ML18153C847

Proposed Tech Spec 3.21-2 Re Operability of Halon Sys for Emergency Switchgear Rooms

ML18153C847
Person / Time
Site:	Surry
Issue date:	12/19/1991
From:	VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:
Shared Package
ML18153C846	List: ML18153C845 ML18153C847
References
NUDOCS 9112270033
Download: ML18153C847 (7)

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ATTACHMENT 1 SURRY POWER STATION PROPOSED TECHNICAL SPECIFICATION CHANGE RECORDS VAULT FIRE SUPPRESSION SYSTEM

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TS 3.21-2

3. Spray and Sprinkler System - that provide protection for the cable tunnel and cable vault shall be operable

4. Low Pressure CO2 Storage Tank - shall be operable with a minimum level of 75% and a minimum pressure of 275 psig.

5. Low Pressure CO2 System - shall be operable to the extent that when equipment in the below listed areas is required to be operable, fire suppression can be provided upon demand.

a. Cable tray rooms

b. Cable tunnels

c. Cable vau Its

d. Safety related charcoal filter banks 3A and 38

e. Emergency diesel generator rooms

6. High Pressure CO2 System - shall be operable to the extend that when equipment in the below listed areas is required to be operable, fire suppression can be provided upon demand. The minimum level of High Pressure CO2 system shall be 90% by weight.

a. Fuel oil storage tank room for emergency service water pumps

b. Fuel oil transfer pump rooms for emergency diesel generators

7. Halon Systems - shall be operable for the Emergency Switchgear I Rooms. The storage tanks shall be at least 95% of full charge weight and 90% of full charge pressure.

8. Fire Hose Stations - the hose stations listed in Table 3.21-2 shall be operable when equipment in the areas served by the hose stations is required to be operable.

ATTACHMENT 2 SURRY POWER STATION PROPOSED TECHNICAL SPECIFICATION CHANGE RECORDS VAULT FIRE SUPPRESSION SYSTEM I

SIGNIFICANT HAZARDS CONSIDERATION

DISCUSSION OF CHANGE Introduction Surry Power Station is building an Administration building which will contain a records vault for the station's records. The new records vault will be protected from fire by a sprinkler system. The existing plant records vault in the South Annex Building is protected by a Halon fire suppression system. Operability requirements for this Halon fire suppression system are included in Technical Specifications.

Background

In 1976, the NRC provided sample fire protection Technical Specifications for guidance to the licensees to incorporate their fire protection systems into the Technical Specifications. Surry proposed fire protection Technical Specifications in accordance with the NRC guidance and these requirements were incorporated into the Technical Specifications by amendment in 1977. At that time the only Halon system at the site was in the South Annex records vault. Although this system is not required for plant safety, the proposed Technical Specifications included a Limiting Condition for Operation and surveillance requirements for the Records Vault Halon fire suppression system.

In order to use the new records vault without violating the Technical Specification requirement for an operable Halon fire suppression system in the station's record vault, the Technical Specifications must be modified.

Technical Specification Change The station records vault fire suppression does not protect safety-related equipment.

Therefore, the proposed Technical Specification will eliminate the operability requirements for this Halon fire suppression system. In addition, operability requirements for the Halon fire suppression systems for the Emergency Switchgear (ESGR) Rooms are being included. Thus, Section 3.21.A.7 is being changed to read, "Halon Systems - shall be operable for the Emergency Switchgear Rooms. The storage tanks shall be at least 95% of full charge weight and 90% of full charge pressure."

Because there is no safety impact associated with the records vault fire suppression system, operability requirements for the new records vault, which is located outside of the security fence (protected area), are not being included into the Technical Specification. The new records vault will continue to meet the requirements of Regulatory Guide 1.88, "Collection, Storage and Maintenance of Nuclear Power Plant Quality Assurance Records," which endorses ANSI standard N45.2.9-1974.

Safety Significance Eliminating the records vault fire suppression system operability from the Technical Specifications does not create any unreviewed safety question. There is no increase in the probability of occurrence or consequences of an accident previously evaluated, nor does it create the possibility of a new or different kind of accident from any accident previously evaluated or involve a significant reduction in a margin of safety. Moving the records vault and eliminating the operability requirements for the records vaults has no impact on plant safety.

e 10 CFR 50.92 SIGNIFICANT HAZARDS CONSIDERATION REVIEW Virginia Electric and Power Company has reviewed the proposed Technical Specification change against the criteria of 10 CFR 50.92 and has concluded that the Technical Specification change as proposed does not pose a significant hazards consideration. The station's record vault is being shifted from its existing location to the new administration building. The new records vault will have a water-sprinkler fire suppression system. The fire suppression system for the records vault has no plant safety significance. Therefore it should not have been originally included in the Technical Specifications. Inclusion of the Emergency Switchgear Room (ESGR) fire suppression system represents an additional *limitation, restriction or control not presently in Technical Specifications" and meets example (ii) of amendments not likely to involve a significant hazard consideration (Federal Register Vol 51, No. 44 of March 6, 1986). Therefore, removal of the operability requirement for the Halon fire suppression system for the existing records vault and inclusion of operability requirements for the ESGR fire suppression system will not:

1. Involve a significant increase in the probability of occurrence or consequences of an accident previously evaluated. The station's record vault does not interface with or effect the operation of any plant system. The ESGR fire suppression system is required to be operable in accordance with the approved Appendix R Program.

Elimination of the operability requirement for the station's record vault fire suppression system and establishing requirements for the existing ESGR fire suppression system does not change or effect the probability or consequences of any previously evaluated accident.

2. Create the possibility of a new or different kind of accident from any accident previously evaluated. The station's record vault and its fire suppression system do not interface with or effect the operation of any plant system. Specifying requirements for the ESGR fire suppression system merely adds appropriate requirements to the Technical Specifications for an existing system. Therefore, a new or different accident from those previously evaluated has not been created.

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3. Involve a significant reduction in a margin of safety. Removing the operability requirements for the station's records vault and and in.eluding the operability for the ESGR fire suppression system does not effect any accident analysis assumption. Therefore, the margin of safety is not significantly reduced by the proposed change.