ML20207E920

Forwards Proposed STS for Fire Protection for Transmittal to NRR for Review

ML20207E920
Person / Time
Site:	05000000, Davis Besse
Issue date:	07/11/1983
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: ML20151H151 ML20151H175 ML20151H330 ML20151H353 ML20151H758 ML20151H856 ML20151H926 ML20151K289 ML20207E883 ML20207E920
References
FOIA-88-92 NUDOCS 8808180180
Download: ML20207E920 (37)

Text

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gv....f JUL 11 1983 MEMORANDUM FOR:

R. L. Spessard, Director, Division of Engineering THRU:

W. S.'Little, Chief, Engineering - Branch II C. C. Williams, Chief, Plant Systems Section FROM:

F. Maura, Reactor Inspector

SUBJECT:

PROPCSED STANDARD TECHNICAL SPECIFICATION FOR FIRE PROTECTION We recently received a request to conduct a review of Toledo Edison's proposed technical specifications for fire pntection. During our review C. Ramsey and J. Ulie noted thst the Standard Technical Specifications (STS) used by Toledo Edison, to generate the Davis-Besse submittal, have the same inadequacies which in the past created our probletas with Point Beach, Big F.ock Point, etc.

For each of the past problems nany man-hours have been spent on tele 9 hone esils with NRR, several memoranda have been written to Eisenhut, and yet all the issues remain unresolved.

In an

/

effort to minimize many "individual issue" memos to NRR ve have reviewed

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the STS for fire protection, including the lat.ast Westinghouse version (to be issued by the NRC in the near future), and have generated the attached ten sections for NRC review and implementation. Two of the attached sections, "Portable Fire Extinguishers" and "Emergency Lighting Units", are new. The remaining eight sections are revisiens to existing ones with changes noted by vertical lines on the right hand of the page.

All changes are based on:

1.

Industry Codes (NFPA, ANSI /ANS59.4-1979, etc.).

2.

Studies made by the U.S. Department of Labor, EPRI, NRC, NFPA, DOE, and consultants to licensees or the NRC.

3.

Region III inspection findings at D. C. Cook Big Rock P3 int, Callaway, LaSalle, etc.

4.

Appendix R requirements, Branch Technical Positions, etc.

5.

Manufacturer's recomendations including nationally recognized testing laboratorier.

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e o 8808180180 690718 PDR FOIA JONES 88-92

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R. L. Spessard JUL 11...;

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s We request that the att'sthed STS proposed package be forwarded to NRR for

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their review as part of our effort to upgrade the NRC's fire protection requirements to the level of recognized industry standards.

1 Reactor Inspector Attachments:

1.

Fire Detectors and Associated Instrumentation 2.

Fire Suppression Water Systems 3.

Spray and/or Sprinkler Systems 4.

CO2 Systems 5.

Halon Systems 6.

Fire Hose Stations 7.

Yard Fire Hydrants and Hydrant Hose Houses 8.

Fire Rated Assemblies 9.

Portable Fire Extinguishers 10.

Emergency Lighting Units cc:

C. Ramsey J. U11e I

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1 INS *tRUMENTATION 4

FIRE DETECTORS AND ASSOCIATED INSTRUMENTATION LIMITING CONDITION FOR OPERATION 3.3.3.8 As a minimum fire detectors and associated instrumentation for each fire detection zone shown in table 3.3-11 shall be OPERABLE.

APPLICABILITY: Whenever equipment protected by the fire detectors and associated instruments are required to be OPERABLE.

ACTION:

With one or more fire detectors and associated instruments inoperable 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) where the inoperable fire detector (s) is installed at least once per hour, unless the detector (s) is located inside 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 l

containment air temperature at least once per hour at the locations listed in Specification 4.6.1.6).

b.

The provisions of Specification 3.0.3 and 3.0.4 are not applicable.

