ML20196J317
| ML20196J317 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 03/08/1988 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20196J315 | List: |
| References | |
| NUDOCS 8803140255 | |
| Download: ML20196J317 (7) | |
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UNITED STATES NUCLEAR REGULATORY COMMISSION j
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E WASHINGTON, D. C. 20555 i
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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION PELATED TO AMENDMENT N0. 114 TO FACILITY OPEATING LICENSE NO. DPR-35 BOSTON EDISON COMPANY PILGRIM NUCLEAR POWER STATION DOCKET NO. 50-293
1.0 INTRODUCTION
By letter dated Mav 92, 1987 (BEC0 87-08?), the licensee proposed changes to their fire protection Technical Specifications. The proposed cnanges include, and implement, changes proposed earlier by the licensee in letters dated July 1
11 (BECO 83-180), November 16 (BECO 83-282) and December 28, 1983 (BECO 83-300), and March 27, 1984 (BECO 84-047).
During a neeting with the licersee on June 17, 1987, the staff requested clarification on several of the proposed l
changes.
By letter dated July 28, 1987 (BECO 87-127) and September 21, 1987 (BEC0 87-153), the licensee provided the requested clarifications. During a telephone conference call on August 11, 1987, the staff requested the licersee to provide additional information,,iustification and format changes.
By i
letter dated December 17, 1987 (BEC0 87-200), the licensee provided the requested information. The information and changes in the July 28, September P1, and December 17, 198 letters do not affect the substance of the proposed amendtrent as noticed.
These changes to the fire protection Technical Specifications were proposed:
to reflect actual conditions resulting from modifications to the plant that were required to comply with specific technical provisions of Appendix R to 10 CFR 50; to clarify the language and meaning of specific sections of the Technical Specifications; and to correct numbering and references to specific sections in the Technical Specifications and in other documents.
During the June 17, 1987 meeting, the licensee provided a side-by-side comparison of the involved sections of the Technical Specifications as provided for in Amendment No. 35 and the changes proposed on July 11, November 16 and December 28, 1983, March 27, 1984 and May 22, 1987. The licensee provided this comparison to assist the staff during our review and evaluation of this submittal.
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. During telephone conference calls in October 1987, the staff requested the licensee to (1)iretain'a diesel fire pump inspection requirement; (2) clarify the wording relative to the sampling requirement of the diesel fuel for the diesel driven fire pump to assure the latest revision of the ASTM Standards will be used; (3) additional justification for the charges in Section 4.12.G.7, Alternate Shutdown Panels; and (4) format changes.
The licensee responded to the staff's request by letter dated December 17, 1987.
As noted in the licensee's response, the changes were bounded by the initial safety evaluation and determination of no significant hazards consideration as initially noticed (52 FR 32193).
2.0 EVALUATION A summary of each proposed change follows:
?.1 Sections 3/4.12.A:
Fire Detection Instrumentation Sections 3.12.A and 4.12.A have been extensively revised (1) to reflect correct identification of Technical Specification sections, (2) to reduce the minimum acceptable number of operable detectors in each detection zone to 50%
and (3) to reflect that all fire detection circuits are supervised.
Table 3.12-1 was also changed to reduce to 50% the minimum acceptable number of operable detectors in each detection zone to 50% before other compensating actions are required.
Current requirements as provided for in Table 3.12-1, stipulate the minimum number of fire detectors to be operable in each identified Detection Zone without the imposition of other compensating actions. The total number of detectors is not now shown in Table 3.12-1.
During a telephone conference call on August 11, 1987, the licensee explained that Table 3.12-1 reflects the following criteria governing minimum number of operable detectors.
Number of Detectors in Number of Detectors that a Given Detection Zone May be Inoperable 1 to 2 3 to 10 1
More than 10 2
According to the proposed revision of Table 3.12-1, the number of detectors in the various Detection Zones ranges from 1 to 25, and the minimum number of detectors "equired to be operable in those Detection Zones ranges from 1 to 13.
