ML20214H986

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Application for Amend to License NPF-29,changing Tech Specs by Deleting Condition 2.C & Adding New Std Fire Protection License Condition (Designated 2.C.(41))
ML20214H986
Person / Time
Site: Grand Gulf Entergy icon.png
Issue date: 05/19/1987
From: Kingsley O
SYSTEM ENERGY RESOURCES, INC.
To:
Shared Package
ML20214H975 List:
References
NUDOCS 8705270577
Download: ML20214H986 (7)
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Text

AECM-87/0046 Page 5 BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION LICENSE N0. NPF-29 l

DOCKET N0. 50-416 IN THE MATTER OF MISSISSIPPI POWER & LIGHT COMPANY and SYSTEM ENERGY RESOURCES, INC.

and SOUTH MISSISSIPPI ELECTRIC POWER ASSOCIATION AFFIRMATION I, 0. D. Kingsley, Jr., being duly sworn, stated that I am Vice President, Nuclear Operations of System Energy Resources, Inc.; that on behalf of System Energy Resources, Inc., and South Mississippi Electric Power Association I am authorized by System Energy Resources .Inc. to sign and file with the Nuclear Regulatory Commission, this application for amendment of the Operating License of the Grand Gulf Nuclear Station; that I signed this application as Vice President, Nuclear Operations of System nergy Resources, Inc.; and that the statements made and the matters set f t therein are true and correct to the best of my knowledge, information an ,b 'i ef .

\

<\ / e STATE OF MISSISSIPPI COUNTY OF HINDS SUBSCRIBED AND SWORN T0 befo e me, a Notary Public, in and for the County and State above named, this A? day of S/Maa , 1987.

0 (SEAL)

. 44% e N GfbuJ Notary Public My commission expires:

My Camr.ini n Expl:n C:P. 21. 1937 B705270577 870519 PDR ADOCK 05000416 P PDR J

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ENCLOSURE 1

SUBJECT:

Facility Operating License No. NPF-29, License Condition 2.C.(23) Fire Protection Program.

DESCRIPTION OF CHANGE:

System Energy Resources, Inc. (SERI) proposes that Operating License Condition 2.C.(23) be deleted and replaced with the following:

2.C.(41) Fire Protection Program (Section 9.5, SER, SSER#1, SSER#3, SSER#5)

SERI shall implement and maintain in effect all provisions of the approved Fire Protection Program as described in Section 9.5.1 of the Updated Final Safety Analysis Report and as approved in the SER dated September 1981 and Supplements dated December 1981, July 1982, August 1984, and (date of Supplement approving this request) 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 maintain safe shutdown in the event of a fire.

DISCUSSION: Nuclear Regulatory Commission Generic Letter 86-10

" Implementation of Fire Protection Requirements," dated April 24, 1986 allows licensees to revise the fire protection license condition to provide consistency with the standard license condition. This revision may be requested provided the fire protection program approved by the NRC including the Fire Hazards Analysis and major commitments that form the basis for the Fire Protection Program are incorporated into the Final Safety Analysis Report (FSAR).

For purposes of this revised license condition, the GGNS Fire Protection Program is described in Section 9.5.1 of the Updated Final Safety Analysis Report (UFSAR), including Appendices 9A, 98 and 9C. Appendix 9A includes by reference the Fire Hazards Analysis (FHA). Major commitments that form the basis for the GGNS Fire Protection Program are included in Section 9.5.1.

The Fire Hazards Analysis is maintained apart from the UFSAR and is updated and submitted to the NRC on an annual basis in accordance with the requirements of 10CFR50.71(e).

The major commitments which form the basis for the GGNS Fire Protection Program are 1) the commitments to Appendix A of the Branch Technical Position APCSB 9.5-1, dated August 23, 1976 and

2) commitments to Appendix R to 10CFR50, Sections III.G. III.J and III.0. Details of these commitments are described in the UFSAR Tables 9.5-11 and 9.5-12, respectively.

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Th'e addition of Operating License Condition 2.C.(41) will make the operating license and the UFSAR the controlling documents for the GGNS Fire Protection Program and will allow deletion of

- the technical specifications related to. fire protection. As the Comission provided in Generic Letter 86-10, pursuant to the proposed license condition, SERI could make changes to its Fire Protection Program without Staff approval as long as the changes (1) do not otherwise involve a chancondition do not place GGNSor ain technical sp a position where it would not be able to achieve and maintain safe shutdown in the event of a fire and (3) do not constitute-an unreviewed safety. question'as defined by 10 CFR 50.59. SERI will utilize the 10CFR50.59 review process on such changes.

