ML19317E114
| ML19317E114 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 12/15/1977 |
| From: | Parker W DUKE POWER CO. |
| To: | Schwencer A Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 7912130826 | |
| Download: ML19317E114 (6) | |
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u.s. NUCLEAD F.EGULATORY COMMIShSI NRC PwM 195 n-a NRC DISTRIBUTION Pon PART 50 DOCKET MATERIAL FROM:
DATE CP QCCUMENT 70 '.
12/15/77 Duke Power Company Mr. Edson G. Case Charlotte, North Carolina c4TE nECEivEo William O. Parker, Jr.
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. Consists of comments on proposed interim tech specs on fire protection trans-mitted by NRC's 11/25/77 Itr.....
PLANT NAME: Oconee Units 1-2-3 DISTRIBlIIION OF FIRE PROTECTION INFO PER S.SHEPPARD 9-22-76 FOR OPERATING REACTORS RJL' 12/21/77 (2-P)
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Mr. Edson G. Case, Acting Director 7
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Attention:
Mr. A. Schwencer, Chief Operating Reactors Branch No. 1
Reference:
Oconee Nuclear Station Docket Nos. 50-269, -270, -287
Dear Mr. Case:
Your letter of November 25, 1977 transmitted proposed interim Technical Specifications on fire protection. We have the following comments on the proposed Technical Specification revision.
Proposed Technical Specification 3.17.5 states that when a penetra-tion ire barrier protecting a safety related area is determined to be nrm-functional, a continuous fire watch shall be established on at least one side of the affected penetration within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.
Ignition sources and storage of combustible materials in the safety related areas where fire barrier penetrations are located are controlled by station directives.
In addition, these safety related areas are protected by smoke detectors which provide an alarm to the control room.
It is propused that Technical Specification 3.17.5 be changed to reflect these fire protection provisions by requiring that when a fire barrier penetration protecting a safety related area is deter-mined to be non-functional, the area shall be protected by operable smoke detectors and within one hour a fire watch patrol shall be established to inspect the area at least once per hour.
If the smake detectors in the area are inoperable, a continuous fire watch shall be established on at least one side of the affected penetration within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.
It is felt that establishing a fire watch patrol will be a sufficient backup source of detection to assure that areas pro-tected by barriers are properly isolated in the event of a fire.
Proposed Technical Specification 4.19.l(f) states that each valve that is not testable during plant operation should be cycled once every eighteen months. All valves in the fire protection system at Oconee Nuclear Station are testable during plant operation.
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Mr. Edron G. Caza, Acting Director Page Two December 15, 1977 Therefore, this specification is not applicable to the fire protection system at Oconee Nuclear Station.
Please find attached a copy of the proposed revision incorporating these comments.
It is requested that a 20 day period be provided between the date of issue of these amendments aad the effective date. This wilt allow adequate time to receive and process the approved amendments and will assure compliance with the final version of the amendments.
Very truly yours, TJL4 o. P William O. Parker, Jr.
WAA LJB:ge Attachment
3.17.3 The sprinkler systems in safety related areas listed in Table 3 17-1 shall be operable.
If a system is determined to be inoperable, the following corrective action shall be taken.
1.
A continuous fire watch backup fire suppression equipment shall be established in the area within I hour.
2.
The sprinkler system shall be restored to operable status within 14 days or a report shall be submitted to the Commis-sion within the next 30 days outlining the cause of inoper-ability and the plans for restoring the system to operable status.
3.17.4 The fire hose stations listed in Table 3 17-1 shall be operable or additional equivalent capacity hoses shall be provided at an operable hose station within one hour such that the additional hoses can be readily connected to the operable station and extended into the unprotected area if the need arises.
3.17.5 When a penetration fire barrier protecting a safety related area is determined to be non-functional.. the area shall be protected by operable fire detection instrumentation and within one hour a fire watch patrol shall be established to inspect the area at least once per hour.
If the the fire detection instrumentation in the area is inoperable, a continuous fire watch shall be established on at least one side of the affected penetration within one hour.
3.17-2
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" BASES Operability of the fire detection instrumentation ensures that adequate warning capability is available for the prompt detection of fires.
This capability is required in order to detect and locate fires in their early stages. Prompt detection of fires will reduce the potential for damage to safety related equipment and is an integral element in the overall facility fire protection program.
In the event that a portion of the fire detection instrumentation is inoperable, the establishment of frequent fire patrols in the affected areas is required to provide detection capability until the inoperable instrumentation is restored to operability.
The operability of the fire suppression systems sures that adequate fire suppression capability is available to confina 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 sprinklers, and fire hose staticas. The collective capability of the fire suppression systems is adequate to minimize potential damage to safety related equipment and is a major element in the facility fire protection program.
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 inoperable equipment is restored to service.
In the event the fire suppression water system becomes inoperable, immediate 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 for prompt evaluation of the acceptability of the corrective measures to provide adequate fire suppression capability for the continued operation of the nuclear plant.
The functional integrity of the penetration fire barriers ensures that fires will be confined or adequately retarded from spreading to adjacent portions of the facility. This design feature minimizes the possibility of a single fire rapidly involving several areas of the facility prior to detection and extinguisnment. The penetration fire barriers are a passive element in the facility fire protection program and are subject to periodic inspections.
During periods of time when the barriers are not functional, a fire watch patrol will be required to inspect the area at least once per hour and fire detection instrumentation will be operable in the area.
If fire detection instrumentation is not operable, a continuous fire watch is required to be maintained in the vicinity of the affected barrier until the barrier is re-stored to functional status.
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4.19 FIRE PROTECTION AND DETECTION SYSTEM Applicability Applies to the fire protection and detection systems which protect systems and equipment required for safe shutdown.
Objective To verify the operability of fire protection and detection systems.
Specifications 4.19.1 The High Pressure Fire Protection System components shall be tested as follows:
Item Frequency (a)
High pressure service water pump Monthly functional test (b)
System functional test Every 18 months (c)
High pressure service water pump Annually capacity test to verify flow of 3000 gpm (d)
System Flow Test in Accordance with Every 3 years Chapter 5, Section 11 of the Fire Protection Handbook, 14th Edition, NFPA (e) Alignment of fire protection valves Monthly (f)
Sprinkler systems in safety related areas 1.
System functional test Annually 2.
Inspection of spray headers Annually 3
2nspection of spray nozzle Annually (g)
Fire hose stations 1.
Visual inspection Monthly 2.
Maintenance inpsection Annually 3
Partial opening of fire hose Every 3 years station valve 4.
Hose Hydrostatic test at least Every 3 years 50 psig greater than the maximum pressure at the station 4.15-1 l
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