ML20127N053

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Proposed Tech Specs to Relocate Fire Protection TSs to an owner-controlled Document Consistent W/Guidance Provided in Generic Ltrs 86-10 & 88-12
ML20127N053
Person / Time
Site: Zion  File:ZionSolutions icon.png
Issue date: 12/22/1992
From:
COMMONWEALTH EDISON CO.
To:
Shared Package
ML20127N009 List:
References
GL-86-10, GL-88-12, NUDOCS 9301290076
Download: ML20127N053 (53)


Text

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ATTACHMENT A ZION NUCLEAR GENERATING STATION DESCRIPTION AND SAFETY ANALYSIS -__

TSCR N0, 91-11 RELOCATION OF FIRE PROTECTION REQUIREMENTS w

ZNLD-2334-6 9301290076 PDR 921222 P

ADOCK 05000295 PDR

ZION NUCLEAR GENERATING STATION Technical Specification Change Request (TSCR) No. 91-11 Relocation of Fire Protection Requirements I. DESCRIPTION OF PROPOSED CHANGE This Technical Specification Change Request (TSCR) proposes to relocate the fire protection requirements of Technical-Specification Section 3/4.21 and fire brigade staffing requirements of Specifications 6.1.3 and 6.1.5 from the Technical Specifications. In addition the Fire Protection Section 3/4.21 special reports have been removed from Special Report Table 6.6-1 to be consistent with the relocation of the associated Limiting Conditions for Operation (LCO) out of the Technical Specificaties. This submittal also requests the replacement of the existing Fire Protection license conditions with the standard license condition for i Fire Protection Program as suggested in Generic Letter 86-10, " Implementation of Fire Protection Requirements," dated April 24, 1986.

Changes to the 19chnical Specifications and License Conditions of Operating Licens(s Nos. DPR- 39 and DPR-48, NRC. Docket Nos. 50-295 and 50-304, respectively are noted in the annotated copy of the affected pages of the Technical Specifications and the Operating Licenses (Attachment B).

The removal of fire protection requirements from the-Technical Specifications is requested in accordance with the guidance in Generic Letter 86-10, " Implementation of Fire Protection Requiicments," dated April 24, 1986 and Ceneric Letter 88-12, " Removal of Fire Protection Requirements from Teciinical Specifications," dated August 2, 1988. The following paragraphs address the elements that these generic letters

'ecommend the license amendment request should contain, the guidance of these generic letters requires that the fire protection program be incorporated into the Final Safety Analysis Report (FSAR).

This incorporation may be made by reference to the documents which define the licensee's Fire Protection Program. Zion Station's Fire Protection Program including the Fire Hazards Analysis and major commitments is currently incorporated by reference into the FSAR. Therefore no FSAR changes should be required.

ZNLD-2334-7

I. DESCRIPTION OF PROPOSED CllANGE (Continued)

Second, the LCOs, Surveillance Requirements and associated bases for fire detection systems, fire suppression systems and fire barriers of Technical Specification Section 3/4.21 and the fire brigade requirements of Specifications 6.1.3 and 6.1.5 will be relocated from the Technical Specifications to the Fire Protection Program. Specification 6.1.3 provides Fire Brigade Staff manning requirements while Specification 6.1.5 provides Fire Brigade Staff training requirements. The guidance from Generic Letter 88-12 recommends removing Fire Brigade Staffing requirements from the Technical Specifications and utilized the Westinghouse Standard Technical Specifications (WSTS) as a model for these changes. Specification 6.1.5 is an administrative control requirement not contained in the WSTS. Its relocation with the Fire Brigade Staff mannkg requirements to the Fire Protection Program is consistent with the intent to relocate Fire Protection requirements which do not directly affect the safe operation of the plant from the Technical Specifications. Also the special reports based on the LCOs of Fire Protection Section 3/4.21 will be removed from Special Report Table 6.6-1 consistent with the relocation of the associated LCOs out of the Technical Specifications. The existing Technical Specification administrative controls related to fire protection audits will be retained in the Technical Specifications.

Third, the Administrative Controls Section of the Technical Specifications currently requires the On-Site Review and Investigative Function, Specification 6.1.7.B.2, to review proposed changes to the Fire Protection Program and review all applicable plant administrative procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February, 1978, and changes thereto. The Fire Protection Program administrative procedures are recommended in Appendix A, thus they are required to be reviewed by On-Site Review. Specification 6,1.7.B.4(a) requires copies of all reports, reviews, investigations and recommendations prepared or performed per Specification 6.1.7.B.2 to be forwarded to the Superintendent of the Off-Site Review and Investigative Function. Tnus although the exact wording of the administrative controls On-Site Review responsibility regarding the Fire Protection Program is different from that in the Generic Letter, the level of review is equivalent. It assures that a multi-discipline review by the On-Site Review and Investigative Function will be conducted on proposed changes to the Fire Protection Program requirements once they are removed from the Technical Specifications and implemented through an administrative program.

Fourth, the Administrative Controls Specification for Plant Operating Procedures (Technical Specification 6.2) currently requires written procedures be prepared, implemented and maintained for Fire Protection Program implementation. Therefore no revision to this Specification is neeoed.

ZNLD-2334-8 j

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1. DESCRIPTION Of PROPOSED CHANGE (Continued) finally, the current fire protection license conditions will be removed and replaced by the standard fire protection license condition of-the Generic Letters, in order to implement the standard license condition, a final Safety Evaluation Report (SER) must be issued for Section 3.2.1, Administrative Controls, from the NRC's March 10, 1978 SER. Attachment E provides additional information on the open areas from Section 3.2.1, and should allow the NRC to issue the needed SER.

Corresponding changes will be made to the Table of Contents and List of Tables pages of the Technical Specifications to reflect the relocation .

from Technical Specifications of fire Protection Section 3/4.21 and associated tables. In addition, administrative errors in the listing of the page numbers and the survelllance requirement section numbers for LCOs 3.13.9, 3.13.10 and 3.13.11 are being corrected on the Table of Contents. Also LCO 3.24 and Ba:es are being added to the Table of Contents page. All these changes to the Table of Contents and List of Tables pages are administrative and have no affect on safety.

II. W ETY ANALYSIS Recent activities in the NRC and Westinghouse Owner's Group have focused on a Technical Specification Improvement Program aimed at reducing the voluminous requirements of the Technical Specifications. The objective of the program is to remove those Technical Specifications which do not directly affect the safe operation of the 1)lant and can be effectively maintained through an administrative program._ Removing the fire Protection Technical Specifications is consistent with the criteria established for the Technical Specification Improvement Program in that these systems are not part of Design Basis Accident mitigation as defined by the program criteria. Removal of the Fire Protection Technical Specifications will reduce the size and complexity of the current Technical Specifications which the operators must interface with daily.

Removal of these Technical Specifications will not detract from Commonwealth Edison's ability to maintain the required level of fire.

protection. Commonwealth Edison believes that this request is consistent with the NRC's ongoing goals for Technical Specification ~ improvements.

All requirements currently contained in the affected Fire Protection Technical Specifications will be incorporated into the fire Protection Program in accordance with the guidance of Generic Letters 86-10 and 88-12. The proposed change will not modify the existing fire protection requirements. The relocation of the fire Protection Technical Specifications to the fire Protection Program _is an administrative matter which will allow future changes to be made without a license amendment subject to the proposed standard license condition. This will relieve both the NRC and CECO of an administrative burden. The proposed license condition will require the Fire Protection Program including the relocated Fire Protection Technical Specification requirements be implemented and maintained in effect.

ZNLD-2334-9

_ . s 1

II. SAFETY ANALYSIS (Continued)

The 10CFR50.59 process will be utilized as the control mechanism for the relocated specifications. Additionally, the proposed license condition for the Fire Protection Program change process ensures changes do not adversely affect the ability to achieve and maintain safe shutdown in the j event of a fire and is consistent with Generic letter 86-10. Prior NRC approval is required for changes that are considered to adversely affect the ability to achieve and maintain safe shutdown. The change p ocess will allow CECO to make changes to the relocated Technical Specifications if the change does not involve an unreviewed safety question. The control process for the fire Protection Program and implementing procedures which implement this program shall be 10CFR50.59. Changes to the program and implementing procedures shall become effective after review and acceptance by the On-Site Review Committee. The FSAR will be updated periodically pursuant to 10CFR 50.71 to reflect any changes to the Fire-Protection Program, including the relocated Specifications. These controls combined with the General Surveillance Program utilized at the station will ensure that the requirements of the Fire Protection Program are effectively implemented once the fire Protection Technical Specifications are relocated.

The existing fire protection license conditions imposed by Amendments 48 and 45 for Unit 1 and Unit 2 respectively required completion of modifications on a schedule identified in the March 10, 1978 Safety Evaluation and supplements issued by the NRC concerning fire protection at the Zion Nuclear Groerating Station. This requirement of the license condition has been fulfilled and has no ongoing operational impact on the Zion Nuclear Generating Station. Therefore, this requirement of the license condition can be removed with no safety significance.