That minimum number is restricted, however, by a note statino that, "no more than two (21 adjacent detectors shall be out of service."
In addition, the surveillance requirements of Section 4.12.A.1 states that each fire j
detector instrument noted in Table 3.12-1 shall be demonstrated by test at i
least once per 6-months to be operable.
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. During telephone conference calls on August 4 and 11,19A7, the licensee provided the following clarifications and supportino information.
1.
These minimum numbers of operable detectors are. applicable to detection systems installed to provide early warning detection only.
2.
Detection systems that initiate operation of automatic fire suppression systems are considered to be part of the fire suppression system.
In the case of water spray and/or sprinkler systems (Section 3.12.C), the system.must be charged with water if more than one detector is inoperable.
In the case of Halon systems the other detector in that bay and all other detectors in all adjacent bays are operable.
3.
Plant procedures stipulate prompt repair of any detector found to be inoperable.
4 Detectors are generally installed at a more conservative spacing (less floor area per detector) than the maximum square foot area spacing permitted by NFPA 720 - Stardard for the Installation, Maintenance and Use of Proprietary Protective Signa 11no Systems.
Therefore, more detectors may be inoperable pending repair without degradation of detection capability in the zone sufficient to require imposition of the action item listed in Section 3.12. A.
?.? Section 3/4.12.B: Fire Water Supoly System Section 3.12.B.1 has been revised to explicitly state minimum flow (2,000 gon), pressure (125 psig), and automatic start requirements for the fire pumps. These minimum flows and pressures are required to assure adeouate water volume at sufficien' pressure for proper operation of all automatic water fire suppression systems and manual fire hose stations.
The automatic start provision for the fire pumps is consistent with requirements of NFPA 70
- Standard for the Installation of Cen.trifugal Fire Pumps.
Sections 3.12.B.2 and 3.12.B.3 have been revised to correct identification of Technical Specifications Sections and to simplify / clarify the language.
Section 3.12.8.b.1 has been revised to correct an ambiguity in the "action" statements concerning establishment of a backup fire suppression water supply system within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> with no fire suppression in water supply system operable.
Section 3.12.B.b.3, shown in Anendment No. 35 and the proposed revision of November 16, 1983, has been deleted from the May 22, 1987 revision. The deleted section specified notification of the Comission within 14 days outlinino the cause of the malfunctions, action taken and plans for restorina the system to operable status. The licensee had not fully justified this deletion in their letter of May 2?, 1987.
By telephone conference call on August 11, 1987, the licensee directed the staff to Section 50.72 of 10 CFR
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50 as already requiring such notification.
Section 50.72(b)(1)(A) requires notification within one hour of the initiation of any nuclear plant shutdown required by the plant's Technical Specifications.
The staff agrees that this deletion is acceptable.
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, Section 3.12.B.b.2, shown in the March 27, 1984 proposed revision has been deleted from the May 22, 1987 proposed revision.
The deleted section required bringina the plant to cold shutdown within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> if a backup fire suppression water supply system cannot be provided within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The staff did not acree with the deletion and so advised the licensee. By telephone conference call on August 11, 1987, the licensee agreed to restore the deleted material of Section 3.12.B.b.2.
This was submitted by letter dated September 21, 1987 (BECO 87-153).
i Section 4.12.B has been revised to more clearly state the objectives of these Surveillance Requirements.
The changes are generally editorial in nature.
However, where changes are made in actual technical requirements, they become more restrictive, not less (i.e., requirino automatic starting and test runnino time of 30 minutes for each fire pump once a month rather than automatic startino and test running time of 70 minutes only for the diesel driven fire pump once every operating cycle as originally specified, and cerforming a water flow test of the fire water yard loop at least once a year rather than once per 3-years as originally specified). These changes represent good fire protection engineering practice and are consistent with NFPA-20 and the recomended practice contained in the NFPA Fire Protection Handbook.