SURVEILLANCE REQUIREMENTS J

J l

4.3.3.8.1 Each of the above spot type or line type fire detectors and 1

associate instruments including all fire alarms accessible during plant operation shall be demonstrated CPERABLE by performance of a channel

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functional test and where applicable, a detector sensitivity test every 6 months. At this time, cleaning and maintenance of ionization and

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1 photoelectric detectors shall be performed to remove accumulations of dust I

or dirt in accordance with NFPA 72E. Pire detectors which are not accessible during plant operation shall be demonstrated OPERABLE by performance of a channel functional test, detector sensitivity test where applicable, cleaning and maintenance in accordance with NFPA Standard 72E during each q

j cold hhutdown exceeding 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> unless performed within the previous i

6 months.

l e

4.3.3.8.2 The circuit supervision of alarms associated with each of the i

above required fire detectors and associated instruments shall be demonstrated OPERABLE at least once per 2 months by performance of a channel functional test of the circuitry between the control room alarm annunciator panel and 3

l the detector alarm signal transmitter and between the detector alarm signal transmitter and the detector unit. Where a single break or ground fault condition occurs, a distinctive trouble signal shall be indicated as required

- j i

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• by NFPA Standard 72 4gircuit test shall be made from the control room daily, 1

i 4.3.3.8.3 Where permitted by NFPA 72.D. non-supervised circuits associated l

with fire detectors, alarms and instruments between the detector unit and l

local panels and between local panels and the control room shall be demon-

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strated OPERABLE at least once per 31 days.

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Flid lEClic110!. It.bil unil i A110N TOTAL NUMBER INSTRUMENT LOCATION OF INSTRUMENTS **

(J11ustrative)

HEAT TTAME SMOKE (x/y)

(x/y}

(x/y) 1.

Containment #

a.

Zone 1 Elevation b.

Zone 2 Elevation 2.

Control Room 3.

Cable Spreading i

a.

Zone 1 Elevation b.

Zone 2 Elevation 4.

Computer Room 5.

Switchgear Room 6.

Remote Shutdown Panels 7.

Station Battery Rooms 8.

Turbine f

a.

Zone 1 Elevation t

b.

Zone 2 Elevation 9.

Diesel Generator a.

2one 1 Elevation b.

Zone 2 Elevation 10.

Safety Ra'stes Pur.ps a.

Zone 1 Ele.ation b.

Zone 2 Elevation 11.

Fuel Stcrage a.

Zone 1 Elevation b.

Zone 2 Elevation (List all detectors in areas required to ensure the OPERABILITY of safety-related equipment).

• (x/y):

x is number of Function A (early warning fire detection and notification only) instruments.

y is number of Function B (actuation of Fire Suppression Systems and early warning and notification) instruments.

1. The fire detection instruments located within the containment are not required to be OPERABLE during the performance of Type A containment leakage rate tests.

_ _ _ ~

4.3.3.8.4 The fire detection system and associated equipment shall be inspected once per 31 days and maintained in proper operating condition.

4.3.3.8.5 Prior to returning any fire detector and associated insttumenta-tion to a functional status following any event which affected its operability, a channel functional test and detector sensitivity test (where l

applicable) shall be performed.

JUSTIFICATION FOR PROPOSED CHANCES l

LIMITING CONDITION FOR OPERATION 3.3.3.8 The words "The fire detection instrumentation" was changed because hTPA Standards 71, 72A, 72B, 72C, 72D, 72E, 74 and others detail the require-ments for the interconnection of detectors, the control configurations, the power supply or the output systems responding to automatic fire detector actuation as separate standards for devices or equipment. Automatic fire detectors are devices designed to detect the esegce of fire and initiate action. Alarm transmitting devices and othe T) ment through various methods can be used in conjunction with fire detectors. The words "Fire detection instrumentation" dddnot clearly address the specifies of fire detectord devices and other equipment which may be associated with them.

Reference:

NFPA 3tandards as stated above.

