ML17320A277

Proposed Tech Spec 3.7.9.3 Change,Allowing for Use of Roving Fire Watch Patrol in Unoccupied Areas Affected When Automatic Carbon Dioxide Fire Suppression Sys Temporarily Isolated to Facilitate Personnel Access

ML17320A277
Person / Time
Site:	Cook
Issue date:	12/30/1982
From:	INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG
To:
Shared Package
ML17320A276	List: ML17320A275 ML17320A277
References
NUDOCS 8301040201
Download: ML17320A277 (10)

Text

O PLANT SYSTEMS LOW PRESSURE C02 SYSTEMS LIMITING CONDITION FOR OPERATION 3.7.9.3 The low pressure CO systems located in the areas shown in Table 3.7-6 shall be OPERABLE.

APPLICABILITY: Whenever equipment in the low pressure CO2 protected areas is required to be OPERABLE.,

ACTION:

With one or more of the. above required. low, pressuxe CO systems

. isolated. for personnel protection,. to permit entry for routine tours, maintenance, construction or surveillance testing,. verify the operability of the fire detection system as per Specification 4.3.3.7 in the affected areas(s) and establish a Roving Fire Watch Patrol, (as defined in the Bases Section) in those areas affected by the isolated CO system(s) which axe not occupied by workers. In the event that (he Roving Fire Watch Patrol cannot be maintained in .

the affected areas, then personne1 must be evacuated and the CO2 system returned to its normal'ondition.

With one or mora of the- above, required low pressure CO systems b.

," 'noperable, within L hour. establish a continuous fire watch with

'ackup fire suppression equipment: for those areas in.-which. redundant safe shutdown systems or. components could be damaged; for othex areas ensure that back-up fire suppression equipment is. available and establish. an hourly fire watch patrol. Restore the system to OPERABLE status within 14 days or, in lieu of any other report required. by Specification 6.9.1,. prepare and submit, a Special Report to the Commission pursuant to Specification 6.9.2 within the next 30 days outlining the action taken, the cause of the inopexability and the*plans~ and schedule for restoring the system to OPERABLE status.

c. The provisions of Specifications 3.0.3 and 3.0.4 ax'e not applicable.

SURVEILLANCE RE UIREHENTS 4.7.9.3 Each'of the'bove required low pxessure CO systems shall be demonstrated OPERABLE:

a. At least once per. 7 days by verifying the CO storage tank Level to be ~ 50% and pressure to be E 285 psig, and

b. At least once per 18 months by verifying:

1. The system, valves, associated ventilation dampers and self closing fire doors actuate manually and automatically, upon receipt.,n< .~,simulated actuation signal, and

2. Flow fxom each nozzle during a "Puff Test".

- '1 3(4 7-4V Amendment No.

P,

D. C. COOK UNIT 8301040201'21230 PDR ADOCK 05000315

~

PDR,

f Bases 3/4.7.9 FIRE SUPPRESSION SYSTEMS The OPERABILITY of the fire suppression systems ensures that adequate fire suppression capability is available to confine and extinguish fires occurring in.any portion of the facility where safety related equipment is located. The fire suppression system consists of the water system,, spray and/or spzinklers, CO , Halon and,'fix'e hose stations.. The collective capability of. the. fire suppression systems is adequate- to mizdmisa potentia3 damage to safety related equipment and is a major element in the facility fire pxotection program.

In the event that one or mora of the required low px'assure C02 systems are isolated for personnel, protection, to permit entry for routine tours, maintenance,, construction or surveillance testing, the fire detection system(s) required by specification 3.3.3.7 shall be verified to be operable and a Roving Fixe Watch Patrol established in the affected areas not occupied by workers. The Roving Fire Watch

.Patrol(s) shall consist of one or mors persons knowledgeable of the location and operation of fire fighting equipment and good fire protection/personnel safety practices such aa maintenance of access and egress. routes and personnel accountability measures. The functions of the Roving Fire Watch Patrol can be fulfilled by personnel involved in other tasks (e.g. an operator. on- tour) provided that such personnel fulfilled. the above stated. requirements, As a minimum,, each unoccupied area. affected by an isolated low pressure:CO system must be visited every twenty-five (25) to. thirty-five (35) minutes by the Roving Fire

'Watch Patrol. .Such measures will provide the necessary level of fire protection. while affording necessary provisions for personnel safety.

