ML20105C424
| ML20105C424 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 11/07/1983 |
| From: | Benaroya V Office of Nuclear Reactor Regulation |
| To: | Thomas C Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML19303B912 | List: |
| References | |
| TAC-51479, NUDOCS 8311140486 | |
| Download: ML20105C424 (7) | |
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ATTACHMENT 2
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[kj UNITED STATES g
NUCLEAR REGULATORY COMMISSION r,
r; waswiscrow. o. c. rosss e
f NOV 7 1983 MEMORANDUM FOR:
Cecil 0. Thomas, Chief Standardization and Special Projects Branch Division of Licensing FROM:
Victor Benaroya, Chief Chemical Engineering Branch Division of Engineering
SUBJECT:
GRAND GULF NUCLEAR STATION UNIT 1 - TECHNICAL SPECIFICATIONS (TAC #51479)
Plant Name: Grand Gulf Nuclear Station Unit 1 Docket No.:
50-416 Licensing Stage:
OL Milestone No.: N/A Responsible Branch & Project Manager:
LB #2; D. Houston Reviewers:
J. Stang, F. Witt Requested Completion phte: October 31, 1983 Status:
Complete We have reviewed the plant Technical Specifications and compared them to the Standard Technical Specifications to identify any deviations. Our findings are attached in (Enclosure 1).-
In addition, we recommended that emergency lights and portable fire extinguishers also be included in the technical specifications.
Proposed technical specifications for both are enclosed. (Enclosure 2).
By letter dated ' September 9,1983, the aplicant proposed additional changes to the fire detection instrumentation and hose station sections of the fire protection technical, specifications.
We have reviewed the proposed changes and compared them to the Standard Technical Specifications to identify any deviations.
Our findings are included in Enclosure 1.
With the revisions as stated in the enclosures we conclude that these sections of the plant technical specifications are acceptable.
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Victor Benaroya, C tef
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Chemical Engineering Branch Division of Engineerng
Enclosures:
As stated 46 'I cc: See next page
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y Contacts:
F. Witt J. Stang x28360 x24730
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r, NOV 7 1983
'C:cil 0. Thomas -
cc:
R'. Vollmer W. Johnston D. Eisenhut S. Pawlicki T. Sullivan R. Ferguson C. McCracken D. Hoffman i
F. Miraglia D. Brinkman J. Stang F. Witt D. Houston S
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ENCLOSURE 1 Chemical Engi.neering Branch Comparison of Technical Specification to The Standard Technical Specification Grand Gulf Nuclear Station Unit 1 Docket No.,50-416 We have reviewed Sections 3/4.4.4, Chemistry; 6.8.4.c, Administrative Controls Post-Accident Sampling; 3.3.7.9, Fire Detection Instrumentation; 3.7.6.1, Fire Suppression Water System; 3.7.6.2, Spray and/or Sprinkler Systems; 3.7.6.3, CO Systems; 3.7.6.4, Halon Systems; 3.7.6.5, Hose Stations; 2
3.7.6.6, Yard Fire Hydrants and Hydrants Hose Houses, 3.7.7, Fire Rated Assemblies, and compared them to the Standard Technical Specification.
Based'on our review, we conclude Section 3/4.4.4, Chemistry and 6.8.4.c, Administrative Controls Post-Accident Sampling are acceptable.
We recommend the following chang'es to the remaining sections:
1.
Page 3/4 7-28, paragraph 3.7.6.1 Action paragraphs a. and b. - these paragraphs should be rewritten as follows:
a.
With.one pump and/or one fire water storage tank inoperable, restore the inoperable equipment to OPERABLE status within 7 days or provide an alternate backup pump.or supply.
The provisions of Specifications 3.0.3 and 3.0.4 are not app.licable.
' b.
With the F, ire Suppression Water System otherwise inoperable establish a backup Fire Suppression Water System within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
2.
Page 3/4 7-29, paragraph 4.7.6.1.1c. - Add the following surveillance requirement: (At least once per 6' months,by performance of a system flow test).
3.
Page 3/4 7-31, paragraph 3.7.6.2 - Action paragraph a. - delete the special reporting requirement to the Commission.
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4.
Page 3/4 7-3, paragraph 4.7.6.2 - Add the following surveillance requirement.
By a visual inspection of each nozzle's spray area.to j
verify the spray pattern is not obstructed.
5.
.Page 3/4 7-33, paragraph 3.7.6.3 - Action paragraph a. - delete the special reporting requirement to the Commission.
6.
Page 3/4 7-36, paragraph 3.7.6.4 - Action paragraph a. - delete the special repo'rting requirement to the Commission.
7.
Page 3/4 7-37, paragraph 4.7.11.4b - this paragraph should be rewritten as follows:
b'.
