ML20082D301

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Proposed Tech Spec Changes Re Fire Protection
ML20082D301
Person / Time
Site: Pilgrim
Issue date: 11/16/1983
From:
BOSTON EDISON CO.
To:
Shared Package
ML20082D288 List:
References
NUDOCS 8311220379
Download: ML20082D301 (10)
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Text

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Attachment Proposed Change to Fire Protection Technical Specifications Proposed Change The proposed change involves Pilgrim Nuclear Power Station Technical Specifica-tions, Appendix A, Section 3/4.12, Fire Protection. Specifically, it is proposed that the following technical specification subsections be modified as described below and as shown on the attached technical specification pages.

These technical specification pages remain unnumbered until the last fire protection technical specification submittal is made in complete form.

3/4.12.B Fire SuDDression Water System This subsection is to be replaced with the attached Subsection 3/4.12.B. Fire Water Supply System. Substantive changes to this subsection include:

1. Vague wording in Subsection 3.12.B.3 regarding water flow paths was revised to remove an unnecessary limiting condition for operation that could have been caused by an inoperable valve with two independent water flow paths still available.
2. To meet National Fire Protection Association (NFPA) requirements and

. to describe existing station practice, Subsection 4.12.B.l .b was revised to require running each fire pump for thirty minutes during testing.

3. Subsection 4.12.B.2.b was revised to update the revisions of ASTM standards pertaining to diesel fuel inspection. The revised subsection was renumbered as Subsection 4.12.B.1.h.
4. Various surveillance requirements in Subsection 4.12.B were combined, renumbered, or modified as deemed necessary.

3/4.12.C Soray and/or Sprinkler Systems This subsection is to be replaced with the attached Subsection 3/4.12.C, Spray and/or Sprinkler Systems. Substantive changes include:

1. The plant areas required to be operable in Subsection 3.12.C.1 and 4 were expanded to encompass plant design changes that have been made to the sprinkler systems in the diesel generator and recirculation pump MG set rooms.
2. The actions required in Subsection 3.12.C were revised to provide improved guidance for fire watch patrols. These changes were prompted by ALARA concerns and the desire to take credit for the redundant fire protection and detection mechanisms available.
3. The valve operability and surveillance requirements in Subsection 3/4.12.C were moved to revised Subsection 3/4.12.B. Fire Water Supply System.

8311220379 3 PDR ADOCK 0 0 PDR P

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3/4.12.D CO2 System 4 As described in the proposed technical specification change transmitted by letter from W. D. Harrington to D. B. Vassallo, dated October 13,1983 (BECo 83-257), this subsection is to be deleted. The use of CO2 at Pilgrim was replaced by installing a Halon system to serve the cable spreading room and by installing two new fire water hose stations to serve switchgear rooms A and B. The Halon system is specified by a new Subsection 3/4.12.E, Halon System, which was provided by the above referenced letter. The new fire water hose j stations have been added to revised Technical Specification Table 3.12-2. j i

3/4.12.E and Table 3.12-2 Fire Hose Stations  :

This subsection is to be replaced with the attached newly-numbered Subsection 3/4.12.0, Fire Hose Stations. In addition, Technical Specification Table 3.12-2, Fire Hose Stations, is to be replaced with the attached revised Table 3.12-2. Substantive changes include:

1. Table 3.12-2, Fire Hose Stations, was revised to include several new fire hose stations and to conform to a recent renumbering of the hose stations.
2. The action required by new Subsection 3.12.D.a was improved to reduce the probability of damage to fire hoses. Backup fire hoses would not be required to be physically connected and stretched out to prevent j

their exposure to physical damage from normal plant activities.

3/4.12.G Dry Chemical Systems This technical specification subsection pertaining to the diesel generator dry chemical systems is to be deleted. The newly-installed diesel generator preaction sprinkler system provides improved fire protection for the diesel generator rooms. Technical specificatio.is for this sprinkler system are provided in Subsection 3/4.12.C.

