ML20077R310

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Proposed Change 83-9 Revising Tech Spec 3/4.12 Re Fire Protection
ML20077R310
Person / Time
Site: Pilgrim
Issue date: 09/12/1983
From:
BOSTON EDISON CO.
To:
Shared Package
ML20077R178 List:
References
NUDOCS 8309160291
Download: ML20077R310 (6)
v • d • e


Text

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Attachment Proposed Technical Specification Change Proposed Change Reference is made to Pilgrim Nuclear Power Station, Unit #1 Technical Specifica-tions, Appendix A, Section 3.12, " Fire Protection."

Item 3.12.F The Limiting Condition for Operation, Surveillance Requirements, and Bases for Item 3.12.F are changed in their entirety. The existing Item 3.12.F is reproduced below. Refer to Pages 206e, 206e-1, and 206j in this Attachment for the proposed replacement of Item 3.12.F.

LIMITING CONDITION FOR OPERATION SURVEILLANCE REQUIREMENTS F. Penetration Fire Barrier F. Fire Barrier Penetration Fire Seals All fire barrier penetration fire seals protecting safety related 1. Penetration fire barriers areas shall be functional. shall be verified to be functional by a visual APPLICABILITY: At all times. inspection at least once per operating cycle and ACTION: subsequent to any instal-lation, modification, or With a penetration fire barrier maintenance, not functional, a continuous fire patrol 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 />. (NOTE: In the case of the fire penetration barrier between the main steam tunnel and turbine building, substi-tute a "once per hour fire patrol" for the " continuous fire patrol").

(Bases appear on next page) .

8309160291 830912 PDR ADOCK 05000293 PDR p

Bases 3/4.12F FIRE BARRIER PENETRATION SEALS The functional integrity of the fire barrier penetration seals 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 extinguishment. The fire barrier penetration seals are a passive element in the facility fire protection program and are subject to periodic inspection.

During periods of time when the seals are not functional, a continuous fire patrol is required to be maintained in the vicinity of the affected seal until the seal is restored to functional status.

The substitution of action statements from " continuous fire patrol" to "once per hour fire patrol" for the fire penetration barrier between the main steam tunnel and turbine building is based on:

(1) Only one fire barrier between the Turbine Building and reactor building is required. Thus, the steam tunnel can be included with either the RHR "A" Valve Room or Turbine Ruilding fire areas.

(2) The existing configuration (i.e. no door and an unrated blowout assembly) provides adequate fire separation and protection capabilities on the following bases:

(a) Combustible loadings in the areas of concern are very low. Tran-sient loadings are administratively controlled.

(b) The blowout panel is constructed of materials consistent with

" rated" fire barriers offering protection up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.

(c) A fire detection system exists in the RHR Valve Room and a fire suppression system exists in the Turbine Building.

Reason for Change The existing Technical Specifications address only fire barrier penetration seals.

The entire fire barrier system should be addressed in accordance with the logic presented in 10CFR50, Appendix R. This proposed change expands the scope of the Technical Specifications to more fully comply with 10CFR50, Appendix R. Specifi-cally, requirements for operability and surveillance of fire doors and dampers have been added. Appropriate action statements are specified if fire doors or dampers are not functional. These action statements are consistent with the BWR Standard Technical Specifications. The only exceptions are when High Radiatiori Areas (> 100 mr/hr) exist on both sides of a fire barrier. An hourly fire patrol for these situations seems justified based on ALARA concerns when weighed against the risk posed by a station fire.

Safety Considerations These changes do not present an unreviewed safety question as defined in 10CFR 50.59. They have been reviewed and approved by the Operations Review Committee and reviewed by the Nuclear Safety Review and Audit Committee.

Significant Hazards Considerations It has been determined that the amendment request involves no significant hazards consideration. Under the NRC's regulations in 10CFR50.92, this means that opera-tion of the pilgrim Nuclear Power Station in accordance with the proposed amend-ment would not (1) involve a significant increase in the probability or conse-quences of an accident previously evaluated; or (2) create the possibility of a new or different kind of accident from any accident previously evaluated; or (3) involve a significant reduction in a margin of safety.

The NRC has provided guidance concerning the application of standards for deter-mining whether license amendments involve significant hazards considerations by providing certain examples (48 FR 14870). One example of an amendment that is considered not likely to involve a significant hazards consideration is "...(11)

A change that constitutes an additional limitation, restriction, or control not presently included in the technical specifications: for example a more strigent surveillance requirement..." This proposed change adds requirements for oper-ability and surveillance of fire doors and dampers.

Schedule of Change As stated in our letter of May 13, 1983, we expect the NRC to issue the seven submittals as a single amendment. This amendment will be effective upon our receipt of approval from NRC.

Fee Determination Pursuant to 10CFR170.12, Boston Edison Company proposes these changes as one seg-ment of the Fire Protection submittal, which, when taken as a whole will be classified as a Class III amendment. Accordingly, a check for $4000 will be transmitted with the final segment of this amendment request.

LIMITING CONDITION FOR OPERATION SURVEILLANCE REQUIREMENTS E. Fire Hose Stations E. Fire Hose Stations The interior fire hose stations Each interior fire hose station shall shown in Table 3.12-2 shall be be verified to the OPERABLE:

OPERABLE.

