RBG-48054, Application to Adopt GL 86-10 Standard License Condition for Fire Protection Program

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Application to Adopt GL 86-10 Standard License Condition for Fire Protection Program
ML20307A647
Person / Time
Site: River Bend Entergy icon.png
Issue date: 11/02/2020
From: Gaston R
Entergy Operations
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
RBG-48054
Download: ML20307A647 (13)
v • d • e


Text

Entergy Operations, Inc.

1340 Echelon Parkway Jackson, MS 39213 Tel 601-368-5138 Ron Gaston Director, Licensing 10 CFR 50.90 RBG-48054 November 2, 2020 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

Application to Adopt GL 86-10 Standard License Condition for Fire Protection Program River Bend Station, Unit 1 NRC Docket No. 50-458 Renewed Facility Operating License No. NPF-47 In accordance with Title 10 of the Code of Federal Regulations (CFR) Part 50, Section 50.90, "Application for amendment of license, construction permit, or early site permit," Entergy Operations, Inc. (Entergy) is submitting a request for an amendment to the River Bend Station, Unit 1 (RBS) Renewed Facility Operating License (FOL).

The proposed amendment would revise License Condition 2.C.(10), "Fire Protection (Section 9.5.1, SER and SSER 3)," by replacing the current wording with wording from Generic Letter (GL) 86-10, "Implementation of Fire Protection Requirements," and deleting Attachment 4, "Fire Protection Program Requirements."

The Enclosure to this letter provides a description and assessment of the proposed change.

The Attachment to the Enclosure provides the existing FOL pages marked-up to show the proposed change.

Approval of the proposed amendment is requested by December 3, 2021. Once approved, the amendment shall be implemented within 90 days.

This letter contains no new regulatory commitments.

In accordance with 10 CFR 50.91, "Notice for public comment; State consultation," paragraph (b), a copy of this license amendment request, with enclosure, is being provided to the designated State Officials.

RBG-48054 Page 2 of 2 Should you have any questions or require additional information, please contact Tim Schenk, Regulatory Assurance Manager, River Bend Station at 225-381-4177.

I declare under penalty of perjury, that the foregoing is true and correct.

Executed on November 2, 2020.

Respectfully, Ron Gaston RWG/jls

Enclosure:

Description and Assessment of the Proposed Change Attachment to

Enclosure:

Renewed Facility Operating License Page Markups cc: NRC Region IV Regional Administrator NRC Senior Resident Inspector - River Bend Station, Unit 1 Louisiana Department of Environmental Quality NRC Project Manager - River Bend Station, Unit 1

Enclosure RBG-48054 Description and Assessment of the Proposed Change

RBG-48054 Enclosure Page 1 of 7 DESCRIPTION AND ASSESSMENT OF THE PROPOSED CHANGE 1.0 Summary Description In accordance with Title 10 of the Code of Federal Regulations (CFR) Part 50, Section 50.90, "Application for amendment of license, construction permit, or early site permit," Entergy Operations, Inc. (Entergy) is submitting a request for an amendment to the River Bend Station, Unit 1 (RBS) Renewed Facility Operating License (FOL).

The proposed amendment would revise License Condition 2.C.(10), "Fire Protection (Section 9.5.1, SER and SSER 3)," by replacing the current wording with standard wording from Generic Letter (GL) 86-10, "Implementation of Fire Protection Requirements," and deleting Attachment 4, "Fire Protection Program Requirements."

On April 24, 1986, the U.S. Nuclear Regulatory Commission (NRC) issued GL 86-10 to provide guidance to licensees on acceptable methods of satisfying the regulatory requirements concerning fire protection. In GL 86-10, the NRC requested that licensees incorporate the NRC-approved Fire Protection Program in their Final Safety Analysis Reports, and encouraged licensees, upon completion of this program, to apply for an amendment to their operating licenses that would (1) replace the current license conditions regarding fire protection with a new standard condition and (2) remove unnecessary fire protection Technical Specifications (TS).