3/4.12.H Yard Hydrants and Exterior Hose Houses This technical specification subsection is to be deleted. The yard hydrants

and exterior hose houses were once temporarily added to provide hose protection to two interior plant areas that did not have appropriate interior fire hose stations. The appropriate interior fire hose stations have since been installed and provide improved fire protection to these areas. In a like manner, the attached revised Table 3.12-2, Fire . Hose Stations, has been revised to delete reference to these yard hydrants and exterior hose houses.

Reason for Chance These technical specification changes are being proposed to address plant design changes that have been made for fire protection and to address changes that are required by NFPA standards or are deemed desirable for safe and efficient operation of the Pilgrim Station.

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Safety Considerations These changes do not present an unreviewed safety question as defined in 10CFR50.59. 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 operation of the Pilgrim Nuclear Power Station in accordance with the proposed amendment would not (1) involve a significant increase in the probability or consequences 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 determining 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 stringent surveillance requirement..."

Proposed technical specifications of this type are those described above that add restrictions to address plant design changes or conformance to NFPA standards.

Those proposed changes that are deemed desirable, but do not add new restrictions, are examples of "...(vi) A change which either may result in some increase to the probability or consequences of a previously-analyzed accident or may reduce in some way a safety margin, but where the results of the change are clearly within all acceptable criteria..."

Schedule of Chance As stated in our letter of May 13, 1983, we expect the NRC to issue the proposed fire protection technical specification changes as a single amendment. This amendment will be effective upon our receipt of approval from the NRC.

Fee Determination Pursuant to 10CFR170.12, the Boston Edison Company proposes these changes as one segment of the fire protection submittal, which, when taken as a whole will be classified as a Class III amendment. Accordingly, a check for $4,000.

will be transmitted with the final segment of this amendment request.

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LIMITING CONDITION FOR OPERATION SURVEILLANCE REQUIREMENTS l

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3.12 FIRE PROTECTION 4.12 FIRE PROTECTION )

B. Fire Water SupplV System B. Fire Water Supply System The Fire Water Supply System shall 1. The Fire Water Supply System be operable with: shall be tested and verified to be OPERABLE:

1. Two (2) 2000 gpm/125 psig fire pumps which are arranged to a. by checking the volume of start automatically. water in each fire water tank at least once every
2. Two (2) water supplies with a 7 days.

minimum storage quantity of 240,000 gallons of water in b. by automatically starting each. each fire pump at least once every month and

3. Two (2) independent water flow running each pump for paths f rom Item Nos.1 & 2 thirty minutes at that above to each fire water sup- time.

pression system. (3.12.C and 3.12.0) c. by visually checking every shutoff valve on APPLICABILITY the fire water supply system at least once At all times when any safety related every month for equipment is required to be OPERABLE. proper position.

ACTION: d. by cycling each fire water supply system

a. With less than the above required shutoff valve through its equipment, restore the inoperable full operation at least equipment to OPERABLE status with- once per cycle, in 7 days or prepare and submit a report to the Commission within the e. by verifying at least next 30 days outlining the plans once per cycle that each and procedures to be used to pro- pump starts and delivers vide for the loss of redundancy in at least 2000 gpm while this system. maintaining a system pressure of at least 125
b. With no FIRE SUPPRESSION WATER psig.

SYSTEM OPERABLE, within 24 hrs.

f. by performing a Water
1. Establish the backup Fire Flow Test on the fire Suppression Water System. water yard loop at least once every year.
2. If the requirement of b.1 above cannot be met, an s. by verifying at least orderly shutdown of the once every month that the reactor shall be initiated diesel fire pump fuel and the reactor shall be in storage tank contains a the cold shutdown condition minimum of 175 gallons of within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. fuel oil.

LIMITING CONDITION FOR OPERATION SURVEILLANCE REQUIREMENTS

3. Notify the Commission and h. by verifying at least prepare and submit a report to once per 3 months that the Commission within the next a sample of diesel fuel 14 days outlining the cause f rom the fuel storage of the malfunctions, tank, obtained in accord-the action taken, and the ance with ASTM 0210-77, plans for restoring the system is within the acceptable to OPERABLE status, limits specified in Table 1 of ASTM 0975-75 with respect to viscosity, water content, and sediment.
1. by demonstrating that the diesel starting 24-volt battery bank and charger are OPERABLE as follows:
1. at least once per week by verifying that the electrolyte level of each battery is above the plates and battery voltage is at least 24 volts.
2. at least once per 3 months by verifying that the specific gravity is appropri-ate for continued service of the battery.
3. at least once per operating cycle by verifying that the batteries, all plates, and battery racks show no visu-al indication of physical damage or abnormal deteriora-tion and the bat-tery-to-battery and terminal connections are clean, tight, free of corrosion, and coated with anti-corrosion material.

