ML20086Q422

Proposed Tech Spec 4.12.F.1.a Re Visual Insp Interval for Fire Barrier Penetration Seals

ML20086Q422
Person / Time
Site:	FitzPatrick
Issue date:	12/19/1991
From:	POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
To:
Shared Package
ML20086Q416	List: JPN-91-069, Forwards Application for Amend to License DPR-59,changing Tech Spec 4.12.F.1.a to Provide 3-month Extension Until 920515 to Complete Fire Barrier Penetration Seal Visual Insp ML20086Q420 ML20086Q422
References
NUDOCS 9112300184
Download: ML20086Q422 (7)

Text

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% 4 ATTACHMENT l to JPN 01069 PROPOSED TECHNICAL SPECIFICATION CHANGES '

ONETIME EXTENSION OF FIRE BARRIER PENETRATION SURVEILLANCE INTERVAL (JPTS-91430) l 1

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4 New York Power Authority JAMES A. FITZPATRICK NUCLEAR POWER PLANT Docket No. 50-333 -

DPR-59 '

1 1 9112300184 911219 FDR ADOCK 05000333  !

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E. Rre Protection Systems Smoke and Heat Detectors E. Rre Protection Systems Smoke and Heat Detec, tors

1. a. Fire protection systems smoke and/or heat 1. A chanrK.H octional test of smoke and heat detectors and I

- detectors in each protected area as designated in associated circuitry shall be performed every 6 months. i Tables 3.12.1 and 3.122 shall be operable except as This test includes operability of valves associated with the l specified below: detectors and verifying that the automatic valves in the  !

flow path actuate to their correct poshions. i

b. From an-* after the date that more than one smoke and/or but detector in each protected area is found i or made inoperable within one hour an hourly patro!!ing fire watch shall be establisheci. ,

I 2. IF the fire protection systems smoke and/or twat detectors in Tables 3.12.1 and 3.122 cannot be restored to an operable status within 14 days, a wTitten report to the Commission outiining the action taken, the cause of  ;

inoperability and plans and schedule for restonng the -  ;

detectors to an operable status sha!! he prepared and submitted witnin 30 days.  !

t F. Are Barrier Penetration Seais F. Rre Ba rier Penetration Seals  !

1. a. The fire bamer penetration seals shall be functional 1. a. A!! fire bamer ;mr=hdion seals for each protected l'

. for each protected area except as specified below- area sha!! be visually inspected once/1.5 years to verify furdiOW integnty.* l

- b. Within one hour . that any of the . fire barrier 5

penetration seals for any protected area is found or b. Any repair of fire barrier perubdion seals sha3 be made non-functional a continuous fire watch shall be fo!!cwed by avisualir@l established on one side of the fire barrier.

t The current surveillarce interval for visua!y inspecting fire i

bamer penetration seals is extended until f/ay 15,1992.

This is a onetime extension, etfective only for this <

inspection interval. The next surveillance interva! began  !

Amendment No. - , September 27,1991.  ;

2449

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Attachment 11 to JPN 91 OG9 SAFETY EVALUATION FOR PROPOSED TECHNICAL SPECIFICATION CHANGES ONETIME EXTENSION OF Fl9E BARRIER PENETRATION SURVElu.ANCE INTERVAL (JPTS 91030)

1. DESCRIPTION OF THE PROPOSED CHANGE The proposed chan00 to tho James A. FitzPatrick Tochnical Specifications is as follows:

Pago 2440, Specification 4.1PJ Add an astorisk to the oM o Spocdr ation 4.12.F.1.a.

Add at the lower right hand :orner of the pago the following fouinote:

"The curront survoitiance interval for visually inspecting firo barrior ponotration seals is extended until May 1!,1992. This is a onethno extonsion, offectivo only for this Inspoction interval. The next survoillarr.o interval bogan September 27,1991.*

11. PURPOSE OF THE PROPOSED CHAhGE The croposed chango to the James A. FitzPatrick Technical Specifications extends tho survol!!anco Interval for firo barrior ponotration soals schedulod to end on September 27,1991 until May 15,1992.

Firo barrior ponotration seals protoct equipmont required to mitigato accidonts and perform other safoty related functions from the offoct of fires. Technical Spocification 4.1EF.1.a requires that all firo barrior ponotration seals for each protected area bo visually inspected o?co overy 18 months.

The schedulod completion dato for this survoillanco interval was September 27,1991. Technical Specification 4.0.B.1 allows the Authority to extend survolllance intervals by a maximum of 25%

Applying this extension extends the completion dato until February 11,1992. This proposed chango requests a throo month extension in addition to the 25% permitted by Specification 4.0.B.1 until May 15,1992.