The existing fire protection license cond'$lon! 1rposed by Amendments 48 and 45 also required the submittal of additional information on Zion's Fire Protection Program on a schedule identified in the March 10, 1978 Safety Evaluation Report (SER). CECO provided information for all areas identified in the schedule and all but Section 3.2.1, Administrative Controls (fire protection), were approvea in supplemental Safety Evaluation Reports dated May 26, 1478; June 26, 1978; February 14, 1979; April 13, 1979; March 24, 1980; December 9, 1990; Harch 7, 1983; June 7, 1988, and January 7, 1991. The NRC approved a number of the areas within I the fire protection administrative controls section in Safety Evaluation l Reports dated March 24, 1980 and November 24, 1980. In addition, the

November 24, 1980 Safety Evaluation Report provided CECO with the NRC-guidelines for approval of the remaining-Section 3.2.1.open areas. In a letter dated March 18,-1981, CECO provided additional information on the Section 3.2.1 open areas.which
ldentified CECO's conformance to the NRC's guidelines. In Attachment E, we have provided additional information i related to these open areas which demonstrates Zion Station's conformance with the November 24, 1980 guidelines. This should allow the NRC to issue their final Safety Evaluation Report on this area.

a ZNLD-2334-10

A11ACHMENT D ZION NUCLEAR GENERATING STATION PROPOSED CHANGES TO TECHNICAL SPECIFICATIONS AND OPERATING LICENSES FOR TSCR NO. 91-11 RELOCATION Of FIRE PROTECTION REQUIREMENTS PAGES30DlLIID Composite License Unit 1 page 3 Composite License Unit 2 page 3 tv xi 300 301 324 PAGES_ADDID 295D-V EAGES E 1EIED 295D 29EE 295f 295G 295H 2951 295J 295K 295L 295M 295N 2950 29SP 2950 295R 295S 295T 29SU 295V ZNLD-2334-11

)

ANNOTATED COPY OF CURRENT ,

ZION TECHNICAL SPECIFICATIONS AND OPERATING LICENSES

. INDICATING PROPOSED CHANGES-FOR TSCR NO. 91-11 RELOCATION OF FIRE PROTECTION REQUIREMENTS

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- ZNLD-2334-12

.' DPR-39 licensee may proceed with and is required to compie (5 e

'; modi ions indicated in Paragraphs 3.1.1 through . 20 of the NRC's Protection [ valuation (SE) on th 1on Nuclear  :

j#f-Jo Power Station da March 10,1978 and suppJements thereto, i l / These modificatio (ns sh (1 be completed Js specified in Table 3.1  !

of Supplement No. 1 or in fM Queat' supplements to that S[. In i

addition, the licensee shal a (e he additional-information identified in lable 3. the above c E in accordance with !

the schedule con ed therein. In the even e dates for submittal c be met, the licensee shall submit a ort expla g the circumstances, together with a revised sche (A ed 4-13-79; Am. 48)

(6) 1he licensee shall fully implement and maintain in effeet all provisions of the commission-approved physical security, guard training and aualification, and safeguards contingency plans including amendments made pursuant to provision of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The plans, which contain Safeguards Information protected under 10 CFR 73.21, are entitled: " Zion Nuclear Power Station Security Plan,' with revisions submitted through June 30,1988; ' Zion Power Station Training and Qualification Plan,' with revision submitted through February 16, 1984; and " Zion Nuclear Power Station Safeguards Contingency Plan," with revisions submitted through r February 1,1984. Changes made in accordance with 10 CFR 73.55

'( shall be implemented in accordance with the schedule set forth therein (revised 11/01/88, Am. 113).

(7) Spent Fuel Pool Modification l

The licensee is authorized to modify the spent fuel pool as described in the application dated April 13,1978, as supplemented October 24, November 8 and 29,1978, January 24 and

26. February 23,-March 7 and March 19,1979. (revised 1-15-81; Am. 61)

(a) Fuel stored in the spent fudi pool shall have a U-235 loading less than or equal to 46.4 grams per axial centimeter. (revised 02/19/86; Am. 94) l l

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! Amendment No M b

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I The/tcensee shall taplement and maintain in effect all / '*d provisionsoftheapprovedFireProtectionProgramasp _ erough and as approved in the SERsdattle/ G 6bject to the following provision:

Supplement The licensee may make changes to the approved Fire Protection Program without prior approval-of the Comission only if those changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire.

Fekeq H, ti l? j A pr.l 13 ,197 7, Mac A tc, torr, oby 24, is 7 r, Jue 24, s97trj At e d -7 19FL, Mvmfy 24 lc}pt h c%Q C) 19 M 14/ch 2d fl'l PD j a - z ,v , u. m z m,, _ , u & a u m ,, a .c d'( P4Nb aMN %4.ve un+r et 5) c

- - ~ - - - - - - - ~ _ . _ _ _ _ _

- OPR 48 (5) 1 licensee may protecd with and is required to complete tJe

, modi tions indicated in Paragraphs 3.1.1 through 3). 40 ci the NRC's lon Nuclear

+

  1. Power Statloa ProtectionEvaluation(SE)onthe)tsthereto.

March 10,1978 and supplemen g#

g These modificat'ons s be completedpfp'ecified in lable 3.1 of Supplement No. 1 or in s que (supplements to that SE. In the additional information

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addition, the licensee shal identified in Table the above d SE in accordance with the schedule co ned therein. In the ev ' these dates for submittal not be met, the licensee shall subm eport expla ng the circumstances, together with a revise (d sch%le, ed 4-13-79; Am. 48)

(6) The licensee shall fully implement and maintain in effeet all provisions of the commission-approved physical security, guard training and qualifiestion, and safeguards contingency plans including amendments made pursuant to provision of the l

Miscellaneous Amendments and Search Requirements revisions to 10 CF.R 73.55 (51 FR 27817 and 27822) and-to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The plans, which contain Safeguards Information protected under 10 CFR 73.21, are l

entitled: " Zion Nuclear Power Station Security Plan," with revisions submitted through June 30, 1988; " Zion Power Station Training and Qualification Plan," with revision submitted I

through February 16, 1984; and " Zion Nuclear Power Station Safeguards Contingency Plan," with revisions submitted through February 1,1984. Changes made in accordance with 10 CFR 73.55

~

( shall be implemented in accordance with the schedule set forth therein (revised 11/01/88, Am.102) .

(7) } pent Fuel Pool Modification The licensee is authorized to modify the spent fuel pool as

( described in the application dated April 13, 1978, as i supplemented October 24, November 8 and 29,1978, January 24 and 26, February 23, March 7 and March 19,1979. (revised 1-15-81; Am. 61) l (a) Fuel stored in the spent fuel pool shall have a U-235 loading less than or equal to 46.4 grams per axial centimeter. (revised 02/19/86; Am. 94)

Amendment No. M2 I

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'-%SW, The/lcenset shall laplement and maintain in effect all cribed f- provisions of the approved Fire Protection eree dt -

- Program asi ,

and as approved in the SERsdated.m 'M bject to the following prov'.l Supplement The licensee may make chang 0s to the approved Fire Protection Program without prior approval of the ,

Commission only if. those changes would not adversely; J affect the ability to achieve and malatain safe shutdown in the event of a fire, u 8

N rch (c, (%77 , th y % ,117r, Jue. 24, M l&j niq N, ii77) April f 3,197 7, b,.

Much L; - 84 fb, Novemfet- 2.'l, l'\ ro, hc<mW Dy l MD , NArch

~5, -l Jet. 7 l#Wf j j d%wy 7 j 1% l 3 an/ (dde. of [ w l M 4//ec M e f M<< pnA4h ~ almx ws4ue c.rkels)

SURVEILLANCE EAE LIMITING CONDITION FOR OPER$110B REOUIREMENT 3.13 Refueling Operations 4.13 243 3.13.1 Core Reactivity 4.13.1 243 3.13.2 Protection from Damaged Spent Fuel 4.13.2 244 3.13.3 Containment Status 4.13.3 245 3.13.4 Radiation Monitoring 4.13.4 246 3.13.5 Refueling Equipment Checkout 4.13.5 246 3.13.6 Refueling Equipment Operability 4.13.6 246 3.13.7 Spent Fuel Pit Cooling Systems 4.13.7 246 3.13.8 Fuel Inspection Program 4.13.8 247 3.13.9 Residual Heat. Removal .

System Operation 4.39 247ta 3.13.10 Hater Level - Reactor Vessel 4. 8 3, t o 2474t 3.13.11 Water Level - Storage Pool 4.13.,911 247td 24S Bases 3.14 Plant Radiation Monitoring 4.14 250 254 Bases 3.15 Aux 111ary Electrical Power System 4.15 255 271 Bases 3.16 Radiological Environmental Monitoring 4.16 275 279 Bases 3.17.1 Ventilation 4.17.1 281 283 3.17.2 (Section Deleted) 287 Bases.

Steam Generator Activity 4.18 289 3.18 290 Bases 3.19 Failed Fuel Monitoring 4.19 292 293 Bases Radioactive Solids 4.20 295a 3.20 ,

Bases 4.21 295D-V 3.21 Ftre-Protection-(T co.4 behde l)

Bests-3.22 Shock Suppressors (Snubbers) 4.22 295M 295Z e Bases 295AB 3.23 (Section Deleted) 3, v4 %M Smccm C. ~4 4. ~d .' o ^ 4.z4 2w A b pq s- A f La3 TABLE OF CONTENTS (Continued) ,

Iv Amendment Mos.199 and-128-

.W4  %

Table Ease 4.15-1 Deleted 270 l 4.15-2 Diesel Generator Test Schedule 270s .

