JPN-91-068, Proposed Tech Specs,Revising Actions for TS 3.12.F.1.b Re Fire Watches

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Proposed Tech Specs,Revising Actions for TS 3.12.F.1.b Re Fire Watches
ML20086Q479
Person / Time
Site: FitzPatrick Constellation icon.png
Issue date: 12/19/1991
From:
POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
To:
Shared Package
ML20086Q467 List:
References
JPN-91-068, JPN-91-68, NUDOCS 9112300219
Download: ML20086Q479 (12)
v • d • e


Text

- R JAFNPP ,

2. If the CO2 protection for the areas Lsted in Table 3.122 cannot be restored to an operable siatus within 14 days a written report to the Commission outlining the action taken, the cause of inoperability, and plans and schedule to restore the system to an operable status shall be prepared and submitted within 30 days.

D. Manual Fire Hose Stations D. Manual Rre Hose Stations

1. a. The manual fire hose stations listed in Table 3.12.3 1. The manual fire hose stations are inspected as listed in

. shall be operable except as specified be!cw: Table 4.12.3.

b. Frcm and after the date that any of the manual fire hose stations listed in Table 3.12.3 is made or found

, to be inoperable, additional hose lengths shall be added to adjacAnt operable manual hose stations such that the enure area of protection is maintained within one hour.

E. Fire Protection Systems Smoke t 1 Heat Detectors E. Fire Protection Systems Smoke and M at Detectors

1. a. Fire protection systems smoke and/or heat 1. A channel functional test of smoke and heet detectors and detectors in each protected area as designated in associated circuitry shan be oerformed every 6 months.

Tables 3.12.1 and 3.122 shall be operable except as This test includes operabiFif of valves associated with the specified below- detectors and verifying that the automatic valves in the flow path actuate to their correct posi*Jons.

b. From and after the date that mcre than one smoke and/or heat detector in each prctccted area is found or made inoperable within one hour an hourly patrolling fire watch sha!! be established.

AnWndment No. ,

244f 9112300219 911219 PDR ADOCV 05000333 P PDR

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JAFNPP ,

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2. . lf the fire protection systems smoke and/or heat detectors in Tables 3.12.1 and 3.12.2 cannot be restored to an operable status within 14 days, a written repcri to the

! Comrnission outlining the action taken, the cause of

inoperability and p!ans and schedule for restoring the detectors to an operable status sha'l be prepared and

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. submitted within 30 days. j F. Fire Barrier Penetration Seals F. Fire Barrier Penetration Seals

1. All fire barrier penetrations, including cable penetration 1. All fire barrier penetration seals for each protected area l ,

barriers,' fire . doors and fire dampers, in fire zone

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shall be visually inspected .once/1.5 years to verify - ,

boundaries protecting - safety related areas shall be functional integnty. For those fire barrier-penetrations that functional. are not in the as-designed conditKm, an evaluation shall be ,

performed to show that the rnoddication has not degraded the fire rating of the fire bamer penetration.

j 2. With one or more of the required fire barrier penetrations 2. Any repair of fire barrier penetration seals shall be followed l

non-functional, within one hour es'ablish a continuous fire try a visualinspection. -

! watch on at least one side of the affected penetration or verify,the operability of fire detectors on at least onc side of ,

. the non-functional fire barrier and establish an hourly _ fire watch patrol. .Restore the non-functional fire barrier penetration (s) to functional status within 7 days or, in lieu

of any other report required by Specification 6.9.A, prepare
j. and submit a Special Report to the Commission pursuant -

to Specification 6.9.B within 30 days outlining the action -

l taken, the cause of the non-functional penetration and plans and schedule -for restoring the fire . barrier penetration (s) to functional status. .j E44g l

