ML20203K276

Application for Amends to Licenses DPR-57 & NPF-5,allowing Relocation of Fire Protection Requirements Contained in Tech Specs to FSAR & Revising License Conditions Re Fire Protection.Fee Paid

ML20203K276
Person / Time
Site:	Hatch
Issue date:	07/25/1986
From:	Beckham J GEORGIA POWER CO.
To:	Muller D Office of Nuclear Reactor Regulation
Shared Package
ML20203K278	List: ML20203K276 ML20203K279
References
GL-86-10, SL-980C, TAC-62123, TAC-62124, NUDOCS 8608070141
Download: ML20203K276 (9)

Text

F Georgia Pvwer Company

. 333 P/;drnont Avenue At!anta Grega 30308 Telophone 404 526-7020 Maihng Address Post Othce Box 4545 At:anta. Georgia 30302 Georgia Power.

J. T. Beckham, Jr.

Vice Presidert and General Manager nucree Gonoranon SL-980c 0625C July 25,1986 Director of Nuclear Reactor R'egulation Attention: Mr. D. Muller, Project Director BWR Project Directorate No. 2 Division of Boiling Wate:a Reactor Licensing U. S. Nuclear Regulatory Commission Washington, D. C. 20555 NRC DOCKETS 50-321, 50-366 OPERATING LICENSES DPR-57, NPF-5 EDWIN I. HATCH NUCLEAR PLANT UNITS 1, 2 FIRE PROTECTION TECHNICAL SPECIFICATIONS AND LICENSE CONDITIONS Gentlemen:

Nuclear Regulatory Commission Generic Letter 86-10, " Implementation of Fire Protection Requirements," dated April 24, 1986, and draft Generic Letter 86-XX, " Fire Protection Technical Specifications," allow licensees to relocate fire protection requirements presently contained in the Technical Specifications to the Final Safety Analysis Report (FSAR) and to revise the license conditions related to fire protection, provided that certain specified requirements are met.

This submittal proposes changing the fire protection portions of the Technical Specifications and revising the license conditions related to fire protection for Edwin I. Hatch Nuclear Plant Units 1 and 2.

The proposed changes include:

1. Revision of the fire protection license conditions (License l Condition 2.C(3) for Unit 1 and 2.C(3)(b) for Unit 2) to provide consistency with the standard fire protection license condition contained in Generic Letter 86-10.

2. Deletion of the limiting conditions for operation and the surveillance requirements for fire protection equipment from -

Technical Specifications Chapters 3 and 4.

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GeorgiaPower A Director of Nuclear Reactor Regulation Attention: Mr. D. Muller, Project Director BWR Project Directorate No. 2 July 25,1986 Page Two

3. Deletion of the minimum fire team staffing requirement from Technical Specification 6.2.2.

4 Revision to Technical Specification 6.5.1.6 so that Plant Review Board (PRB) review is required for changes to the fire protection program and the implementing procedures.

5. Addition to Technical Specification 6.9.2 of a requirement that special reports for fire protection equipment operating and surveillance requirements be submitted to the Commission, as required by Appendix B of the Hatch Fire Hazards Analysis and Fire Protection Program, hereafter referred to as the FHA.

Revisions to the Technical Specifications are proposed to reflect the foregoing changes.

The updated FHA, which was submitted on July 22, 1986, and is incorporated by reference into the FSARs for Unit 1 and Unit 2, contains requirements replacing those that were previously included in the Unit 1 and Unit 2 Technical Specifications and addresses the fire protection items that are part of the license conditions for each unit.

Enclosure 1 provides a detailed description of each proposed change and the basis for the change.

Enclosure 2 details the bases for our determination that the proposed changes do not involve a significant hazards consideration.

Enclosure 3 provides page change instructions for incorporating the proposed changes into the Technical Specifications.

The proposed Technical Specifications pages follow Enclosure 3.

Payment of a filing fee in the amount of one hundred and fifty dollars is enclosed.