At an August 2,1991 mooting with the NRC's Roglon I staff, the New York Power Authority committed to complete a full basolinn barrior soal inspection not lator than 30 days after startup from tho 1993 refuel outago (Referenco 1). The Authority accolorated its basolino inspection schedulo by 18 months to run concurrently with the firo barrior penetration scal ic.spections iequired by Technical Specifications 4.12.F.1.a. Each ci those inspections takes longer bocarso tho baso!!no ine.poetion requiromonts are moro dotallod than thoso previously employod at FitzPatrick. The first fire barrior ponotration soal was inspected on November 8,1991.

Ill, SAFETY IMPUCATIONS OF THE PROPOSED CHANGE Firo barrior ponotration seal inspections can bo safely extended until May 15,1992 for th6 following reasons:

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. Attachmont 11 to JPN 910G9 SAFETY EVALUATION Pago 2 of 5 The ability of the plant to detect and suppress a fire will not be significantly degraded as a result of this extension. Other existing fire protection systems and featuros will further assure that a fito in tho vicinity of a non functional firo barrior ponotration seal will bo promptly detocted and extinguishod. Thoso includo:

. Automatic supprossion and/or detoction systems aro Installed in somo fire hazard arcas including carbon dioxido systems, halon and water sprays. l

. Manual hose stations aro installod throughout the plant.

. A trained firo brigado is on sito to respond to a fire. l

. A local firo departmont it, available to rospend to a fire.

. Portablo extinguishers are installod throughout the plant.

. Firo protoction systems are periodically tostod to assure that they aro capablo of performing their intended function.

. Firo barriors separato safoty related compononts and reduce the potential for tho spread of fire betwoon fire areas or zonos.

. An attornato safo shutdown panol, proceduros and oporator training will assure that the plant can be safely shutdown and maintainod in a shutdown condition.

. The physicalintogrity of structural stoolis assured by fire proof coatings.

. Emergency lighting and communication systems havo boon Installed.

No significant seal degradation is expected during extension period. Existing seals will not be significantly affected during tho relatively short throo month extension the Authority has roquestod. Because of the design and matorials used in the construction of fire barrior ponot atica seals, they do not degrado rapidly Degradation normally occurs duo to the long term offects of moisturo, heat, radiation, physical v; oar and dirt. The small amount of degradation the seals may undorgo during the extension period is insignificant and will not significantly reduce their abihty to provent the spread of fire from ono sido of tho barrior to the other.

This is a one time extension. The Authority will not request any additional or further extensions to the fire barrior ponotration soal survoillanco test interval.

The three month extension requented by the Authority is less than 12 percent of the maximum inspection interval permitted by the existing specification. FitzPatrick Surveillanco Roquiromont 4.12.F.1.a requires that fito barrior ponotration scals be visually inspected once ovory 18 months (1.5 years). Section 1.0.T 'SurvoiPanco Frequency" (p. 5) and Section 4.0.B "Surveillanco Requiroments-General" (p. 30) permit surveillanco intervals to be extended a

l Attachment 11 to JPN 91069 SAFETY EVALUATION Pago 3 of 5 4

maximum of 25 porcont. Applying this extension to the fire barrior ponotration scalinspoction interval yloids a maxirn'Jm intorval of 22.5 months (10 month + 4.5 months).

The next scheduled inspection will not be delayed as a result of this extension. This is consistont with FitzPatrick Specification 1.0.T 'Survolllance Frequency' for casos whoro the clapsod inspection Intorval exccads one hundred percent of the inspection Interval. Specification 1.0.T states in part

• In casos whoro tho olapsod interval has excoodod 100 porcont of tho speciflod interval, the next surveillanco intorval shall commence at the end of the original specified intorval."

Sinco the last inspection Interval onded on September 27,1991, the next 18 month firo barrior inspection interval will end on March 27,1993. (Application of the twenty fivo porcent extension permittod by Spocifications 1.0.T and 4.0.0 could be appiled to extend this dato until August 11, 1993.)

The inspection procedure and acceptance criteria is more detailed than used in pact inspections. As a basoline inspection, this inspection uses inspection requiremonts moro detailed than proviously employed at FitzPatrick and new acceptance critoria. The first firo barrior penetration soal was inspected on November 8,1991.

These baseline Inspections are being conducted on an expedhed basis. Authority personnot are working two snitts to complete thoso inspections on an accelerated schedulo. Approximately 8000 (or 57 porcent) of the approximately 14000 penetration inspections will be completod by the expiration of the original survoillanco interval (February 11,1992). The additionalthroo months roquestod by this extension is required to complete all inspections, FitzPatrick Surveillance Requirement 4.12.F.1.a requires a visual inspection of all fire barrier penetration seals every eighteen months. A 100 percent inspection provides a very high degroo of confidence in the ability of the operability of fire barrier seals. Other visual technical specifications survoillance requiromonts do not mandate a 100 percent sample of installod compononts. For example, shock supprossors (snubbers) need only be sampled during tho inspection interval to assuro that they are oporable. Samplo size is increased and inspection intervalis decreased as a function of the type (category) of snubbor and thelt failuro rato L (Referenco 2). A similar inspection program could be applied to the visual Insretion of fire barrior penetratlun seals to reduce personnel radiation exposure without reducirQ confidece in tho seals operability. .