At least once per 6 months by verifying Halon storage tank weight to be at leas't 95% of full charge weight (or level) and pressure to be at least 90% of full charge pressure, and 8.
Page 3/4 7-36,-paragraph 3.7.6.4 - Acti~on paragraph a. - delete the special reporting requirement to the Commission.
9.
Page 3/4 7-39, paragraph 3.7.6.6 - Action paragraph a. - delete the special reporting requirement to the Commission.
10.
Page 3/4 7-41, paragraph 3.7.7 - Action paragraph a. - delete the
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specialreportingrequirementtotheCommission}.
In addition, we recommend that the fire extinguishers and emergency lights be included _in the Technical Specifications.
The emergency lights are needed for performing post-fire safe shutdown.
The portable extinguishers are an,important early fire defense to prevent small' fires from becoming large fires and reducing fire, smoke and suppressant damage to redundant safety systems. contains proposed technical specifications for the emergency lights an'd fire extinguishers.
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By letter dated September 9, 1983, the applicant requested changes to the Fire Detection Instrumentation and Hose Station sections of the Technical g
Specifications.
Based on our review, we conclude that the changes to the Hose Station section reflect the as-built conditions in the plant and therefore are acceptable.
We recommend the following changes to the Fire Detection Instrumentation Section of the proposed technical specification.
1.
Page 3/4 3-76, paragraph 3.3.7.9 - Action paragraphs a.,
- b. and c. -
these paragraphs should be rewritten as follows:
With any, but not mor,e than one-half the total in any fire zone, a.
Function A fire detection instruments shown in Table 3.3.7.9-1 inoperable, r:e' store the inoperable instrument (s) to operable status within 14 days or within the next I hour establish a fire watch patrol to inspect the zone (s) with the inoperable instrument (s.)
at least once per hour, unless the instrument (s) is located inside the containment, drywell, or steam tunnel then inspect that containment zone at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> (or monitor the containment drywell and steam tunnel air temperatures at least once per hour at the locations listed in Specification 4.6.1.6).
b.
With more than one-half of the Function A fire detection instruments in any fire zone shown in Table 3.3.7.9-1 inoperable, or with any Function B fire detection instruments shown in Table 3.'3.7.9-1 inoperable, or with any two or more adjacent fire detection
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instruments whown in Table 3.3.7.9-1 inoperable, within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> establish a fire watch patrol to inspect the zone (s) with the l
inoperable instrument (s) at least once per hour, unless'the instrument (s) is located inside the containment, drywell, or steam tunnel then inspect thit containment zone at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> (or' monitor the containment air temperature drywell and steam tunnel at least once per hour at the locations listed in Specification 4.6.1.6).
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c.
The provsions of Specifications 3.0.3 and 3.0.4 are not applicable.
2.
Page 3/4 3-77, 3/4 3-78, 3/4 3-79, 3/4 3-80, 3/4 3-80a, 3/4 3-80b, 3/4 3-80c and 3/4 3-80d.
Table 3.3.7.9.1 - Revise table 3.3.7.9-1 using the following as an illustration:
TABLE 3.3.7.9-1 FIRE DETECTION INSTRUMENTATION TOTAL NUMBER INSTRUMENT LOCATION OF INSTRUMENTS (Illustrative)
HEAT FLAME SMOKE (x/y)
(x/y)
(x/y) 1.
Contairment #
a.
Zone 1 Elevation. '
b.
Zone 2 Elevation
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Control Room 3.
Cable Spreading a.
Zor!e 1 Elevation b.
Zone 2 Elevation 4.
Computer Room 5.
Switchgear Room 6.
Remote Shutdown Panels 7.
Station Battery Rooms
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Turbine
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Zone 1 Elevation i
b.
Zone 2 Elevation 9.
Diesel Generator a.
Zone 1 Elevation 5.
Zone 2 Elevation 10.
Safety Related Pumps a.
Zone 1 Elevation b.
Zone 2 Elevation
- 11. Fuel Storage
. a.
Zone 1 Elevation b.
Zone 2 Elevation (List all detectors in areas required to ensure the OPERABILITY of safety-related equipment).
- (x/y):
x is number of Function A (early warning fire d.etection and
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notificahion only) instruments.
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y is number of Function B (actuation of Fire Suppression Systems and early warning and notification) instruments.
- The fire detection instruments located within the containment are not required to be OPERARLE during the performance of Type A containment leakage rate tests.
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LA4actuAf 2 n A*:T SYST d PORTABLE FIRE EXTINGUISHERS
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LIMITING CONDITION FOR OPERATION All hand-held portable fire extinguishers (including water-based types, dry, chemical, carbon dioxide, halon, loaded s,tream and dry powder extinguishers) in fire zone boundaries protecting safety related areas shall be functional.