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l LIMITING CONDITION FOR OPERATION SURVEILLANCE REQUIRENENTS C. Sorav and/or Sprinkler Systems C. Sorav and/or Sprinkler Systems The spray and/or sprinkler systems The spray and/or sprinkler systems located in the following areas shall shall be demonstrated to be be OPERA 8LE except as noted below: OPERABLE according to the following:

1. Diesel Generator Room Preaction 1. Each sprinkler system and sprinkler systems (including water spray system alarm detectors). shall be tested at least
once every year by opening
2. Diesel Fire Pump Fuel Oil the alarm bypass or in-Storage Room wet pipe sprinkler spector test valve. Alarms system. in high rad area are to be tested once per cycle.
3. Auxiliary Boiler Room wet pipe sprinkler system. 2. Each wet pipe sprinkler system shall be proven to be unob-
4. Recirculation Pump MG Set Room structed by opening the in-wet pipe sprinkler system. spector test connection at least once per cycle.
5. Standby Gas Treatment System J

water spray system. 3. Each preaction sprinkler system shall be trip tested at 4

6. Hydrogen Supply 011 Unit least once per cycle.

preaction sprinkler system.

4. Each water spray system shall
7. Turbine Basement Addition wet be trip tested automatically pipe sprinkler system. by simulated actuation of the heat detectors at least once APPLICABILITY per cycle.

At all times when equipment in the spray / 5. At least once per 3 years, a sprinkler protected area is required to flow test through each open be OPERABLE. head spray / sprinkler header shall be performed and each ACTIONS: open head spray / sprinkler

nozzle shall be verified to be
a. From and after the date that a unobstructed.

spray and/or sprinkler system is made or found to be INOPERABLE, within one hour establish a continuous fire watch patrol with backup suppression, or

b. If the suppression system of 3.12.C.1, 4, or 5 is inoperable, establish an hourly fire watch patrol with backup suppression

.provided that the detection system in that fire area and the detection and. suppression system for the redundant fire area is operable, or W

LIMITING CONDITION FOR OPERATION SURVEILLANCE REQUIREMENTS

c. If two or more detectors of 3.12.C.1 are found or made to be inoperable within one hour, charge the sprinkler piping with an equivalent water supply.

EXCEPTION: When the fire area protected by a spray and/or sprinkler system is 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.

D. Fire Hose Stations D. Fire _ Hose Stations The interior fire hose stations Each interior fire hose station shown in Table 3.12-2 shall be shall be verified to be OPERABLE:

OPERABLE.

1. At least once per month by APPLICABILITY: visual inspection of the station to assure that the At all times when the equipment in the hose and nozzle are properly area protected by the fire hose station installed.

is required to be OPERABLE.

2. At least once per cycle by ACTION: removing the hose for

- inspection, replacing degraded

a. With a hose station INOPERABLE, coupling gaskets and reracking.

provide an additional equivalent capacity hose for the unprotected 3. At least once per three (3) area at/from an OPERABLE hose years by:

4 station within one (1) hour,

a. partially opening each hose station valve to verify valve operability and no obstruction.
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

LIMITING' CONDITION FOR OPERATION SURVEILLANCE REQUIREMENTS

2) annually at the applicable service test pressure as listed in Table 821 of the " Standard for Care, Maintenance

/ and Usa of Hose",

NFPA No. 198-1972,

, 4 or

c. by replacing each hose with a new or used hose which has been hydrostatically tested in accordance with the pressures specified in 4.12. D.3.b.