ACTION:

SectionE.1.(a)ofAppendixAtoNRCBranchTechnicalPositionAPCSp.5.1 a.

dated August 23, 1976 states that "Fire detection systems should as a minimum comply with NFPA 72D, standard for the installation, maintenance and use of proprietary protective signaling systems".

It has been our ob ervation that except for minor deviations, licensees comit to install fire detection systensin accordance with NFPA 72D.

Article 3330 of NFPA 72D states "Fire detection equipment shall be installed in accordance with NFPA 72E, automatic fire detectors." Section 3.5 and Appendix A and B of NFPA 72E specifies minimum spacing for fire detector installations based on ceiling shcpe and surfaces, ceiling height and con-figuration or contents, burning characteristics of combustible materials present, ventilation air flow patterns and other parameters. Generally, on smooth ceilings, 30 foot spacing is used as a guide for spot type ionization, photoelectric heat detectors, flame sensing or gas sensing detectors. The manufacturers installation instructiems usually specify spacing requirements for line type fire detectors. NTPA Standards cover mininsua performance and instellation requirements.

Where detectors are cross zoned, there may be a function A and a function B detector circuit. However, normally at least one detector on each circuit 1

within the sone vould have to respond to actuate the alarm signal. Consid-ering that detector spacing depends largely on the volume of air circulated in a room or enclosure, it can only be speculative to determine which detectors can be INOPERABLE while the system is still considered OPERABLE.

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i From our review of TSAR's and commitments made by licensee's, in no i

instance have we found that licensee's have cosunitted to install more I

i fire detectors and associated instrumentation than required by NTPA Standards.

J Therefore, by deleting the words "with the number of OPERABLE fire detection I

instrument (s) less than the minimum number OPERABLE requirement of table j

3.3-11", this change is added to improve the inspectability of present 4

Standard Technical Specifications.

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Referencet NFPA Standards as stated above.

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SURVE31.ANCE REQUIREMEMS 4.3.3.8.1.

NTPA 72D, Article 1232d.

States thet "Inspection and test of automatic fire detection devices shall be in accordance with NFPA 72E.

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j Section 8.3. of NFPA 72E specifies periodic tests for automatic fire detectors 1

including tests for automatic nonrestorable type spot detectors, restorable spot type heat detectors, pneumstic line type detectors, line type fixed i

i temperature detectors flame and other fire output detectors. Section 8.4 of NFPA 72E requires periodic cleaning of ionisation and photoelectric detectors j

to remove dust or dirt which has accumulated and that cleaning, checking operation and sensitivity adjustments be attempted only after consulting the manufacturers instructions. Article 3532 of NFPA 72D requires that suitable and practical facilities be provided to permit periodic testing j

for sensitivity. This change is added to improve the inspectability of j

present Standard Technical Specifications.

t Reference NFPA Standards as stated above and ANSA 59.4.

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4.3.3.8.2.

Article 1232 of NFPA 72D specifies periodic test for proprietary j

protective signaling systems including provisions for making daily tests 1

of the system to insure reliable operation from the central supervising station; a test every two months, or more frequent for all transmitters j

and water flow actuated devices, semi-annually for gate valve supervision i

switches, manual fire alarm boxes, tank water level devices, etc. This change is requested to improve the inspectability of present Staudard i

Technical Specifications.

Reference:

NFPA Standards as stated above and ANSI 59.4.

i 4.3.3.8.3.

Concerning automatic smoke detectors Article 350 of NFPA 72D i

requires that a smoke detecting combination of a Class A proprietary system j

be capable of operating for a smoke alarm signal during a single break

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or a single ground fault condition of the circuit wiring conductors between the central supervising station and the smoke alarma signal transmitter and between the smoke alars transmitter and the smoke detector control unit.