In GL 88-12, "Removal of Fire Protection Requirements from Technical Specifications," the NRC provided guidance for the preparation of a license amendment request (LAR) to implement Generic Letter 86-10. Specifically, the LAR would: 1) institute the standard fire protection license condition; 2) remove and relocate the fire protection systems and fire brigade staffing TS; and 3) add administrative controls to support the Fire Protection Program. The LAR submittal must also include the update of the Final Safety Analysis Report (FSAR) to include the Fire Protection Program, if this has not been previously completed.

2.0 Detailed Description 2.1 Current License Condition RBS Renewed FOL NPF-47, License Condition 2.C.(10) states:

"EOI shall comply with the requirements of the fire protection program as specified in Attachment 4. Attachment 4 is hereby incorporated into this renewed license." to Renewed FOL NPF-47 states:

"EOI shall comply with the following requirements of the fire protection program:

1. EOI shall implement and maintain in effect all provisions of the approved fire protection program as described in the Final Safety Analysis Report for the facility through Amendment 22 and as approved in the SER dated May 1984 and Supplement 3 dated August 1985 subject to provisions 2 and 3 below.

RBG-48054 Enclosure Page 2 of 7

2. EOI may make no change to the approved fire protection program which would significantly decrease the level of fire protection in the plant without prior approval of the Commission. To make such a change EOI must submit an application for license amendment pursuant to 10 CFR 50.90.
3. EOI may make changes to features of the approved fire protection program which do not significantly decrease the level of fire protection without prior Commission approval provided (a) such changes do not otherwise involve a change in a license condition or technical specification or result in an unreviewed safety question (see 10 CFR 50.59), and (b) such changes do not result in failure to complete the fire protection program approved by the Commission prior to license issuance. EOI shall maintain, in an auditable form, a current record of all such changes, including an analysis of the effects of the change on the fire protection program, and shall make such records available to NRC inspectors upon request. All changes to the approved program shall be reported to the Director of the Office of Nuclear Reactor Regulation, along with the FSAR revisions required by 10 CFR 50.71(e)."

2.2 Reason for Proposed Change In GL 86-10, the NRC stated that variations in fire protection license conditions have created difficulties for licensees in that these license conditions do not adequately specify when a licensee may change the approved Fire Protection Program without requesting a license amendment. As an alternative, the NRC provided a standard license condition that licensees could adopt through a license amendment. This standard license condition states:

Fire Protection (Name of Licensee) shall implement and maintain in effect all provisions of the approved fire protection program as described in the Final Safety Analysis Report for the facility (or as described in submittals dated

_____________) and as approved in the SER dated ____________(and Supplements dated ____________) 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.

The current RBS license condition (i.e., License Condition 2.C(10) and Attachment 4) is not consistent with this standard license condition, as well as the clarifying text in GL 86-10 regarding the standard license condition. These inconsistencies have impacted the ability of RBS to make changes to the approved fire protection program that would otherwise be acceptable under the standard license condition.

RBG-48054 Enclosure Page 3 of 7 2.3 Description of the Proposed Change The following changes are proposed. Marked-up FOL pages are provided in the Attachment to this Enclosure.

a. Replace current License Condition 2.C(10), in its entirety, with the following text.

EOI shall implement and maintain in effect all provisions of the approved fire protection program as described in the Final Safety Analysis Report for the facility, and as approved in the SER dated May 1984 and Supplement 3 dated August 1985 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.

b. Delete the body text from Attachment 4 and replace with "DELETED."

3.0 Technical Evaluation In GL 88-12, the NRC provided guidance on the administrative TS controls that would be necessary to support the relocation of Fire Protection TS and implementation of the standard license condition. Specifically, GL 88-12 identified two administrative controls:

1. Fire Protection Program implementation shall be added to the list of elements for which written procedures shall be established, implemented; and
2. 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).