In the event that. portions of the fire suppression systems are inoperable, alternate backup fix'e-fighting equipment is required to be made available in the affected areas until the inoperable equipment is restored to service. When. the inoperable fire-fighting equipment ia intended for. use as a backup means of fire suppression, a longer period of time is allowed to provide an alternate means of fire-fighting than if the inoperable equipment is the primary means of fire suppx'ession.

,, The surveillance requirements provide assurance that the minimum OPERABILITY requirements of the fire suppression systems axe met. An allowance is made for ensuring a sufficient volume of Halon and C02 in the storage tanks by verifying either the weight, level, or pressure of the tanks, In the event the fire suppression water system becomes inoperable,

~ediate corrective measures must be taken since this system provides the major fire suppression capability of the plant. The requirement for a twenty-four hour report to the Commission provides foz prompt evaluation of the acceptability of the corrective measures to provide adequate fire suppression capability for the continued protection of the nuclear plant.

D. C. COOK UNIT 1 B 3/4 7-7 Amendment No.

P 3/4.7.9 FIRE SUPPRESSION SYSTEMS (Cont d)

Because of the inaccessibility of the loweer containment to personnel during operation due to,.ALARA radiation exposure concerns, the use of one or more CCTVs in the lower containment, to monitor for fire and smoke, is an acceptable substitute to an hourly fire watch, the fire suppression system becomes inoperable.

if 3/4.7.10 FIRE RATED ASSEMBLIES The OPERABILITY of the, fire barriers and barrier penetrations ensure: that fire damage will be limited. These, design features minimize the possibility of a single fire involving more than one fire area prior to detection and. extinguishment.- The fire barriers, fire barrier penetrations, for, conduits, cable trays and piping, fire dsmpers, and fire doors are periodically inspected to verify their OPERABILITY.

D. C. COOK - UNIT 1 B 3/4 7-8 Amendment No.

4 PLANT SYSTEMS r

LOW PRESSURE C02 SYSTEMS LIMITING CONDITION FOR OPERATION 3.7.9.3 The low pressure CO systems located in the ax'eas shown in Table 3.7-6 shall be OPERABLE.

APPLICABILITY: Whenever equipment in the. low pressure CO protected areas is required to be OPERABLE.

ACTION

a. With one or more of the above requixed low pressure C02 systems isolated for personnel protection, to. permit entry for routine.

tours,, maintenance, construction or surveillance testing, verify the operability of the fire detection. system as per Specification 4.3.3.8 in the affected areas(s) and establish a. Roving Fire Watch Patrol (as defined 'in the Bases Section). in those areas affected by the isolated CO system(s) which are not occupied by workers. In the. event that. the Roving Fire Watch Patrol cannot be maintained in the affected areas, then personnel must be evacuated and the CO2

- system xeturned to its normal condition; b.. With one or. more of the above requix'ed. low pressux'e CO systems inoperable, within 1. hour establish, a continuous. fire watch with backup fire. suppression. equipment. for 'those areas in which redundant safe shutdown systems or components could. be damaged; f'r other areas ensure that. back-up fire suppression equipment is available

-and establish an hourly .fire watch patxol. Restore the system to OPERABLE. status within 14 days oz,. in lieu of any other report required by Specification 6.9,1, prepare and submit a Special Report

. to the Commission pursuant to Specification 6..9.2 within the next 30 days outlining the action taken, the cause of the inoperability and the plans and schedule for restoring the system to OPERABLE status.

c.. The provisions of Specifications 3.0.3 and 3.0.4 axe not applicable.