Article 240 of NFPA 72D requires that all system viring employed to inter-connect separate units of a smoke detecting system and its power supply circuit wiring shall be electrics 11y supervised so that the occurrence of 3

a break or ground fault condition which prevents the normal operation of 1

the system or failure of the main power supply source, be indicated at the l

central supervising station by a distinctive trouble signal. Exceptions to

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this are those features of a system that need not be supervised which aret i

d a

4

,_ _ _._ r. _ _. _. _ _ _. - - - -., _ _ _, _ _. _, _ _ _ _ -. _, _ _ _ - _, _ _ _..

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-l a.

The station circuits for alara bells and registers which are controlled by devices which have them operating circutta electrically supervised.

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b.

Main power supply failure if the condition is otherwise indicated so as l

to be obvious to the operator on duty.

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c.

A supplementary circuit for operating a fan actor stop or similar industrial control equipment intended to be actuated at the time of an alarm signal, l

provided a fault condition of the circuit in no way affects the normal operation of the signaling systes.

d.

'A trouble signal circuit.

i In addition Article 350 of NTPA 72E requires that ruoke detection systems provide electrical supervision of all filaments of photoelectric cell J'

illuminating leaps and the filaments and heaters of all electronic tubes l

I if their failure prevents normal operation for a smoke alare signal. The i

l failure of all electrically supervised circuits and parts are required to j.

be indicated by a distinctive trouble signal.

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To clarify what is meant by "non-suparvised circuits associated with detector alares" and "between the instrument and the control roon".

a this chan p is requested to' improve the inspectability of present Standard Technical Specifications.

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Reference:

NFPA Standards as stated above.

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i 4.3.3.8.4.

Article 350 of NTFA 72D requires that smoke detecting equipment be i

c inspected monthly and maintained in proper operating condition. This is l

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requested to be specified to provide further assurance of operability of fire detectors and associated instruments and to improve the inspectability s-of present Standard Technical Specifications.

a j

Reference:

NFPA Standard as stated above.

4 l

i 4.3.3.8.5.

This addition is requested to provide further assurance of the f

1 operability of fire detectors and associated instruments which have been j

physicayanaged,as1 functioned.improperlyusintained,repairedand/or j

replaced.

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Reference:

Good Industry Practice and NFPA 72E. Section 8.5.1.

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PLANT SYSTD4S i

3.4.7.11 FIRI SUPPRESSION SYSTD(S PIRE SUPPRESSION VATER SYSTDt LDlITING CONDITION FOR OPERATION I

3.7.11.1 The fire suppression water system shall be OPERABLE with:

a.

At least two (2) fire pumps functional and capable of providing a characteristic pump curve within the acceptance limits of d

i the standard head-discharge curve per the manufacturer's design and NFPA Handbook, 14th Edition, Section 11 Chapters 1 and 4 and hTPA 20 through automatic operation.

b.

Separate water supplies, each with a minimum contained volume sufficierat to supply the fire pumps at a 150 percent of rated capacity for the estimated duration of the water demand.

4 c.

An OPERABLE flow path capable of taking suction from the water I

supply and transferring water from the fire pumps at the required flow and pressure through the water distribution system piping with OPERABLE sectionalizing control or isolation valves (including

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gate valves, check valves. OS&Y valves, post indicator valves, globe and test valves, hydrants, alarm, deluge and dry pipe valves) j to the fire suppression headers, the fire loop, standpipe, deluge, j

a f,

sprinkler or spray systems required to be OPERABLE per j

Specifications 3.7.11.2, 3.7.11.5 and 3.7.11.6.

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APPLICABILITl: At all times i

ACTION:

a.

With one pump and/or one water supply inoperable, restore the inoperable equipment to OPERABLE 9tatus within 7 days or, provide an alternate backup pump or supply. The provisions of Specifications 3.0.3 and 3.0.4 are not applicable.

b.

With the fire suppression water system otherwise inoperable establish a backup fire suppression water system within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

1 SURVEILLANCE REQUIRDGNTS l

4.7.11.1.1 The fire suppression water systen shall be demonstrated OPERABLEt a.

At least once per 7 days by verifying the contained water supply t,

volume by pressure gauge or water level indication, and at least I

4 once per 31 days by visual verification of the contained volume of i

j water.

i

b.