We request that the proposed amendment be issued with an effective date of November 30, 1986, the date which coincides with our NRC-required implementation date. In order to allow time for procedure revision and orderly incorporation into the Technical Specifications, we request that the amendment be issued no later than 60 days prior to that time.

0625C 700775

GeorgiaPower d Director of Nuclear Reactor Regulation Attention: Mr. D. Muller, Project Director BWR Project Directorate No. 2 July 25, 1986 Page Three Pursuant to the requirements of 10 CFR 50.91, a copy of this letter i and all applicable enclosures will be forwarded to Mr. J. L. Ledbetter of the Environmental Protection Division of the Georgia Department of Natural Resources.

Mr. J. T. Beckham, Jr. statas that he is Vice President of Georgia  ;

Power Company and is authorized to execute this oath on behalf of Georgia '

Power Company, and that to the best of his knowledge and belief, the facts set forth in this letter are true.  ;

GEORGIA POWER COMPANY By: P y J. T. Beckham, Jr. '

Sworn to and subscribed before me this 25th day of July 1986.

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Notary Public

.w.my Puohc. Croytvo Cosnt, 6eutg.c iser femmission Empires Dec 12.1989 Enclosure c: Geor[if a Power Company U.S. Nuclear Regulatory Connission Mr. t . P. O'Reilly Dr. J. N. Grace, Regional Administrator Mr. H. C. Nix, Jr. Senior Resident Inspector G0-NORMS State of Georgia Mr. J. L. Ledbetter 0625C 700775

GeorgiaPower d  !

ENCLOSURE 1 NRC DOCKETS 50-321, 50-366 OPERATING LICENSES DPR-57, NPF-5 EDWIN I. HATCH NUCLEAR PLANT UNITS 1, 2 CHANGES TO FIRE PROTECTION TECHNICAL SPECIFICATIONS AND LICENSE CONDITIONS Basis for Change Request:

Changes are proposed to ra ise the license conditions and modify the Technical Specifications associated with fire protection for the Edwin I. .

Hatch Nuclear Plant Units 1 and 2 licenses.

Proposed Change 1: To revise the fire protection license conditions (License Condition 2.C(3) for Unit 1 and 2.C(3)(b) for Unit 2) to achieve consistency with the standard fire protection license condition stated in NRC Generic Letter 86-10.

We recommend that the revised license condition for both Hatch units read as i follows:

" Georgia Power Company shall implement and maintain in effect all j provisions of the fire protection program, which is referenced in the l

Final Safety Analysis Report for the facility, as contained in the updated Edwin I. Hatch Nuclear Plant Units 1 and 2 Fire Hazards Analysis

- and Fire Protection Program, originally submitted by a letter dated July 22, 1986. The licensee may make changes to the fire protection program without prior approval of the Commission only if the changes would not l

adversely affect the ability to achieve and maintain safe shutdown in

[

the event of a fire."

l Basis for Change 1:

The present fire protection License Condition 2.C(3) for Unit 1 requires that all modifications identified in the NRC's Safety Evaluation Report (SER) dated October 4,1978, be completed. These modifications have been included in the updated Fire Hazards Analysis and Fire Protection Program, hereafter referred to as the FHA. Therefore, this requirement is no longer necessary.

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Georgia Power d ENCLOSURE 1 (Continued)

CHANGES TO FIRE PROTECTION TECHNICAL SPECIFICATIONS AND LICENSE CONDITIONS The fire protection license conditions for Unit 1 and Unit 2 presently require that the modifications which would allow the reactor to be taken to cold shutdown without reliance upon the control room or the cable spreading room be submitted to the NRC for review and approval. This requirement was superseded by 10 CFR 50.48, paragraph (c)(50), which requires that the design descriptions of modifications needed to satisfy Appendix R,Section III.G.3, be submitted to the NRC. The design descriptions were submitted,

-and NRC approval was documented in the SER dated February 11, 1983.

Therefore, this requirement is no longer necessary.