4.16-1 MaximumValeesfortheLowerljattsofDetection(LLD) 280 4.17-1 Charcoal Filters .*

284 4.17-2 NEPA Filters 285 -

4.19-1 Deleted 295 l 4.21-1 Pee T.etectM insi. _ .d u - De\d*d 295p- d36 b4 4.21-2 Deleted

-295e- d75 D-V l-4.21-3 $pr-lakler-$ystoes hk+< A 2953- 795 t>-V 4.21-4  % Sy- t ;- . h.A44< A 295t- 715'b-\/

4.21-5 F1 ";;; Stettent 'De.le+t.d h 29fB V 6.6-1 Spectal Reports 323 6.s-1 Doendary poors for Flood Conditions 328 tssi or TAetts-(continued >-

A'mendment Nos.131 and420-xi.

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_- q w LIMITING CONDITION FOR OPERAT;0N SURVEILLANCE EEQUIREMENT 3e21 PROTECTION 4.21 FIRE PROTECTION ,

Applic (ty: Applicability:

\ Applies to portions of the pla/nt fire suppression an

. Applies to port ns of the plant fire suppression and detection systems tecting areas containing safety detection systems protect.ing areas containing, safety '

related equipment. related equipment.

/

/

Objective: Objective: /

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i' To assure adequate fire protectio apability for To establisly p'criodic testing and survev111ance requir safety related plant areas. ments to verify adequate fire protection capability for safefy related plant areas.

Specification: Specification:

I g 1. Fire Detection Instrumentation 1. Fire Detection Instrumentation

  • l A. The fire detection instrumentation for each g A. The fire detection instrumentation for cach fire detection zone listed in Table ,

fire detection zone listed in Table 4.21.1 shall be demonstrated operable at least once

{, 4.21-1 shall be operable at all times ,/

j uhen equipment in that zone is required / per 6 months by perfonning a functional test i to be operable, except as noted in of each detector and the associated zone 3.21.1.0 and 3.21.1.C. ervisory circuitry.

l Firb detection instrumentation listed ~as inaccelsible shall be demonstrated operable once during each operating cycle. This  !

instrizuentation, however, shall be tested consistent wi(Ir the semiannual requirerent above during any shutdown greater than 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. The outag ed not be extended fo the sole purpose of com tir.g the testing of fire detection instrum tion. Detectors in zones 22 and 23, however, re exceipt t

from this requirement and shalbbe tested onc

/ each operating cycle.

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B. When it'is detennined that the number of operable B. Not applicable j detectors for. a given zone is less than that _ _

required b Table 4.21-1, a fire surveillance - -- -

atrol sha 1 be established to inspect the z d50 Amendments M & 33-effect1 # 0/8U 8-

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finG CouplTica FOR OPtitATION SullWEILUWICE RUNIROIENT  ;

! 3.21.1.8 ~ within hour and additional 4.23.1.5 j laspectl 11 he conducted at least ,-

- I' once per hour tli the detectors are / t t

restored to e M e states.

C. Mhen it is deteralmed t the number of C. IIet Appitcable. -  ;

)

t operable detectors fier a zone is ,

4 less than that regelred by T e 4.21-1  ;

the muster.of operable detector a the '

aene shall be restored to that r red  !

by Table 4.21-1 wlthin 14 days er. t /_ j i

! 11em of any other report regelred by f  ;

i Specification 6.6.2. prepare and selimit / f

, a Special Report to the Commission within the nest 30 days outilning the- _

, action taken, the cause of..the / l

!. Inoperability and time plant and schedule -

for restoring the lastrument(s) to

~

h operable states.

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~ 2. Fire Suppression teater System.. 2. Fire SuppressieuQInter System s N il

!2 A. The fire suppression er system A. The fire suppretstem unter systes  ; ,

l' supplytne safety r sted plant' areas supplying safety related plant areas shall ' i shall contain higi pressere fire be demonstrated operabi h s follows- r

! pumps.-each' wing a rated capacity of th their discharges aligned N t 2000 gym N.

'I' to thodtre suppresslen water header. N N ,

T tre suppression water. system. '

i actedlag both fire pumps and automatic i Initiation logic for each fire pump.

- .shall'he operable at all times, escept [

4 as noted'la 3.21.2.S.-3.21.2.C and i 3.21.2.0. i

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[ LIMITING TION FOR OPERATION ,

SURVEILt.ANCE REQUIREMENT ,/ D, 4.21.2.A.1 / -

1. Each fire pump shall be started aut tically and allowed to operate under fire heade/ pressure for 1 at least 15 minutes each month.

l h 2. By verifying, at least once each valve that is not locked ealed or otherwise operating cycle that secured in automatic) in position the flow (manual, path ispower in itsoperated or

c. nect posittor.

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3. The system shall be flu ed once per operating cycle. I

[ 4. Each motor-operated o air operated valve in the flow j' path shall be cycle at len,t once per 12 months j trough at 1 cast os(e comp 1~ t cycle of full travel.

5. A sy a flow t shall be performed at least once
every 3 ars (n accordance with Chapter 5. Section 11 of the Fir tection Handbook 14th Edition, published b e National Fire Protection Association. j
6. At least nce per o rating cycle by performing a  ;

I-system unctional tes hich includes simulated aut ic actuation of th system throughout its  !

oper ting sequence, and:

t l a Verifying that each automatic valve in the flow path

. actuates to its corrept positio b) Cycling each valve in the flow pathht is not testable during plant operation through least

one complete cycle of full travel, j i

i c) Verifying'that the discharge flow and pressure f  :

Amendenen t s ,=, _ =_ ,~, ",= " " " ~ ' '

  • 295F each fire pump are within 110% of the manufacturePs acceptance criteria for rated system operating i j

condition, and , ,

'd) Verifying' the automatic sta-t function and setpoint of l

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I CriDIT!**iS F0tt- OPEHATIOlI l -SU:st!!LtANCE REQt11RDtr.1tTS ,

LIMIT . .

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l 3.21.2.5 4.21.2.8; - ,

B. When Lt is ' termined that less than two fire B. The Firo pu.ep diesel engine and starting'12 volt' associate 1 initiation logic . I battery bunt and charger shall be dednstrated pui.ys and tl.a opersb'o: /, -

circuits aru ore to,the inoperable esguipeent  ; -

' t sh 11 be restored to etablo status within l1. At least once per 7 days,by verifying that:

7 J.sys, or in lieu of anNther report * -

- re paircJ by Specification 6AJ. prepara and . ** a) The overall battefy voltage is>12 volts

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submit a Seccist Report to the - 1ssion within '

the n.:st. 30 days outlis.ing the plan iJ pro-; I / ,

v 2. At least once'per inonth by verifying that: -

ccJares to Le used to provido for the 1 l

/ '

.of redundancy-in this nystem. :i -

.N .

' s) Tye' fuel storage tar.k contains at least 28" '

! j 's {225 gallons of fuci), .

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2 b) The diesci starts frca erblent conditions and

operates for at:1 east 15 minutes, and * -' ,

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t  :

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+ c e electrolyte level of each bittery is above l '

lates. <

Y*  !

! th t

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.  ; 3. At lesst o per 3 conths by verifying thstt . .

4

j n) A supplc.of d of fuel frr,
n the storege

, tank obtained in orJance with AS1M-D270-65, is within the acc tal.lc limits specified e j* ' .in Tablo 1 of AS111 b975-7(with respect to I ,

  • ' ~ viscosity, water content and.scatuent. '

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I  ; j i 8 b) The specific grav'ty of the starting, battery bank is appropriate for continued service:

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.- :of the battery.

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! 295G endments 39 3,%  :; . .

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f - SURVEILLANCE REQUIREMENTS

'y LIMITIN6'tONillTIONS FOR OPERATION ,

4.21.2.B '

,/y 3.21.2.8 /

4. At least once per 18 months by verifying that: ,,/ ,

1 p

\ n) "Iho batteries, and battery

,rneks show no visual indica'tlen of physical damage or abnormal deterioration,

- and b) The hattery-to-battery isnd teminst connections are clean, tight, free of

~ - corrosion and coated with anti-corrosion

~

- material. ,

. S. t Icast once per 18 months by:

a) Sub ting the dicsci to an inspection in accords with procedures prepared in conjunction th its manufacturer's recommendations the class of service, and ,

b) verifying the diesel s a ambient conditions on the auto-start signal and

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operates for >JS minutes while loaded wi$

the fire pump.

29511 Amendments 3-5 & 33 cffsctice S/ CRC.

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(I;.: 41:.G C(mblTIONS loa OPEEATION -

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SuaVellt.At:CE RCQuinnc!GS '

3.21. . 4.21.2.

C. h it is determined that any portion of the C.

fire e .prossion water system supplying Not applicable

/

/

s a fety ated plant areas in inoperable. -

-/ f other than o fire pumps and their assocla-  ! .

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tcJ initiation ogic circuits, the inoperable components shall restored to oper:ble status within 7 days, r in lieu of any

  • other report re guiscJ th* ieci ficatlun 6.6.2, i

prepare :ind suhait a Speeld Report to the j Consission within the next 36 ays out-1 lining the plans and procedures o be used -

to provide for tino loss of rcJund.: in this systene.