At least once per 31 days on a STAGGERED TEST BASIS by starcing each electric motor driven pump and operating it for at least 15 minutes on recirculation flow.

At least once per 31 days by verifying that each va'1ve (manual, c.

power operated or automatic) in the flow path is in its correct position.

I d.

At least once per 6 months by performance of a system hydrant flush under maximum system pressure with the valves to any i

i inside sprinkler or standpipe system closed.

At least once per 12 months by cycling each testable valve in the e.

flow path through at least one complete cycle of full travel, and by oiling or groasing valves as required.

i e

f.

At least once per 18 months by performing a system functional test which includes simulated automatic actuation of the system i

throughout its operating sequence, ands l

(1) Cycling each valve in the flow path that is not testable j

during plant operation through at least one complete cycle of full travel.

J (2) Verifying that each fire suppression pump starts (sequentially) and delivers 150 percent of rated capacity at not less than 65 percent of the total rated head and that the shutoff head j

does not exceed 120 percent of rated head for split-case

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pumps, nor 140 percent for end section pumps at rated speed

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through automatic operation.

l s.

At least once per 3 yaars by performing a flow test of the systes in accordance with Chapter 5, Section 11 of the Fire Protection Handbook, 14th Edition published by the National Fire Protection Association.

j 4.7.11.1.2 the fire pump diesel engine shall be demonstrated OPERAB1.Es i

s.

At least once per 31 days by verifying:

1 (1) The fuel storage tank contains at laast gallons of fuel, and l

(2) The diesel starts from ambient conditions and operates j

j automatically for at least 30 minutes on recirculation l

flow.

j b.

At least once per 92 days by verifying that a sample of diesel i

fuel from the fuel atorage tank, obtained in accordance with i

s ASIN-D270-1975, is within the acceptable limits specified in i

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Table 1 of ASTM D957-1977 when checked for viscosity, water and j

sediment.

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At least once per 18 months, during cold shutdown, by subjecting c.

the diesel fire pump to an inspection in accordance with procedures l

prepared in conjunction with its manufacturer's reconnendations for the class of service.

4.7.11.1.3 The fire punp diesel starting 24-volt battery bank and charger shall be demonstrated OPERABLE:

a.

At least once per 7 days by verifying thatt (1) The electrolyte level of each battery is above the plates, and (2) The overall battery voltage is greater than or equal to 24 volts.

b.

At least once per 92 days, by verifying that the specific gravity is appropriate for continued service of the battery.

c.

At least once per 18 months by verifying thatt (1) The batteries, cell plates, and battery racks show no visual indication of physical damage or abnormal deterioration, and (2) The battery-to-battery and terminal connections are clean, tight, free of corrosion and coated with anti-corrosion material.

f' t

JUSTIFICATION FOR PROPOSED CHANCES i

LIMITING CONDITION FOR OPERATION 3.7.11.1 i

a.

The rating of fire pumps will vary from plant to plant based on the National Fire Protection Association (NTPA) Standards for design and installation of various water suppression systems. Fire pumps are designed to provide maximum reliability and specific net head discharge characteristics because the amount of water d

needed to control and extinguish a fire cannot be established in precise teras. The hydraulic performance of fire pumps is deter-i mined by measurements of three points on the standard curver (1) shutoff-with the pump operating at rated speed and the discharge valve closed, the total head of a horizontal centrifugal pumps shall not exceed 120 percent of the rated head capacity. For a vertical pump, the total head at shut off shall not exceed 140 percent of the rated head capacity.

(2) Overload-fire pumps s

shall furnish not less than 150 percent of rated capacity at a total head of not less than 65 percent of the total rated head.

