ML20056A689

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Proposed Tech Specs Re Fire Protection CO2 Sys
ML20056A689
Person / Time
Site: Millstone Dominion icon.png
Issue date: 07/31/1990
From:
NORTHEAST NUCLEAR ENERGY CO.
To:
Shared Package
ML20056A688 List:
References
NUDOCS 9008090032
Download: ML20056A689 (8)
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. Docket No. 50-423 B13582 4

Attachment 1 Millstone Nuclear Power Station, Unit No. 3 Proposed Changes to Technical Specifications July 1990 9008090032 90073j fDR ADOCK 05000423 PDC

\j, 'l l PLANT SYSTEMS l

{&, SYSTEMS LIMITING CONDITION FOR OPERATION 3.7.12.3 The following 00: Systems shall be OPERABLE:

a. A Emergency Generator Fuel Oil Tank Vault,(*)
b. B Emergency Generator Fuel Oil Tank Vault,(*)

c.- North Electrical Tunnel,(*)

d. South _ Electrical Tunnel,(*)

e.: Cable Spreading Room,

f. West Switchgear' Room,(*)

.g. East Switchgear Room,(*)

h.- A MCC and Rod Control Area,(*) and

i. B MCC and Rod Control Area.(*)

APPLICABILITY: Whenever equipment protected by the C0: Systems is required to be OPERABLE.

ACTION:

a. With the cable spreading roor C0 system not OPERABLE, within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> establish a continuous fire wate1 with backup fire-suppression equipment.
b. WithoneormoreoftheaboverequiredC0; systems (asindicatedby asterisk (*)) not OPERABLE, within 1 t.our verify that the fire barrier between adjacent areas is OPERABLE, and:
1. If the fire barrier is OPERABLE, establish an hourly fire watch patrol for the affected area, or
2. If the fire barrier is not OPERABLE, establish a continuous fire watch for the affected area,
c. The provisions of Specification 3.0.3 are not applicable.

SURVEILLANCE RE0VIREMENTS 4.7.12.3.1 Each of the above required CO, Systems shall be demonstrated OPERABLE at least once per 31 days by verifying that each valve (manual, power-operated, or automatic) in the flow path is in its correct position.

MILLSTONE - UNIT 3 3/4 7-35

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I PLANT SYSTEMS.

BASES ,

L 3/4.7.11 SEALED SOURCE CONTAMINATION (Continued) u plutonium. This limitation will ensure that leakage from Byproduct, Source, and Special Nuclear Material sources will not exceed allowable intake values. ,

l Sealed sources are classified into three groups according to their use, ,

with Surveillance Requirements commensurate with the probability of damage to a source in that group. ~Those sources which are frequently handled are required to be tested more often than those which are .not. Sealed sources which are continuously enclosed within a shielded mechanism (i.e., sealed sources within radiation monitoring or boron measuring devices) are considered to be stored and need not be tested unless they are removed from the shielded mechanism.

3/4.7.12 FIRE SVPPRESSION SYSTEMS L

The OPERABILITY of the Fire Suppression Systems ensures that adequate l fire suppression capability is available - to confine and extinguish fires i

occurring in any portion of the facility where safety-related equipment is I

located. The Fire Suppression System consists of the water system, spray, and/ or sprinklers, CO2 , Halon, fire hose stations, and yard fire hydrants, l

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,

l. alternate backup. fire-fighting equipment is required to be made available in t l the affected areas until the inoperable. equipment is restored to service, c When the inoperable fire-fighting equipment is intended for use as a backup

! means of fire suppression, a longer period of time .is allowed to provide an alternate means of fire fighting than if the inoperable equipment is the primary means of fire suppression.

In the event'that the Fire Suppression System in the Cable Spreading Room is inoperable, a continuous fire watch is required due to the presence of h redundant safe shutdown systems and/or components in the Cable Spreading Room l that could be. damaged by a common fire. The criteria for redundancy is described in Branch Technical Position (BTP).9.5-1.

L lt The Surveillance Requirements provide assurance that the minimum OPERABILITY L requirements of the Fire Suppression Systems are met. .An allowance is made for l; ensuring a sufficient volume of Halon in the Halon storage tanks by verifying l- either the weight or the level of the tanks. Level measurements are uade by either a U.L. or F.M. approved method.

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.

MILLSTONE - UNIT 3 B 3/4 7-7

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i ELANT SYSTEMS I BASES 3/4.7.13 FIRE RATED ASSEMBLIES The functional integrity of the fire rated assemblies and barrier penetra-l tions ensures that fires will be confined or adequately retarded from spreading

-to adjacent portions of the facility. These design features minimize the possi-bility of a single fire rapidly involving several areas of the facility prior to detection and_ extinguishing of the fire. The fire barrier penetrations are l l

a passive element in the facility Fire Protection Program and are ' subject to l periodic inspections.

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Fire barrier penetrations, including cable penetration barriers, fire doors and dampers are considered functional when the vis ' ally observed condition is the  ;

same as the as-designed condition. For those fire berrier penetrations that are '

not in the as-designed condition, an evaluation shall be performed to show that 1 the modification has not degraded the fire rating of the fire barrier penetration. I During periods of time when a barrier is not functional, either: (1) a con-tinuous fire watch is required to be maintained in the vicinity of the affected I barrier, or (2) the fire detectors on at least one side of the affected barrier must be verified OPERABLE and an hourly fire watch patrol established until the ,

o barrier is restored to functional status.

l 3/4.7.14 AREA TEMPERATURE MONITORING The area temperature limitations ensure that safety-related equipment will not be subjected to temperatures in excess of their environmental qualification temperatures. Exposure to excessive temperatures may degrade equipment and can cause a loss of its OPERABILITY. The temperature limits include an allowance for instrument error of 12.20F.

