ML20207E883
| ML20207E883 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse, LaSalle, 05000000 |
| Issue date: | 11/04/1983 |
| From: | Little W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Spessard R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML082321542 | List: |
| References | |
| FOIA-88-92 NUDOCS 8808180170 | |
| Download: ML20207E883 (6) | |
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UNITED STATES 4
NUCLEAR REGULATORY COMMISSION I'
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9 83 MEMORANDUM To:
R. L. Spessard, Director, Division of Engineering
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TERUs W. S. Little, Chief. Engineering - Branch II C. C. Williams, Chief. Plant Systems Section FROM:
F. A. Maura, Reactor Inspector
SUBJECT:
PROPOSED STANDARD TECHNICAL SPECIFICATIONS FOR FIRE PROTECTION DURING THE RECENT INSPECTION AT DAVIS-BESSE AND LASALLE We have encountered numerous failures in the operability of fire dampers and energency lighting vuits. Present Technical Specifications do not require testing of this equipment. A review of our proposed standard Technical Specifications, transmitted to NRR by letter (R. Spessard to D. Eisenhut) dated July 12, 1983 showed that surveillance testing to determine operability was inadvertently lef t out. Therefore, attached are the revised Technical Specifications in question and ask that they be sent to NRR for their consideration.
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P. A. Maura, Reactor Inspector Attachments: As Stated
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PLANT SYSTEMS 3/4.7.12 FIRE RATED ASS?XBLIES LIMITING CONDITION FOR OPERATION 3.7.12 All fire rated assemblies (walls, floor / ceilings, cable tray enclos-ures and other fire barriers) separating safety-related fire areas or separating portions of redundant systems important to safe shutdown within a fire area and all sealing devices in fire rated assembly penetrations (fire doors, fire windows, fire dampers, cable, piping, and ventilation duct pene-tration seals shall be OPERABLE.
APPLICABILITY At all times.
ACTION:
I a.
With one or more of the above required fire rated assemblies and/or sealing devices inoperable, within one hour either establish a continuour fire watch on at least one side of the affected assembly, or verify the OPERABILITY of fire detectors on at least one side of the inoperable assembly an,d establish an hourly fire watch patrol.
b.
The provisions of Specifications 3.0.3 and 3.0.4 are not
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applicable.
SURVEILLANCE REQUIRDfENTS i
4.7.12.1 AL least once per 18 months the above required fire rated assemblies and penetration sealing devices shall be verified OPERABLE by performing a visualinspectionfoft At least 20% of each type of sealed penetration against established
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a.
acceptance criteria based on accepted test configurations. If apparent changes in appearance et abnormal degradations are found, a visual inspection of an additional 10% of each type of sealed penetration shall be made. This inspection process shall continue until a 10% sample with no apparent changes in appearance or abnormal degradation is found. Samples shall be selected such that each penetration will be inspected every 7.5 years.
b.
Each fire rated cable tray enclosure / conduit wrap and associatsd i
hardware.
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c.
During cold shutdown by visual and/or operation inspection of the fire rated assemblies not accessible during plant operations to assure their operability.
i Rev. 1, Oct. 83 I
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4.7.12.2 At least once per 18 months the above required active fire rated.
assemblies (doors and dampers) shall be verified OPERABLE in the as is condition by tripping the closure devices and verifying the assembly moves to its close position.
4.7.12.3 At least once per 6 months verify by a maintenance inspection that the fire doors and fire damplers (accessible during plant operation) are OPERABLE byt a.
Inspecting the chains employed on suspended doors to look for excessive wear and stretching.
b.
Lubricating guides and bearings to facilitate operation.
Examining hardware (hinges, moving parts) and any parts found c.
to be inoperative shall be replaced immediately.
d.
Ensuring that door openings and the surrounding areas are kept free of all obstructions, e
e.
Ensuring that fusible links or other heat actuated devices are i
kept free of foreign substances.
f.
Ensuring that care is taken to prevent paint accumulation on 4
stay rolls.
l g.
Ensuring that any breaks in the face covering of doors shall be repaired immediately.
h.
Ensuring that combustible material are kept 20 feet away from openings.
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4.7.12.4 Ensurt sach of the abo"e required fire doors are OPERABLE in case of fite by:
Verifying daily that electrically supersised fire doors are kept a.
closed and in the latched position.
l b.
Performing a daily visual inspection of self-elosing fire doors chat are not electrically supervised to verify that they are kept closed and in the latched position.
Performing a weekly visual inspection of automatic closing fire c.
doors that are not electrically supervised to varify that their automatic hold-open and release devices will permit them to 1
j automatically close in the event of a fire.
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4.7.12.5 Prior to returning a fire rated assembly to functional status 4
following any event which may have affected the operability of fire rated assemblies by performance of a visual inspection of the affected fire rated I
assembly (ies).
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d Rev. 1, Oct. 83 1
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JUST'.FICATION FOR PROPOSED CHANGES f
SURVEILLANCE KEQUIRDtENTS Paragraph 4.7.12.1 changed the surveillance frequency and added minimum acceptable acceptance criteria to be used by the licenseo. Specifically, paragraph a. incorporates our LaSalle experience regarding the need of an acceptance criteria rhich is tied to the tested configuration. In addition based on that experience, among others, it is our position that a surveillance program of 10% /18 month stretching over 15 years is too small.
