ML20005E101

Proposed Tech Specs,Relocating Fire Protection Requirements to Fire Protection Plan

ML20005E101
Person / Time
Site:	Rancho Seco
Issue date:	12/28/1989
From:	SACRAMENTO MUNICIPAL UTILITY DISTRICT
To:
Shared Package
ML20005E100	List: ML20005E099 ML20005E101
References
NUDOCS 9001030259
Download: ML20005E101 (39)

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ATTACletENT.II PROPOSED AMENDMENT 180 AFFECTED TECHNICAL SPECIFICATION PAGES l

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F-RANCHO SECO UNIT 1 TECHNICAL SPECIFICATIONS ProDosed Amendment 180:

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Amend paragraph 2.C.(4) of Facility Operating License No. DPR-S4 to read as follows:'

(4)'

The licensee shall implement and maintain in effect all provisions of the approved fire protection program, as described in.the fire Protection Plan for Rancho Seco Nuclear Generating Station, and as approved in the SER dated

, subject to the following provision:

The licensee may make changes to the approved fire protection program-

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7, without prior approval of. the Commission only if those changes would-not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire.

(Amendment 180 - 12/4/89) l-l l

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Definitions 1.11 DELETED-q 1.12 STAGGERED TEST BASIS

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A STAGGERED TEST BASIS shall consist of:

a.. A test schedule for n systems, subsystems, trains or designated components obtained by dividing the specified test interval into n equal subintervals.

b.

The testing of one system, subsystem, train'or designated components during each subinterval.

1.13 PROCESS CONTROL PROGRAM

. PROCESS CONTROL PROGRAM (PCP) - The PROCESS CONTROL PROGRAM shall contain the sampling, analysis, and formulation determination by which SOLIDIFICATION /DEHATERING of radioactive wastes from liquid-systems is assured, 1.14 SOLIDIFICATION SOLIDIFICATION shall be the conversion of radioactive wastes from liquid systems to a homogeneous (uniformly distributed),

monolithic, immobilized solid with definite volume and shape, bounded by a stable surface of distinct outline on all sides (free-standing).

Amendment No. 78, 23, 53, 98, 180 1-6

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Amendment No. 75, 85, 180 4-62

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RANCHO SECO UNIT 1

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Administrative Controls FACILITY $(AFF h

6.2.2 The Facility organization shall be as shown in the USAR and:

l a.

Each on duty shift shall be composed of at least the minimum shift crew composition shown in Table 6.2 l.

h.

At least one licensed Operator shall be in the control room when fuel is in the reactor.

c.

At least two licensed Operators, one of whom shall be senior licensed, shall be present in the control room when the unit is in other than cold shutdown or refueling.

d.

An individual qualified in radiation protection practices and procedures shall be on site when-fuel is in the reactor, e.

ALL CORE ALTERATIONS after the initial fuel loading shall be directly supervised by either a licensed Senior Reactor Operator or Senior Reactor Operator limited to Fuel Handling who has no other concurrent responsibilities during this operation, f.-

DELETED g.

Administrative procedures shall be developed and implemented to limit the working hours of facility staff who perform safety-related functions; e.g., senior reactor operators, l

reactor operator s, radiation protection personnel, auxiliary operators, and key maintenance personnel.

Amendment No. 49, 96, 100, 180 6-la

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RANCHO SECO UNIT 1 TECHNICAL SPECIFICATIONS Administrative Controls 6.3 FACILITY STAFF OUAlIFICATIONS i

6.3.1 Each member of the unit staff shall meet or exceed the minimum qualifications of ANSI N18.1-1971 for comparable positions, except for (1) the Manager, Radiation Protection who s.:all meet or exceed

.t the qualifications of Regulatory Guide 1.8 September 1975, and (2) the Shift Technical Advisor who shall have a bachelor's degree or equivalent in a ' scientific or engineering discipline. The STA shall receive specific training in plant design, and response and analysis of the plant for transients and accidents.

t.4 TRAINING 6.4.1 A retraining and replacement training program for the operating staff shall be maintained under the direction of the Manager, Training and shall meet or exceed the requirements and recommendations of Section 5.5 of ANSI N18.1-1971 and Appendix "A" of 10 CFR, Part 55.

6.4.2 DELETED 6.5 REVIEW AND AUDIT 6.5.1 PLANT REVIEW COMMITTEE (PRC)

FUNCTION 6.5.1.1 The Plant Review Committee shall function to advise the AGM, Nuclear Power Production and the Management Safety Review Committee on all matters related to nuclear safety.

