ML20127D728
| ML20127D728 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 01/08/1993 |
| From: | Beck G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20127D733 | List: |
| References | |
| NUDOCS 9301190023 | |
| Download: ML20127D728 (8) | |
Text
10CFR50.90 PIIILADELPIIIA ELECTRIC COMPANY NUCLEAR GROUP HEADQUARTERS 955-65 CHESTERBROOK BLVD.
WAYNE, PA 19087 5691-January 8, 1993 (215) 640 60i10 Docket Nos. 50-352 50-353 License Nos. NPF-39 NPF-85 NUC1 EAR SFRVICES del %RTMENT U.
S.
Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555
Subject:
Limerick Generating Station, Units 1 and 2 Technical Specifications Change Request No. 92-18-0 Gentlemen:
Philadelphia Electric Company is submitting Technical Specifications Change Request (TSCR) No. 92-18-0, in accordance with 10CFR50.90, requesting an amendment to the Tochnical Specifications (TS) ' Appendix A) of Operating License Nos. NPF-39 and NPF-85.
Information supporting this Change Request is contained in Attachment 1
to this
- letter, and the proposed replacement pages are contained in Attachment 2.
This submittal requests changes to TS Sections 4.3.7.9.1 and 4.3.7.9.2, and Bases section 3/4.3.7.9 to reduce the frequency of testing of certain fire detection instrumentation in accordance with the guidance provided in the 1990 Edition of the National Fire Protection Association (NFPA) Standards.
If you have any questions or require additional information, please do not hesitate to contact us.
Very truly yours,
/<
G. JI Beck, Manager Licensing Section Attachments cc:
T. T. Martin, Administrator, Region I, USNRC w/ attachments T. J.
Kenny, USNRC Senior Resident Inspector, LGS w/ attachments W. P. Dornsife, Director, PA Bureau of Radiological Protection w/ attachments t
9301190023 930100 DR ADOCK 05000352 p
goal eDR ll g
c.-
' COMMONWEALTH OF PENNSYLVANIA ss.
COUNTY OF CHESTER D.
R. Helwig,- being first duly sworn, deposes and says:
That he is Vice President of Philadelphia Electric Company, the Applicant herein; that he has read the foregoing Application for Amendment of Facility Operating License Nos. NPF-39 and NPF-85 (Technical Specifications Change Request No. 92-18-0) to reduce the frequency of testing of fire detection instrumentation, and knows the contents thereof; and that the statements and matters set forth therein are true and correct to the best of his knowledge, information and belief.
\\
N Vice President Subscribed and sworn to u4 before me this a day-of Jo 1993.
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ATTACHMENT 1 LIMERICK GENERATING STATION Units 1 and 2 Docket Nos. 50-352 50-353 License Nos. NPF-39 NPF-85 TECHNICAL SPECIFICATIONS CHANGE REQUEST
" Reduced Testing Frequency for Fire Detection Instrumentation" Supporting Information for Changes - 5 pages
,TSCR'No. 93-18-0 Docket Nos. 50-352 and 50-353
.Page 1 Philadelphia Electric Company (PECo), Licensee under Facility Operating Licenses NPF-39 and NPF-85 for Limerick Generating Station (LGS), Units 1 and 2,
respectively, requests - that the Technical Specifications (TS) contained in Appendix A of the Operating Licenses be amended as proposed herein to reduce - the frequency of-testing of _ certain fire detection instrumentation.
The proposed changes are indicated by a vertical bar in the margin of TS pages 3/4 3-92, new page 3/4 3-92a, and Bases page B 3/4 3-6 for both LGS Unit I and Unit 2 TS, and are contained in Attachment 2.
We request that the changes proposed herein be offective within two (2) weeks issuance of the Amendments.
This Change Request provides a discussion and description of the proposed-TS changes, a safety assessment of the proposed TS changes, information supporting a finding of No Significant Hazards Consideration, and information supporting an Enviranmental
-Assessment.
Discussion and Description of the Proposed Changes Fire and smoke monitoring, detection, and alarm.are accomplished through the installation of smoke detectors and/or heat detectors in areas where fire potential exists.
At LGS, the fire and smoke detection systems for annunciation are separate from fire detection systems for actuation of fire extinguishing systems. -
The fire and smoke detection system is also electrically supervised to detect circuit breaks, ground faults, and power failure.
All fire or trouble alarms-register on the audible / visual annunciator on the fire protection panels in the Main Control _ Room (MCR).
The fire and smoke detection system conforms to the guidance provided in National Fire Protection Association -(NFPA) Standard 72D (1979),
" Proprietary' Protective' Signaling Systems,"'with some exceptions and clarifications as described -in Section 9.5.1.2.9 - of the LGS Updated Final Safety Analysis Report - (UFSAR).
NFPA 72D (1979)-
refers to NFPA Standard 72E -(1978), " Automatic Fire Detectors,"' for testing of the fire detection system.
TS Section 4.3.7.9.1 currently requires that all smoke detectors be demonstrated operable at least-once per _ six (6) months.