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$' TABLE 3.12-2 g .-

st - FIRE H0SE STATIONS S

e E,f REACTOR BUILDING SECONDARY CONTAINMENT ACCESS LOCK Sta. # Sta. #

RB-13-117 North Wall, Elev.117' SL-F'-23 Reactor Bldg. Truck Lock RB-06-117 South Wall, Elev. 117' Elev. 23' RB-12-91 North Wall, Elev. 91' RB-05-95 Standby Liquid Control, REACTOR AUX. BAY fystem Area, Elev. 91' RB-11-74 4:"th Wall, Elev. 74' RA-41-23 Auxiliary Plant Heating' Boiler Room RB-04-74 r ue' Pool. Heat Exchanger Elev. 23'

....-r, Elev. 74' RA-42-06 RBCCW Loop B Area RB-09-51 North Wall, Elev. 51' Elev. 3' RB-03-51 Outside MG Set Room - RA-43-23 Water Treatment Area West Wall, Elev. 51' . .Elev. 23' RB-10-51 Inside North MG Set Airlock RA-44-06 Condensate Demin./ Resin Corridor Elev. 51' Area Elev. 3' RB-14-23 Decontamination Room North Wall, Elev. 23' RADWASTE'& CONTROL AREA RB-07-23 West Wall, RHR Loop B Stairway, Elev. 23' RC-73-01 Monitor Tank Pump Area RB-02-23 West Wall, RCIC Stairway .

.Elev. -l' Elev. 23' RC-57-01 Radwaste Stairway to Turbine RB-16-23 Reactor Bldg. Access Bldg. Elev. -l' Lock Elev. 23' RC-69-01 Outside Radwaste Control RB-15-03 CRD Quadrant Room Elev. -l' Elev. 2'9" RC-68-01 Radwaste Area North Corner, RB-17-03 RHR Quad Loop \ Elev. -l' Elev. 2'9" RC-56-23 Water Box Scavenging Pump RB-08-03 RHR Quad Loop B Area, Elev. 23' E! Elev. 2'9" RC 49-23 Stairway Outside Vital MG EE RB-01-03 RCIC Quad Set Room Elev. 23' Elev. 2'9" RC-72-23 Corridor Switchgear Room B Elev. 23' TB-39-51 East Wall Near B-8 Load Center Elev. 51'

4 TABLE 3.12-2'(Continued)

y TURBI.NE BUILDING RADWASTE & CONTROL AREA - Continued U Sta. # TB-38-51 Between Feed Pumps and Turbine F'ev. 51' 5 TB-35-06 West End Elev. 6' TB-37-51 Reactor Feed Pump Area Elev. 51' TB-29-06 East Wall Elev. 6' RC-65-51 Outside Microwave Room, Elev. 51' South Wall East Condenser Area'. RC-59-37 Stairway Outside Control Room TB-28-06 URC Control Panel Elev. 3'- Elev. 37' TB-27-06 Condensate Demin. Area Doorway RC-66-37 Radiation Chemical Lab, Elev. 37' TB-33-51 South Wall Near VSF-102A, Elev. 51' RC-62-37 Maintenance Office, Elev. 37' TB-30-06 Southeast Corner Pine Area, Elev. 3' RC-63-37 Maintenance Office North End, Elev. 37' TB-32-51 South Wall Elev. 51' RC-64-23 Maintenance Office Area, Elev. 23' TB-31-51 South Wall, Elev. 51' RC-61-23 Machine Shop Across From Lathe, Elev. 23' TB-34-51 West Wall Elev. 51' RC-67-23 Access Control Area, Elev. 23' TB-26-37 Recombiner Room Door Elev. 37' ,

TURBINE AUX. BAY TA-86-51 Outside Standby Gas Room TA-87-51 Outside Fan Room #1, Elev. 51' 0FF-GAS RETENTION BUILDING OR-91-23 Retention Building, Elev. 23' OR-93-05 Retention Building, Elev. 5' OR-92-06 Retention Building, Elev. -6' DIESEL GENERATORS DG-46-23 Diesel Generator Room A DG-47-23 Diesel Generator Room B INTAKE STRUCTURE

$ IS-96-23 Near Fire Pu,nps

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