APPLICABILITY: At all times.
ACTION:
With one or more of the above required portable fire extinguishers a.
inopesable, within eight hours. replace with a portable fire axtin-guisher having the same clag's_ification and at least. equal rating.
b.
The provisions of Specifications 3.0.3 and 3.0.4 are not applicable.
SURVEILLANCE REQUIRDfENTS, T
Each of the above required portable fire extinguishers shall be verified to
'b3 functional:
At least once per 31 days by visual inspection of the portable fire a.
. extinguishers accessible during plant operations to assure operabil-icy.
The following shall be minimally inspected while conducting the surveillance:
(1)
Verify extinguisher is in its designated location and unobstructed, that tamper indicators are in place, and that the extinguisher i
is not damaged, impaired, leaking, under or overcharged, or has any obvious corrosion, i
b.
At least once per 12 months by a maintenance inspection of the portable fire extinguishers accessible during plant. operations to assure operability. The following shall be minimally inspected while conducting the surveillance:
(1) Verify gage shows proper pressuru.
Extinguishers not using a gage shall be visually inspected for proper level and weighed.
(2)
Examine nozzle and hose or horn for obstructions and any cracks.
Also verify operability of components in those that can be tested by movement.
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(3)
For ' dry chemeial ~ extinguishers deter =ine that extinguishing
. agent is in a free-running condition.
Verify that the contents
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- recommendations of weight including cartridge; also inspect gaskets and. replace any degraded gaskets.
(4)
Include items listed in paragraph (a).
At least once per 12 months by recharging foam, pump tank water, c.
and pump tank calcium chloride base antifreeze type fire extin-guishers to assure their operability.
d.
At least once per 18 months by maintenance inspectio'n of the portable fire extinguishers not accessible during plant operations to assure extinguisher operability.
a.
At least once per 6 years, stored pressure dry chemical extinguishers
- that require a 12-year hydrostatic test shall be emptied and subjected to the applicable maintaance procedures to assure their operability.
' f.
Portable fir $ extinguishers shall be iy'drostatically tested at intervals not exceeding those specified in the following-table:
Extinguisher Type Test Interval (years)
Soda Acid 5
Cartridge operated Water and/or Antifreeze 5
Stored Pressure Water and/or Antifreeze 5
Wetting Agent 5
Foam 5
AFFF (Aqueous Film Forming Foam) 5 Load Stream
'5 Dry Chemical with Stainless Steel Sheels 5
Carbon Dioxide (Wheeled-Unit Hose Assembly Pressure 1250#)
5 Dry Chemical, Stored Pressure, with Mild Steel Shells, Arazed Brass Shells, or Aluminum 12 Shells Dry Chemical, Cartridge or Cylinder Operated, with Mild Steel Shells 12 Bromotrifluoromethane - Halon 1301 12 Bromochlorodifluoromethane %- Halon 1211 12 Dry Powder, Cartridge or Cylinder Operated, with Mild Steel Shells 12 Compressed Gas Cylinders - Wheeled Units 5
g.
At least,once per 12 years by hydrostatic test at 300 psi for dry chemical cartridge operated extinguisher hose assemblies to assure their operability.
h.
Prior to returning a portable fire extinguisher to functional status following repairs or maintenance by performance of a visual inspection of the affected portable fire extinguisher.
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" Prior te returning a portable fire extinguish. to functional status following any event which could have affected its structural integrity and/or operability by performance of a hydrostatic test to the affected extinguishers.
JUSTIFICATION FOR REQUESTED CHANGE Presently no standard technical specification exist for portable fire extin-guishers.
Since prompt extinguishment of fires is important to reactor safety, the application of portable fire hxtinguishers rather. than automatic suppression systems should be preferred.
Properly maintained portable fire extinguishers along with a trained fire brigade (present NRC requirement) should control and extinguish fires while in the incipient stage.
The purpose of port.ble fire extinguishers and hose stations is to control and/or extinguish fire before it gains in magnitude,to affect safety related equip-ment and also to reduce the need for automatic ! suppression system actuation causing additional safety related concerns.
This has been referred to as
" Fire. Suppression System Interaction Lines of Inquiry" resulting in safe shutdown equipment failure or environmental qualification proble=s presently under technical review by NRR.
Also, the Electric Power Research Institute has furnished a test report to the NRC titled, " Water as a Means of Cable Fire Protection and Operational Effects Experience" (EPRI NP-1193) dated October 1979.
This report describes industry expe".iences with the use of water as an extinguishant and points out tha potential for initiat'ing additional hazards from the operation of water sprays.