1. at least once per month by visual APPLICABILITY: inspection of the station to assure all equipment is available.

At all times when the equipment in the area protected by the fire 2. at least once per cycle by re-hose station is required to be moving the hose for inspection, operable, replacing degraded coupling gaskets, and re-racking.

ACTION:

3. at least once per 3 years by With a hose station inoperable, route an additional equivalent a. partially opening each hose capacity hose to the unprotected station valve to verify area from an OPERABLE hose station valve operability and no within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. blockage.
b. by conducting a hydrostatic test of each hose
1) at a pressure 50 psig greater than the maximum available pressure at that hose station, or
2) annually at the applicable service test pressure as listed in Table 821 of the

" Standard for Core, Main-tenance and Use of Hose,"

NFPA No. 198-1972, or

c. by replacing each hose with a new or used hose which has been hydrostatically tested in ac-cordance with the pressures specified in 4.12., E.3.b.

F. Fire Barrier System F. Fire Barrier Penetrations All fire barrier systems providing 1. Fire barrier penetration seals separation of redundant safe shut- Each fire barrier penetration seal down systems shall be functional. shall be verified to be functional l

by a visual inspection at least APPLICABILITY: once per operating cycle and'sub-At all times when the safe shut- sequent to any installation, mod-down systems are required to be ification or maintenance affecting l operable. the seal.

2. Fire Doors A TION- Each fire door shall be tested With one or more of the required once per cycle for operability fire barrier systems non-functional, of closure and latching mechanisms within one hour either establish a and for integrity.

l continuous fire watch patrol on 206e one side of l

sendment No. . .- -

LIMITING CONDITION FOR OPERATION SURVEILLANCE REQUIREMENTS the affected barrier or verify the 3. Fire Dampers OPERABILITY of an automatic fire Each fire damper shall be detection or suppression system on tested once per cycle for at least one side of the non- operability and integrity.

functional fire barrier and estab-lish an hourly fire watch patrol.

EXCEPTION: When the Fire Areas on A BOTH sides of the effected fire /F\

barrier are designated "HIGH RADIATION AREAS", an hourly fire watch patrol may be established (e.g. for ALARA considerations) in lieu of a continuous fire watch patrol.

G. Dry Chemical Systems G. Dry Chemical Systems The fixed dry chemical systems Each dry chemical shall be verified located in the following areas to be OPERABLE:

shall be OPERABLE: A. At least once per 6 months by

1. Diesel Generator Room ,,A,,.

checking all stored dry chemical

2. Diesel Generator Room B. containers by pressure and weight APPLICABILITY against the required minimums.

At all times when equipment in B. At least once per 18 months by:

the protected area is required to be operable. 1. Verifying the system actuates manually and automatically, ACTION: upon receipt of a simulated With a dry chemical system test signal, and inoperable, establish a con-tinuous fire patrol with 2. Performance of a flow test backup fire suppression through headers and nozzles equipment for the unprotected to assure no blockage.

areas within one hour; restore the system to OPERABLE status within 14 days or prepare and submit a Special Report to the Commission within the next 30 days outlining the action taken, the cause of the inoperability and the plans for restoring the system to OPERABLE status.

H. Yard Hydrants and Exterior Hose H. Yard Hydrants and Exterior Hose Houses Houses

The yard hydrants and exterior Each hydrant shall be verified hose houses shown in Table OPERABLE

3.12-2 shall be OPERABLE.

1. At least once per month by a APPLICABILITY: At all times. visual inspection of the hose ,

ACTION: house to assure all equipment ~

With a yard hydrant inoperable, is available.

within one hour have a sufficient number of additional lengths of 2. At least twice per year (once 2-1/2" diameter hose located in in the fall and once in the an adjacent OPERABLE hydrant's spring) by inspecting each out-hose house to provide service I aoor fire hydrant.

to the area protected by the  !

inoperable hydrant. i 3. At least once per year by per-forming surveillance requirements E.3.b or c.

Amendment No. g 206e-1

BASES 3/4.12F FIRE BARRIER SYSTEM The functional integrity of the fire barrier system ensure:., that fires will be confined or adequately retarded from spreading to adjacent portions of the facility. A functional fire barrier system, is considered to be the barrier itself with all penetration seals, doors and dampers intact or operable. This design feature minimizes the possibility of a single fire rapidly involving several areas of the facility prior to detection and extinguishment. The fire barrier systems are a passive element in the facility fire protection program and are subject to periodic inspections.

Safe shutdown systems are those systems which must operate after a {

loss of offsite power and are required to achieve and maintain safe shutdown i (hot and cold shutdown) conditions. kll During periods of time when the barriers are not functional, either, j

1) a continuous fire watch patrol is required to be maintained in the ,

vicinity of the affected barrier, or 2) the automatic fire detection or l suppression system on at least one side of the affected barrier must be '

verified OPERABLE and an hourly fire watch patrol established until the ,

barrier is restored to functional status. A fire watch patrol is a compensatory measure to survey area (s) in which the active and/or passive fire detection, suppression or barrier system (s) are in a degraded mode and is utilized for .

detection and reporting of fires. I The surveillance requirements are considered to be adequate since they were determined using accepted industry .eference material as a basis applying good engineering judgement and station operating considerations. '

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