3.2 Standard License Condition Th proposed license condition is consistent with the standard license condition from GL 86-10, as well as the RBS fire protection licensing basis specified in current License Condition 2.C(10).

3.2 Remove and Relocate Fire Protection Systems and Fire Brigade Staffing TS By letter dated November 30, 1993 (Legacy ADAMS Accession Nos. 9312130216 and 9312130231), Gulf States Utilities (i.e., the RBS licensee prior to Entergy) submitted a license amendment request to improve the current RBS TS (CTS) through implementation of the guidance in NUREG-1434, Standard Technical Specifications, General Electric BWR/6 Plants,"

Revision 0, dated September 1992. This LAR included the proposed removal and relocation of the following TS to licensee-controlled documents, consistent with GL 86-10, GL 88-12, and NUREG 1434.

CTS 3/4.3.7.8 Fire Detection Instrumentation CTS 3/4.7.6 Fire Suppression System

RBG-48054 Enclosure Page 4 of 7 CTS 3/4.7.7 Fire Rated Assemblies CTS 6.5.1 Facility Review Committee (FRC)

CTS 6.5.2 Technical Review and Control In addition to these deletions and relocations, the proposed LAR renumbered CTS 6.8.1, "Procedures and Programs," Item g, "Fire Protection Program Implementation," to 5.4.1.d with the same title. The NRC approved the proposed license amendment by letter and Safety Evaluation dated July 20, 1995 (i.e., Amendment 81 to FOL NPF-47) (Legacy ADAMS Accession Nos. 9508010166, 9508010172, and 9508010174).

3.3 Administrative Controls to Support the Fire Protection Program As listed in Section 3.2 above, Amendment 81 to FOL NPF-47 renumbered CTS 6.8.1.g. The amended RBS TS 5.4.1.d states the following, which establishes compliance with the first necessary administrative control.

5.4.1 Written procedures shall be established, implemented, and maintained covering the following activities:

d. Fire protection program implementation In addition to the removal and relocation of fire protection systems and fire brigade staffing TS, and consistent with NUREG-1434, Amendment 81 removed and relocated CTS 6.5.1, "Facility Review Committee (FRC)" and CTS 6.5.2 "Technical Review and Control," (i.e., the "Unit Review Group (Onsite Review Group") discussed in GL 88-12. In that the TS improvements that were promulgated in NUREG-1434 superseded the GL 88-12 guidance, the second administrative control specified in GL 88-12 concerning a Unit Review Group TS is no longer applicable.

3.4 UFSAR Chapter 9.5.1, "Fire Protection System" In addition to compliance with the required administrative controls described in Sections 3.2 and 3.3 above, GL 88-12 indicated that an LAR to adopt the standard license condition must also include an update to the Final Safety Analysis Report (UFSAR) to include the Fire Protection Program, if this had not been previously completed. RBS UFSAR Section 9.5.1, "Fire Protection System," describes the RBS Fire Protection Program, thus establishing compliance with the GL 88-12 requirement.

4.0 Regulatory Analysis 4.1 Applicable Regulatory Requirements/Criteria One of the principal objectives of a commercial nuclear power plant fire protection program is to ensure that the risk of fire-induced radiological hazards to the public, environment, and plant personnel is minimized. To meet this objective, Title 10 of the Code of Federal Regulations (10 CFR) 50.48, "Fire protection," requires each operating nuclear power plant to have the means to limit fire damage to structures, systems, or components (SSCs) important to safety so that the capability to shutdown the plant safely is ensured. The objective of the plant safe-shutdown is

RBG-48054 Enclosure Page 5 of 7 to assure that at least one means of achieving and maintaining safe-shutdown capability is available during and after any postulated fire.

