ML20212L926

Application for Amend to License NPF-43,revising Tech Specs to Remove All Fire Protection Requirements as Recommended by Generic Ltr 86-10.Fee Paid

ML20212L926
Person / Time
Site:	Fermi
Issue date:	03/06/1987
From:	Agosti F DETROIT EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20212L930	List: ML20212L926 ML20212L933
References
GL-86-10, VP-NO-87-0019, VP-NO-87-19, NUDOCS 8703110003
Download: ML20212L926 (10)

Text

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o March 6, 1987 VP-NO-87-0019

'U...S. Nuclear Regulatory Commission Attn Document Control Desk Washington, D. C. 20555 References- 1) Fermi'2 NBC Docket No. 50-341 NRC License No. NPF-43

Subject:

Proposed Technical Specifications (License Amendment) Change - Fire Suppression

.Svatamm (3/4.7.7) l Pursuant to 10CFR50.90, Detroit Edison hereby proposes to amend Operating License NPF-43 for the Fermi 2 plant by incorporating the enclosed change into the Plant Technical Specifications. The proposed change removes all fire protection requirements ' contained in. the Technical Specifications as recommended'by Generic i- Letter 86-10 (April 24, 1986). Additionally, Detroit j j Edison requests that the proposed amendment-changes i- submitted in letter VP-86-0091 dated July'15, 1986 not i be included in the Plant Technical Specifications. This a additional 10CFR Part 50, Appendix R information' will be

! incorporated into the Final Safety Analysis Report along with the requirements currently existing in the l Technical Specifications.

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Detroit Edison has evaluated the proposed Technical Specification changes against the criteria of'10CFR50.59

and 10CFR50.92 and determined that no unreviewed safety l- qucation or significant hazards consideration is involved.

The Fermi 2 Onsite Review Organization has approved and the Nuclear Safety Review Group has reviewed these p proposed Technical Specification changes and concurs with the enclosed determinations.

I~ Pursuant to 10CFR170.12(c), enclosed with this amendment is a check for one hundred fifty dollars ($150.00) .

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, US RC March 6, 1987 VP-NO-87-0019 Page 2 In accordance with 10CFR50.91, Detroit Edison has provided a copy of this letter to the State of Michigan.

If you have any questions, please contact Mr. Steven Frost at (313) 586-4210.

Sincerely, 02 Enclosure cc Mr. A. B. Davis Mr. E. G. Greenman Mr. W. G. Rogers Mr . J . J . Ste f an o Supervisor, Advanced Planning and Review Section, Michigan Public Service Commission 1

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USNRC-March 6, 1987 VP-NO-87-0019 Page 3 I, FRANK E. AGOSTI, do hereby affirm that the foregoing statements are based on facts and circumstances which are true and accurate to the best of my knowledge and belief.

• %dt 4-6 FRANK E. AGDSTI

• Vice President Nuclear Operations On this day of  ! , 1987, before me personally appeared Frank E. Agosti, being first duly sworn and says that he executed the foregoing as his free act and deed.

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Notary Public MARCIA DUCK Nctary Public. Washtenaw County, MI M/ W Mloft Dpiru Dec.20, Igg deh ~), i,v p +x w

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r-Ehclosur3 to VP-ND-87-0019 Page 1 mammeggmas

%e exis' ting Final Safety Analysis Report (FSAR) and Technical Specifications contain various fire protection requirements. S e proposed change would remove the Technical Specification requirements and incorporate these requirements into the FSAR. The FSAR would then contain by reference the fire protection program and major connitsents, including the fire hazards analysis.

Additionally, the proposed change requires anending Page 5 of the Facility Operating License, Item 2.C(9) as attached.

On April 24, 1986, the Nuclear Regulatory Connission (NIC) issued Generic Letter 86-10, "Inplementation of Fire Protection Requirements" providing guidance to licensees for requesting license anendment revisions to the fire protection program. %e Generic Letter requested that licensees transfer the fire protection elements from the Tectmical Specifications to the FSAR and to anand the Facility Operating License Condition.

%is change will, in effect, transfer fire protection program canitments, reporting requirenents and anenonents from the jurisdiction of 10CFR50.73 and 10CFR50.90 to 10CFR50.59 and 10CFR50.71(e) . Se NIC basis for this request (as taken directly from the Generic Letter) is as follows:

"Most licenses contain a section on fire protection. License corr 3ftfons for plants licensed prior to January 1,1979, contain a condition requiring inplenentation of aqdifications connitted to by the licensee as a result of the B'IP review. W ese conditions were added by apenonents issued between 1977 and February 17, 1981, the effective date of 10CFR50.48 and Appendix R.

Wo points should be noted in regard to these conditions: (1) they did not explicitly cover required fire protection features where modifications to the existing plant configuration or procedures were not required, and (2) sone of the provisions in these cor:11tions ney have been sugerseded by Sections III.G, J, 0, and L of Appendix R.

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7 Riclosuro to VP-lO-87-0019 Page 2 License conditions for plants licensed after January 1,1979 vary widely in scope and content.

Some only list open items that naast be resolved by a specified date or event, such as exceeding five percent power or the first refueling outage. Same reference a comunitment to meet Apperdix R; sane reference the FSAR and/or the E Staff's SER.

'these verlations have created problems for licensees and for NRC inspectors in identifying the operative and enforceable fire protection requirements at each facility.