COMPOSITION 6.5.1.2 The Plant Review Committee shall be composed of a chairman, and a minimum of six members.

Amendment No. 74, 18, 2A, 37, 62, 96, 180 l

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RANCHO SECO UNIT 1

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All events requiring a Licensee Event Report as defined by g.

10CFR50.73 and NUREG 1022 to determine adequacy of corrective action and to detect any degrading trend.

E h.

Special investigations and reports thereon as requested by the AGM, Nuclear Power Production.

i.

The Plant Security Plan and thanges thereto.

m j.

The Emergency Plan and changes thereto.

k.

Changes to the PROCESS CONTROL PROGRAM, the OFFSITE DOSE CALCULATION MANUAL and the RADIOLOGICAL ENVIRONMENTAL MONITO PROGRAM MANUAL.

(See Specifications 6.15 and 6.16.)

1.

Major changes to the Radioactive Haste Treatment Systems (Liquid, Gaseous and Solid), and all information required by Specification 6.17.

Review of any accidental, unplanned, or uncontrolled release of

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radioactive material to the environs including the preparation and forwarding of reports covering evaluation, recommendations, and disposition of the corrective action to prevent recurrence, and the fo" warding of these reports to the Nuclear Plant Manager and to the r

MSRC.

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The Fire Protection Plan and changes thereto.

AUTHORITY 6.5.1.7 The Plant Review Committee shall:

Recommend in writing to the AGM, Nuclear Power Production a.

approval or disapproval of items considered under 6.5.1.6(a) through (m) above.

b.

Render determinations in writing with regard to whether or not each item considered under 6.5.1.6(a) through (e), and (1) above constitutes an unreviewed safety question.

Provide immediate written notification to the Chairman of the c.

Management Safety Review Committee of disagreement between the PRC and the AGM, Nuclear Power Production; however, the AGM, Nuclear Power Production shall have responsibility for resolution of such disagreements pursuant to 6.5.1.1 above.

Amendment No. 24, 62, 63, 96, 98, 180 6-5

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RANCHO SECO UNIT 1 TECHNICAL SPECIFICATIONS Administrative Controls RESPONSIBILITIES (Continued)

RECORDS 6.5.1.8 Records of the PRC activities shall be prepared, approved and distributed as indicated below:

a.

Minutes of each PRC meeting, including appropriate documentation of reviews encompassed by Specification 6.5.1.6e and g, shall be prepared, approved, and forwarded to the AGM, Nuclear Power Production and to the Chairman, Management Safety Review Committee within fourteen (14) days following each meeting.

Amendment No. 24, 62, f3, 96, 98, 180 6-Sa

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RANCHO SECO UNIT 1 TECHNICAL SPECIFICATIONS Administrative Controls Special Reports 6.9.5 Special reports shall be submitted to the Regional Administrator, Region V Office, within the time period specified for each report.

These reports shall be submitted covering the activities identified below pursuant to the requirements of the applicable reference specification:

A.

A one-time only, " Narrative Summary of Operating Experience" will be submitted to cover the transition period (calendar year 1977).

B.

A Reactor Building structural integrity report shall be submitted within ninety (90) days of completion of each of the following tests covered by Technical Specification 4.4.2 (the integrated leak rate test is covered in Technical Specification 4.4.1.1).

1.

Annual Inspection 2.

Tendon Stress Surveillance 3.

End Anchorage Concrete Surveillance 4.

Liner Plate Surveillance C.

In-Service Inspection Program O.

Inoperable Accident Monitoring Instrumentation 30 days (3.5.5)

E.

DELETED F.

Inoperable Emergency Control Room /TSC Ventilation Room Filter System G.

Radioactive Liquid Effluent Dose 30 days (3.17.2)

H.

Noble Gas Limits 30 days (3.18.2)

I.

Radiciodine and Particulates 30 days (3.18.3)

Amendment No. 80, 85. 97, 180 l

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• Safety Analysis Report Log No. 1092 Proposed Amendment No. 180 Page 1 of 8 SAFETY ANALYSIS REPORT t

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Descriotion of Chance Proposed Amendment 180 removeg the fire protection requirements from the Rancho Seco Technical Specifications in accordance with the guidelines of Generic L4tter 88 12. " Removal of Fire Protection Requirements from Technical Specifications".