Further, as provided by the Comission in Generic Letter 86-10, temporary changes to specific fire protection features.which may be necessary to accomplish maintenance or modifications are 4

acceptable provided interim compensatory measures are implemented where necessary.

The proposed renumbering of the fire protection license-condition would maintain the requirement for reporting violations of comitments, as applicable, pursuant to Comission regulations (e.g.,10 CFR 50.72 and 73), but would remove the requirement to report insignificant items not-otherwise reportable.

JUSTIFICATION: The proposed standard operating license condition, when approved, will require that the approved Fire Protection Program be maintained as described in the UFSAR. In. Generic Letter 86-10, i

the Commission encouraged all licensees to request.this new license condition, as appropriate.

The present fire protection operating license condition requires that SERI maintain the fire protection program to meet the

" intent" of Appendix R to 10CFR50. The " intent" is defined in SER Section 9.5.9 to be the implementation of Appendix R Sections III.G, III.J and III.0 with exceptions as justified by.

fire protection evaluations approved by the NRC. SERI has filed with the NRC certain exceptions to the literal requirements of Appendix R as a result of the Appendix R reevaluation submitted t l- to the NRC on May 7, 1985. Although final NRC approval of the GGNS Appendix R reevaluation has not been received, it is anticipated that the final approval will be granted prior to or concurrent with the approval of this license condition and will be incorporated by SERI into the UFSAR at the next annual update.

As part of the UFSAR, the comitments to the applicable sections of Appendix R will be controlled and implemented in accordance with the proposed license condition.

requires that Section violations2.F of the operating of Operating Licenselicense currently Condition 2.C. (23) be reported within twenty-four (24) hours in accordance with 10CFR50.72 f

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with written follow-up in.accordance with 10CFR50.73. The proposed renumbering of the fire protection license condition would delete an additional reporting requirement for fire protection other than that contained in Commission regulations, e.g., 10 CFR 50.72 and 73. This is consistent with Commission direction set forth in Generic Letter 86-10.

j SIGNIFICANT HAZARDS CONSIDERATION:

- The proposed amendment does not involve a significant hazards consideration because operation of Grand Gulf Unit 1 in '

accordance with this amendment would not:

1) involve a significant increase in the probability of an accident previously evaluated. The proposed change to the
operating license does not affect any accident previously evaluated nor does it involve changes to safety related systems. The proposed amendment' to the operating . license condition does not alter the results of the Fire Hazards Analysis and will assure that the fire protection requirements as stated in the UFSAR will continue to be i met.

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2) create the possibility of a new or different kind of accident from any accident previously evaluated. The
proposed amendment does not affect the operation of safety t

related systems nor does it propose operation of systems

in a manner not previously analyzed. Future changes to the i Fire Protection Program will be reviewed in accordance with the requirements of 10CFR50.59 to assure that the changes do not involve an unreviewed safety question or do not otherwise place GGNS in a position where it would not be able to achieve and maintain safe shutdown in the event of a fire.
3) involve a significant reduction in the margin of safety.

The proposed change is administrative in nature and involves no significant reduction in the margin of safety -

as described in the technical specifications or the UFSAR.

The proposed license condition provides for review of i proposed changes to the. Fire Protection Program in accordance with 10CFR50.59. This review process will i assure that those changes are evaluated for their impact on j 4 the margin of safety.

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ENCLOSURE 2 NLS-86/01 Changes to the Technical Specifications Related ,to Fire Protection -

SUBJECT:

Technical Specification 3.3.7.9,3.7.6.1,3.7.6.2,3.7.6l3, 3.7.6.4, 3.7.6.5, 3.7.6.6 and 3.7.7.

Surveillance Requirements 4.3.7.9, 4.7.6.1, 4.7.6.2, 4.7.6.3, 4.7.6.4, 4.7.6.5, 4.7.6.6, and 4.7.7.

Tables 3.3.7.9-1, 3.7.6.5-1 and 3.7.6.6-1. s Administrative Control 6.2.2.

Bases 3/4.3.7.9, 3/4.7.6 and 3/4.7.7.

