ML18054A874
| ML18054A874 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 07/31/1989 |
| From: | Berry K CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML18054A875 | List: |
| References | |
| GL-86-10, GL-88-12, TAC-73819, NUDOCS 8908030246 | |
| Download: ML18054A874 (2) | |
Text
'(
. (
consumers Power POWERINli
_ lllllCHl&AN'S PIUl&RESS General Offices:
1945 West Parnall Road;Jackson, Ml 49201 * (517) 788-1636 July 31, 1989 Nuclear Regulatory Commission_
Document-Control Desk Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT -
Kenneth *w Berry Director Nuclear Licensing PROPOSE~ LICENSE AND TECHNICAL SPECIFICATION CHANGE REQUEST - FIRE PROTECTION (TAC NO. 73819)
This change requests the revision of li~ense_condition 3.E and the removal of the fire protection technical specifications *. The proposed revision to the License condition is included in Attachment 1.
The proposed changed technical specification pages are enclosed in Attachment 2.
Generic letters 86-10 and 88-12 provide guidance for the license to request an amendment to delete the fire protection technical specifications.
This guidance requires that the fire protection program be included by reference in the Final Safety Analyses Report (FSAR) update and the operating license be amended to substitute the standard license condition for fire protection.
Therefore, in accordance with t~is guidance, Consumers Power proposes a revision to license condition 3.E to make it similar to that presented in the Generic Letters.
Regarding the Palisades FSAR update, Attachment 3 is the proposed update and it incorporates the former technical specification requirements and will also include by reference the Fire Protection Program Report (FPPR) and major commitments. is the Fire Protection Program Report.
This report contains the Fire Protection Plan, Fire Hazards Analysis, Safe Shutdown Analysis, and indices for the Appendix R Exemptions, Safety Evaluation Reports and Engineering Analyses.
Existing-Plant procedures and Administrative Controls, which insure implementation -
of the present Technical Specification Requirements, will remain in effect.
These controls require the periodic verification of the fire protection system operability.
If any portion of the fire protection system becomes inoperable, the administrative procedures will require appropriate actions be implemented similar to those currently required by the Technical Specifications to restore equipment to operable status and initiate fire watches or alternate methods of fire protection OC0789-0001-NL02 8908030246 890731 PDR ADOCK 05000255 1
-J P
~
~ Nuclear Regulatory Commission Palisades Plant License & TSCR - Fire Protection
. July 31, 1989 2
As discussed above, the proposed revision to License Condition 3.E provides controls for maintaining and revising the approved Fire Protection Program.
These controls, combined with the effective General Surveillance Program, will ensure that the requirements of the Fire Protection Program are effectively implemented once the Fire protection Technical Specifications are removed.
Removing the fire protection requirements from the Technical Specifications does not affect Consumers Power's commitment to adhere to 10CFR50 Appendix R as required by the Palisades Fire Protection Program Report.
Surveillances consistent with those currently required by the Technical Specifications will be required to be performed to meet the requirements of the Fire Protection Program which is based on the Fire Protection Program Report.
Without formal Technical Specifications, fire protection activities will continue to be implemented similar to current practice.
In addition, the fire protection system is classified as reliability related and as such, the Quality Assurance Department also audits the fire protection activities to ensure compliance.
The NRC has recommended a Technical Specification Improve~ent Program aimed at reducing the requirements of the Technical Specifications.
The objective of the program is to remove those Technical Specifications which do not directly affect the safe operation of the plant and can be effectively maintained through an administrative program.
Moving the Fire Protection Technical Specifications to the FSAR is consistent with the criteria established for the Technical Specification Improvement Program in that these systems are not part of Design Basis Accident mitigation.
Relocation of these requirements will not detract fro~ Consumers Power's ability to maintain the required level of fire protection.
Consumers Power believes that this request is consistent with the NRC's ongoing goals for Technical Specification improvements.
Consumers Power Company anticipates that the proposed Technical Specif icaton Change submitted September 23, 1988 which transfers the responsibilities of the Nuclear Safety Board (NSB) to the Nuclear Safety Services Department (NSSD) will be issued before this proposed change is issued.
Therefore, the attached proposed page changes will exist after the September 23, 1988 submittal is issued.
In addition, Consumers Power Company will not make the proposed changes effective until (120) days after approval is received~ This will provide time to update the FSAR and make the procedure revisions necessary to implement the administrative program.
Kenneth W Berry Director, Nuclear Licensing CC Administrator, Region III, USNRC NRC Resident Inspector - Palisades Attachment OC0789-0001-NL02