Proposed Amendment 180 requires the following changes to the Technical Specifications:

o Delete Sections 1.11, 3.14, 4.18, 6.2.2.f and related footnote, 6.4.2, and Section 6.9.5.E from the Technical Specifications, o

Add a new paragraph, 6.5.1.2.n, to the Technical Specifications to require PRC review and approval of the Fire Protection Plan and changes thereto.

(Existing Technical Specification requirements for quality assurance audits of the fire protection program remain unchanged).

In addition, Proposed Amendment 180 revises the existing fire protection related license condition in Paragraph 2.C.(4) of the Operating License to a standard fire protection license condition. The new license condition would read as follows:

(4)

The licensee shall. implement and maintain in effect all provicions of the approved fire protection program, as described in the Fire Protection Plan for Rancho Seco Nuclear Generating Station, and as approved in the SER dated

, subject to the following provision:

The licensee may make changes to the approved fire protection program without prior approval of the Commission only if those changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire.

Minor changes to the fire protection system operability / testing requirements are incorporated into the Fire Protection Plan.

(These changes would become effective when approval is received to delete the fire protection Technical Specifications). These changes provide clarifications of the operability requirements and previously approved alternatives for fire protection surveillances.

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Safety Analysis Report Log No. 1092 p

Proposed Amendment No. 180 Page 2 of 8 c

The guidelines of Generic Letter 8812 allow the licensee to remove fire protection requirements from Technical Specifications, by submittal of the license' amendment and incorporation of the facility fire protection program into the facility FSAR.

(The fire protection program includes the fire hazards analysis and descriptions of the fire protection and post fire shutdown systems, I

administrative and technical controls, the fire brigade and fire protection technical staff, and other related plant features).

In accordance with the Generic Letter 88-12 guidelines, the Fire Protection Plan has been developed to incorporate and consolidate material from the existing Updated Fire Hazards Analysis, engineering reports, the fire protection Technical Specifications, USAR Section 9.9.1, previous NRC submittals providing descriptions of the post fire shutdown systems, and descriptions of the fire protection related administrative controls and casualty procedures. The new Fire Protection Plan will be referenced in the USAR. /oministrative controls as required by 10CFR$0.59 will ensure that proposed xevisions to the Fire Protection Plan are properly reviewed.

Reason for Chance This change will provide an operational enhancement by improving the Technical Specifications in accordance with the recommendations of Generic Letter 88 12.

This change relocates the fire protection system operebility/ resting requirements and the fire brigade staffing / training requirements from the Technical Specifications to the Fire Protection Plan, a new licensing basis document.

The I

plant fire hazards analysis is relocated from the Updated Fire Hazards Analysis Report (ERPT M0047) to the Fire Protection Plan. The Fire Protection Plan consolidates the design bases for the fire protection systems. This change does not reduce the level of fire protection provided for the facility.

Evaluation and Basis for Safety Findines a)

Systems, Subsystems, Components Affected Proposed Amendment 180 modifies the type of administrative controls for those portions of the plant fire protection systems covered by Technical Specifications 3.14 and 4.18.

The plant fire protection systems are described in Section 9.9.1 of the USAR.

b)

Safety Function of the Affected Systems / Components The affected portions of the fire protection systems provide fire detection and fire suppression capability within the plant, including:

1.

Fire detection instruments within the Reactor Building, Auxiliary Building, Turbine Building, Nuclear Services Electrical Building, Auxiliary Feedwater Pump area, and TDI Diesel Generator Building.

Safety Analysis Report Log No. 1092 Proposed Amendment No. 180 Page 3 of 8 l

2.

The fire suppression water system, including the fire pumps and the s

underground fire loop servicing the Auxiliary Building, Turbine i

Building, Nuclear Services Electrical Building, Auxiliary Feedwater Pump Area, and TDI Diesel Generator Building.

i 3.

Fire protection spray / sprinkler systems in the Auxiliary Building, Turbine Building, Nuclear Services Electrical Building, TDI Diesel

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Generator Building, and Auxiliary Feedwater Pump Area.

L 4.

Carbon dioxide fire suppression systems in the Auxiliary Building and Turbine Area.

5.

Fire hose stations in the Auxiliary Building, Turbine Building, Nuclear Services Electrical Building, and the TDI Diesel Generator Building, and fire hydrants FHV 002, FHV 003, FHV 024 and FHV 026.

6.

Fire rated assemblies'in the Auxiliary Building, Turbine Building, Nuclear Services Electrical Building, Transformer Alley, and TDI Diesel Generator Building.

The affected portions of the fire protection systems provide fire detection and fire suppression capability within the safety related structures / areas of the plant. The safety function of the system is to ensure that a fire, should it occur, will be promptly detected, confined, and suppressed or extinguished.

