ML19325D404

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Application for Amend to License DPR-28,revising Tech Spec Section 3.13.D.2 to Reduce Frequency of Fire Watch from Continuous to Not Less than Once Per Hour Provided Fire Detection Sys Operable
ML19325D404
Person / Time
Site: Vermont Yankee Entergy icon.png
Issue date: 10/16/1989
From: Murphy W
VERMONT YANKEE NUCLEAR POWER CORP.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML19325D405 List:
References
NUDOCS 8910230224
Download: ML19325D404 (3)


Text

. . _ , 4 VERMONT YANKEE '

" NUCLEAR POWER CORPORATION  :

I

.. , Ferry Road, Brattleboro, VT 05301 7002 y ,,,

) ENGINEERING OFFICE p./

sao uAm smitt .

BOLTON MA Me  !

(SD6) 77D4711  ;

October 16, 1989 I

U.S. Nuclear Regulatory Commission Washington, D.C. 20555  !

I Attention: Document Control Desk l

References:

a) License No. DPR-28 (Docket No. 50-271) b) Letter, U3NRC to VYNPC, Sample Technical Specification, [

dated 12/2/76  !

t

Dear Sir:

Subject:

I Proposed Change to Vermont Yenkee Technical Specifications: Compensatory Fire Watches Pursuant to the Commission's Rules and Regulations as set forth in i 10CFR50.90, Vermont Yankee Nucle w Power Corporation (VYNPC) hereby proposes the  !

following change to Appendix A of the Vermont Yankee plant operating license

[ Reference a)). {

PROPOSED CHANGE  :

Replace page 187-g of the Vermont Yankee Technical Specifications with the attached revised page 187-g. The proposed change revises section 3.13.0.2 per-taining to the establishment of compensatory fire watches. Specifically, this i proposed change will reduce the frequency of the fire watch from continuous to l not less than once per hour provided the appropriate fire detection system is operable. This proposed change provides compensatory measures determined to be adequate and practical and ensures consistency with other compensatory measures directed by Technical Specifications in Section 3.13.D.  ;

REASON AND BASIS FOR CHANGE The fire protection Technical Specifications at Vermont Yankee were deve-  !

loped using the sample fire protection Technical Specifications provided to VY'  ;

by the NRC in 1976 (b). At that time, redundant motor control centers and l cables necessary to support safe shutdown were contained in, or passed through, i the cable spreading area or the switchgear room. This configuration was deter-  ;

mined acceptable with a Technical Specification requirement for a continuous  ;

fire watch should the CO2 system become inoperable.  :

Modifications were later made to satisfy new Appendix R regulations.

Control and power equipment for dedicated safe shutdown equipment was provided ,

and protected in areas of the plant independent of the cable spreading area.

The switchgear room was divided by a rated fire barrier providing separation of independent trains of safe shutdown equipment.

f p [, .

8910230224 891016 PDR ADOCK 05000271 fg  :

'P FDC

VECMONT YANKEE NUCLEAR POWER CORPORATION U.S. Nuclear Regulatory Commission October 16, 1989 Page 2 ,

i The Cable Vault and Switchgear Rooms are now separated from other safe shutdown areas by one hour rated fire barriers. These rooms have independent I detection and suppression systems.

These additional modifications and dedicated safe shutdown equipment provide I assurance of safe shutdown capability independent of a total loss, due to fire, of the cable spreading area or either of the switchgear rooms.  :

l The ionization detection systems which trip, and provide alarms for, the [

cable vault and switchgear room CO2 systems exceed the capabilities of a con- r tinuous fire watch. The basis for the Fire Protection System's Technica'. '

Specifications state, in part, that the smoke detectors provide the early t warning fire detection capability necessary to detect fires in these areas of the plant. These systems alarm locally and remotely in the control room.

Appropriate firefighting equipment is readily available and located in all of these areas. The availability of the fire detection system will ensure quick response if any alarm condition occurs.

This proposed change will modify the requirement from a continuous fire watch to a not less than once per hour fire watch in the event of an inoperable cable vault or switchgear room CO2 system provided the corresponding detection system is operable. Considering the improved design which enhances the availa-bility of redundant equipr,ent for safe shutdown, the acceptability of a total l loss due to fire in the cable spreading area or a switchgear room, and the pre- ,

sence of an operable detection systems the change to an hourly fire watch will I have no significant impact upon plant safety or operations. The compensatory i

measures (3.13.D.2) described in the proposed Technical Specification change i are, therefore, determined to be appropriate. This change will also provide consistency throughout Vermont Yankee's Fire Protection Technical Specifications for inoperable fire suppression equipment reflecting current plant design. ,

SAFETY CONSIDERATIONS This proposed change in the frequency of the compensatory fire watch is an administrative action. As such, there are no unreviewed safety questions as defined by 10CFR50.59.

This change has been reviewed by the Vermont Yankee Plant Operations Review Committee, and by the Nuclear Safety Audit and Review Committee. I SIGNIFICANT HAZARDS CONSIDERATION '

10CFR50.92 states that a proposed amendment v.111 not involve a significant hazards consideration if the proposed amendment does nots (1) involve a signi- i ficant increase in the probability or consequences of an accident previously

  • evaluated; (ii) create the possibility of a new or different kind of accident from any accident previously evaluated: or (iii) involve a significant reduction in a e,argin of safety.

,-.r

. . i VERMONT YANKEE NUOLEAR POWER CORPORATsON U.S. Nuclear Regulatory Commission October 16, 1989 Page 3 This proposed change provides consistency in the application of compen-satory measures for inoperable fire suppression systems at Vermont Yankee. This change, therefore, does not significantly increase the probability or consequen-ces of an accident previously evaluated because the change is administrative and  ;

does not weaken or degrade the facility. The proposed change does not create '

the possibility of a new or different kind of accident from any accident pre-  :

viously evaluated because the change is administrative and ensures that the l plant does not exceed the applicable safety limits. The proposed change does ,

not involve a significant reduction in a safety margin since the change is  !

adininistrative and does not involve any physical change to the facility. '

SCHEDULE OfF, CHANGE This change to the Vermont Yankee Technical Specifications will be imple-mented as soon as practicable following receipt of your approval. '

We trust that the information provided above adequately supports our request however, should you have any questions or desire further information, please do not hesitate to contact us.

Very truly yours, VERMONT YANKEE NUCLEAR POWER CORPORATION y anAp Warren P. M rphy Vice President and {

l Manager of Operations  ;

l /dm cci USNRC Regional Administrator, Region I USNRC Resident Inspector, VYNPS Vermont Department of Public Service STATE OF VERMONT)

)ss WINDHAM COUNTY )

Then personally appeared before me, Warren P. Murphy, who, being duly I sworn, did state that he is Vice President and Manager of Operations of Vermont I Yankee Nuclear P r Corporation, that he is duly authorized to execute and file the foregoin gs Me the name and on the behalf of Vermont Yankee Nuclear Power Corp n and t e statements therein are true to the best of his knowledge nd belief, t

j l Diane M. McCue J Notary Public PUBUC S My Commission Expires February 10, 1991

$ 4

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