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JAFNPP ,

3.12 and 4.12 BASES i The Fire Protection System specifications provide pre-established B. Safety related equipment areas protected by water spray or minimum levels of operabil'y.to assure adequate fire protection during sprinklers are listed in Table 3.12.1. V#ienever any of the any operating condition including a design basis accidert or safe protected areas, spray or sprinklers are inoperable continuous shutdown earthquake. fire detection and backup fire protection equipment is available in the area where the water spray and/or sprinkler protection A. The high pressure water fire protection system is supplied by was lost. '

redundant vertical turbine pumps, one diesel driven and one electric motor driven, each design rated 2500 gpm at 125 psig Performance of the tests and inspections listed in Table 4.12.1 discharge pressure. Both pumps take suction from the plant will prevent and detect nozzle blockage or breakage and verify insure. Both pumps take suction from the plant intake cooling header integrity to ensure operability. '

water structures from Lake Ontario. The high pressure water fire ,

protection header is normally maintained at greater than 115 C. The carbon dioxide systems provide total flood protection for psig by a pressure maintenance ' subsystem. If pressure eight different safety reisted areas of the plant from either a 3 ton -

decreases, the fire pumps are automatically started by their or 10 ton storage unit as indicated in Table 3.122. Both CO2 initiation logic-to maintain the fire protection system header storage units are equipped with mechanical refrigeration units to pressure. Each pump, together with its manual and automatic maintain the storage tank content at 0*F with a resultant pressure initiation logic combined makes up a redundant high pressure of 300 psig. Automatic smoke and heat detectors are provided water fire pump. in the CO2 protected areas and initiation is automatic and/or manual as indicated in Table 3.12.2. For any area in which the A third fire pump, diesel-driven, has been installed and is set to CO2 protection is made or found to be inoperable, continuous -

automatically Lactuate upon decreasing . pressure after the fire detection is ava%bie and one or more large wheeled CO2 actuation of the first two fire pumps. No credit is taken for this fire extinguisher is a% available for each area in which pump in any analyses and the requirements of Technical protection was lost.

Specifications 3.12 and 4.12 do not apply. . .

Weekly c'iecks of storage tank pressure and level verify proper Pressure Maintenance subsystem checks, valve position checks, operation of the tank refrigeration units and availabirrty of .

system flushes and comprehensive pump and system flow- sufficient voteme of CO 2 to extinguish a fire in arry of the and/or performance tests including logic and starting subsystem protected areas. ,

tests provide for the early detection and correction of component -

failures thus ensuring high levels of operability.

1 Amendment No. 1 244h e i

JAFNPP ,

3.12 and 4.12 BASES (continued)

Performance of the periodic tests and inspections listed in Table Testing of smoke and heat detectors and associated circuitry 4.12.2 are in accordance with NFPA-12,1973, will verify the every 6 months, in accordance with manufacturers and NFPA integrity of system nozzles and distribution headers as well as 72E-1974 recommendations ensures a high level of operability.

detect and remove any accumulation of rust or scale. The use of

' puff test" rather than full flow tests will demonstrate proper valve F. The functional integrity of the fire barrier penetrations ensure that operation without .the attendant potential equipment and fire will be confined or adequately retardud from spreading to personnel hazards associated with full flow tests. adjacent portion of the facility. This design feature minimizes the possibility of a single fire rapidly involving several areas of the D. Manual hose statione provide backup fire protection throughout facility prior to detection and extinguishment. The fire barrier the Plant. Those hose stations that are in or near areas with penetrations are a passive element in the facility fire protection safety related equipment are listed in Table 3.12.3. Hose station program and are subject to periodic inspections.

location and hose length se!ection provides the capability of reacning any fire in a safety related area with the hose stream. The barrier penetrations, including cable penetratiori barriers, fire "

When any of the hose stations listed in Table 3.12.3 is doors and dampers are considered functional when the visually.'

inoperable, providing additional hose lengths from other observed condition is the same as the as-designed condition.

operable hose stations assures maintenance of this capability.

Periodic inspection and tests are in accordance with NFPA Code During periods of time when the barriers are not functicnal, guidelines and assures prevention, detection and correction cf either,1) a continuous fire watch is required to be maintained in hose, nozzle, valve and/or gasket damage or deterioration to the vicinity of the affected barrier, or 2) the fire detectors on at maintain high levels of operability. least one side of the affected barrier must be verified operable and a hourly fire watch patrol established until the barrier is '

E. Early. fire detection - and fire fighting activity is essential to restored to functional status.

ensuring that any fire will result in minimum damage to safety related equipment. Since each area monitored utilizes a number of smoke and/or heat detectors when more than one detector is inoperable, early fire detection is assured by establishing a patrolling fire watch which check the area where the detectors are inoperable at least hourly.