The eighteen month surveillance Interval is based on a nominal fuel cycle length not on operating experience or anticipated failure mechanisms. Although the Authority has not boon able to confirm the basis for the eightoon month inspection interval, Indications are that it was selected to coincide with the nominal longth of a reactor fuel cycle. This would permit access to ponoWation seals in radiation ercas during refueling outago when radiation levels are gonorally lower and minimizo personnel radiation exposure incurred during the inspections. The Authority did not identify any other reason (based on operating experience or anticipated falluto mechanisms) for the eighteen month interval.

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Attachmont ll to JPN 91069 SAFETY EVALUATION Page d of 5 New baseline criteria is resulting in a higher than anticipated inspection failure rate. As of December 18,1991, approximatoly 1812 ponotrations at FitzPatrick have boon Inspected under this program. This reprosonts approximately 26 porcent of the approximatoly 7,000 ponotration seals at FitzPatrick. Engincoring ovaluations have boon completed for 1617 of the ponotrations inspected. Ono thousand, one hundred and forty six of thoso moot the now acceptanco critoria.  !

Ono hundred and fifty flvo of those penetrations did noi moot the now acceptanco critoria but not to tho extent that they woro declared inoporablo. Throo hundred sixtoon of thoso penotrations did not moet the now acceptanco critoria and were declared inoperable, This reprosonts a significantly higher failuro rato than anticipated by the Authority.

IV. EVALUATION OF SIGNIFICANT HAIARDS CONSIDERATION Operation of the FitzPatrick plant in accordanco with the prcposed Amendment would not involvo a significant hazards consideration as defined in 10 CFR 50.92, sinco it would not:

1. involvo a significant inercaso in the probability or consequences of an accident )

previously evaluated. 1 The proposed one timo extension of the firo barrior ponotration sealinspoction interval involves no hardware modifications, changos to systom merating proceduros or affects tho ability of any system to perform its intendod function. The probability of a firo is not increasod and the ability of plant porsornol and fire protection equipment to detect and extinguish a firo is not affected. The proposed one ilmo extension of the fire barrior ponotration soal inspection interval will not introduco any additional combustibio materials or Ignition sources into the plant,

2. croato the possibility of a now or different kind of accident from thoso previously evaluated.

The proposed one timo extension of the firo barrior penotration coal inspection Interval doos not creato the possibility of a now or different kind of accident or fire. Analysos havo boon performed based on the presence of a firo in each area or zone regardless of the actual fire hazard and combustible loading present. Fire protection features (including fire barriors and firo barrior ponotration seals) have boon installed throughout the plant to limit the spread of fires betwoon zones and areas. Analysos hava demonstrated that the plant can be safely shutdown and maintained in a shutdown condition assuming the loss of all equipment is any singlo fire area or zone.

3. Involvo a significant reduction in the margin of safety.

The proposed one timo extension of the fire barrior ponotration soal inspection interval does not reduce the ability of the barriors to perform their intended function. The small amount of degradation the seals may undergo during this porlod is insignificant and will not significantly reduce their firo rating or their ability to provent the spread of fire from one sido of the barrior to the other. In addition, other fire protection features romain available to detect and suppress a fire. Firo watches will be posted for non-functional seals in accordance with Technical Specification requiremonts.

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. Attachment 11 to JPN 91-0G9

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SAFETY EVALUATION Pago 5 of 5 V. IMPLEMENTATION OF THE PROPOSED CHANGE Tho proposed onetimo extension of the fire battler penetration seat inspection interval will not affoct the Fire Protection program or the environmont. The extension will only increase tho amount of timo available to comploto the inspection required by Specification 4.12.F.1.a.

VI. CONCLUSION Thoso changos, as proposed, do not constiteto an unroviewed safety question as defined in 10 CFR E0.59, That is, they:

1. will not increase the probabi,ity of occurrence or the consequences of an accident or malfunction of equipment important to safoty previously evaluated in the safety analysis repor1;

2. will not increase the pc ability for an accident or malfunction of a typo different from any evaluated previously in tho safoty analysis report;

3. will not reduce the margin of safety as defined in the basic for any technical specification; and

4. - involves no significant hazards consideration, as defined in 10 CFR 50.92.

Vll. REFERENCES

1. NYPA letter, R.E. Beodio to U.S. NRC, dated September 13,1991, (JPN 91@0),

regarding schedulo for long term fire protection actions.

2. NRC Generic Letter 90-09, ' Alternative Requirements for Snubber Visual inspection intervals and Correctivo Actions", dated December 11,1990._

3. James A. FitzPatrick Nuclear Power Plant Updated Final Safety Analysis Report, Section 9.8.

4. James A. FitzPatrick Nuclear Power Plant Safety Evaluation Report (SER), dated November 20,1972, and Supplements.

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