10 CFR 50.48(a) requires that each operating nuclear power plant have a fire protection plan which satisfies General Design Criterion (GDC) 3, "Fire Protection," of Appendix A to 10 CFR Part 50. The approved fire protection plan is the plan required to satisfy 10 CFR 50.48(a).

Specific fire protection features deemed necessary to ensure this capability are delineated in Appendix R to 10 CFR Part 50. For areas of the nuclear power plant where fire protection features cannot ensure safe-shutdown capability,Section II.D of Appendix R to 10 CFR Part 50 requires that an alternative shutdown capability be provided. Specific design criteria and performance goals of the alternative shutdown capability are contained in Section III.G.3 and III.L of Appendix R.

GDC 3 requires that SSCs important to safety be designed and located to minimize the probability and effect of fire and explosions. It further requires that the fire-fighting systems shall be designed to assure that their rupture or inadvertent operation does not significantly impair the capability of these SSCs.

Licensees may make changes to their approved fire protection program without prior NRC approval only if those changes would not adversely affect the ability to achieve and maintain safe-shutdown in the event of a fire. This is based on the licensee having the standard fire protection license condition that was published in GL 86-10, "Implementation of Fire Protection Requirements." All changes to the fire protection plan must ensure that compliance is maintained with the requirements of 10 CFR 50.48(a).

4.2 No Significant Hazards Consideration Analysis Entergy Operations, Inc. (Entergy) has evaluated the proposed changes to the River Bend Station, Unit 1 (RBS) Renewed Facility Operating License (FOL) using the criteria in 10 CFR 50.92 and has determined that the proposed changes do not involve a significant hazards consideration.

1. Does the proposed change involve a significant increase in the probability or consequences of any accident previously evaluated?

Response: No The proposed change revises the Fire Protection Program license condition to establish consistency with a standard license condition provided by the U.S. Nuclear Regulatory Commission (NRC) in Generic Letter (GL) 86-10, "Implementation of Fire Protection Requirements." The proposed license condition is an administrative change, and does not adversely affect the Fire Protection Program, implementation of the program, or plant operation. The revised license condition is not an initiator or precursor to any accident previously evaluated. Nor does it affect the response to any accident previously evaluated.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

RBG-48054 Enclosure Page 6 of 7

2. Does the proposed change create the possibility of a new or different kind of accident from any previously evaluated?

Response: No No new or different accidents result from utilizing the proposed change. The change does not involve a physical alteration of the plant (i.e., no new or different type of equipment will be installed) or a change in the methods governing normal plant operation. In addition, the change does not impose any new or different requirements. The change does not alter assumptions made in the safety analysis.

The proposed change is consistent with the safety analysis assumptions and current plant operating practice.

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Does the proposed change involve a significant reduction in a margin of safety?

Response: No The design, operation, testing methods, and acceptance criteria for systems, structures, and components (SSCs), specified in applicable codes and standards (or alternatives approved for use by the NRC) will continue to be met as described in the plant licensing basis (including the final safety analysis report and bases to TS),

since these are not affected by the revised license condition. Similarly, there is no impact to safety analysis acceptance criteria as described in the plant licensing basis.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based upon the reasoning presented above, Entergy concludes that the requested change does not involve a significant hazards consideration as set forth in 10 CFR 50.92(c), Issuance of amendment.

4.3 Precedent This license amendment request is based on Amendment No. 273 to Renewed FOL No.

DPR-53 and Amendment No. 250 to Renewed FOL No. DPR-69 for the Calvert Cliffs Nuclear Power Plant, Unit Nos. 1 and 2 (ADAMS Accession No. ML051390039).

4.4 Conclusion In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.

RBG-48054 Enclosure Page 7 of 7 5.0 Environmental Consideration The proposed change would not change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR Part 20, and would not change an inspection or surveillance requirement. The proposed change does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed change meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed change.

Attachment:

Renewed Facility Operating License Page Markups

Attachment to Enclosure RBG-48054 Renewed Facility Operating License Page Markups



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