D. t(nen it is Jeturnined that D. Not applicable suppression water systess and theinstalleJ entire tire'\ '

backup capiipuent (s otherwise inoperable, k' except as requircJ for equipinent or system -

testing purposes, a backup fire suppression -

water systea shall- ho established within 24/ ,

hours. A Special kepurt shall be subalfted by telephone within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, confirued by telegraph, mailgram or facsimlic fpflo.eing

  • the event, and in writing withipli Jays .

following the e vent , 'out Iining'the act ion f t.sken, the cuisse of the 1:3at f erability and the plans anJ scheJuicfdr rostoring ti.e .

systco to operable ststus. ,

E. If 3.21.2.D sityi nuot be fulf!!!cJ. place the reactor in flot Standby within the n.:st 4

\ .

hours and ColJ Shutdown within the

\

follow g thirty (30) hours. .

3. Spri er Systems -

3.' Sprinkler Systems

. "the sprinkler systems located in each zono A. *Ihe sprinkler systems located in each e listed in Table 4.21-3 shall be operable at i listed in Table 4.21-3 shall be demotistra'ted j 6

W G

T .

- beump -

1,1?41T M CONN!TIONS FOR OPERAT10tf

- l SURVP.II.IANCE REQUIRmLNTS

/\ .

3.21.3.X .

4.21.3.A 1 all ti. wher, equipment in that zone is operable as follows-required be operable, except as noted in '

{ 3.21.3.D and 21.3.C. 1. Each testa % valve in the flow path shal-1 j

be cyc through at least one coeplete cycliv full travel at least once per l'4onths.

. A sprinkler header flow test shall be i performed on each system by opening its  ;

remote flow test valve et least once per operating cycle.

j

~ ~ '

3. %c sprinkler henders and spriniter heads i shat! be visually inspected at least once I

~ '

' per operating cycle to verify they are intact and not blocked or corroded.

i When it is deter 31 ed that the sprinkler B. Not applienblo B.

- system for a tone listed in Table 4.21-3 .

is inopern , within I hour, backup fire suppres n equipment and continuous fire ,

wate shall be established for that zone '

upril the sprinkler system is restored to /

/ 6perable status. ,

{

l Amendments 2' ! ?? effecti . m -0/8/ M.

DELE yt O '

s 7 .

LfM{. ,.i; CONulTIONS FOR OPERATION SURVEILLANCE REQUIRDIENTS /\ ' '

3.21.3.C 4.21.3.C .

C. hh it is determined that the sprinkler C. Not applicable syste or a zone listed in Table 4.21.-3 is in-operable, the system shall be restored to operabis at is within 14 days, or in lieu of .

any other repo required by Specification '

6.6.2, prepare an gubstt a Special Report to the Cosmission with he next 30 days outlining the action taken, the c e of the inoperability and the plans and schedule r restoring the system to operablo status. ,

4. Low Pressure CO2 SYstems 4. Low Pressurs CO2 Systems A. The CO2 system protecting each A. The CO., system protecting each tone listed zone IIated in Table 4.21-4 shall in Table 4.21-4 shall be demonstrated be supplied from a single CO 2 Operable as follows:

storage tank having a minimurn 1 et of 5 tons and a asinimum pres re of 250paig. The CO 3 synt pro-tecting each zono IIste Fin Table 4.21-4 shall bo opora l's at all '

times when equipmen in that zone .

is required to be parable, except as noted in 3. . 4 4B and 3.21.4.C 1 The CD storage tahk level and pressure

, s 11deverifiedat least once each wee

2. A brief low test (" puff test'9 shall

. be conduct r each system to verify flow from ca 2 nozzle at least onco per operatin cycle. At the time of this test, both tomatic and manual actuation of th CO2 system and its associated equipment (ncluding valve and ventilation dampers shd I be demon-strated by simulated initiat signals.

~

y e YW f .

C3  % -

1.IhtTitiG C0!iD1TIONS FOR OPERATION SURVE11.1.ANCE REQUIRDIDITS / -

3.21.4 . 4.21.4.3 ,

B. Wh en t is determined that the CO2 system for a R. Not applicable '

l_ zone 1 ad in Table 4.21-4 is inoperable, a

continuous to watch with backup firo a suppression e ent shall be established for the zone within hour until the CO2 system is restored to oper o status.

l C. When it is determined the he CO system for a 2

C. Not applica le zone listed in Table 4.21-4 Inoperable, the ,

system shall be restored to ope le status with-in 14 days, or in lieu of any othe e required by Specification 6.6.2, prep % port o and submit a Special Report to the Consnissio. within the next 30 days outlining the action taken, the cause of the inoperability and the plans and schedule for restoring the system to operable ,

status. .

. D. A CO2 system for a zone listed in Table 4.21-4 may be inoperable during periods of maintenance on a diesel generator in that zone provided th the zone is not unattended duri the .

period of maintenance. ,

5. Fire llose Stations 5. Fire Mose Stations .

A. The fire hos ations listed in Table A. Each fire hose stat listed in Table 4.21-5 sh be operable at all times 4.21-5 shall be demons ted operable when e pment in their zones of as follows:

pro ction is required to be operable,

  • cept as noted in 3.21.5.B. .

295L Amendments 36-t-339ffnh G/8N .

r~  :- .-

D G'Lk r c.h ..

'N (. '

.aitVEII.1.ANCE REQUIRE lLIEhTS ']

IMITIMO: D.Tict FOR OPERATIGI

) <

l 4.21.5.A.1

.21.5.8

. 1. Each accessible fire hose stati shan be visuallyinspectedonceeach/onthtoverif all equipment is at the station. For those hose stations loeded in inaccessible

{ areas, visual inspections shall be performe 1 when practicable.M determined by area I accessibility. /

/

2. Each firo hose shall be removed from the

.' statto(, visually inspected and re-racted 3 hon hydrostatically tested. Duriner f this inspection, all degraded hoses and/

/ or coupling gaskets shall be replaced.

3. ,ch hose station valvo shall be partially ope d at least once cach three years . '

to ve Mr operability and no blockage.

' . . Each fire hose all be hydrostatically tested at Icast on each three years at a pressure at least sig greater than the maximum pressure av 'able at that hos station.

When it is det r61ned that a fire hose R. Not applicable B.

station 11 d in Table 4.21-5 is in-operab , an additional equivalent ty fire hose shall be routed to ca- -

io unprotected zone from an operable hose station within ono hour. ,

~ .

1 295M Amendments - .. u =ffecttve 4/8/784 -

DELEN --

r- ,

LIMITING CONDITION FOR OPERATION SURVEILLANCE REQUIREMENT ,

g

_' \

r (, ~f' 3021 4.21 /

Penetration Fire Barri,ers

6. Penet tion Fire Barriers 6.

A. All pe tration fire barriers pro- A. Each of the 's'afety related tecting a ty related areas shall penetrat16n fire barriers shall be functiona t all times. he verifled to be functional by o' visual inspection.

p .

,/ 1. At least once per 18 nonths,

/ and

/

/ 2. Prior to declaring a penetra-I tion fire barrier functional following repairs or mainte-

/ .

nance.

/ .

B. With one or more of the aboveje-quired penetration fire ba lers not intact a continuous re watch sha13. be established at least one side of the a ted penetra-tion within 1 . If an oper-able fire dete'ctor is located in the area,'an rly inspection of the penetr on fire barrier may be perf med rather than establishing a ontinuous fire watch. -

7. e provisions of Specifications 3.0.3 7. Oot Applicable.

\ are not applicable to Specification

\ 3.21. ~

\

N

, ./

gf S g

~,

l

( g- .

ses 3.21 s (.21

  • l

- - opera 141ty of the fire detection instruman- In the eYent that the fire suppression Oater' tation chasires that adequate warning system becom' e s inoperable, impediate correttive capability 3s available for the prompt ,moasures must be taken since this syste( provides f detection of Y res. - This capability is the major fire suppression capability'for the i i required in or to detect and locate fires plant, The requirenent for a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />,r(port to the .

! in their early at s. Prompt detection Consulssion provides for prompt evaluation of the acceptability, l , of fires will reduceNha potential for damage or* the corrective meastees to proville adequate fire I

,l l to safety related equ ent and is an integral suppression capability for tha4cntinued protection of the

. element in the overall f 111ty fire protec-

  • nu'cicar plant. I ri tion program.

The functional' integrity of the penetration fire barriers

. Ir. thu event that a portion of't a fire detec- ens m s a es e c nMned or adequately ntaNed I

tion instrumentation: protecting s ety related fr a 5Preadins de adjacent p I plant areas is inoperable, the esta ishment This -  ; ,

of frequent fire patrols in the affcc d areas design fea,ta[e-minimizes possib1111ty the,ortions of of the facility.

a single fire is required to provido detection capabi ty raPldly nvolving several areas of the facility prior to

^

.de t on and extinguishment. The penetration fire barriers until the inoperable instrumentation is re

~

turned to service. . s A Passive element in the facility fire protection -

program and are subject te periodic inspections. .

