillance Requirements associated with fire detection systems, fire suppression systems, fire barriers, and the administrative controls that address fire brigade staffing would be relocated from the TS. An index of those specifications is provided in Enclosure 2. The existing administrative controls related to fire protection audits are to be retained in TS. Also, any specifications related to the capability for safe shutdown following a fire, e.g. see Item in Enclosure 1 to Generic Letter 81-12, are to be 8(j)ined reta in TS.

QUAD CITIES POSITION: The attached proposed changes to Section 3.12/4.12 and those contained in Section 6.0 implement the requirements of GL 88-12. Quad Cities Units 1 and 2 TSs do not contain requirements concerning the capability for safe shutdown following a fire.

1) GENERIC LETTER 88-12: All operational conditions, remedial actions, and test requirements presently included in the TS for these systems, as well as the firt brigado staffing requirements, shall be incorporated into the Fire Protection Program. In this manner, the former TS requirements will become an integral part of the Fire Protection Program and changes subsequent to this amendment will be subject to the standard license condition. These remedial actions include shutdowns currently required by TS 3.0.3 when an LCO and its associated Action Requirements cannot be met. An example of such a requirement is tra shutdown required for the loss of the fire suppression water system and failure to establish a backup water supply within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

QUAD CITIES RESPONSE: The Quad Cities Fire Protection Program (as described in UFSAR Section 10.6) has incorporated the TS requirements for the systems proposed to be relocated including TS shutdown requirements. A copy of the UFSAR changes and Fire Protection Program Imp.lementing procedures is attached to this amendnient request, for information only.

4) GENERIC LETTER 88-12: The standard fire protection license condition in Generic Letter 86-10 must be included in the

l license. Any other current fire protection license conditions shall be removed. This license condition precludes changes to i the approved Fire Protection Program without prior Commission approval if those changes would adversely affect the ability to achieve and maintain safe shutdown conditions in the event of a fire. The shutdown requirement that applies because of a failure to establish a backup water supply within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after a loss of the fire suppression water system is an example of a Fire Protection Program requirement that would be subject to the license condition and could be changed in accordance with the standard license condition. However the staff believes that any change to the shutdown requiremen,t would also require the implementrtion of extraordinary compensatory measures. Absent such extraordinary measures, changes to this requirement are likely to have an adverse effect on the ability to achieve and maintain safe shutdown in the event of a fire and therefore, could not be made without prior Commission approva,l.

g CITIES POS::TIONu The attachen proposed change to the Facility Operat;.ng Licenses for Quad Cition Units 1 and 'J includes the replacement of present Fire Protection 13conse condition 3.F with the standard license condition from Geaeric Letter 88-10.

5) GENERIC LETTER 1R-121 The Administrative Controls section of the TS shall be augmented to support the Fire Protection Program, This shall be accomplished by additicns to two specifications. First, the Unit Review Group (Onsite Review Group) shall be given responsibility for the review of the Fire Protection Program and implementing procedures and the submittal of recommended changes to the Company Nuclear Review and Audit Group (Offsite or Corporate Review Group). Second, Fire Protection Program implementation shall be added to the list of elements for which written procedures shall be established, implemented, and maintained.

The Emergency Plan and the Security Plan were used as models to determine the appropriate administrative control for the Fire Protection Program. These additions will provide administrative controls for the Fire Protection Program that are equivalent to those for other programs that are implemented by license condition. The enclosed marked pages of the Westinghouse Standard Technical Specifications serve as a model for the changes to the administrative (STS) controls. If the plant's TS differ from the STS, additions to the administrative controls for the Fire Protection Program should be proiosed that are consistent with the administrative controls for the Emergency and Security Plans.

QUAD CITIES POSITION:

The Administrative Controls Section 6.0 of the Quad Cities Technical Specifications contains provisions that are

different from the STS. The Fire Brigado manning requirements of present 6.1.C are deleted while corporate and plant designated responsibility for the Fire Protection Program are retained. Training provisions for the Firo Drigado contained in present 6.1.E are retained. The present Offsite Review and Investigative Functions in 6.1.G.1 requiring review and audit functions for the Firo Protection Program and implementing proceduros are retained. In accordance with GL 80-12 recommandations the required review of the Fire Protection Program and implementing procedures is added to Section 6.1.G.2.a, Onsite Review and Investigative Function. Present Fire Protection Program inspections and audits required by 6.1.H are retained. Present Section 6.2, Plant Operatlng Procedures, contains the GL 88-12 recommendation for Fire Protection Program implementation and, thus, no changes are required for this section. The changos described here for Section 6.0 are shown with other changes contained in a separate package for Soction 6.0.

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PROPOSED TECH SPEC I

TS 3.12/4.12

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EXISTING TECH SPEC TS 3.12/4.12

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