ML20203B312
| ML20203B312 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 04/10/1986 |
| From: | VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | |
| Shared Package | |
| ML20203B310 | List: |
| References | |
| NUDOCS 8604180134 | |
| Download: ML20203B312 (8) | |
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ATTACHMENT 1 1
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8604180134 960410 PDR ADOCK 05000338 i
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INSTRUMENTATION FIRE DETECTION INSTRUMENTATION LIMITING CONDITION FOR OPERATION 3.3.3.7 As a minimum, the fire detection instrumentation for each fire detection zone shown in Table 3.3-11 shall be OPERABLE.
APPLICABILITY: Whenever equipment protected by the fire detection instrument is required to be OPERABLE.
ACTION:
With the number of OPERABLE fire detection instrument (s) less than the minimum number OPERABLE requirement of Table 3.3-11:
a.
Within I hour establish a fire watch patrol to inspect the zone (s) with the inoperable instrument (s) at least once per hour, unless the instrument (s) is (are) located inside the containment, then inspect the containment at leest once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> or monitor the containment air temperature at least once per hour at the locations listed in Specification 4.6.1.5.1.
b.
Restore the inoperable instrument (s) to OPERABLE status within 14 days or prepare and submit a Special Report to the Commission pursuant to Specification 6.9.2 within the next 30 days outlining the action taken, the cause of the inoperability and the plans and schedule for restoring the instrument (s) to OPERABLE status.
I c.
The provisions for Specifications 3.0.3 and 3.0.4 are not j
applicable.
1 SURVEILLANCE REQUIREMENTS l
l 4.3.3.7.1 Each of the above required fire detection instruments which are outside containment shall be demonstrated OPERABLE at least once per 6 months by performance of a CHANNEL FUNCTIONAL TEST. Fire detection instruments which l
are inside containment shall be demonstrated OPERABLE by the performance of a 1
CHANNEL FUNCTIONAL TEST during each COLD SHUTDOWN exceeding 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> unless performed in the previous 6 months.
4.3.3.7.2 The NFPA Code 720 supervised circuits supervision associated with the detector alarms of each of the above required fire detection instruments shall be demonstrated OPERABLE at least once per 6 months.
4.3.3.7.3 The non-supervised circuits between the local panels in Specifi-cation 4.3.3.7.2 and the control room shall be demonstrated OPERABLE at least once per 31 days.
NORTH ANNA - UNIT 1 3/4 3-52
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4 INSTRUMENTATION FIRE DETECTION INSTRUMENTATION LIMITING CONDITION FOR OPERATION 3.3.3.7 As a minimum, the fire detection instrumentation for each fire detection zone shown in Table 3.3-11 shall be OPERABLE.
APPLICABILITY: Whenever equipment' protected by the fire detection instrument is required to be OPERABLE.
ACTION:
With the number of OPERABLE fire detection instrument (s) less than the minimum number OPERABLE requirement of Table 3.3-11:
a.
Within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> establish a fire watch patrol to inspect the zone (s) with the inoperable instrument (s) at least once per hour, unless the instrument (s) is (are) located inside the containment, then inspect the containment at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> or monitor the containment air temperature at least once per hour at the locations listed in Specification 4.6.1.5.1.
b.
Restore the inoperable instrument (s) to OPERABLE status within 14 days or prepare and submit a Special Report to the Commission pursuant to Specification 6.9.2 within the next 30 days outlining the action taken, the cause of the inoperability and the plans and schedule for restoring the instrument (s) to OPERABLE status, c.
The provisions for Specifications 3.0.3 and 3.0.4 are not applicable.
SURVEILLANCE REQUIREMENTS 4.3.3.7.1 Each of the above required fire detection instruments which are outside containment shall be demonstrated OPERABLE at least once per 6 months by performance of a CHANNEL FUNCTIONAL TEST. Fire detection instruments which are inside containment shall be demonstrated OPERABLE by the performance of a CHANNEL FUNCTIONAL TEST during each COLD SHUTDOWN exceeding 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> unless performed in the previous 6 months.
4.3.3.7.2 The NFPA Code 72D supervised circuits supervision associated with the detector alarms of each of the above required fire detection instruments shall be demonstrated OPERABLE at least once per 6 months.
4.3.3.7.3 The non-supervised circuits between the local panels in Specifi-cation 4.3.3.7.2 and the control room shall be demonstrated OPERABLE at least once per 31 days.