(3) A convenient rate of flow at or near capacity rating. Other pumps for commercial / industrial use are of a different design for maximum efficiency and economy of operation. Therefore, the operability of fire pumps should be determined by their performance j

1 l

within the pump manufacturers design limits when in conformance to NFPA's fire pu=p standatd. This change is requested to improve i

assurance of the operability of the fire protection system and to improve the inspectability of present Standard Technical Specifica-i tions.

j Reference Section 11. Chapter 1 and 4 hTPA Handbook,14th Edition i

and hTPA 20, Standard for the Installation of Centrifugal l

Fire Pumps, b.

The volume of water supply for fire suppression should be sufficient to supply the fire pumps at overload rate (150 percent of rated capacity) for the estimated duration of the water demand. This i

change is requested to improve assurance of the operability of the l

fire protection system and to improve the inspectability of present j

Standard Technical Specifications.

l

Reference:

Section 11. Chapters 3 and 4 hTPA Handbook,14th Edition, NFPA 13. Installation of Automatic Sprinkler Systems, hTPA 15, Water Spray Fixed Systems and hTPA 1231, Water Supplies.

j c.

This section of the current Standard Technical Specifications does not clearly define an operable flow path for the fire water distribu-l tion system. This change is requested to improve the inspectability of present Standard Technical Specifications.

j

Reference:

NFPA 26. Water Suppliers - Valve Controlling and Section

[

11. Chapter 3. hTPA Handbook, 14th Edition.

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SURVEILLANCE REQUIREMENTS l

4.7.11.1.1 a.

More specific information is needed as to how the contained volume of water supply should be verified. Wells, gram storage tanks, elevated storage tanks, rivers, ponds or reservoirs requires different methods to determine this. For example, pressure gauges i

cannot be relied upon to give accurate indication of water levels in elevated gravity storage tanka because the tanks become a settling basin, resulting in large accumulatdons of sediment which plugs pressure gauges and causes them to give inaccurate pressure indications. This change is requested to improve the inspectability i

of present Standard Technical Specifications.

I

Reference:

Factory Mutual Loss Prevention Data Section 11. Chapters 1 and 3. NTPA Handbook, 14th Edition and NFPA 1231, l

Water Supplies.

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b.

Flushing is accomplished to remove stones and debris from the system.

l If valves to inside sprinkler and standpipe systema are not closed any foreign debris will be washed into them. T1ushing of the system l

i

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should be accomplished under maximum system pressure. This change is requested to provide further assurance of operability of the fire protection system.

References Section 11. Chapters 1 and 2. NFPA Handbook, 14th Edition.

c.

This change is requested to improve the inspectability of present

)

Standard Technical Specification.

Reference:

Section 11. Chapter 2. NFPA Handbook. 14th Edition.

OLD F(2) This is requested to be deleted from the present Standard Technical Specification because if new F.2) is performed in accordance with NTPA 20 requirements, this verification will not be necessary.

I OLD F(3) Now becomes 4.7.11.1 f.1) This emphasis was added to improve the inspectability of present Standard Technical Specifications.

References Section 11. Chapter 3. NFPA Handbook.14th Edition.

1 OLD F(4) Now becomes 4.7.11.1 f.2) which has been Laproved to require fire pump testing in accordance with NFPA 20 and Section 11. Chapter 4 NFPA Handbook. 14th Edition. This emphasis was added to improve the inspectability of present Standard Technical Specifications.

i Reference Memo to D. Eisenhut from R. L. Spessard dated February 18, 1983.

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O PLANT SYSTD(S i

SPRAY AND/OR SPRINKLER SYSTDtS LIMITING CONDITION FOR OPERATION 4

3.7.11.2 The following spray and/or Sprinkler Systems shall be OPERABLE:

.l a.

(Plant dependent - to be listed by name and location.)

b.

c.

APPLICABILITY: Whenever equipagnt protected by the Spray / Sprinkler System is required to be OPERABLE.

4 ACTION:

a.

