ML20027D460

Tech Specs 3.12 & 4.12 Re High Pressure Water Fire Protection Sys.Safety Evaluation Encl

ML20027D460
Person / Time
Site:	FitzPatrick
Issue date:	10/28/1982
From:	POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
To:
Shared Package
ML20027D454	List: ML20027D453 ML20027D457 ML20027D460
References
NUDOCS 8211040327
Download: ML20027D460 (6)

Text

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ATTACHEMENP I PROPOSED TECHNICAL SPECIFICATION CHANGE RELATED TO HIGH PRESSURE WATER FIRE PRO'1ECTION SYSTEM SURVEILLANCE REQUIREMENTS POWER AUTHORITY OF THE STATE OF NEW YORK JAMES A. FITZPATRICK NUCLEAR POWER PLANP DOCKET 10. 50-333 DPR-59 8211040327 821028 PDR ADOCK 05000333 P PDR ,

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JAFNPP IM1ITING OONDITIONS FOR OPERATION SUINEILI1WCE REQUIIDENTS 3.12 FIRE PIUTECTION SYSTDE 4.12 FIRE PICfDCTION SYSTDE Applicability: Applicability:

Applies to the Operational Status of the Fire Applies to the Surveillance of the Fire Protection Systems. Protection System.

Objective: Objective:

To assure operability of the Fire Protection To verify the operability of the Fire Pro-

• Systems, tection Systems.

Specification: Specification:

A. Iligh Pressure Water Fire Protection System A. Iligh Pressure Water Fire protection System

1. a. Both high pressure water fire 1. Iligh pressure water fire protection protection punps and associated . system testing:

autcmutic and manual initiation Item Frequency logic shall be operable and aligned to the high pressure a. Iligh pressure water Once/ week water fire header. fire protection sys-tem pressure check.

b. 'Ihe high pressure water fire pro-tection system shall be operable b. Each ptmp, on a ST10- Once/ week uith an operable flow path capable GERED TEST BASIS, by of taking suction frcm the lake starting and operating and transferring the water it for at least 20 through distribution piping with minutes on recirculat-operable sectionalizing control ing flow or isolation valves to the yard hydrant curb valves and the first c. Valve operational test once/12 valve ahead of the water flow months alarm device on each sprinkler, d. System flush once/6 hose standpipe or spray system months riser required to be operable per e. Functional. test includ- Once/18 l specifications 3.12.B and 3.12.D. ing: months 244a Amendment No. g

JAFNPP A. Iligh Pressure Water Fire Protection Systan (Ocnt'd) A. Iligh Pressure Water Fire Protection System (Cont'd)

c. With one pump and/or associated Item Frequency autanatic and manual initiation -

logic inoperable, restore tiu 1. Simulated autanatic inoperable equipnent to operable actuation of each punp, status within 7 days or, in lieu of any other report required by 2. verifying that each Specification 6.9.1.A, autanatic valve in the subnit a Special Report to the flow path actuates to Ocnmission, within the next 30 its correct position, days outlining the plans and procedures to be used to provide 3. verifying that each for the loss of redundancy in this punp develop at least system. 2500 gpn at a pressure of 125 psig, and

d. With the high pressure water fire protection system otherwise inop- 4. verifying that each pump i erable: starts (at 95 psig for the l electric punp and 85 psig

1. Establish a backup fire for the diesel driven punp) suppression water system '

to maintain the fire sup-within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, and pression water system pres-sure.

2. Subnit a Special Report:

, .f . System flow test in accordance Once/3 years a) By telephone within 24 with Section ll, Chapter 5 I

hours, of the Fire Protection llandbook, 14th Edition, b) Confirmed by telegraph, published by the National mailgram or facsimile Fire Protection Association transmission no later than the first working g. Each valve in the flow path Once/ Month day following the event, by verifying it is in its and correct position.

c) In writing within 14 days following the event, out-lining the action taken, the cause of the inopera-bility and the plans and schedule for restoring the system to operable status.

Amendment No. g 244b

f ATTACHEMENT II SAFETY EVALUATION 4 RELATED TO

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HIGH PRESSURE WATER FIRE PROTECTION SYSTEM SURVEILLANCE REQUIREMENTS I

l POWER AUTHORITY OF THE STATE OF NEW YORK JAMES A. FITZPATRICK NUCLEAR POWER PLANT DOCKET 10. 50-333 DPR-59 1

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Snction I - Dnscription of Modification

• • In Section 4.12.A.1.0 on page 244a, the word " system" is deleted.

Section 4.12.A.l.e.1 on page 244b, is reworded to eliminate j a reference to an " operating sequence." In its place,

" actuation of each pump" is substituted.

The word " sequentially" has been. deleted from Section 4.12.A.l.e.4 on page 244b.

Section II - Purpose of the Modification I

The word " system" on page 244a (Section 4.12.A.1.e) was I deleted because the term " System Functional Test" is undefined I by the Technical Specifications, while " functional test" is defined in Section 1.0.F.1.

Section 4.12.A.1.e.1 (page 244b) is reworded to eliminate a reference to an " operating sequence" since no such sequence exists. The pump control circuit is a simple one using a pressure switch for automatic start, and local or remote switches for manual initiation. No automatic valves (excluding pump discharge check and relief valves) are in either the fire pump suction or discharge lines.

The phrase "...each pump starts sequentially..."in Section

-- 4.12.A.l.e.4-(page 244b)chas been interpreted to mean a single, -

unbroken decrease in fire protection system pressure from normal to 85 psig with the observed start of the electric pump '

at 95 psig and the diesel at 85 psig. The Authority believes that such a test is neither necessary nor desirable when the l design of the fire protection system is considered. This test requires that both pumps operate simultaneously, which would result in both pumps operating at or above rated conditions.

The resulting flow exceeds the range of existing flow ,

instrument. Any additional demand, due to either automatic or inadvertent manual initiation of any sprinkler, spray or hose would further load the pumps beyond their design condition.

Sequential testing of the fire pumps does not demonstrate any component operable or system attribute not demonstrated by nonsequential testing. Independent tests of both pumps satisfy the requirement for "... simulated automatic actuation..." required by Section 4.12.A.l.e.l.

Further, NUREG-0123 Revision 3 (" Standard technical Specifications for General Electric BWRs") indicates that the term " sequential" is optional and dependent upon plant design.

This change will further resolve NRC Inspection and Enforcement Unresolved Item No. 81-15-02.

Section IV - Implomontation of the Modification

,, The changas, as proposed, will not impact the ALARA or Fire Protection programs at FitzPatrick. Surveillance tests will be conducted at the same frequency as previously required, thereby assuring the same reliability and availability,of the High Pressure Water Fire Protection System.

Section V - Conclusion The incorporation of these modifications: a) will not increase the probability nor the consequences of an accident or malfunction of equipment important to safety as previously evaluated in the safety analysis report; b) will not increase the possibility for an accident or malfunction of a different type than any evaluated previosly in the safety analysis report; c) will not reduce the margin of safety as defined in the basis for an technical specification; and d) does not consitute an unreviewed safety question.

Section VI - References (a) JAF FSAR (b) JAF SER s

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