Pages y, viii, ix, xiii, xv, pages 3/4 3-80, 3-81, 3-82,'

3-83, 3-84, 3-85, 3-86, 3-87, 3-88, 3-89, 7-17, 7-18, 7-19, 7-20, 7-21, 7-22, 7-23, 7-24, 7-25, 7-26, 7-27, 7-28, 7-29, 7-30, 7-31, page 6-1, pages B 3/4 3-5 and B 3/4 7-4.

DISCUSSION: The changes proposed in this submittal are made in response to the NRC's Generic Letter 86-10 dated April 24, 1986 which allows.

licensees to relocate fire protection requirements contained in the technical specifications to the Final Safety Analysis Report (FSAR).

The proposed changes to the technical specif.ications are to delete the Limiting Condition For Operation, Surveillance Requirements, associated tables and Bases sections for the following technical specifications:

3/4.3.7.9 Fire Detection-Instrumentation 3/4.7.6.1 Fire Suppression Water System 3/4.7.6.2 Spray and/or Sprinkler Systems 3/4.7.6.3 CO Systems.

2 3/4.7.6.4 Halon Systems 3/4.7.6.5 Fire Hose Stations 3/4.7.6.6 Yard Fire Hydrants and Hydrant-Hose Houses 3/4.7.7 Fire Rated Assemblies The detail (i.e., Limiting. Conditions for Operation, Surveillance Requirements and associated tables) will be transferred to a GGNS Administrative Procedure entitled Fire Protection Plan.

The proposed change to Administrative Controls Section 6.2.2 will delete the Unit Staff requirements for the site Fire Brigade from the technical specifications. These requirements are currently included in UFSAR Section 98.7, Fire Brigade (see Enclosure 3).

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c JUSTIFICATION: The GGNS fire protection requirements are currently implemented through the technical specifications. Following NRC approval f of'the deletion of the technical specifications related to fire protection, the detail from the technical specifications will become part of the Fire Protection Plan. The Fire Protection Plan is an administrative level procedure controlled under GGNS Technical Specification 6.8.1.f. As an administrative procedure, the Fire Protection Plan is required to be reviewed periodically. Changes to this procedure will require evaluation in accordance with the proposed operating license condition 2.C.(41) (Fire Protection Prograd as well as PSRC review and approval prior to implementaticc. Therefore, the Fire Protection Plan will provide an adequate level of assurance that the fire protection features currently described in the technical specifications will function as

. required in the event of a fire.

The site Fire Brigade requirements contained ir Technical Specification 6.2.2.e are also currently included in FSAR section 98.7. The current Fire Brigade requirements as described in the UFSAR will be maintained in accordance with the proposed operating license condition 2.C(41) (Fire Protection Program). Therefore, deletion of the Fire Brigade requirements from the technical specifications is considered an administrative change in which control of this requirement will be transferred from the technical specifications to the operating license and UFSAR.

The Fire Protection Program as described in Enclosure 1 and the Fi.re Protection Plan will provide an equivalent level of protection to that currently provided by the technical

, specifications.

SIGNIFICANT HAZARDS CONSIDERATION:

The proposed amendments do not involve a significant hazards consideration because operation of Grand Gulf Unit 1 in accordance with these amendments would not:

1) ' involve a significant increase in the probability of an accident previously evaluated. Transfer of the fire protection requirements from the technical specifications to a station administrative procedure does not alter the results of any accident previously evaluated. The requirements to demonstrate operability of the fire protection systems and to establish compensatory measures will be maintained through the operating license in accordance with the UFSAR. Therefore, a ' level of fire protection equivalent to that of the technical specifications'will be maintained and no increase in the probability of an accident will be introduced.

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2) create'the possibility of a new or different' kind of accident from any accident previously. evaluated. The proposed ' amendment does not affect the operation 'of _ safety related systems nor does it propose operation of systems in a manner.not previously analyzed. The proposed .

amendments' involve only a-transfer'of control of theJfire protection features from the: technical specifications to

. the GGNS. administrative program.- In accordance with the-proposed Operating License Condition 2.C.(41) changes-to the Fire' Protection Plan would require evaluation in, accordance with 10CFR50.59 and would require review and-approval by- the Plant ' Safety Review Committee. .

3) .

involve a significant' reduction:in the margin of safety.

The proposed amendments are administrative in nature and involve no significant. reduction'in the margin of '

safety. -Future changes.to the Fire Protection Plan will be reviewed in accordance with 10CFR50.59. This review process will assure that those~ changes are evaluated for their impact on the marginlof safety.

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