With one or more of the above required Spray and/or Sprinkler Systems inoperable, within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> establish a continuous fire watch with backup fire suppression equipment for those areae l

in whict. redundant systems or components could be damaged; for other areas, establish a hourly fire watch patrol.

b.

The previsions of Specifications 3.0.3 and 3.0.4 are not applicable.

SURVEILLANCE REQUIRDENTS l

i 4.7.9.2 Each of the above required spray and/or sprinkler systems shall l

be demonstrated OPERABLEt j

a.

At least once per 31 days by verifying that each individual system control valve (outside screw and yoke valves, globe valves and automatic actuated valves) in the system flow path is in the correct position; and record system water / air pressures to verify that pressure fluctuations are within the nora.

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b.

At least once per 6 months by:

(1) Cycling each individual system testable control valve in the system flow path at least one complete cycle of full travel.

1 1

(2) Terforming a system functional test (including a 2-inch main drain test, alarm test, automatic valves trip test Q

l where applicable, and inspectors test) to simulate automatic.

l actuation of the system.

c.

At least once per 18 months:

(1) By verifying that all circuit interfaces (transmitters) actuate to ensure system operability; and j

(2) By cycling each valve in the flow path that is not testable

{

during plant operation through at least one complete cycle j

of full travel during each cold shutdown unless the test has been performed in the previous 6 months: and j

(3) By visual inspection of the wet pipe, dry pipe, pre-action.

deluge, and combined dry pipe and pre-action systems including sprinkler heads, fixed-spray nossles, systen piping and hangers to verify their integrity and (4) By visual inspection of each sprinkler head or fixed spray nossle area of operation to verify the spray pattern is not obstructed, they are in good condition, clean, free from corrosion or loading, not painted or whitewashed, and not bent or damaged; and l

(5) By visual inspection of each sprinkler systen strainers, piping and hangers to verify their not being obstructed or used for support of ladders, or other material, that i

they are in good condition and free from mechanical injury I

and if the inspection indicates a plugged line, an interval ava=4 nation of the piping shall be done.

d.

At least once per 3 years by parforming a flushing of the sprinkler piping (including the hydraulic asthod or the hydropneumatic method) through the sprinkler risers, feed asins, cross mains, and the branch lines in the same directions in which water would flow during a fire to verify the piping system is unobstructed, and perform an air flow test through each open head spray / sprinkler header to verify each open head spray or sprinkler nomsle is unobstructed.

e.

Prior to returning a spray and/or sprinkler system to functional status following any event which could affect its operability, perform a system functional test as specified in paragraph 4.7.9.2(b)2 of this specification on the affected spray or sprinkler system (s).

M TIFICATION FOR PROPOSED WANCES The NFPA has prepared a suonary of sprinkler performance reports that in-cluded an analysis of fires in sprinkler system buildings that have been rew rted to the NFPA since 1897. Of%pproximate6000 failures,thereasons for unsatisfactory sprinkler performance included:

u.

0 4

l (1) Closed sprinkler control valves (36%)

j (2) Inadequate water suppliegs and piping obstructions (22%)

l (3) Inadequately estatained sprinkler systems (9%)

i' This study demonstrates the need for spray and sprinkler systems to be properly maintained on a more frequent schedule than presently exists.

Another study which demonstrated the need for maintaining sprinkler systems in accordance with the NFPA standards was conducted by the U.S. Department l

3 of Energy entitled "Automatic Sprinkler Systen Performance and Reliability in U.S. Department of Energy Pacilities from 1952 to 1980". The findings of this report confirm the value of the automatic sprinkler system as a l

1 fire protection tool. One finding and reason for it stands cuer ehmt is, that D.O.E. facilities inspection and maintenance recordsFof sprinkler ~#swiawrmden systess far exceed the U.S. average. The siseable inspection and maintenance i

record difference between private industry and D.O.E. facilities is that D.O.E. has adopted the NTPA fire protection standards as being mandatory D.O.E. standards.

