ML20195H880

Application for Amend to License NPF-1,consisting of License Change Application 151,removing Portions of Tech Specs Re Fire Protection & Relocating Them to Vol 1 to PGE-1012, Trojan Nuclear Plant Fire Protection Plan..

ML20195H880
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	12/24/1987
From:	Cockfield D PORTLAND GENERAL ELECTRIC CO.
To:
Shared Package
ML20195H869	List: ML20195H866 ML20195H880 ML20195H897
References
NUDOCS 8801200391
Download: ML20195H880 (6)

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PORTLAND GENERAL ELECTRIC COMPANY EUGENE WATER & ELECTRIC BOARD AND PACIFIC POWER & LIGHT COMPANY Operating License NPF-1 Docket 50-344

' License Change Application 151 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".

PORTLAND GENERAL ELECTRIC COMPANY By [fY Sw Q .'W. Cockfie171 Vice President Nuclear Subscribed and sworn to before me this 24th day of December 1987.

W Notary Public of Oregon My Connission Expires: //>" I"' N 12h P P _ _ - _ _ _ _

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LCA 151 Page 1 of 5 Description of Channe This proposed change removes those portions of the Trojan TechnieT1 Specifications (TTS) which are related to the fire protection program from the TTS and relocates them to PCE-1012. "Trojan Nuclear Plant Fire Protection Plan - Program Description". Amendment 3 to PCE-1012, including the relocated operating specifications for the fire protection program, was submitted to the NRC on June 30, 1987. The relocated TTS sections are identified as follows:

PCE-1012 TTS Section Subj ect Section

- 3/4.3.3.7 . Fire Protection Instrumentation 8.1 l -

Table 3.3-10 Fire Detection Instruments Table 8-1

- 3/4.3.3.8 Decouple Switches 8.2

- 3/4.7.8.1 Fire Suppression Water System 8.3 3/4./.8.2 Spray, Sprinkler, and/or Deluge 8.4 Systems

- 3/4.7.8.3 Fire Hose Stations 8.5

- Table 3.7-4 Fire Hose Stations Table 8-2

- 3/4.7.9 Penetration Fire Barriers- 8.6

' - B3/4.3.3.7 Fire Detection Instrumentation Bases 8.1.3

- B3/4.3.3.8 Decouple Switches Bases 8.2.3

- B3/4.7.8 Fire Suppression Systems Bases 8.3.3 B3/4.7.9 Penetration Fire Barriers Bases 8.6.3 6.4.2 Training (Fire Brigade) 8.7 i

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, j The special reporting requirements in TTS Section 6.9.2 applicable to fire protection are also deleted. The reporting requirements of Title 10, code of Federal Regulations Part 50. Sections 72 and 73 (10 CFR 50.72 and 50.73) will govern as required by Section E of NRC Ceneric Letter 86-10 (April 2 , 1986). Furthermore. License condition 2.c.(8) is deleted and i replaced by the model license condition cited in NRC Ceneric Letter 86-10.

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h Proposed replacement pages for the TTS and the Trojan Operating License

! are provided as Attachments 1 and 2, respectively. Attachment 3 is a 4

excerpt from the Trojan Nuclear Plant Updated FSAR. It includes FSAR

Section 9.5.1 which references Topical Report PCE-1012 for a description

of the Trojan Nuclear Plant Fire Protection Program. Also provided as Attachment 4 is a copy of Section 8 from PCE-1012. "Trojan Nuclear Plant Fire Protection Plan - Program Description".

j j These changes to the Trojan Technical Specifications have been reviewed t by a multidisciplinary group of responsible, tachnical supervisory and

management personnel, including the Plant Review Board and the Trojan j Nuclear Operations Board (refer to TTS Sections 6.5.12 and 6.5.2.2, i respectively).