'the license conditions also create difficulties L because they do not specify when a licensee may make changes to the approved prograun without requesting a license amendment. If the fire protection program cannitted to by the licensee is required by a specific license condition or is not part of the FSAR for the facility, the provisions of 10CFR50.59 may not be applied to make changes without prior NBC approval. Thus, licensees may be required to submit amendnent requests even for relatively minor changes to the fire protection program.

'the aforementioned probless, in general, exist because of the many subnittals that constitute the fire protection prograer for each plant. The Commission believes that the best way to resolve these problems is to incorporate the fire protection program and major cannitaants, including the fire hazards analysis, by reference into the Final Safety Analysis Report (FSAR) for the facility. In this manner, the fire protection program, including the systems, the administrative and technical controls, the organization and other plant features associated with fire protection would be on a conalstent status with other plant features described in the FSAR. Also, the provisions of 10CFR50.59 would then apply directly for changes the licensee desires to make in the fire protection program that would not adversely affect the ability to achieve and unintain safe shutdown. In this context, the determination of the involvenent of an unreviewed safety question defined in 50.59(a) (2) would be made based on the

" accident... previously evaluated" being the postulated fire in tle fire hazards analysis for the fire area affected by the change. The Consnisalon also believes that a standard license condition, requiring licenoces to conply with the

Ehclosura to VP-le-87-0019 Page 3 provisions of the fire protection program as (

described in the FSAR, should be used to ensure uniform enforcenent of fire protection requirenants."

Detroit Edison has evaluated this position and concurs with the NIC in that the Fermi 2 Fire Protection Program should be completely described and controlled through ,

the FSAR rather than through the ccabination of the FSAR and Technical Specifications. By regulation, the FSAR is a licensee-controlled document which can only be changed pursuant to 10CFR50.59.

'Ihe Fire Protection Program currently in place at Fermi 2 nuets the requirenents of the existing Technical Specifications. With relatively straightforward administrative changes to the FSAR and plant procedures, the Program's commituents will be defined within FSAR Section 9.5 and Appendix 9A. Additionally, the FSAR is being amended to include a discussion of fire protection operations, testing and surveillances.

SIGGFIChlff MIAleg tynetumairIm In accordance with 10CFR50.92, Detroit Fdison has made a determination that the proposed amendment involves no significant hazards consideration. 'Ib make this determination, Detroit Edison must establish that operation in accordance with the prcposed amendnant would not: 1) involve a significant increase in the probability or consequences of an accident previously evaluated, or 2) create the possibility of a new or different kind of accident from any accident previously evaluated, or, 3) involve a significant reduction in a nergin of safety.

1. 'Ite proposed change to remove the fire protection Technical Specifications does not involve a significant increase in the probability or consequences of an accident previously evaluated because the change does not involve a physical modification to the plant, a change to any safety system or a change to any setpoint. W administrativo corcept of concurrently removing the fire protection requirenents frcat the Technical specifications and incorporating these elenents into the FCAR doud not affect tlW l safety analysis presenttd in the Fermi 2 FlWH.

! W change will not affect tie functionirvj of l the fire prottetion program, which will be l

nelntnined pursuant to the facilitics operating license. No chervjes will be nede to the program that conflicto with the requirements of the licenoo. e i

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'Ihus, there is no significant increase in the probability or consequences of an accident previously evaluated.  ;

2. '!he proposed change to remiove the fire protection Technical Specifications does not create the possibility of a new or different kind of accident from any accident previously ,

evaluated because the change is purely '

administrative in nature and does not affect the accident analysis or the operation or function of any safety-related equipment. The fire protection program requireaants will continue to be maintained. No new nodes of operation a:e being introduced.

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'Ihus, the change does not create the ,

possibility of a new or different kind of I accident from any accident previously evaluated.

3. 'the proposed change to remove the fire protection Technical Specifications does not involve a significant reduction in the rargin of safety because the incorporation of the fire protection requirements into the FSAR doec not decrease the level of fire protection in the plant. In effect, the change would increase the nargin of safety based upon the incorporation of all fire protection program and major ccanitnents being roferenced in a single document. Mditionally, the 10CFR50.59 criteria for fire protection program changes and the incorporation of the ntarmlard licenso corv11 tion will ensure uniform enforcenent of the fire protection requirements.

Thus the change doon not involve a significant reluction in a margin of nafety.

IssvinasseenE Issect Detroit nilson han revlwed the proposed Tecinical Dpecification ayahmt the criteria of 10CrH50.22 for environmental conalderations. As nhown above, tim proposed changen do not involve a significant hazards consideration, nor increase the typen anr1 anounts of effluento that may be releasal of fnite, nor algnificantly incroace Irw11vidual or ctmulative occupational radiation exposuren. Doned on the foregoing, Detroit R11aon corcludun that the propor4d Ttchnical specifications do umt the criteria given in

EhclosurO to VP-IO 87-0019 Page 5 10CFR51.22(c)(9) for a categorical esclusion frcan the requirement for an Environmental Impact Statement.

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%e change to transfer the fire protection requirementsfroen the Tacimical Specifications to the FSAN is purely administrative in nature. Encept for those programatic changes identified in Generic Letter 86-10, the fire protection ~ requirements and program consnitments at Fermi 2 have not changed. Se deletion of the Fire Protection Technical Specifications have been reflected on numerous dockets and recently licensed plants. %ese plants include the Perry Nuclear Power Plant, Hope Creek Cenerating Station and Clinton Power Station.

Based on the evaluations above: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manrwr, and (2) such activities will be conducted in compliance with the Consnission's regulations and proposed amendnents will not be inimical to the common defense to3 security or to the health and safety of the public.

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