In 1976, the U.S. Department of Labor, Occupati,onal Safety and Health Association of Fire EquJpment Distributors (NAFED) performed an in-depth broad-base study on the use of portable fire extinguishers.
The scope of this study examined the performance of 14,091 fire extinguishers en 5,400
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fires.
The report concluded that 327 of 5,400 fires were not extinguished while attempting to use portable fire extinguishers.
Reasons given for not extinguishing the fires included extinguishers which had been previously discharged and left in services in a empty or near empty condition, broken syphons, caked chemical, foreign objects lodged in horn, clogged hoses, damaged extinguishers, frozen extinguishers, etc.
Surveillance requirements are referenced from NFPA Pamphlet 10, ANSI /ANS 59.4 - 1979 titled, " Generic Requirement for Light Water Nuclear Power Plant Fire Protection", and frem discussions with licensees present practice for surveillance require =ents on portable fire extinguishers.
SURVEILLANCE REQUIREMENTS Paragraphs (a), (b), and (c) were included for the purpose of performing an operational test to, give reasonable assurance that the extinguisher is fully charged and operable.
These requirements are in accordance with NFPA 10, Sections 4-3, 4-4 and 4-5.2, respectively.
Paragraph (e), (f), and (g) were included for the pur' pose of performing a maintenance test which includes a thorough examination, any necessary
f rcpcir cr.repicccmant end tha nacd for a hydroatstic' tost.
Theco require-ments are in accordance with NFPA 10, Sections 4-4.1.1, 5-3 and 5-4.4 respectively.
Paragraph (if was added to give assurance that the extinguisher would be hydrostatically tested prior to being put back in service if involved in cny event which could affect its structural integrity.
This require:nent is in accordance with NFPA 10, Section 5-1.3(d).
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/o E4ERGENCY LIGHTING UNITS LIMITING CONDITION FOR OPERATION All Emergency Lighting Units in fire zone boundaries protecting safety related areas shall be functional.
APPLICABILITY: Modes 1, 2, 3 and 4 ACTION:
- a.
With one or more of the above required emergency lighting units inoperable, within eight hours the unit shall be replaced with a operable emergency lighting unit.
b.
The provisions of Specifications 3.0.3 and 3.0.4 are not applicable.
SURVEILLANCE REQUIREMENTS Each of the above required emergency lighting units shall be verified to be functional:
A.
At least once per 31 days by an operational test (to include verifying unit operatien, electrolyte level and position of hydrometer discs (lead acid only) of the emergency lighting units accessible during plant operations to assure their operability.
b.
At least once per 6 months by a maintenance test (to include cycling battery and checking change-over setting) of the emergency lighting units accessible during plant operations l
to assure their operability.
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c.
At least once per 18 months by maintenance test of the emergency lighting units not accessible during plant operations to assure their operability.
d.
Prior to returning a emergency lighting unit to functional status following any event which could affect its operability, repairs, or maintenance by performance of a operational test to the affected lighting unit.
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. JUSTIFICATION FOR REQUESTED CHANGE l
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the pl. int is di ;. r..:. nt in ir:.c c:.t.6.r en..11. rna t i ve nl.ut dovr. p t c:..
5.u r requiring pi trus.nel tc. t ravel thrc. ugh ares,s of the plant with:.ut nat urai nr nnrmal lighting available to reach cafe shutdown equipu.cnt and perfuri:-
necessary functions.
Two previous Region III inspections (Big 1ock Point 50-155/83-13(DE) and D. C. Cook 50-315/82-08(DE)) have indicated inadequate or nonexistent preventative maintenance program implementation for emergency lighting units.
In addition,Section III.J of Appendix R to 10 CFR Part 50, requires at
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1 east an 8-hour battery power supply be provided.
However, no emergency lighting unit operability test program is required at this time.
Surveillance requirements were derived from American National Standard Instit'utes (ANSI) document ANS 59.4-1979 Edition, titled, " Generic Rsquirements for Light Water Nuclear Power Plant Fire Protection" and from discussions with teledyne big beam emergency lighting unit manu-fccturer representatives.
SURVEILLANCE REQUIREMENTS Paragraph (a) requires a bnthly inspection according to ANSI 59.4, Table 2 and manufacturer recommendations to verify unit operation, electrolyte
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level and position of the Hydrometer Discs (Lead Acid Only).
P$ragraph (b) requires a semi-annual inspection ~ according to ANSI 59.4, Tcble 2 and manufacturer recomnendations to cycle the battery, checking the change-over setting and verifying items listed in paragraph (a).
1-Paragraph (c) is a standard paragraph from S.T.S. to a,ssure emergency lighting. units in high radiation areas will be inspected within a raasonable time.
to give assurance that the unit would be tested Paragraph (d) was added,in service if involved in any event which could prior to being put back af fact its operability.
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