Paragraph 4.7.12.3 for fire doors and dampers (active barriers) states the specific surveillance requirements or a combination of such requirements for each assembly.
In our draft current minimum Appendix R. NFPA, and ANSI inspection frequencies have been included. The term "visual inspection" alons does not adequately describe the depth of inspection necessary to be performed for a fire door or damper (active barriers). Since fire doors and dampers are equipped with hinges, moving parts and the like they required increased surveillance requirement,s and a more thorough inspection.
In our draft copy, we have used the terms "operational" or "maintenance" inspection i
for clarification in describing a more in-depth surveillance, inspection in i
addition to the term "visual inspection".
During a recent fire protection inspection at the Big Rock Point Nuclear Plant, a surveillance procedure existsd to inspect fire dampers only once every 3 threes.
It was felt by the inspectors that this surveillance require-ment was too infrequent resulting in an open item in the inspection report (50-155/82-13(DE)). No violation could be cited due to Big Rock Point's
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Technical Specification Bases section which up until recently stated, "The
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penetration fire barriers are a passive element in the facility fire pro-s tection program."
2 Paragraph 4.7.12.3&4 is from field experience which as demonstrated the present surveillance requirement of 18 months is not common fire protection practice.
Nor is the requirement in accordance with current fire protection industry standards. Discussions with licensee personnel indicate present plant's practice to conduct routint inspections of the penetration fire barriers while the plant is operatug and on a semi-annual to annual bawis i
for operational type inspections.
i On July 12-16, 1982, a fire protection consulting firm performed a fire protection a it at the D. C. Cook Nuclear Plant during which they identified 11 of 45 (2
) fire doors inspected during the inspection contained defic-iencies and his occu red within six months of the previous inspection. Also j
during this inspection 13 of 140 (10%) fire dampers inspected during a operational test failed tc operate during a 18 month surveillance inspection.
Our draft surveillance requirements havt been referenced from NFPA pamphlets 80 and 90A. Included in this section are ten inspection criteria to be used as guidance in performing the surveillance.
Paragraph 4.7.12.5 states that in the event a fire rated assembly is involved in a fire, damaged or impaired in some way, surveillance of the affected assembly and their operability would be verified (defense in-depth).
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Rev. 1, Oct. 83
Q PLANT SYSTEMS EMERGENCY LIGHTING UNITS LIMITING CONDITION FOR OPERATION All Emergency Lighting Units in fire zone boundaries protecting safety related arose shall be functional.
APPLICABILITY: Mcdes 1, 2, 3 and 4 ACTION:
a.
With one or more of the above required emergency lighting units inoperable, within eight hours the unit shall be replaced with a operable amergency lighting unit, b.
The provisions of Specifications 3.0.3 and 3.0.4 are not applic-able.
SURVEILLANCE REQUIREKINTS t
Each of the above required emergency lighting units shall be verified to i
be functionalt 1
a.
At least once per.31 days by an operational test (to include verifying unit operation, electrolyte level and positien of I
hydrometer discs (lead acid only) of the emergency lighting units accessible during plant operations to assure their operability.
b.
At least once per 6 months by a maintenance test (to include cycling battery and checking change-ever setting) of the j
emergency lighting units accessible during plant operations to assure their operability.
i c.
At least once per 18 months by maintenance test cf the emergency lighting units not accessible during plant operations to assure their operability.
d.
Prior to returning a emergency lighting unit to functional status following any event which could affect its operability, repairs, or maintenance by performance of a operational test to the affected lighting unit.
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Rev. 1, Oct. 83 l
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At least once per 18 =0nths by performing a discharge test to verify the units mest sneir design requirements.
JUSTIFICATION FOR REQUESTED CHANGE Presently no standard technical specification exist for emergency lighting units. Based on present NRC postulated fire scenario's safe shutdown of the plant is dependent in some cases on alternative shutdown systema. Thus requiring personnel to travel through areas of the plant without natural or normal lighting available to reach safe shutdown equipment and perform necessary functions.
Two previous Region III inspections (Big Rock Point 50-155/83-13(DE) and D. C. Cook 50-315/82-08(DE)) have indicated inadequate or nonexistent preventative maintenance program implementation for emergency lighting units.
In addition,Section III.J of Appe'ndix R to 10 CFR Part 50, requires at least an 8-hour battery power supply be provided. However, no emergency lightirg unit operability test program is required at this time.
Surveillance requirements were derived from American National Standard Institutes (ANSI) document ANS 59.4-1979 Edition, titled, "Generic Re-quirements for Light Water Nuclear Power Plant Fire Protection" and from discussions with teledyne big beam emergency lighting unit manu-facturer representatives.
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SURVEILLANCE REQUIREMENTS Paragraph (a) requires a monthly inspection according to ANSI 59.4. Table 2 and manufacturer recommendations to verify unit operation, electrolyte level and position of the Hydrometer Discs (Lead Acid Only).
Paragraph (b) requires a semi-annual inspection according to ANSI 59.4, Table 2 and manufacturer recommendations to cycle the battery, checking the change-over setting and verifying items listed in paragraph (a).
Paragraph (c) is a standard paragraph from S.T.S. to assure energency lighting units in high radiation areas will be inspected within a reason-able time.
Paragraph (d) was added to give assurance that the unit would be tested prior to being put back in service if involved in any event which could affect its operability.
Rev. 1, Oct. 83 9
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