SURVEILLANCE REQUIREMENTS 4.7.9.3 Each of the above required. low pressure CO systems shall be demonstrated OPERABLE:

a. At least once- per 7 days by vexifying the CO storage tank level to be ~ 50% and pressure,to be ~ 285 psig, and

b. At least once per 18 months by verifying:

1. The system valves, associated ventilation dampers and self closing fire doors actuate manually and automatically, upon receipt of a simulated actuation signal, -and

2. Flow from each nozzle duxing a "Puff Test".

D. C. COOK UNIT 2 3/4 7-42 Amendment No.

PLANT SYSTEMS BASES 3/4.7.8 SEALED SOURCE CONTAMINATION The limitations on removable contamination for sources requiring.

leak testing, including alpha emitters, is based on 10 CFR 70,39(c) limits for plutonium.. This limitation wiLl ensure that. leakage from byproduct,, source, and,special nuclear-material sources will not exceed allowable intake values.

3/4.7.9 FIRE SUPPRESSION SYSTEMS The OPERABILITY of the fize suppression systems ensures that adequate fixe suppression capability is available to confine and extinguish fires occurring in any portion of the facility where safety related equipment is located. The fire suppxession system consists of the water system, spray and/ox" spzinklers, CO , Halon and fire hose stations, The collective capability of, the- fkze. suppression systems is adequate to minimizepotential damage to safety related equipment and is a ma)or element in the facility fixe protection progxam.

In the event that one or more of the requized low pxessuze C02 systems are isolated foz personnel protection, to permit entry for routine tours, maintenance, construction or surveillance testing, the fire detection system(s) required by specification 3.3.3.8 shall be verified to be opex'able and a Roving Fire Watch Patrol established in the affected areas not occupied by workers;. The Roving Fix'e Watch Patrol(s) shall. consist of one or more persons knowledgeable of the location and operation of fire fighting equipment and good fixe protection/personnel safety practices such as maintenance of access and egress routes and personnel accountability measures. The functions of the Roving Fire Watch Patrol can. be fulfilled by personnel involved in other tasks (e.g. an operator on tour) provided that such personnel fulfilled the above stated requirements. As a minimum,, each unoccupied area affected by an isolated low pressure CO system must be visited every twenty-five (25) to thirty-five (35) minutes by the Roving Fix'e Watch Patrol. Such measures will provide the necessary level of fire protection while affording necessary provisions for personnel safety.

In the event that portions of the fire suppression systems are inoperable, alternate backup fire fighting equipment is required to be made available in the affected areas until the inopexable equipment is restored to service. When the inoperable fire-fighting equipment is intended for use -~'~"'a'ackup means of fire suppression, a longer period of tMe is allowed to provide an alternate means of fire fighting than if the inoperable equipment is'the primary means of fire suppression.

D. C. COOK UNIT 2 B 3/4 7-6 Amendmen't No.

PLANT SYSTEMS 3/4.7.9 FIRE SUPPRESSION SYSTEMS (Cont'd)

The surveillance requirements provide assurance that the minimum OPERABILITY requirements of the fire suppression systems are met. An allowance is made for ensuring a sufficient volume of Halon and C02 in the storage tanks by verifying either the weight, level, or pressure of the tanks.

In the event. the fire: suppression water system becomes. inoperable, immediate corrective measures must.'e taken since this system provides the ma)or fire suppression. capability of the plant. The requirement for a twenty-four hour. report to the Commission provides for prompt evaluation of the acceptability of the corrective measux'es to provide adequate fire suppression capability for the continued protection of the nuclear plant.

Because of the inaccessibility of the lower containment to personnel during operation due to ALARA radiation exposure concerns,.

the use of one, or more CCTVS in the lower containment to monitor for fire and smoke, is an acceptable substitute to a continuous fire watch, if the fire suppression system becomes inopexable.

3/4.7.10 FIRE RATED ASSEMBLIES The OPERABILITY of the fire barriers and barrier penetrations ensure that fire damage will be limited. These design features minimize the possibility of a single fire involving more then one fire area prior to detection. and extinguishment.. The fire bax'riers, fix'e barrier penetrations for conduits, cable tx'ays and piping, fire dampers, and fire doors axe periodically inspected to verify. their OPERABILITY.

D. C. COOK UNIT 2 B 3/4 7-7 Amendment No.

0 l l