The present fire protection License Condition 2.C(3) for Unit 1 also contains a provision which allows changes to be made to the approved fire protection program without NRC approval, with the exception of changes to the NRC-approved modifications identified in the SER dated October 4,1978, provided that such changes do not result in a decrease in the effectiveness of the program. Since these modifications are included in the updated FHA, as noted above, the reference to the modifications is no longer appropriate. To standardize the license conditions and to clarify what constitutes "a decrease in the effectiveness of the program" the following change, in regard to revising the fire protection program without prior NRC approval, is proposed:

" changes that do not result in a decrease in the effectiveness of the program," would be revised to read: " changes that would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire."

The addition of this provision to the Unit 2 license is appropriate in order to achieve consistency between the two operating licenses.

As explained in Generic Letter 86-10, the new ifcense condition will permit the licensee to alter specific features of the program, provided that, for those portions of the FHA which are contained within 10 CFR 50.48 or 10 CFR 50, Appendix R, the requirements of 10 CFR 50.59 are met. Temporary changes to specific features which may be. necessary to accomplish maintenance or modifications are acceptable, provided that interim compensatory measures are met.

Proposed Change 2: To revise the Edwin I. Hatch Nuclear Plant Unit 1 and Unit 2 Technical Specifications to allow for the following:

1. Deletion of the limiting conditions for operation and the surveillance requirements relative to fire protection equipment from Technical Specifications Chapters 3 and 4.

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Georgia Powerk' h ENCLOSURE 1 (Continued)

CHANGES TO FIRE PROTECTION TECHNICAL SPECIFICATIONS AND LICENSE CONDITIONS

2. Deletion of the minimum fire team staffing requirement from Technical Specification 6.2.2.

3. Addition of a requirement to Technical Specification 6.5.1.6 which requires Plant Review Board (PRB) review of changes to the fire protection program and the implementing procedures.

4. Addition of a requirement to Technical Specification 6.9.2 which states that special reports relative to fire protection equipment operating and surveillance requirements be submitted to the Commission, as required by Appendix B of the FHA.

5. Revision of the Technical Specifications Tables of Contents, Definitions, and Bases to reflect the aforementioned changes.

Basis for Change 2:

Since the fire protection program, i. e., FHA, is included by reference in the Final Safety Reports (FSARs) for Unit 1 and Unit 2, the limiting conditions for operation and surveillance requirements relative to fire 4 protection equipment may be removed from the Techr.ical Specifications.

These operating and surveillance requirements are currently described in

. Appendix B to the updated FHA and are implemented through the written .

procedures required by Technical Specification 6.8.1.f. To achieve consistency between the Unit 1 Technical Specifications and the Unit 2 Technical Specifications and to achieve consistency between the Hatch Technical Specifications requirements and the Standard Technical Specifications requirements and National Fire Protection Association standards, as well as other minor changes identified or developed during the update of the FHA, the requirements hsyc been revised to incorporate the changes required due to Appendix R modifications.

Changes in the fire protection program Nill be made in accordance with the proposed Technical Specifications r h iirem nts related to administrative control s. Revisions to plant procentrss # 3 incorporate these changes.

Similarly, the administrative control regarding minimum fire team staffing requirements discussed in Technical Specification 6.2.2 nay also be deleted. These requirements continue to be enforced by the plant procedures required by Technical Specification 6.8.1.f.

The addition of the fire protection program to the defined responsibilities of the PRB contained in Chapter 6 of the Technical Specifications reinforces the importance of the fire protection program. Therefore, this addition is l

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GeorgiaPower d

. ENCLOSURE 1 (Continued)

, CHANGES TO FIRE PROTECTION TECHNICAL SPECIFICATIONS AND LICENSE CONDITIONS appropriate and consistent with the requirements established for similar programs, such as the Security Plan and the Emergency Plan. The change assures that a multidiscipline review of the proposed changes relative to regulatory requirements and safety is conducted by the PRB.