Amendment No. ,1 ,

244, i

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(B) SPECIAL REPORTS

, 1. Fiftoon copics of the Evaluction Report of the results of the first fivo years of l performance of the non-destructive inspection listed in Tablo 4.6-1 of Technical Specifications 4.6.F. Structural Integrity, relating to tho FitzPatrick in-service inspection program shall be submitted to the NRC, Director of '

Operating Roactors, within three months of the completion of the fifth year of the program.

2. Special reports relating to firo protection equipment and systems shall bo submitted to the NRC in acccrdance with Specifications 3.12.A.1.c, 3.12. A.1.d.2, 3.12.B .2, 3.12.C.2, 3.12.E.2, and 3.12.F.2. l 6.10 RECORD RETL'NTION (A) The following records shall be retained for at least five years:
1. Records and logs of facility operation covering timo intervals at cach power level.
2. Records and logs of principal maintenance activitics, inspections, repair and replacement of principalitems of equipment related to nuclear safety.
3. All Roportable Events.
4. Records of surveillance activities, inspections and calibrations required by thoso Technical Specifications.
5. Records of reactor tests and experiments.
6. Records of changes made to Operating Procedures.
7. Records of radioactive shipments.
8. Records of scaled sourco leak tests and results.
9. Records of annual physicalinventory of all source material of record.

Amendment No. ,

. Attachmont 11 to JPN 91068 ,

l SAFETY EVALUATION FOR PROPOSED TECHNICAL SPECIFICATION CHANGES FIRE BARRIER PENETRATION (JPTS-91-028)

1. DESCRIPTION OF THE PROPOSED CHANGES -

The proposed changes to the James A. FitzPatrick Technical Specifications are as follows:

Pago 244f, SpocFications 3.12.E and 4.12.E Delete the words *C. Carbon Dioxide Systems (Cont'd)" from the top of the left column.

Movo Specif; cation 3.12.E.1 from page 244g to the bottom of the left column.

Move Specification 4.12.E.1 from pago 244g to the bottom of the right column.

Page 244g, opecifications 3.12.F and 4.12.F D01010 the contents of Specification 3.12.F.1.a and replace with:

'All fire barrier penetrations, including cable penetration barriors, fire doors and fire dampers, in fire zone boundaries protecting safety related areas shall be functional."

Deleto the contents of Specification 3.12.F.1.b and replace with:

"With one or more of the required fire barrier penetrations non-functional, within one -

hour establish a continuous fire watch on at least one side of the affected penetration or verify the operability of fire detectors on at least one side of the non-functional fire barrier and establish an hourly fire watch patrol. Restore the non functional fire barrior penetration (s) to functional status within 7 da,e or, in lieu of any other report required -

by Specification 6.9 A, prepare and submit a Special Report to the Commission pursuant to Specification 6.9.B within 30 days outlining the action taken, the cause of the non-functional penetration and plans and schedule for restoring the fire barrier penetration (s) to functional status."

Renumber Specifications 3.12.F.1.a and 3.12.F.1.b as 3.12.F.1 and 3.12.F.2, respectively.

Add to the end of Specification 4.12.F.1.a the following sontonce:

"For those fire barrier-penetrations that are not in the as designed condition, an evaluation shall be performed to show that the modification has not degraded the fire rating of the fire barrier penetration."

Ronumber Specifications 4.12.F.1.a and 4.12.F.1.b as 4.12.F.1 and 4.12.F.2, respcctively.

m. .,

Attachment ll to JPN 91-0G8 SAFETY EVALUATION Pago 2 of 6 Page 244h, Bases 3.12 and 4.12 C Move from page 2441 the first two paragraphs of Bases Section 3.12 and 4.12 C and insert at the end of the right column.

Page 2441, Bases 3.12 and 4.12 F Doloto the contents of Bases Section 3.12 and 4.12 F and replace with:

"The functional integrity of the fire barrior penetrations ensure that firo will be confined or adoquately retarded from spreading to adjacent portion of the facility. This design feature minimizes the possibility of a single fire rapidly involving several areas of the <

facility prior to detection and extinguishment. The fire barrier penetrations are a passive element in the facility fire protection program and are subject to periodic inspections.

The barrier penetrations, including cable penetration barriers, fire doors and dampors aro considered functional when the visually observed condition is the same as the as.

designed condition.

During periods of time when the barriers are not functional, either,1) a continuous fire watch is required to be maintained in the vicinity of the affected barrier, or 2) the fire detectors on at least one sido of the affected barrior must be verified operablo and a hourly firo watch patrol established until the barrier is restored to functional status."