The staff agrees with these changes as shown on pages ?.06a, 206i and 2061-1 (revised 9/21/87) and 206R (revised 5/22/87).
2.3 Sections 3/4.12.C:
Spray and/or Sprinkler Systems Section 3.12.C and 4.12.C have been revised to reflect additional water spray and sprinkler systems installed to comply with specific provisions of Appendix R to 10 CFR 50, and to more clearly state the requi enents of these Technical Specifications. The staff acrees with these chances as shown on pages 206c (revised 7/28/87) and 206c-1 and 206d (revised 5/22/87).
2.4 Sections 3/4.12.E: Fire Hose Station Secticns 3.12.E and 4.12.E have been revised to show the correct reference to NFPA No. 1962 rather than No. 198, to reflect the correct Technical Specifications section numbers, and to more clearly state the requirements of these Technical Specifications.
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In 1979 the NFPA withdrew Recomended Practice for Care, Maintenance and Use l
of Fire Hose - NFPA 198, and issued in its place Standard for the Care, Use
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and Maintenance of Fire Hose Includino Connections and Nozzles - NFPA 1967..
This proposed change of references is orcoer. The other changes are essentially editorial in nature for correction of identification of sections in the Technical Specifications and for clarification of specific recuirements. The staff acrees with these changes as shown on page ?O6e (revised 7/28/87) and Table 3.12-2, which lists the various Fire Hose Stations, as shown on pages 206g and 206q-1 (revised 5/22/87).
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, 2.5 Sections 3/4.12.G: Alternate Shutdown Panels; 4.5: Core and Containment C' olina Systems; and 4.9. A.1:
Diesel Generators The former Sections 3.12.G and d.17.G, Dry Chemical Systems, have been deleted because the Diesel Generate Nms are no longer protected by Dry Chamical Fire Suppression systems.
New Sections 3.12.G and 4.17.G. and their bases, coverino Alternative Safe Shutdown Panels, have been added. These alternative safe shutdown panels have been installed to comply with specific requirements of Appendix R to 10 CFR 50 Section 3.12.G lists the eight safe shutdown systems for which alternative safe shutdown panels have been provided and requires that the alternative shutdown panel shall te capable of operating the shutdown system for which it is provided.
It also requires that when any alternative shutdown panel is inoperative, action will be taken to innediately verify all applicable automatic ' ire detection and suppression systems are operable as required in the Cable Spreading Room ar.d in the detection zones and fire zones for the respective safe shutdown systems for which the alternative safe shutdown panel has been provided.
If such verification is not possible, a continuous fire watch must be established in the Cable Spreading Room, and/or an hourly fire watch patrol must be established in the other affected safe shutdown system detection zones and fire zones. These new requirements replace the applicable actions and associated SRs (i.e., accelerated testing of applicable subsystems and diesel cenerators) which are required per existing Technical Specifications when any one of the systems cannot be operated from the associated alternative shutdown panel (s).
Section 4.12.G details the surveillance tests that are required of the eight systems to deaonstrate their operability from the applicable alternative shutdown panels. The proposed testing, including the test frequency, is the seme as in the existing SR for all the systems except for the energency diesel generators. The proposed SR for the diesel generators requires that their control circuits be isolated from the cable spreading room once each refueling outace (once per operating cycle per existing SR) and that each diesel generator be started from its applicable alternative shutdown panel (started and loaded per existing SR).
The licensee justifie1 deletion of the words "and loaded" stating that it involves manual actions only at the applicable switchgears in the switchgear rooms and consequently does not involve the alternative shutdown panels, and further that these loading operations are covered in the Appendix R shutdown procedures.
Since the systems that can be operated from the alternative shutdown panels are explicitly covered in the proposed Sections 3.12.G and 4.12.G as described above, the licensee has proposed deletion of references to alternative shutdown panels or stations from the existino SRs for these systems (4.5 A.