The operability of the fife suppression sys-Ing periods of time when the barriers are not functional tems ensures that adequate fire suppressi capability is available to confino and a taq(Inuous fire watch is required to be maintained in the fi extinghish fires occurrliig in any po ion of vicinKy of the affected barrier untti the barrier is /

the facility whero safety related cipment restore to functional status. 7 is located. 'The fire supprossi system . .

consists of the water system, ' pray and/or sprinklers, CO 2 , and firp h e stations. The

. co11cetivo capability of to fire suppression ,

systems is adequate to inimize potentisi .

damago to safety re ed equipment and is a '

major alement in e facility fire protec-tion program.'

In the av that portions of the fire f ,

suppran on systerms protecting safety re-lated laut arcan are inoperable, alternate J/

bac p fire fighting equipment is required /

tp be made available in the af fected areas -

fntil the af fccted equipment can be restored to service.

' 2950 Amendments 35 0 33-efr41m 6/8/7&r

_r_ _ _ _ _ _ _ _ _ - _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . . _ . _ . _ _

hM . .

TABLE 4.21-1 i f!RE DCTECTION INSTRUMENTS /

LOCAT!DN MINIMUM DCTT.CTORS OPhRADf.r.

i

/

1. R Control Rooms 1 un t 1 (zone 2) 1 .

Uni 2 (Zone 2)

2. Battery ooms
  • Batte 111 (Zono 3) .

Battery 12 ltono 4) .

1

. Battery 1 (Zone 3) 1 Battery 21 (Zono 4) 1 Battery 011 Zono 19)

3. Aux. Electric Eq pment Rooms 3 .

Unit 1 (Zone 5) 3 ,

Unit 2 (Zone 5) ,

Essential Switchgear oss 2 4.

Switchgear Bus 147 ( na 7) 2 Switchgear sus 140 (3 e 8) 2 .

Switchgear Bus 149 (Zo . 9) 2

( Switchgear Bus 247 ( on 7) y Switchgear Dus 240 (Zono )

2 2

Swit*chgear Bus 240 (Zono 9

5. Cablo Ponetration Vaults 1 Unit 1, E1. Gl?' (zone 10) 1 Unit 1, E1. G17' (zone 11) 1 Unit 1, E1. 630' (Zone 12* 1 Unit ), E1. 630' (zono 1 ) 1
Unit 2, El. 617' (Zono 0) 1 Unit 2, E1. 617' (Zon 11) 1 Unit 2. E1. G30' (to c 12) 1 Unit 2, E1. 630' (: ne 13)
6. Containnents
  • 1 Unit 1 Cablo Pe trations (7.one 14) 3 Unit 1 Steam C .ncrators IA & Ic,'cl. SG8' (2 e 22) 23)- 4 ,.

Unit 1 Stcas encrotors ID & 10, E1. 568' (:o .

1

  • Penetrations ( ene 14)
  • Unit 2 Cabl .conerators-2A ) 3 Unit 2 Ste 6 2C, E1. 568' (Zor.o 4 Unit 2 S am Generators 2D & 2D, El. 560' (zone 2
7. Diesel C nerator Rooms 1
  • Dios Generntor 1A (:ene 20) 1 Die el Generator ID (Zone 21) 1 D sel Cencrator 2A (:ene 70) , 1 ,

~'

iesci Cencrator 2n (zone 21) 1 Diesel concrator 0 (ronc 19)

/

l '

  • g
  • naccessib p Amendments 26 1 ?? all=:ive 0/0n er I-

- . ,- TABLE 4.21-1 (continued) f i .

yton MINIMUM DiiisCiORS OFFRABLE Containment Spray s Rooms 1

8.
  • Unit 1 (sone 25) 1 Unit 2 (sone 25) .

6

f. Cable spreading (Rooms:en,46)

Unit 1 Inner - 15 .--

Unit 1 outer zone 27) 6 Unit 2 Inn (Zone 26) 15 Unit 2 er (sor.e 27)

10. Cr ouse 7 ,N 5artice Water Pumps Room (zone 25)

DElh S. -

/'

i .

fb t

,a.+. , '

,\ .

0,'^,'7^.

.295Q Amendments 30 f. 33 ef f ath

I e

! ( '

l DELETED I

i .

1 L<

295R Amendment Nos C; e,,; 120

j .

( 7 TABLE 4.21-3 x N

/ ~'

SPRINKLCR SYSTEMS tone _

LOCATIC}f *

, 142 Diesel Generator 1A Fusi 011Jto 3 (Room 143 Diesel Generator 13 Fuel.01T Storage R 241 Diesel GeneratorprfE1011 Storage Room 242 Diesel Generatcf 2D o Fuel OilStorage ruel oil Storage Room Room Diesni Mn'erator .

d

(.1k.  %)

i e

g 2955 Amendments $$ & ;3 effscrivw c/a/73.

. . ... , p. . .

=-

e t .

~

.i ,

.L m

  • TA31.E 4.21-4 CO2 Systems

' EONE Location 1=K2 Diesel' Generator 1A '

1-X3 ,

, Diesel Generator Ir 2-K1 Diesel Gen at6'r 2A

  • 2 .

Die nerator 2B 1-K t

1 Generator 0-f 61k .

f~

i

- 2 l .

' Amendments 25 i 33 :ffdf u- 9/ M &.

QST e, is+.--w,--~e-r-e ,---,._w -.....-*~.,,:e re-, ,c..+v --ww. w .....e__#.,.-...,,,,-m-,,.-aw.we, , .-.m,. ,--w *- . * - - - .,w -

i)suTsb TA3LE'4.21-5 L*

T1RE NOSE STATIONS g

1. Auxilia Building, E1. 642' / -20 2 .* Auxiliary 11 ding, E1. 617' 'K-26 .

J-20 N-20 1 4 Auxiliary Buildin , E1. 592' L-28

3. * .K-25 W-20 N-14 Auxiliary Building, El. 579' N'24
4. ,

.N-20

' 5.- 14,-

i Auxiliary Building, E1. 560 . -E-26

5. 2 0 5-14 l

r 6. Auxiliary Building, E1. 542' K-26 N-20 5-14 4

s-6

! 7. , Unit 1 Containment, E1. 617' 3'13 f

Unit 1 containment, 1. 590' t-6

8. *

.3-13 e, E1. 568' . 5-5

$. Unit 1 Containe 3-:13 i.

10. Unit 2 conta aant, E1. 417' . 3-22 3-29 E-23 -
11. Unit 2 tainment, E1. 590' -

3-29:

containment, E1. 568' -22 l 12. Unit S 29 it 1 Cable Spreading Room, E1. 630' K-2 31.

L l Unit 2 Cable Spreadin j Itoom, nl. 630' e 11-14

1. s l u i.

29W . Amendments G6-a-35 eff=d l c 0/0/70.

I $

1

+--

6

COL 14 CAT!0N G-27

, 15. Turbin uilding, El. 642' J-25 '

G-22 H-15 C-13

- / '

/ C-33

16. Turbine Building, E1.

\ G-27 C-22 l

. C-13 G=7 C-33

17. Turbine Building 1. 592' C-27

. F-22 c-13 C-7

/

xbine 11uilding, E1. 560' 18.

' N2

$-N N ~ -

l bOI5YJ)

I

.. a I

l l

l I

L l

/

.'f Y-295Y Amendnents 30 " 33 p ffect-4ve S/?M9-t

,a p

6.0 AD41MISTRATIVE CONTROLS

-6.1 Organization. Review. Investigation, and Audit

1. Onsite and offstte organizations shall be estabitsbed for unit operation and corporate m respectively.

j safe *y of the nuclear power plant.

a. Lines of authority, responsibility, and communication shall be established and defined for the highest management levels through Intermediate levels to and including all operating organization positions.

These rel.tlonships shall be documented and v;wfated, as appropriate, in the form of organization charts functional descriptions of departmental responsibilities and relationships, and shall The requirements job descriptions be documentedfor in key personnel positions, or in equivalent forms of documentation.the Quality Assurance Manu {

Authority. Activity and Section 6 Inter-Departmental Relationships.

b.

The Station Manager shall be responsible for overall unit safe operation and shall have control over 4 those onsite activltles necessary for safe operation and maintenance of the plant.

c. The Senior vice President Muclear Operat'1ons shall have corporate responsibility for overall plant nuclear safety and shall take any'sensures needed to ensure acceptab11r performance of the staff la operating, maintaining, and providing technical support to the plant to ensure nuclear safety.

, ,r, ,

d. The Individuals who train the operating staff and those who carry out health physics and quality

- assurance functions may report to an appropriate onsite manager; however, they shatt have sufflctent organizational freedom to ensure their independence from operating pressures.

l 2. Deleted. ,a.

The Assistant Superintendent Operattag.

3. The shift manning for the station shall be as shown in Figure 6.1-1. The

- Operating Engineer, Shlf t Engineers.. and Shif t Foreman shall have a Senior Reactor Operators License.

The Fuel Hand 11pg Foreman shall have a sentor Reactor Operator or t.1mited Senior Reactor Operators License. An Vice. President PHR Operations on the corporate' level has responsibility for the Fire Protection Program.