Due to the large number of _ fire detectors at LGS, Units 1:
and 2, testing at this frequency requires a significant amount of time, ef fort, and resources, including personnel that are dedicated
- to-performing fire ' detector tests.
-TS Section 4.3.7.9.1 is consistent with NPFA 72E (1978) which recommends that smoke detectors be_ tested semiannually (i.e., every 6-months).
- However, this recommendation was changed in 1987 such - that the current edition (1.e., 1990) of NFPA 72E recommends that smoke detectors be functionally tested annually (i.e.,
every 12 months).
The:NFPA Technical Committee's basis for making this change was that-testing six (6) months had "no sound technical -basis," and that every.
TSCR*No. 92-18-0
~
' Docket Nos. 50-352 and 50-353-Page 2 annual testing reflected the common practice which was found to be acceptable within the industry.
Accordingly, we propose to change the frequency of functional testing of the smoke detectors as specified in TS Section 4.3.7.9.1 from "at least once per 6 months" to "at least once per 12 months"-
to make the LGS TS consistent with the 1990 Edition of NFPA 72E and thereby reduce the impact of this testing on personnel resources.
TS Section 4.3.7.9.1 also currently requires that all heat detectors be demonstrated operable at least once per six (6) months.
Due to the large number of fire detectors at LGS, Units 1 i
and 2, this testing requires a significant amount of time, effort, and resources, including personnel that are dedicated to performing fire detector tests.
In contrast to the LGS TS requirement, NFPA 72E (1978) recommends that at least one detector in each signal-initiating circuit be tested semiannually and that different detectors be selected for each test.
This recommendation was i
changed in 1987 such that the 1990 Edition of NFPA 72E includes an additional recommendation that all heat detectors be tested within a five (5) year period.
These recommendations ensure that each signal-initiating circuit is capable of performing its intended function on a six month basis by ensuring that one or more of-the heat detectors in each circuit is operable.
At LGS, testing of a heat detector includes testing of the entire signal-initiating-circuit.
Signal-initiating circuits at LGS are specific to individual fire areas, i.e.,
a signal-initiating circuit does not l
cross fire area boundaries but initiates the fire - suppression j
system that is installed in the fire area in which the circuit is
~
located. These recommendations also ensure that all heat detectors in signal-initiating circuits are tested over a five (5) _ year
- period, i
i Accordingly, we propose to change TS Section 4.3.7.9.1 such that a sample of heat detectors (i.e., at least one or more) be tested every six (6) months, that different detectors be selected i
for each test, and that all heat detectors be tested within a five
~
(5) year. period.
This change is being proposed to make the LGS TS consistent with the 1990 Edition of NFPA'72E and thereby reduce the impact of this testing on personnel resources.
The surveillance testing interval for all-other types of= fire detectors remains unchanged (i.e.,
every six (6) months)_by the proposed TS changes.
TS.Section 4.3.7.9.2 currently requires that the supervisory circuits associated with.' detector alarms be demonstrated operable at" least once per six months.
This testing _also requires a significant amount of
- time, effort, _
and resources.
This requirement is based on the frequency as specified in the NRC's
-Standard Technical Specifications that were in effect at the time of development of the LGS TS (i.e.,
NUREG-0123, 1980).
In contrast, NFPA 72D (1979) does not provide recommendations on
m.-_
TSCR'No. 92-18-0 Attachment'l
' Docket Nos. 50-352 and 50-353 Page 3
-testing of the supervisory circuits for the detector ~ alarms.-
A recommendation for functionally testing these supervisory circuits -
on an annual basis (i.e.,
every 12 months) was added to the 1990 Edition of NFPA 72,
" Protective Signaling Systems" which is a consolidation of NFPA Standards 72A, " Local Protective Signaling Systems," 72B,
" Auxiliary Protective Signaling Systems,"
- 72C,
" Remote Station Protective Signaling Systems,"
- 72D, and.72F,
" Emergency Voice / Alarm Communication Systems."
Accordingly, we propose to change the frequency of testing of the supervisory circuits for the detector alarms as specified in TS Section 4.3.7.9.2 from "at least once per 6 months" to "at least once per 12 months" to make the LGS TS consistent with the 1990-Edition of NFPA 72 and thereby reduce the impact of this testing on personnel resources.
Safety Assessment The proposed changes involve changing only the surveillance test interval for certain fire detection instrumentation. The fire detection systerr. is a non-safety related system required to provide early detection of a fire to protect safety related equipment in the area of the fire.
Failure of the fire detection system'does not affect any transient or accident evaluation, including the LGS fire safe shutdown analyses.
In addition, no design requirements are being changed and the fire detection system design performance would not be degraded as a result of the proposed changes.
The LGS Fire Protection Program uses the defense-in-depth approach aimed at preventing fires and minimizing the ef fect of any fires that occur.
This is accomplished ~ through separation of redundant safety systems,'an integrated network of components and equipment providing detection and suppression of fires, concepts of design and layout, administrative controls and procedures, and personnel training.