Effects on Safety Functions The adequacy of the fire detection and fire suppression capability is not affected by this change.

The change does not physically modify any plant structures, systems, or equipment.

There are no changes to the plant fita barriers, to the fire area arrangement, or to the plant fire detection or fire suppression zones.

This change relocates the administrative controls for fire suppression, fire detection and fire brigade requirements from the Technical Specifications to the Fire Protection Plan in accordance with Generic Letter 88-12.

The plant fire hazards analysis is relocated from the Updated Fire Hazards Analysis Report to the Fire Protection Plan. Minor changes to the fire protection system operability / testing requirements are incorporated into the Fire Protection Plan.

(These changes would become effective when approval is received to delete the fire protection Technical Specifications).

Safety Analysis Report Log No. 1092 Proposed Amendment No. 180 Page 4 of 8 The differences in the operability / testing requirements are as follows:

o The Technical Specification requirement for a Special Report for inoperable fire protection equipment which is not returned to service within the required period is replaced by the Fire Protection Plan requirement to initiate a PDQ to assure that the condition is screened for reportability per 10CFR50.72 and 10CFR$0.73. This change is consistent with the guidelines of Generic Letter 88 12.

o The Technical Specification fire pump surveillance flow test discharge pressure requirement is specifically included in the operability statement for the fire pumps in the Fire Protection Plan.

o The editorial corrections to Table 3.14 1 (correct the count of detectors in detection zones 13, 16, 81 and 82) which were previously identified in Proposed Amendment 171 are incorporated into the Fire Protection Plan.

o The Technical Spacification requirement for fire detection instruments and fire suppression spray / sprinkler and carbon dioxide systems to be operable "whenever the equipment protected by the fire protection system is required to be operable" is specifically stated in the fire protection system operability sections in the Fire Protection Plan.

The Technical Specification spray / sprinkler and carbon dioxide systems o

which require continuous fire watch if inoperable are specifically identified in the Fire Protection Plan to ensure that the proper compensatory measures are implemented should any of these systems become inoperable, o

The Technical Specification fire barriers for electrical raceways are specifically identified in the Fire Protection Plan to ensure that compensatory measures are adequately implemented should any of these barriers be breached, o

The Technical Specification monthly surveillance of the fire suppression water system valve position is changed from "in its correct position as indicated by position instrumentation" to "in its correct position as indicated by position instrumentation or visual verification", to correctly identify the surveillance of the non indicating sectional valve in the fire loop, as described in USAR Section 9.9.1.2.2.

o The locations of the fire hose stations for fire hydrants 2, 3, 24, and 26 in Table 3.14-4 are clarified in the Fire Protection Plan (e.g. the associated hydrant hose house is included in the location)

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i Safety Analysis Report Log No. 1092 Proposed Amendment No. 180 Page 5 of S i

o The Technical Specification 31 day visual inspection of the fire hose station to " ensure all equipment is available" is changed in the Fire Protection Plan to " ensure all required equipment is available", as the j

availability of any surplus fire protection equipment maintained in/near the stations does not affect the operability of the hose station.

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The Technical Specification requirement to replace all fire hose every three years with new hose that meets or exceeds NFPA guidelines is replaced j

by the Fire Protection Plan requirement to hydrotest the fire hose every three years to a pressure at least 50 psig greater than the maximum pressure at any hose station. This change is consistent with NFPA standards (refer to NFPA 1962 1988, Standard for the Care, Use, and Service Testing of Fire Hose, Including Couplings and Nozzles, code j

section 2.3).

The change is also consistent with standard Technical Specifications.

o The Technical Specifiestion requirement to inspect all fire rated assemblies every 18 months is footnoted in the Fire Protection Plan to specifically identify the existing procedure to inspect only one side of certain penetrations where inspecti'on of the opposite side would require entry into a high radiation area, f

Analysis of Effects on Safety Functions Proposed Amendment 180 does not change the fire detection or fire suppression capability of the affected fire protection systems.

This change does not physically modify any plant structures, systems or equipment.

There are no changes to the plant fire barriers, fire area arrangement, or to the fire detection or fire suppression systems.

The proposed amendment relocates the administrative controls for fire suppression, fire detection and fire brigade requirements from the Technical Specifications to the Fire Protection Plan, to provide improved Technical Specifications in accordance with the guidelines of Generic Letter 88 12.

Minor changes to the fire protection system operability / testing requirements are incorporated into the Fire Protection Plan.