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4 LCA 151 Page 2 of 5 Reason for Change NRC Generic Letter 86-10 "Implementation of Fire Protection Requirements" April 24, 1986, Section F. "Addition of Fire Protection program into FSAR", mentions several problems for licensees and NRC inspectors in iden*1fying the operative and enforceable fire protection requirements at eats licensed facility. The NRC has attributed these problems to variations in licence conditions added by amendments before the effective date of 10 CFR 50.48 and Appendix R, and to the many sub-mittals which typically constitute the fire protection "programs" for each plant. Among the problems discussed is the difficul6.y in making '

changes to the approved fire protection program without tarst requesting a license amendment. As the NRC staff stated:

"If 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 applie(.

to make changes without prior NRC approval. Thus, licensees mtj 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 familiar 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 tho operators actually need to have memorized to be able to operate the reactor safely. Even if such information is not memorized, it occupies considerable space 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.

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 of this letter, the incorporation of the fire protection program that has been approved by the NRC, including the fire hazards analysis and major commitments that form the basis for the fire protection program. .. At the same time the licenseo may request an amendment to delete the technical specification that will now be unnecessary." (Pages 4 and 5)

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,

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LCA 151 '

Page 3 of 5 t

• V. C. Summer on March 31, 1987, and .

• Joseph P. Farley on July 16, 1987. [

l Stanifiesnt 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:

1. Involve a significant increase in the probability or the consequences  ;

of an acalfent previously evaluated. ,

t This change merely relocatee the fire protection program elements  :

from the TTS to Section 9 4.1 of the FSAR by reference to PGE-1012. '

Wo change is being made to the approved fire protection program. All '

operating limitationF will Continue to be imposed, and all required

surveillances will continue to be performed in accordance with  ;

written procedures and instructions auditabit by the NRC.

Although proposed future changes to the fire protection program  ;

elements heretofore located in the TTS will no longer be controlled ,

by 10 CFR 50.90, the jurisdiction of 10 CFR 50.59 will apply and thereby assure that future revisions and/or changes to the program f are properly reviewed and approved. In addition, the requirements of i 10 CFR 50.71(e) will assure proper NRC staff notification when J

revisions 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 4

10 CFR 50.59 requires an evait ition 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 evaluated.

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2. Create the possibility of a new or different kind of accident from l any previously evaluated.

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l PGE-1012, incorporated by reference in scojan Updated FSAR See- i i tion 9.5.1, already contains the fire hazards analysis. Since this  !

change merely relocates the fire protection program elements from the l TTS to PCE-1012, such that no substantive change to the fire protec- [

i tion program is being made, it is evident that this change does not j affect the ability of the Trojan Nuclear Plant to achieve and main-l tain safe shutdown in the event of a fire. As noted in Paragraph I  ;

above, tl.e provisions of 10 CFR 50.59 will continue to assure that t future fire protection program changes will not create the porsibil-1 ity of an accident different from any previously evaluated in the VSAR. l l

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LCA 151 Page 4 of 5

3. 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; thuc, 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 (vil) 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 { his case, the proposed chrnge a is similar to both example (i) and to example (vii) 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 Letter 86-10.

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. Remo/al 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 matarial which will reduce the size and complexity of technical specifications.

For these reasons, this change is considered purely administrative.

As discussed above, this change to the TTS is part of an effort to con-solidate all elements of the fire protection program into the Updated FSAR (via reference to PGE-1012), as recommended by the NRC staff in Generic Letter 86-10. Although the Generic Letter does not have the same force of law as a change in the regulations, it is a clear statement of staff intent and can thus be viewed as similar to a change in the regulations.

Therefore, base

• on the above discussion, this chan.; has been determined not to involve a significant hazards consideration.

References

1. W. R. Butler (NRC) to M. E. Edelman (Cleveland Electric Illuminating l Co.), November 29, 19h4 I

I 2. Safety Evaluation Report Related to the Operation of Hope Creek Generating Station, NUREG-1048, Supplement No. 6. July 1986,

(

t (Section 9.5.1).

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k LCA 151 Page 5 of 5

3. G. 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 Evaluation 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 Updated FSAR, adequate surveillance is maintained, and there is no significant adverse impact on the environment.

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