NORTH ANNA - UNIT 2 3/4 3-49
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ATTACHMENT 3 SAFETY EVALUATION
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SAFETY EVALUATION DISCUSSION:
The proposed changes to the Unit 1 and 2 Technical Specitications would modify tha surveillance interval for fire detection instruments in containment to every cold shutdown, unless performed within the previous six months.
The proposed changes would also replace the one hour fire watch requirement for containment fire zones with an inspection once every eight hours or hourly monitoring of containment air temperature.
These changes are consistent with the requirements for fire detection instrumentation in Standard Technical Specifications (NUREG-0452, Revision 4.)
North Anna Units 1 and 2 are designed with subatmospheric containments.
The corresponding technical specifications require that the containments be maintained subatmospheric during operations in Modes 1 through 4.
Under these specified subatmospheric conditions, the containment environment is oxygen-deficient thereby requiring respiratory protection.
As a consequence, it is prudent to limit personnel entry into containment during subatmospheric modes of operation.
The present surveillance requirement specifies a functional test of fire i
detection instrumentation every six months. This requires a containment entry every six months to perform the test.
It has been our experience that such testing of fire detection instru=entation inside containment often results in extended stay times, subjecting personnel to radiation exposure as well as the oxygen-deficient environment of the subatmospheric containment.
Consistent with Standard Technical Specification 3.3.3.8 on fire detection instrumentation, we have identified "not accessible during plant operation" as referring to "inside containment".
Independent of personnel safety concerns, we believe that there are a sufficient number of redundant or diverse fire detectors in the containment fire zones to justify the proposed change in surveillance interval.
Likewise, the present action statement would require an hourly fire watch patrol in containment to inspect those containment fire zones which had inoperable fire detection instrumentation.
This requirement is impractical, independent of personnel safety concerns, due to the difficulty of implementing hourly entries into containment.
A containment entry / exit typically takes 8-10 minutes due to the time for depressurization/ pressurization in the air lock. This does not consider the time to don / remove anti-contamination clothing and respirator, travel through access control, etc.
Furthermore, hourly inspection of containment spaces is not justified given the relative lack of consumable material compared to areas outside of containment.
Monitoring containment air temperature in lieu of hourly containment inspections is an appropriate compensatory action to take in the event of instrument inoperability.
4 i
10 CFR 50.92 Significant Hazards Considerations i
We conclude that the proposed changes do not pose a significant hazards l
censideration as defined in 10 CFR 50.92.
The proposed change will not:
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- 1) involve a significant increase in the probability or consequences of l
an accident previously evaluated. Specifically, the proposed changes do not increase the likelihood of an undetected fire in containment.
The proposed compensatory measures of hourly temperature monitoring or visual inspection of containment every eight hours provide adequate interim fire detection capability until the minimum required number of fire detection devices have been restored operable. Likewise, thn proposed change to the functional testing interval for fire detection i
instrumentation in containment merely modifies the test frequency during sustained power operations.
As mentioned before, we believe that there are a sufficient nuchsr of redundant or diverse fire detectors in the containment fire zones to ensure detection and justify the proposed change in surveillance interval.
These changes du not increase the probability or consequences of a previously evaluated l
accident.
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- 2) create the possibility of a new or different kind of accident from any l
accident previously evaluated.
Since the proposed change does not modify the present design, the possibility of a different type of
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accident other than previously analyzed has not been created.
1
- 3) involve a significant reduction in the margin of safety. The proposed changes still require adequate functional testing of fire detection instrumentation and compensatory inspections or hourly temperature monitoring consistent with Standard Technical Specifications.
The Commission has provided examples of changes that do not consitute a significant harsrds considaration in Federal Register, volume 48, page 14870.
Example (vii) states, "a change to make a license conform to changes in regulations where the license change results in very minor changes to facility operations clearly in keeping with the regulations."
The proposed changes are consistent with the hVREG-0452, Revision 4,
Standard Technical Specifications for Westinghouse Pressurized Water Reactors. Therefore, we conclude that the proposed change is similar to example (vii) and that no significant hazards consideration is involved in the proposed change.
10 CFR 50.59 Safety Evaluation:
For the same reasons given above, we conclude that the proposed changes do not involve an unreviewed safety question as defined in 10 CFR 50.59.
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yne Dats lxvoece Number Or Description Crsco Amount Discsunt N t Amtunt 01 01/22/86 0122150G0 150.00 150 00 i
APPLICATION FEE 150.00 150.00
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2 UNITED STATES NUCLEAR 01 '02??13 01/2'l/86 018804
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