Page 254g, Specnication 6.9.B Replace the words:

.. 3.12.C.2 and 3.12.E.2."

with the new words:

. 3.12.C.2,3.12.E.2, and 3.12.F.2."

11. PURPOSE OF THE PROPOSED CHANGES The proposed changes to the James A. FitzPatrick Technical 9pecifications reviso the Limiting Conditions for Operation (LCO) requiring a continuous fir, ~atch when a fire barrier penetration seal is determined to be or made non-functional. The changes adopt the LCO's, action statements, and Bases for fire barrier penetration seals as prescribed in the NRC's Standard Technical Specifications (Reference 3). The Standard Technical Specifications (STS) provide an alternative to the continuous fire watch and clarifies which fire barriers are covered by this LCO. A minor difference between this submittal and the STS is the moving of a sentence from the STS's Bases Section to the Surveillanco Requiremonts of this Technical Specification. This relocation

Attachment il to JPN-91-068 SAFETY EVALUATION Pago 3 of 6 provides 6 more appropriato location for the requirement of ovaluating those ponctration seals that are not in tho as designed condition.

At an August 2,1991 mooting with the NRC's Rogion I staff, the New York Power Authority committed to completo a full baseline barrior seal inspection not lator than 30 days after startup from the 1993 refuel outago (Reference 4). This scheduto superseded an earlier Authority commitment (Rcforence 5) for baseline inspectiors mado in response to an NRC notico of violaton.

Technical Specification 3.12.F.1.b requires that the Authority post within one hour a continuous fire watch at each fire barrior whero a ponotration seal has boon declared non-functional.

Approximately twenty cight firo watches are currently in place.

Need For Prompt Action As of December 18,1991, approximately 1812 ponotrations at FitzPatrick have been inspected under this program. This represents approximately 26 percent of the approximately 7,000 penetration seals at FitzPatrick. Engincoring ovaluations have boon completed for 1617 of the penetrations inspected. One thousand, one hundred and forty six of 'hese mect the new acceptanco criteria. One hundred and fifty five of those penetrations did not meet the new acceptance critoria but not to the extent that they were declared inoperable. Three hundred sixteen of those ponctrations did not moot the new acceptance critoria and werc declared inoperable. This represents a significantly higher failuro rate than anticipated by the Authority.

As more fire barrior penetration seals are declared non functions l, additional personnel will be required to stand continuous firo watch. Because some of these penetrations are in radiation and high radiation areas, the posting of continuous fire watches (as opposed to hourly roving watchos) would incur unnecessary personnel exposures. This is poor practice from an ALARA standpoint.

Where permissible by the standaro technical specifications action statement, the use of roving houriy fire patrols would reduce the total number of individua's required. This would also reduce the anticipated personnel exposure, in accordance with established ALARA principles, by removing the need for a continuous fire watch in iadiction areas. The use of roving fire patrols would provide an estimated reduction 11 personnel exposure of approximately 20 man-rems.

lli. SAFETY IMPLICATIONS OF THE PROPOSED CilANGES Firo barrier penetration seals provide protection for equipment required to mitigate accidents and perform other safety related functions. The Authority has committed to complete a full baseline fire barrier scal inspection. To qualify these inspections as a baseline for future inspections, a moro detailed procedure, then previously used, was impicmented along with new acceptanco critoria. The higher than anticipated failure rato of fire barrior penetration seals requires significant plant resources (i.e., plant personnel) in fulfilling Technical Specification requirements.

These proposed changes, taken from the Standard Technical Specifications, allow the use of roving hourly fire patrols supplementing functional fire detectors. The compensatory actions prescribed in the Standard Technical Specifications have been found by the NRC staff to

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Attachment ll to JPN 91068 SAFETY EVALUATION .

Page 4 of 6 constitute an acceptable alternative to functional fire barrier penetration seals. This proposed

- change will have an insignificant affect on the ability of the plant staff and fire protection systems .-

to detect and extinguish a postulated fire in the vicinity of the non-functional barrier A functional "

fire detection system on one side of the barrier plus an hourly fire patrol or a continuous fire watch constitutes an equivalent level of protection. The use of an hourly fire patrol would reduce the total number of individuals required for fulfilling Technical Specification requirements.