The Fire Protection ~ Program. also uses the defense-in-depth approach to assure that a fire will not prevent the performance of necessary safe shutdown functions and will not cause an undue risk to the health and safety of the public..The Fire Protection Program is formulated such that failure of an active or passive component of one fire protection feature is backed-up by another entirely dif ferent fire - protection-feature (e.g.,
fire rated assemblies, sprinklers, detection, etc.)',
and-therefore, multiple fire protection features would not likely be impacted simultaneously by a common time-based failure nor would the overall effectiveness of the program be significantly compromised by a single component failure.
Based on the above discussion, we have concluded that the proposed TS change, to reduce the frequency of. testing of certain fire detection-instrumentation, does not impact plant safety.
A review of the fire detection instrumentation surveillance-test-history demonstrated that there is no evidence of any failures which would invalidate the above conclusion.
\\TSCH*No. 92-18-0 At.tachmont 1 Docket Non, bO-352 and 50-353 Pago 4 Information Supporting a
Finding of No Significant flazards fionsideration We have concludod that. the proposed changes to the LGS TS, to reduco-tho.
frequency of testing of cortain fire detuction instrumontation, do not conu t.itu to a
Significant flazards Considoration.
In support of this dolormination, an ovaluation of each of the throo st.andards sot forth in 10CFR50.92 is provided below.
1.
The proposed TS changes do not involve a significant increaso in the probability or consequences of an accident previously evaluated.
The proposed TS changos involvo a chango in the survoillanco Losting interval for cortain fire detection instrumentation to make the test interval consistent with the current (i.e.,
1990) edition of tno applicablo NFPA Standards.
The proposed TS changes do not result in any physical changes to the plant nor do they impact any design or functional requirements of the plant syst. oms.
The proposed TS changes do not degrado the performance or increase the challengos of any safety-related systems assumed to function in the accident analysis.
Additionally, no accidents previously evaluated have as their initiators anything related to the chango in frequency of surveillancu 'esting.
Also, the proposed TS changes do not affect the availabilit.y of equipment or systems required to mitigato the consequences of an accident because of the equipment redundancy required by the LGS Fire Protection Program and the f act that the conclusions of the LGS fire safo ahutdown analysos remain unchanged.
Furthermore, a review of the firo detection instrumentation surveillance test history determined that there is no evidence of any failures that would invalidato the abovo conclusions.
Thoroforo, the proposed TS changos do not increase the probability. or ennnequences of an accident previously ovaluated.-
2.
The proposed TS changes do not create the possibility of a' now or diftoront kind of accident from any accident previously evaluated.
The proposed TS changes involvo a chango in the survoillance testing interval for cortain fire dotoction instrumentation to make the test interval consistent with the current (i.e.,
1990) odition of the applicable NFPA Standards.
The proposed TS changes do not introduce nor increase the number of f ailuro I
mechanisms of a now or different type than those previously ovaluated since no physical changes are being made to tho l
facility, no design requirements are being-changed, and the system design performanco is not degraded.
In addition, the frequency of testing is not an accident initiator.
Also, the conclusions of the LGS fire safe shutdown analysos remain valid.
Thorofore, changing the frequency.of testing does not I
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TSCR*No. 98-18-0 Docket Nos. 50-352,and 50-353 Page 5 create a new or different accident.
Furthermore, a review of the fire detection instrumentation surveillance test history determined that there is no evidence of any feilures that would invalidate the above conclusions.
Therefore, the proposed TS changes do not create the possibility of a new or different kind of accident from any previously evaluated.
3.
The proposed TS changes do not involve a significant reduction in a margin of safety.
Although the proposed TS changes will result in an increase in l
the interval between surveillance
- tests, the increased interval is consistent with the guidance provided in the current edition of the applicable NFPA Standards.
The proposed TS changes do'not impact plant safety based on the redundancy of equipment required by the LGS Fire Protection Program and the f act that the conclusions of the LGS fire safe shutdown analyses remain unchanged.
A review of the fire detection instrumentation surveillance test history determined that there is no evidence of any failures that would invalidate the above conclusions.
Therefore, the proposed TS changes do not reduce the margin of safety.
Information Supporting an Environmental Assessment An environmental assessment is not required for the changes proposed by this Change Request because the requested - changes conform to the criteria for " actions eligible for categorical exclusion,"
as specified in 10CFR51.22(c)(9).
The requested changes will have no impact on the environment.
The requested changes do not involve a significant hazards consideration as discussed in the preceding section.
The requested changes do not involve a significant change in the types or significant increase in the amounts of any ef fluent that may be released of fsite.
-In
- addition, the proposed changes do not involve a -significant increase in individual or cumulative occupational radiation exposure.
Conclusion The Plant Operations Review Committee and the Nuclear Review Board have reviewed these proposed changes to the TS and have concluded that they do not involve an unreviewed safety question, or a significant hazards consideration, and will not endanger the health and safety of the public.