Operiting Engineer at the station will be responsible for laplementation _of the Fire Protection Prograsp e ent: :: 21: t t. ; , m r;c, ;,;gn ;un a fri-e 9-S p - ar inc h n ; M 2 htr a v.29 e m  : 7; ;ul,! M --!-t:5 t " ft w w ... w .sy fue ,3.fu,3nuter. or tne ps.rit G Z;r;; cr :ny ;;rtm:t s;d-a-

^

j p

  • etScr ettenth! f nct?^-! t-?nf:[fl. .-. - ,.
  • L e i

300 Amendeent No. al',*. ;^"

14870 15460f18) .

(Continued) 6.1.4 Qualifications of the Station management and operating staff shall meet minimum acceptable levels as described in ANSI M18.1 " Selection and Training of Muclear Power Plant Personnel", dated March 8, 1971 with the exception of the Health Physics Supervisor or t.ead Health Physicist, who shall meet or exceed the quallfications of Radiation Protection Manager of Regulatory Guide 1.8 September,1975. The Shlrt Control Room Engineer shall have a bachelor's degree or equivalent in a scientific or engineering distinilne with specific training in plant design, and response and analysts of the plant for transtents, and accidents. The Individual filling the position of Technical Superintendent shall meet the minimum acceptable level for "Techalcal Manager" as described in 4.2.4 of ANSI M18.1, 1971.

S.

Retraining and rep 1,agement training of Station personnel shall be in accordance with ANSI M18.1 " Selection and Training of Muclear Power Plant Personnel

  • dAtt4_J4argh_8 1971) A-tr*inamtam_f6TE. nr. m49 M

( ^= D " --intsiaed requirements er.Jer th-direc-tic teSediun Of the--Stat 4en_st r. sa%ar33.1 3-e m1i et ~ .vceeLthe 27 vi 6 U".". M 1975-ewce;;t that Tire "rigd: tra%ntat-w!Il t+ Conducted quarterly. 7 _ -

6. Retraining shall be conducted at Intervals not exceeding two years.

7.

The Review and Investigative Function and the Audit Function of activities affecting ' quality during fac111ty operations shall be constituted and have the respons1b111ttes and authorttles outlined below:

Offs 1te Review and Invest 1eative Function A.

The Superintendent

- Quality of theSafety Assurance / Nuclear Offsite(QA/MS).

Review and Investigative Function shall be appointed by the Manager of the Manager of OA/ns and shall be Independent of operations.The Corporats Audit Function shall be the The Manager of QAIMS reports directly to the Chief Executive Officer and has the respons1blitty to set Corporate Policy for both the areas of Quality Assurance and Nuclear Safety. Policy is promulgated through a central policy committee directed by the Manager of QAIMS. The Manager of OAIMS has the responsibility for the to determine that performance QAINS policy is of being periodic audits carried out. of each nuclear station and corporate department

1. The Superintendent of the Offsite Review and Investigative Function shall:

(1) provide directions for the review and Investigative function and appoint a sentor participant to provide appropriate direction.

(2) select each participant for this function.

301 Amendment Mos. 1"O er4 12t-

6.6.3.8 Scecial Recorts (Continueti)

TOPIC SUBMITTAL DATE

1. Pressurtzer PORY or Safety Valve Document the event in the Annual Report challenoes J. (Future)

Steam generator tube laspection and/or Per survelliance requirements 4.3.1.8.5

k. ~

plugging.

Emergency Core Cooling System (ECCS) Hithin 30 days as LER include nozzle usage

8. factor per T.S. 3.3.2.F.3 actuation and injection when RCS temp 1 350*F -

~

m A catscter inoper HTTTty within-30-duri ver T.s r3221.1:c rc. Tk; M :ystes-4aoperehtlity H14his-30 d.fi M c i.S. 3.21-2.8- j Fire ;;;;ressloa 1y11esLIMperAttljlty M4hin- 30 dayswT:S:-h2b2,C-or-3.21:2:0 c.

Mithin-30-days per-T&3.23.3.C

& pe!e S h r syst:= ! :; rebtitty i

/

Ni thi n-30-1feysyr-T.S .- 3.21.4.C ets- p. essers C0z-system-Inoperability --- - ~---- -. - - . . . . . . . . .

Per surve m ance requirement 4.15.1.S.5 pn g Olesel generator failures SPECIAL REPORis

. Table 6.6-1 (Continued) 324 Amendment Mos. 120 end it?

. . . . . -. . . . _ - . _ . _ . _ . _ . .. . . _ . _ _ - -_._ _ _ . . ..m__ .. - - . . .....__ .._..

i

-i i

1 7

P i

TYPED COPY OF ,

PROPOSED CHANGES TO ZION TECHNICAL SPECIFICATIONS AND OPERATING LICENSES -

r

- FOR TSCR NO. 91-11 .

RELOCATION Of FIRE PROTECTION REQUIREMENTS i 4

r i

+

i w

I s

't i

ZN'LD-2334-13--

--wa, .- -. mJ.-,p-y--pr.y -. .g-, 3 m._,,4 i. .. -m-,,,.n,.

, . _ - . . . . + - - - d. ->--asew s 6 m .- w Js.e--* v e es *- "' w

DPR t (5) The licensee shall implement and maintain in effect all provisions  ;

of the approved Fire Protection Program as described in the (Updated) Final Safety Analysis Report for the Zion Nuclear Generating Station and as approved in the SERs dated March 10, 1978, L May 26, 1978, June 26, 1978, February 14, 1979, April 13, 1979, March 24, 1980, November 24, 1980 December 9.-1980, March 7, 1983, June 7,1988, Ja:1uary 7,1991, and (date of- final- SER approval of fire protection administrative controls) subject to the following provision:

The licensee may make changes to the. approved Fire Protection  :

Program without prior approval of the Commission only if those changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire. -t (6) The licensee shall fully implement and maintain in effect all provisions of the commission-approved physical-security, guard training and qualification, and safeguards contingency plans including amendments made pursuant to provision of the Miscellaneous Amendments and. Search-Requirements revisions to 10 CFR 73.55 (51 FR  !

27817 and 27822) and to the authority of 10 CFR 50.90 and 10 CFR _

50.54(p). The plans, which contain Safeguards Information_ protected under 10 CFR 73.21, are entitled: " Zion Nuclear Power Station Security Plan," with revisions submitted through June 30,-1988;

" Zion Power Station Training and Qualification Plan," with revision-

February 1, 1984. Changes made in accordance with 10 CFR 73.55 -

shall be implemented in accordance with the schedule set forth therein (revised 11/01/88, Am. 113),

(7) Spent fuel Pool Modifjntion The licensee is authorized to modify the_ spent fuel pool as .

described in the application dated April 13, 1973, as supplemented  !

October 24, November 8 and 29, 1978, January 24 and 26, February 23,.

March 7 and March 19, 1979. (revised 1-15-81; Am. 61) [

i (a) Fuel stored in the spent fuel pool- shall have a U-235 loading less than or equal to 46.4 grams-per axial centimeter. (revised 02/19/86; Am. 94) '

t Amendment No.

ZNLD-2334-14

t DPR-48 (5) The licensee shall implement and maintain in effect all provisions f of the approved Fire Protection Program as described in the-(Updated) Final Safety Analysis-Report for the Zion Nuclear  !

Generating Station and as approved in the SERs dated March 10, 1978,  !

May 26, 1978, June 26, 1978, February 14, 1979, April 13, 1979,

  • March 24, 1980, November 24, 1980, December 9, 1980 March 7, 1983, June 7, 1988, January 7, 1991, and (date of-final SER approval of fire protection administrative controls) ' subject to the following' provision: 4 The licensee may make changes to the approved Fire Protection Program without prior approval of the Commission only if those changes would not adversely affect the ability to achieve and ,

maintain safe shutdown in the event of a fire. I (6) The licensee shall fully implement and maintain'in effect all provisions of the commission-approved physical security, guard 4 training and qualification, and safeguards contingency plans including-amendments made pursuant to provision of the Miscellaneous ,

Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The plans, which contain Safeguards Information protected 4 under 10 CFR 73.21, are entitled: " Zion Nuclear Power Station -

Security Plan," with revisions submitted thrcugh June 30,-1988; ,

" Zion Power Station Training and Qualification Plan," with revision submitted through February 16, 1984; and " Zion Nuclear Power Station ,

Safeguards Contingency Plan " with revisions submitted through February 1, 1984. Changes made in accordance with 10 CFR 73.55 shall be-implemented in accordance with the schedule set forth-therein (revised 11/01/88, Am. 102).

