ML19305D905

Responds to NRC 800121 Ltr Re Violation Noted in IE Insp Rept 50-293/79-21.Corrective Actions:Fire Protection Operating Procedures Will Be Revised to Implement Requirements Re Tech Specs 6.8.D,3.12 & 4.12

ML19305D905
Person / Time
Site:	Pilgrim
Issue date:	02/29/1980
From:	Andognini G BOSTON EDISON CO.
To:	Brunner E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML19305D902	List: ML19305D905
References
80-36, NUDOCS 8004160133
Download: ML19305D905 (3)

Text

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. t COCTON EDICON COMPANY acNs=Ac omCes eco aOvLSTON sincc?

EOSTON. MasSACNUSCTTS a2199 G. CAAL ANDOGNIND SU PERf MTENDENT NUCLEAR OPERATIONS OEPARTNENT February 29, 1980 BECo. Ltr. #80-36 Mr. Eldon J. Brunner, Chief Reactor Operations and Nuclear Support Branch Office of Inspection and Enforcement Region I U.S. Nuclear Regulatory Commission 631 Park Avene:-

King of Prus;:t , PA. 19406 License No. DPR-35 Docket No. 50-293 Response to IE Inspection #79-21  !

Dear Sir:

Inspection No. 79-21, dated January 21, 1980, contained one item of noncom-pliance. Boston Edison Company's response to that item is presented as follows:

Deficiency Technical Specification 6.8.D states, " Written procedures to implement the Fire Protection Program shall be established, implemented, and maintained."

Plant Procedure 1.3.4, " Procedures," Paragraph III. A, states , in part, "...Proce-dures shall be implemented in accordance with safety standards, Technical Speci-fications, and requirements of regulatory agencies..."

Contrary to the above, the following plant procedures for operation of Fire Protection System:

No. 2.2.25, " Fire Water System" No. 2.2.26, " Deluge and Sprinkler Sys tems" No. 2.2.27, " Carbon Dioxide System" No. 2.2.28, " Dry Chemical Systems" No. 2.2.29, " Smoke Detection Sys tems" did not adequately implement or were not in accordance with various Technical Specification requirements as specified in Technical Specificat ons 3.12 and 4.12.

800 160133

A T C7Jf,TC N EDCON COMPANY )

Mr. Eldon J. Brunner, Chief February 29, 1980 Page 2

Response

The Fire Protection Operating Procedures found to be in noncompliance during the subject NRC Inspection will be revised to implement the requirements of Plant Procedure 1.3.4 and Technical Specifications 6.8.D, 3.12 and 4.12.

Revisions to these procedures incorporating the applicable sections of the referenced requirements will be completed by April 15, 1980. However, we would like to clarify certain misconceptions with the NRC findings specific to Procedures No. 2.2.25 " Fire Water System" and No. 2.2.26 " Deluge and Sprinkler Systems".

Regarding Procedure No. 2.2.25 the NRC findings state that "the procedure appears to allow Fire System operation between 110-125 psig with no operator or automatic actions. T.S. 4.12.B states that Fire Sys tem operation will be a minimum of 125 psig." Unfortunately T.S. 4.12.B has been taken out of con-text and improperly applied. The entire requirement reads as fo.1. lows:

"by verifying that each pump starts and delivers at least 2000 gpm while maintaining a system pressure of at least 125 psig.

This requirement applies to the motor driven and engine driver. fire pumps only as denoted in T.S. 3.12.B while T.S. 4.12B requires that eacit pump deliver 2000 gpm at a system discharge pressure of 125 psig during operation. A jockey pump is utilized to maintain normal system pressure which prevents the motor driven fire pump from cycling on and off. A continuous drop in system pressure will activate the fire pumps which will then deliver their rated capacity at rated pressure. The system as currently designed and described does meet the -

requirements of 4.12.B and is based on sound fire protection engineering practice and judgement. Therefore, no changes will be made to the procedure regarding this matter.

As to the NRC finding relative to Procedure 2.2.26 in which the Inspector stated;

1) " Amendment #35 dated December 21, 1978 required a spray / sprinkler system be installed in the Standby Gas Treatment System (SBGT)" and 2) "the current built in spray system in the SBGT may not meet the requirements of T.S. 3.12.C and 4.12.C,"

we respond as follows:

l 1) The Commission Safety Evaluation Report (SER) accompanying Amendment #35, i clearly identifies the adequacy of the existing automatic water suppression system for protection of fire in the charcoal filters. As stated in Section 5.11 of the SER, the only modification required in this area was the addition of a 25 foot length of hose to the hose station adjacent to this area.

2) The function of the SBGT Filter Spray System as designed, is to cool exothermic reactions within the charcoal filters to prevent radioactive release in the

! event of an unsuppressed fire. Although it's design is dissimilar to the other spray and/or sprinkler systems listed in T.S. 3.12.C, in. that it is not designed to NFPA-13 criteria, the Commission was totally cognizant of this fact at the time of issuance of Amendment #35 and the requirements of T.S. 3.12.C and 4.12.C

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m w BO ",Tt3N EOISON COMPANY '

Mr. Eldon J. Brunner, Chief February 29, 1980 '

Page 3 as issued were considered appropriate and appitcable for this system.

Therefore, no modifications will be made in this area; however, as stated above, operating procedures for this sytem will be implemented in accordance with Plant Procedure 1.3.4 by April 15, 1980.

. - i We trust these actions are responsive to your concerns, however, should you desire additional information please contact us.

Very truly yours,

&c sw

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