5, C, D, and E; 4.9A); otherwise the Technical Specifications, including Action Statements and associated SRs, are the same for these systems as in the existing Technical Specifications (Pages 103, 104, 106-109, and 195).
In this context, the staff notes that an earlier SER (November 2, 19831 had concluded that the post-fire alternative shutdown capability for pilarim Station complies with the requirements of Appendix R. Sections III.G.3 and III.L and that, therefore, it is acceptable. The staff further notes that the licensee has committed as part of their long-term program, completion
. prior to stertup of the unit of all work relating to Appendix R which includes, among other things, development of shutdown procedures, training of operators in the procedures, and performance of a test to verify shutdown capability from outside the control room usina the alternative shutdown panels.
Based on the above, the staff has determined that the existi.7a Action Statements and associated SRs, pertaining to the sa'
-lutdown systems when they cannot be operated from their respective alternas-ve shutdown panels, can be deleted as pernttted by the Generic 1.etter 86-10 "Implementation of Fire Protection Requirerents."
Based on the above, the staff agrees with the licensee on the proposed Technical Specification changes including t.'1eir bases for the alternative shutdown panels as identified or paces 206e-1, 206e-2 (revised 7/28/87) and 2063-1 103,104,106-109 and 194 (Revised May 22, 1987).
0.6 Section 3/4.1?.H:
Yard Hydrants and Exterior Hose Houses _
Sections 3.17.H and 4.12.H, and Table 3.12-7 in Amendment 35, pertained to technical specification equirements for yard hydrants and exterior hose houses which provided supplemental fire hose coverage for manual fire fighting capability in severri locations, inside buildings, containino safe shutdown equipment and components.
The licensee confirmed during a telephone conference call on August 4, 1987, that these hydrants and hoses had been necessary to satisfy specific guidance contained in Appendix A to Branch Technical Position 9.5-1.
However, additional standpipe and hose stations installed as part of the modifications necessary to satisfy requirenent of Appendix R to 10 CFR 50, now provide that fire hose coverage required for manual fire fighting capability in inside locations containinq safe shutdown components, and Section 3.:2.H and 4.12.H pertaining to yard hydrants and exterior hose houses can be deleted.
The staff agrees with these deletions.
Table 3.12-2 has also been changed and now describes the fice hose stations asecciated with the inter.or standpipe and hose system. Evaluation of the proposed changes to Table 3.12-2 is covered above in Section 2.4 of this Safety Evaluation.
3.0
SUMMARY
On the bacis of the above Evaluation, we conclude that all six changes to the Technical Specifications proposed bv the licensee are fully acceptable.
Sections 3/4.12.A - Fire Detection Instrumentation.
These chanaes are described in Section 7.1 above, j
Section 3/4.12 B - Fire Water Supply System.
These changes ara described in Section 2.2 above.
1 Sections 3/4.17.C - Soray and/or Sprinkler Systems. These chances are described in Section 2.3 above.
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, 4.0 ENVIRONMENTAL CONS!'JERATIONS This amendment involves a change in the insta11atien or use of a facility corponent located within the restricted areas as defined in 10 CFR Part 20 The staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual er cumulative occupational radiatir,n exposure. The Comnission has previously published a proposed finding that the amendment involves no sinnificant hazards consideration and there has been no public comment on such finding.
Accordingly, the amendment meets the eligibility criteria for catecorical exclusion se'c forth in 10 CFR 451.22(c)(9).
Pursuant to 10 CFR 451.?2(b), no environmental impact statement or environmental assessment need be prepared in connection with the issua. ice of the amendment.
5.0 COMCLUSION We have concluded, based on the considerations discussed above, that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, and (?) such activities will be conducted in compliance with the Commission's regulations, and the issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributor: D. P. Notley, CF,S Dated:
March 8, 1938 i
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