Other existing fire protection systems and features will further assure that a fire in the vicinity of a non. functional fire barrier penetration seal will be promptly detected and extinguished. These include:

. Automatic suppression and/or detection systems are installed in some fire hazard areas including carbon dioxide systems, halon and water sprays.

. Manual hose stations are installed throughout the plant.

. A trained fire brigade is on site to respond to a fire.

. A local fire department is available to respond to a fire.

. Portable extinguishers are installed throughout the plant.

. Fire protection systems are periodically tested to assure that they are capable of performing their intended function.

. Fire barriers separate safety-related components and reduce the potential for the spread of fire between fire areas or zones.

. An alternate safe shutdown panel, procedures and operator training will assure that the plant can be safely shutdown and maintained in a shutdown condition.

. The physical integrity of structural steel is assured by fire proof coatings.

. Emergency lighting and communication systems have been installed.

IV, EVALUATION OF SIGNIFICANT HAZARDS CONSIDERATION Operation of the FitzPatrick plant in accordance with the proposed Amendment would not involve a significant hazards consideration as defined in 10 CFR 50.92, since it would not:

1. involve a significant increase in the probability or consequences of an accident previously evaluated.-

The proposed changes involve no' hardware changes, no changes to the functions of the fire barrier penetration seals or the fire barriers, and does not change the ability of -

fire protection equipment to perform its intended functions.' The compensatory -

actions impicmented by the Authority constitute a level of protection equivalent to that

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Attachment 11 to JPN 91-068 SAFETY EVALUATION -

Page 5 of 6 '

required in the existing FitzPatrick Technical Specifications and identical to that previously accepted by the NRC staff.

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2. create the possibility of a new or different kind of accident from those previously evaluated.

The proposed changes involve no hardware changes, no changes to the functions of the fire barrier penetration seals or the fire barriers, and do not change the ability of fire protection equipment to perform its Intended functions. These changes will not introduce any new fire hazards. A functional fire detection system on one side of the

, barrier plus an hourly fire patrol or a continuous 9e watch constitutes an equivalent -

level of protection.

3. involve a significant reduction in the margin of safety.

The proposed changes involve no hardware changes, no changes to the functions of the fire barrier penetration seals or the fire barriers, and does not change the ability of fire protection equipment to perform its intended functions. The probability of a fire -

will not be increased nor will the ability of the fire detection and suppression systems to detect and extinguish a fire be degraded as a result of these changes.

V. IMPLEMENTATION OF THE PROPOSED CHANGES Because some of the penetrations are in radiation areas, the posting of a continuous fire watch (as opposed to hourly roving fire patrols) would incur unnecessary personnel exposures, and be a poor implementation of ALARA princip!9s The results of these changes will reduce the dose to plant personnel since the number of continuous fire watches in radiation areas will be reduced.

The proposed changes will not alter the Fire Protection program or affect the environment.

VI. CONCLUSION These changes, as proposed, do not constitute an unreviewed safety question. as defined in 10 CFR 50.59. That is, thay:

1. will not increase the probability of occurrence or the consequences of an accident or -

i malfunction of equipment lt portant to cafety previously eva!uated in the safety analysis report;

2. - will not increase the possibility for an accident or malfunction of a type different from any evaluated previously in the safety analysis report;
3. will not reduce the margin of safety as defined in the basis for any technical specification; and

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Attachmont il to JPN 91068 SAFETY EVALUATION Pago 6 of 6

4. involves no significant hazards consideration, as defined in 10 CFR 50.92, Vll. REFERENCES
1. James A. FitzPatrick Nuclear Power Plant Updated Final Safety Analysis Report, Section 9.8.
2. James A. FitzPatrick Nuclear Power Plant Safety Evaluation Report (SER), dated November 20,1972, and Supplements.
3. NUREG-0123, " Standard Technical Specifications for General Electric Bolling Water Reactors (BWR/5)," Revision 3, Section 3/4.7.8, dated Fall 1980.
4. NYPA lotter, R.E. Beedio to U.S. NRC, dated September 13,1991, (JPN-91-050),

regarding schedule for long term fire protection actions.

5. NYPA letter, W. Fernandez to U.S. NRC, dated June 14,1991, (JAFP-91-0359),

regarding respor.so to Notice of Violation, Inspection Report 50-333/90-09.

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