(These changes would become effective when approval is received to delete the fire protection Technical Specifications).

Safety Analysis Report Log No. 1092 Proposed Amendment No. 180 Page 6 of 8 In general, the changes to the fire protection system operability / testing requirements in the Fire Protection Plan provide clarification of the applicability of the operability / testing requirements.

However, in one case the fire protection system testing requirements in the Fire Protection Plan propose a previously approved alternative to the existing Technical Specification surveillance. The Technical Specification requirement to replace all fire hose every three years with new hose that meets or exceeds NFPA guidelines is replaced by the Fire Protection Plan requirement to hydrotest the fire hose every three years to a pressure at least 50 psig greater than the maximum pressure at any hose station. This change is consistent with NFPA standards (refer to NFPA 1962 1988, Standard for the Care, Use, and Service Testing of Fire Hose, Including Couplings and Nozzles, Code Section 2.3).

The fire protection system operability and testing requirements in the Fire Protection Plan will continue to assure that essential fire protection systems are available and will perform as designed in the event of fire. These changes do not reduce the level of fire protection provided within any plant area.

The plant fire hazards analysis is relocated from the Updated Fire Hazards Analysis Report to the Fire Protection Plan. The fire hazards analysis, as incorporated in the Fire Protection Plan, contains editorial changes to enhance user comprehension of the analysis, but does not change the previous analysis of potential fire consequences or post-fire safe shutdown capability.

In addition, the summary of the key elements of the existing post fire remote shutdown casualty procedures, is relocated from USAR Section 7.4.8.2 to Section 3.8 of the Fire Protection Plan.

The relocation of this material from the USAR to the Fire Protection Plan consolidates the key elements of the fire protection program into a single source document, in order to facilitate user comprehension and minimize redundancy.

The material relocated to the Fire Protection Plan summarizes procedures in place, and does not constitute any change to these procedures.

Descriptions of key fire protection related administrative controls for fire protection system impairments, ignition source permits, and combustible material control are also included in the Fire Protection Plan.

This material is not currently described in the USAR. The addition of this material to the Fire Protection Plan provides material necessary for comprehension of the overall fire protection program at Rancho Seco, in accordance with 10CFR50.48.

This material provides a summary of procedures in place, and does not constitute any change to these controls.

Administrative procedures for 10CFR50.59 determinations of proposed changes, tests, and experiments, will" ensure that ensure that proposed revisions to the Fire Protection Plan are properly reviewed and processed.

n Safety Analysis Report Log No. 1092 Proposed Amendment Nc. 180 Page 7 of 8 Summary Proposed Amendment 180 deletes the fire protection requirements from the Technical Specifications and adds the fire protection requirements to the new licensing basis document, the Fire Protection Plan.

The Fire Protection Plan also incorporates and consolidates material from the USAR fire protection system descriptions, the plant fire hazards analysis, and provides a summary of key fire protection related administrative controls and post fire shutdown procedures.

This Proposed Amendment provides improved Technical Specifications in accordance with Generic Letter 88-12, Removal of Fire Protection Requirements from Technical Specifications.

In addition, this proposed amendment revises the existing fire protection related license condition to a new standard license condition.

The new license condition would allow specific features of the fire protection program to be' altered without prior NRC approval, provided the alterations do not otherwise involve a change in a license condition or technical specification, or result in an unreviewed safety question per 10CFR50.59, and the change does not affect the ability to achieve and maintain safe shutdown conditions in the event of fire, a

The implementation of Proposed Amendment 180 does not involve an Unreviewed Safety Question.

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Safety Analysis Report Log No. 1092 Proposed Amendment No. 180 Page 8 of 8 NO SIGNIFICANT HAZARDS CONSIDERATION The District has reviewed the proposed changes against each of the criterion of 10CTR50.92, and based on the discussion in the above safety analysis the District has concluded that:

o A significant increase in the probability or consequences of an accident previously evaluated in the SAR will not be created because this change does not reduce the level of fire protection provided and does not change the previous analysis of potential fire consequences, o

The proposed changes will not create the possibility of a new or different kind of accident from any accident previously evaluated in the SAR, because this change does not physically modify any plant structures, systems, or equipment, The proposed changes will not involve a significant reduction in the margin o

of safety because adequate administrative controls will be maintained to ensure the operability of fire protection systems within areas where safety-related or redundant systems important to safe shutdown are located.

Based on the above discussion, the District concludes that the proposed changes do not constitute any significant hazard to the public, and in no way endanger the public's health and safety.

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