The addition of the special reporting requirement for fire protection equipment operating and surveillance requirements assures that continued attention will be given to these requirements and that certain deviations will be reported to the NRC. This change is in addition to the Technical Specifications changes being considered by the NRC in draft Generic Letter 86-XX, " Fire Protection Technical Specifications."

The changes to the Technical Specifications Tables of Contents, Definitions, and Bases, which reflect the abovementioned revisions, are administrative in nature.

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GeorgiaPower d ENCLOSURE 2 NRC DOCKETS 50-321, 50-366 OPERATING LICENSES DPR-57, NPF-5 EDWIN I HATCH NUCLEAR PLANT UNITS 1, 2 CHANGES TO FIRE PROTECTION TECHNICAL SPECIFICATIONS AND LICENSE CONDITIONS 10 CFR 50.92 EVALUATION Pursuant to 10 CFR 50.92, Georgia Power Company evaluated the proposed changes to the Facility Operating Licenses and the Technical Specifications for Plant Hatch Unit 1 and Unit 2 and determined that the adoption of the proposed changes would not involve a significant hazards consideration. The basis for this determination is as follows:

Proposed Changes:

1. Revise the fire protection license conditions (License Condition 2.C(3) for Unit 1 and 2.C(3)(b) for Unit 2) to provide consistency with the standard fire p'rotection license condition contained in NRC Generic Letter 86-10, Implementation of Fire Protection Requirements."

2. Relocate the fire protection operability and surveillance requirements from the Technical Specifications to the Hatch Fire Hazards Analysis and Fire Protection Program, hereafter referred to as the FHA.

3. Achieve consistency between the Technical Specifications for Unit 1 and for Unit 2 in regard to the fire protection operability and surveillance requirements.

4. Incorporate the requirements specified in 10 CFR SJ, Appendix R, for new systems and equipment relative to fire protection.

5. Delete references to the fire protection program from the Technical Specifications Tables of Contents, Bases, and Definitions.

Basis:

These changes will enhance the current fire protection requirements for Plant Hatch. The fire protection license conditions contained in the operating license for each uriit is being changed to reflect the standard license condition stated in Generic Letter 86-10. This license condition will assure that any unreviewed safety questions will be submitted to the NRC for approval.

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i GeorgiaPower d ENCLOSURE 2 (Continued)

CHANGES TO FIRE PROTECTION TECHNICAL SPECIFICATIONS AND LICENSE CONDITIONS 10 CFR 50.92 EVALUATION The fire protection requirements will be implemented by plant procedures.

In addition, any proposed changes to the fire protection program or the implementing procedures required by 10 CFR 50.48 or 10 CFR 50, Appendix R, will be reviewed by the Plant Review Board (PRB).

Achieving consistency between the fire protection requirements for each unit is an administrative change and is a logical step in that the same requirements will apply to Unit 1 and to Unit 2. Also, the incorporation of the new equipment and systems required by Appendix R should decrease the consequences of a severe fire. Both of these chances will enhance the Plant Hatch fire protection program.

Revision of the Technical Specifications Tables of Contents, Bases, and Definitions related to the fire protection Technical Specifications which are proposed for deletion is an administrative change. These items will no longer be needed in the Technical Specifications, i Georgia P- er Company reviewed the proposed changes and determined that they do not involve a significant hazards consideration for the following reasons:

(1) The proposed changes do not significantly increase the probability i or consequences of an accident previously evaluated, because no changes to safety systems or setpoints are proposed. The proposed

( changes simply relocate the fire protection requirements from the l

Technical Specifications to the FHA. New controls are also being incorporated for fire protection systems and equipment being added I to the plant in order to meet the requirements of Appendix R.

These changes will decrease the severity of the consequences of a fire.

(2) The proposed changes do not create the possibility of a new or different kind of accident from any accident previously evaluated, because these changes do not affect the operation or function of any safety-related equipment. The fire protection program I

requirements will continue to be maintained. No new modes of operation are being introduced.

(3) The proposed changes do not involve a significant reduction in a margin of safety, because the requirements previously contained in the Technical Specifications are simply being relocated to Appendix B of the FHA.

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