(7) SpenLEueLEooLilodificAtlon ,

The licensee is authorized to modify the spent fuel pool as described in the application dated April. 13, 1978, as supplemented October 24, November 8 and 29,-1978, January 24 and 26,, February 23, March 7 and March 19, 1979. (revised 1-15-81: Am. 61)

(a) Fuel stored in the spent fuel pool shall have a U-235 loading.

less=than or equal to 46.4 grams per axial centimeter. (revised-02/19/86; Am. 94) l l:

5 Amendment No.

t ZNLD-2334-15 y

SURVEILLANCE LIMITING CONDITION FOR OPERATION EEOUIREMENT PI E i 3.13 Refueling Operations 4.13 243 3.13.1 Core-Reactivity. 4.13.1 243 3.13.2. Protection from Damaged Spent Fuel 4.13.2 244 3.13.3 Containment Status 4.13.3 245 3.13.4 Radiation Monitoring 4.13.4 246

, 3.13.5 Refueling Equipment Checkout 4.13.5 245 3.13.6 Refueling Equipment Operability 4.13.6 246 3.13.7 . Spent Fuel P1t Cooling Systems 4.'13.7 246

'3.13.8 Fuel Inspection Program 4.13.8 247 3.13.9 Residual. Heat Removal System Operation. 4.13.9 247a

i. 3.13.10 Hater Level - Reactor Vessel 4.13.10 247c l 3.13.11 Water Level - Storage Pool 4.13.11 247d l

Bases 246 3.14 Plant Radiation' Monitoring 4.14 250 t- Bases 254

. 3.15 Auxiliary Electrical Power System 4.15 255 Bases 271 3.16- Radiological Environmental Monitoring 4.16 275 Bases 279 3.17 1 Ventilation 4.17.1 281 3.17.2 (Section Deleted) 283 Bases 287 3.18 Steam Generator Activity 4.18 289 Bases 290 3.19 Failed Fuel Monitoring 4.19 292 Bases 293 3.20' Radioactive Solids 4.20 295a t~ Bases 3.21 (Section Deleted)' 2950-V l 4 3.22 Shock Suppressors (Snubbers) 4.22 295H Bases 295Z 3.23 (Section Deleted) 295AB 3.24. Sealed Source Contamination 4.24 295AD Bases 295AF TABLE OF CONTENTS (Continued)

, ZOSR-269 tv . Amendment Nos.

lahla P332 4.15-1 Deleted 270 4.15-2 ' Diesel Generator Test Schedule 270a

~4.16-1 Maximum Values for the Lower Limits of Detection (LLD) 280 i

4.17-1 Charcoal Fliters 284  :

I 4.17-2 HEPA Filters 285 4.19-1 Deleted 295 l 4.21-1 Deleted 2950-V 4.21-2 Deleted 295D-V 4.21-3 Deleted 2950-V r

4.21-4 Deleted 2950-V j- 4.21-5 Deleted 2950-V .

6.6-1 Special Reports 323 6.8-1 Boundary Doors-for Flood Conditions 328 I

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List of Tables (Continued) j- ;ZOSR-269 x1 ' Araendment Nos.

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6.0 AQMINISTRATIVE_CQRIRQLS 6.1 Organization, Review, Investigation, and Audit Onsite and offsite organizations shall be established 7or unit operation ;nd corporate management, respectively. The onsite and off site organizations shall include the positions for 7.crivities affecting the j

i safety of the nuclear power plant.

a. Lines of authority, responsibility, c.1d communication shall be established and defined for the highest management levels through intermediate b->els to and including all operating organization positions.

These relationships shall be documented and updated, as appropriate, in the form of organization charts functic.al descriptions c' departmental responsibilities and relationships, and job descriptions for key personnel positions, or i.. equivale-t forms of documentation. The requirements shall be documented in the Quality Assurance Man.s! or the Management Plan for Nuclear Operations, Section 3 Organizational Authority, Activity and Scotton 6 Inter-Departmental Relationships.

b. The Station Manager shall be responsible for overall unit safe operat'.on and shall have control over those onsite activities necessary for safe operation and maintenance of the plant.
c. The Senior Vice President Nuclear Operations shall have corporate responsibility for overall plant nuclear safety and shall take any measures needed to ensure acceptable performance of the staff in operating, maintaining, are providing technical support to the plant to ensure nuclear safety.
d. The individuals who train the cperating staff and ti.ose who carry out health physics and quality assurance functions may report to an appropriate onsite manager; however, they shall have sufficient organizational freedom to ensure their independence from cperating pressures.

l

2. Deleted.
3. The s'iift manning for the station sha)1 be as shown in Figure 6.1-1. The Assistant Superintendent Operating, Operating Engineer, Shift Engineers, and Shift Foreman shall have a Senior Reactor Operators License. The fuel Handling Foreman shall have a Senior Reactor Operator or Limited Senior Reactor Operators License. The Vice President PHR Operations on the corporate level has responsibility for the Fire Protection Program. An Operating Engineer at the station will be responsible for implementation of the Fire Protection Program.

I ZOSR-269 300 Amendment Nos.

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(Continued) 6.1.4 Qualifications of the Station management and operating staff shall meet minimum acceptable levels as described in ANSI N18.1 " Selection and Training of Nuclear Power Plant Personnel", dated March 8, 1971 with the exception of the Health Physics Supervisor or Lead Health Physicist, who shall meet or exceed the qualifications of Radiation Protection Manager of Regulatory Guide 1.8 September, 1975. The Shift Control Room Engineer shall have a bachelor's degree or equivalent in a scientific or engineer *ng discipline with specific training in plant design, and response and analysis of the plar.1 for transients, and accidents. The individual filling the position of Technical Superintendent shall meet the minimum acceptable level for

" Technical Manager" as described in 4.2.4 of ANSI N18.1, 1971.

5. Retraining and replacement training of Station personnel shall be in accordance with ANSI N18.1, " Selection and Training of Nuclear Power Plant Personnel", dated March 8, 1971.
6. Retraining shall be conducted at intervals not exceeding two years.
7. The Review and Investigative Function and the Audit Function of activities affecting quality during facility operations shall be constituted and have the responsibilities and authorities outlined below:

Offsite Re_y_trw Anc in/esticative Function A. The Superintendent of the Offsite Review and Investigative Function shall be appointed by the Manager of Quality Assurance / Nuclear Safety (QA/NS). The Corporate Audit function shall be the responsibility of the Manager of QA/MS and shall be independent of Operations.

The Manager of QA/NS reports directly to the Chief Executive Officer and has the responsibility to set Corporate Policy for both the areas of Quality Assurance and Nuclear Safety. Policy is promulgated through a central policy comittee directed by the Manager of QA/NS. The Manager of QA/NS has the responsibility for the performance of periodic audits of each nuclear station and corporate department to determine that QA/NS policy is being carried out.

i

1. The Superintendent of the Offsite Review and Investigative Function shall:

(1) provide directions for the review and investigative function and appoint a senior participant to provide appropriate direction, (2) select each participant for this function.

ZOSR-269 301 Amendment Nos.

3M " ' i

l 6;6.3.B .Special Reoorts (Continuedl TOPIC SUBMITTAL DAIE

1. Pressurizer PORV or Safety, Valve Document the event in the Annual Report challenges
j. (Future)
k. Steam generator tube inspection and/or Per survelliance requirements 4.3.1.B.5 plugging.
1. Emergency Core Cooling System (ECCS) Hithin 30 days as.LER -

include nozzle usage actuation and.injecticn when RCS temp factor per T.S. 3.3.2.F.3 2 350*F

m. Diesel generator failures Per surveillance requirement 4.15.1.B.5-s-m S.rECIAL REPORTS Table 6.6-1 (Continued)

ZOSR-269 324-- . Amendment-Nos.

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ATTACHMENT C ZION NUCLEAR GENERATING STATION SIGNIFICANT HAZARDS CONSIDERATION EVALUATION TSCR NO. 91-11 RELOCATION OF FIRE PROTECTION REQUIREMENTS 1,

'd ZOSR-269(22)

6 SIGNIFICANT HAZARDS CONSIDERATION Commonwealth. Edison Company has evaluated this proposed Technical Specification Change Request (91-11) and has determined that it involves no significant hazards consideration. This determination has been performed in accordance with the criteria set forth in 10CFR ,50.92(c) as quoted below:

"The Commission may make a final determination, pursuant to the procedures in 50.91, that a proposed amendment to an operating license for a facility licensed under 50.21(b) or 50.22 or for a testing facility involves no significant hazards consideration, if operation of the facility 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 following evaluation is provided for the three categories of the significant hazards consideration standards:

1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated?

The proposed change vill not result in any hardware changes. The fire protection equipment and controls are not assumed to be initiators of analjzed events. The affected fire protection equipment and controls are assumed in the mitigation of the effects of a postulated fire. The removal of the fire Protection Technical Specifications and the addition of a control process does not degrade the requirement to maintain an adequate level of fire protection.

The Fire Protection Technical Specifications will be relocated to the Fire Protection Program and controlled by the proposed fire protection license condition and 10CFR 50.59. These control requirements ensure the level of fire protection will be maintained consistent with that currently existing. Therefore, this change is administrative in nature and does not involve a significant increase in the probability or consequences of an accident previously evaluated.

ZOSR-269(23)

SIGNIFICANT llAZARDS CONSIDERATION (Continued)

2. Does the change create the possibility of a new or different kind of accident from any accident previously evaluated?

The proposed change, which involves relocation of Fire Protection Technical Specifications and the addition of a control process, does not necessitate a physical alteration of the plant (no new or different type of equipment will be installed) or changes in parameters governing normal plant operation. The proposed change will not impose any different requirements and adequate control of information will be maintained. Thus, this change does not create the possibility of a new or different kind of accident from any accident previously evaluated for the Zion Nuclear Generating Station.

3. Does this change involve a significant reduction in a margin of safety?

The proposed change will not reduce a margin of safety because it has no impact on any safety analysis assumptions. The proposed change is administrativ? in nature and ensures the current level of fire protection is maintained. The relocated fire protection requirements will continue to be required to be met. Any changes to these requirements will be evaluated separately in accordance with 10CFR50.59 and the proposed license condition. Additionally, the 10CFR50.59 process used to control changes to the relocated fire protection Technical Specifications is more stringent in that more conservative questions than those asked by the 10CFR50.92 process must be addressed. Therefore this change does not involve a significant reduction in a margin of safety.

NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINMION In conclusion, based on the previous consideration (Standards Categories 1-3), Commonwealth Edison Company submits that the activities associated with Technical Specification Change Request (91-11) satisfy the Significant Hazards Consideration standards of 10 CFR 50.92(c) and, accordingly, a_ finding that this Technical Speciftcation Change Request does not represent-a-Significant Hazards Consideration is' justified.

ZOSR-269(24)

ATTACHMENT D ENVIRONMENTAL CONSIDERATION FOR TSCR NO 91-11 RELOCATION OF FIRE PROTECTION REQUIREMENTS ZOSR-269(25)

- - - - . ._- -- - - - -. -. = ..

ENVIRONMENTAL CONSIDERATION The proposed Technical Specification and Operating License changes of TSCR 91-11 have been evaluated against the criteria for and identification of licensing and regulatory actions requiring environmental assessment in accordance with 10CFR 51.21 It has been determined that the proposed changes meet the criteria for categorical exclusion as provideo for under 10CFR 51.22(c)(9). The following is a discussion of how the proposed Technical Specification changes meet the criteria for categorical exclusion.

10CFR 51.22(c)(9): Although the proposed changes involve changes to Liten:e Conditions, limiting Conditions for Operation and Surveillance Requirements for Fire Protection Requirements:

the proposed changes involve no significant hazards (i) consideration (refer to the Significant Hazards Consideration section of this Technical Specification Change Request),

(11) there is no significant change in the types or significant increase in the amounts of any effluents that may be released offsite since the proposed changes do not affect the generation of any radioactive effluents nor do they affect any of the permitted release paths, and (iii) there is no significant increase in individual or cumulative occupational radiation exposure.

Accordingly, the proposed changes meet the eligibility criteria for categorical exclusion set forth in 10CFR 51.22(c)(9). Based on the aforementioned and pursuant to 10CFR 51.22(b), no environmental assessment or environmental impact statement need be prepared in connection with issuance of an amendment to the Technical Specifications and Operating Licenses incorporating the proposed changes of TSCR 91-11.

ZOSR-269(26)

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ZION NUCLEAR GENERATING STATION FIRE PROTECTION SER MARCH 24, 1978 SECTION 3.2-1, ADMINISTRATIVE. CONTROLS RESPONSES TO REMAINING OPEN ITEMS 5 "6

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p i-ZOSR-269(27) :l 3 --

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Per.Section 3.2.1 of the NRC's March 10, 1978, Safety Evaluation Report of-Zion Station's Fire Protection Program, Commonwealth Edison Company (CECO) was required to provide additional information on several areas in fire protection-administrative controls. NRC Safety Evaluation Reports of March 24, 1980.and November 24, 1980, approved Zion Station's fire protection administrative- .

controls with exception of the following areas: (1) Control of ignition sources, (2; Pre-fire strategies and (3) Control actions to be-taken by_

individuals, control room operators and fire brigade members in the-event of a fire. The NRC Safety Evaluation Report of November 24, 1980,'also listed how these three areas needed to be upgraded to meet the NRC guidelines. CECO's response to those items was provided in a March 18, 1981, letter to the NRC.

In order to support closure of these areas and issuance of the final Safety _

Evaluation Report, the following responses are provided to those guidelines. ,

1. Control of Ignition Sources:
a. NRC Requirement "In response to our position regarding control of ignition sources, the licensee proposed to implement a requirement for fire blankets on any flammable components within a 35-foot radius of any welding operation. The licensee has substituted the term +

" flammable" for " combustible". These terms do not have the-same meanlng and, therefore, are not interchangeable. To meet our guidelines, the licensee should implement a control so that where welding, grinding, open flame work and cutting is being-performed, all immovable combustible material below and within a 35-foot radius wili be protected by asbestos curtains, metal curtains, or flame l proof covers."

b. Response The Zion administrative procedere on fire protection when welding, cutting, or grinding (hot work) . specifies relocating moveable "conibuittbbs" at- least 35 feet from the work site. Where relocation cannot be accomplished all combust 4 e material below and.within 35 feet of the work site will be. covered with fire retardant material.

l Therefore, CECO considers this requirenent to be satisfied.

2. Pre-Fire Strategies:

4

a. NRC Requirements "In response to our position on pre-fire strategies, the itcensee took exception to the following:

- Potential radiological and toxic hazards in fire zones; and Ventilation system operation that ensures desired. plant air-distribution w1en the ventilation flow is modified for fire containment o. smoke clearing.

To meet Paragraphs-12(g) and 13(n) of Appendix R, the licensee should modify their pre-fire strategies to include these items".

l 20SR-269(28)

T

b. Response
1) The Zion pre-fire plans for each fire zone have a specific section devoted to the identification'of specific fire zone hazards such as radiation concerns, contamination concerns and toxic hazards._ Therefore, CECO no longer takes exception to the NRC position and considers this requirement to:be satisfied.
2) The Zion station pre-fire strategies-address ventilation requirements during a fire to ensure'the desired plant air distribution is maintained. The pre-fire plans designate the ventilation system components, power supplies, breaker numbers and powei supply locations for both the normal and emergency ventilation lineups in each fire zone. The plan also provides-details on the recommended method of smoke removal for the zone. The station fire fighting administrative procedure also gives directiot to the control _ room operators to re-start ventilation if it was secured, following verification from the fire brigade leader that the required fire dampers are closed.

If ventilation cannot be restored for long periods of time, it directs the operators to make provisions to provide local ventilation to safety related equipment to provide cooling.

Therefore, CECO no longer takes exception to the NRC position and considers this requi^ement to be satisfied.

3. Control Actions to be taken by individuals, control room operators and fire brigade members in the event of a fire.
a. NRC Requirement "In addition, to meet Paragraphs 9, 10, 11 of '

Section III(K) of Appendix R, the-licensee should modify their administrative controls to establish procedures to:

1) Control actions to be taken by an inc'ividual discovering a' fire, such as notification of control room,-attempt to extinguish fire, and actuation of local fire suppression systems;
2) Control actions to be taken by the control room operator to determine the need for brigade assistance upon report of a. fire- '

or receipt of alarm on control room annunciator panel, such as announcing location of fire over PA system, sounding fire o alarms, and notifying the shift supervisor and the fire brigade L leader of the type, size and location of the. fire; and i 3) Control actions to be 'taken ty the fire brigade af ter i notification by.the control room operator of a fire, such as i

assembling in a designated location, receiving directions from-D the fire brigade leader, and, discharping specific fire fighting responsibilities including selection and transportation of fire- -

7 fighting equipment to fire location, selection of protective equipment, use of fire suppression systems operating instructions, and use of_ preplanned strategies for-fighting-fires in specific areas."

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.ZOSR-269(29)

b. Response
1) The Zion Station fire fighting administrative procedure directs any person discovering a fire, no matter what size, to immediately report it to the control room using the emergency phone number or pubile address system. The person is to provide their name, location of the fire, nature of the fire and if help is necessary. Only after completely informing the control; room is an attempt to be made to extinguish the fire. Annual general employee training instructs employees to only attempt to-extinguish a fire wita a portable fire extinguisher and only if that person has had " hands on" station training with fire extinguishers. Thereby, CECO considers this requirement to be satisfied.
2) The Zion Station fire fighting administrative procedure designates the actions to be taken.by centrol room personnel upon receipt of a report of fire or-fire alarm. Steps-in the procedure direct the operator to first verify the validity and extent or the fire. Once verified, he is to sound the fire-alarm and announce the location of the fire on the public address system. He is also to assure that the shift engineer has been notified about-the fire. The fire brigade leader and the fire brigade are both directed to report to the scene of the fire upon the control room firi location PA announcement.

Therefore, CECO considers this requirement to be satisfied

3) The Zion Station fire fighting administrative. procedure gives the actions to be taken by the fire brigade. All members of the
fire brigade-are directed by the procedure'to report to the l scene of the fire upon the control room fire location PA announcement. It directs that each member report in full' turnout gear consisting of coat, boots, gloves, Nomax hood, helmet and air pack and it details the initial fira fighting
equipment and gear to be brought to the scene by each member.

This initial equipment consists of the suppression systems necessary to fight any of the different types of fires anticipated in the plant. Any additional equipment nocessary.

will be brought to the scene as directed by the fire irigade leader in charge at the scene. - By procedure the fire brigade leader is the one who-directs all fire fighting activities at the scene with the exception of offsite assistar.a. The fire brigade members are all trained on the use of fire fighting equipment and suppressions systems and their operating instructions. The station's pre-fire plans provide guidance on the fire fighting strategies such as zone access and fire-

! attack /extinguishe nt methods for each fire zone. The pre-fire L

plans are available at the fire gear lockers in the plant and on the fire carts used by the fire _ brigade members to bring tne fire gear to the' scene. All members of the fire brigade are given-training on the pre-fire plans. In addition, a step will be added to the fire brigade administrative-procedure recommending the use of the pre-fire plans during fire fighting activities. Therefore, CECO considers this requirement to be-satisfied.

L ZOSR-269(30)-

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