MILLSTONE - UNIT 3 B 3/4 7-8 l

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' , ;- .i Docket No. 50-423-

, , B13582 Attachment 2 Millstone: Nuclear Power Station, Unit No. 3 Description of Proposed Changes to' Technical Specifications

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July 1990 l' "

y g m I U.S.' Nuclear Regulatory Commission

! # B13582/ Attachment 2/Page 1-July 31, 1990 L

L -Millstone Nuclear Power Station, Unit No. 3 p , Descriotion of Proposed Chanaes to Technical Soecifications l

A .' Descriotion of Chanaes l

1. Section 3.7.12.3
a. In the listing - of C0 an l asterisk has been - adde $to. systems requiredsystem each individual to .be operable, listed that does not protect areas where redundant safe shutdown equipment

!: or components are located. l l

l b. In the Action Statement, existing Part (a) has been revised and written as Part (a) and Part (b). The Cable Spreading Room is i the only single area where redundant safe shutdown equipment or components are located that have the potential to be damaged by  ;

a single fire. -The Action for inoperability of the.C0 System 2 l

, protection in this area has not been changed, but new is -  :

f specifically identified as new Part (a). New Part (b), which l l identifies those other areas where redur. dant safe shutdown J equipment do not pass through a single area, now requires the i

l verification of the operability of the fire barriers between l the adjacent , areas before establishing an hourly fire watch.

patrol. Additionally, this part now requires the establishment of a continuous fire watch if the integrity of the fire barriers is questionable and actually provides a higher level I of protection: than was previously- provided by this Technical l Specification. '

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c. Existing Part (b) is now identified as Part (c)-to account for the new expanded Parts (a) and (b). In addition, the applicability of Specification 3.0.4 has been removed to reflect changes previously submitted to the NRC Staff in a letter dated July 17, 1990.
2. Bases Section 3/4.7.12 l A new paragraph has'been added to the Fire Suppression System bases ,

to more fully describe the bases for the requirement of a continuous fire watch for the Cable Spreading Room. In addition, Branch l Technical Position (BTP). 9.5-1 has been identified as the source i providing the criteria for redundancy as it applies to safe shutdown '

equipment required to be available in the event of a fire.  !

3. Other Chanaes Because of the addition of a new paragraph in Bases Section 3/4.7.12 l on page B 3/4 7-7, existing Bases Section 3/4.7.13, Fire Rated l

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U.S. Nucl ear Regulatory Commission B13582/Att.'chment 2/Page 2 July 31, 1990 Assemb'iies, which begins on this page, has now been moved in- its entirety to the next. page, B 3/4 7-8. No changes to the content-or information in this section have been made.

B. Evaluation of Chanaes i The proposed coanges are mainly for clarification only and do not include any hardware modifications. In fact, the requirement to . now verify .i operability of fire barriers iur certain areas providea for a higher level of. protection then was previously provided. As such, there are no credible failure modes associated with these changes.

L The existing Technical Specification leaves the determination of which areas may require a continuous fire watch or only a fire watch patrol subject to interpretation. The proposed revised Technical Specification now specifically identifies the single area where redundant safe shutdown equipment or components are located and removes this element of interpre-tation. . In addition, this proposed Technical Specification now requires the verification of fire barriers for certain areas, along with the requirement for. a continuous fire watch _ if the integrity of the fire barriers are questionable, for those areas that previously- wotG have .

only required an hourly fire watch patrol. R The proposed Technical Specification clarifies the method and frequency of fire watches when any C0 fire suppression system is inoperable' by specifically identifying fir / watch requirements and increases the level of fire protection by now requiring the verification of the integrity of fire barriers. As such, the changes do not affect the current coverage or operability status of the C0 fire suppression systems and will not affect the design, testing, of surveillance requirements of the CO systems in any way. Additionally, there are no new failure modes associ-2 '

ated with the proposed changes, and no design basis accidents are affected.

The proposed changes do not increase the probability of any accident, 'and ,

'therefore the probability of a beyond design basis accident has not been increased to the point where it. should be considered within the design basis due to these changes. Based on this, the proposed changes do not affect the consequences of any design basis accidents. In addition, there are no-impacts on event consequences, and therefore these changes do not impact protective boundaries.

NNEC0 has reviewed the proposed changes in accordance with 10CFR50.92 and, based on the above, has concluded that the changes do not involve a significant hazards consideration in that these changes would not: '

1. Involve a significant increase in the probability of occurrence or the ccasequences of an accident previously identified. The proposed changes only provide clarification of the current requirements and

U.S. Nuclear Regulatory Commission-B13582/ Attachment'2/Page 3-

July 31,1990-have no impact on the probability of occurrence or consequences of 4 an accident previously identified.
2. - C eate the possibility of a new or different kind of accident from eny- previously analyzed. No new failure modes are introduced by +

ihese proposed changes, and since there is no change in the way the plant is operated, the potential for an unanalyzed accident is not treated.

3. I,1volve a significant reduction in a margin of safety. The proposed chinges do not impact any safety limits and do not; affect the-consequences of any accident previously analyzed. . Therefore, there is no reduction in a margin of safety.

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