1 SURVEILLANCE REQUIREMENTS Paragraphs 4.7.9.2(a) and 4.7.9.2(b) were included to provide a more accurate i

and thorough inspection according to NFPA 13, 13A, and 15 mainly in the i

care and maintenance sections.

I Paragraph 4.7.9.a(e) has changed f rom S.T.S. section 4.7.11.2(d). to

-l l

improve the inspectability of the areas to be flushed in a sprinkler

]

system on a periodic basis.

Paragraph 4.7.9.2(h) was added in case the spray and/or sprinkler system l

1 is involved in any event which could affect its operability.

(

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t 1

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PLANT SYSTEMS

,C_04 SYSTDIS LIMITING CONDITION 70R OPERATION

=

l 3.7.11.3 The following High Pressure and Low Pressure CO2 Systems shall be OPERABLE:

a.

(Plant dependent - to be listed by name and location.)

b.

c.

APPLICABILITY: Whenever equipment protected by the coy Systems is required to be OPERABLE.

ACTION:

a.

With one or more of the above required CO2 Systems inoperable, within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> establish a continuous fire watch with backup fire suppression equipment for those areas in which redundant systems I

or components could be damaged; for other areas, establish an hourly fire watch patrol.

f k,_.

b.

The provisions of Specification 3.0.3 and 3.0.4 are not applicable.

SURVEILLANCE REQUIRDENTS I

4.7.11.3.1 Each of the above required CO2 Systems shall be demonstrated i

OPERABLE at least once per 31 days by verifying that each valve (manual, power operated, or automatic) in the flow psth is in its correct position.

4.7.11.3.2 Each of the above required low pressure CO2 Systems shall be l

demonstrated OPERABLE:

a.

At least once per 7 days by verifying the CO storage tank level 2

to be greater than __

and pressure to be greater than psig, and examine all system components and their overall appearance for any condition which may affect the system operability.

b.

At least once per 12 months by verifyiegt (1) The system valves, associated ventAlation equipment and fire door interlocks, time delays, and alarm interlocks actuate manually and/or automatically.

l

i (2) Plow from each nossle during a "puff tes,t" (partial discharge test) and examine the agent cylinders or tank physical L

3 4

condition.

l c.

In accordance with the hydrostatic test schedule by verifying full discharge of the entire design quantity of carbon dioxide through system piping to ensure that carbon dioxide is discharged onto the hasard, and that the concentration is achieved and l

maintained for the period of time required by the design specifica-tions and that all pressure operated devices function properly, t

d.

Prior to returning a low pressure CO2 System to functional status

{

following any event which could affect its operability. r epairs, or maintenance by performance of a full discharge test on the affected CO2 System.

4.7.11.3.3 Each of the above required high pressure CO2 Systems shall be demonstrated "0PERABLE" l

a.

At least ones per 6 months by verifying the CO2 high pressure cylinders are weighed to be at least 90% of full charge weight.

b.

Same as 4.7.11.3.2.b. above.

t (1) Same as 4.7.11.3.2.b. above.

(2) Performance of a flow test through headers and nozzles to

)

assure no blockage, and

/

I

(

(3) Performance of the high pressure CO2 System an operational

)

i inspection of the solenoid, autons. tic detectors or manual stations to ascertain operability.

c.

Same as 4.7.11.3.2(c) above.

j (1)

Same as 4.7.11.3.2(c) (1) above.

d.

Same as 4.7.11.3.2.(d) above except work "low pressure" to "high pressure".

JUSTIFICATION F0P. REWESTED CHANGE l

SURVEILLANCE REQUIRDENTS Paragraph 4.7.11.3.2(c) has been added because of present on-going problems existing at D. C. Cook Nuclear Plant which could be a generic issue. The Unit 1 and 2 control room cable vaults are protected with a combined total flooding Halon 1301 system added after original design to the CO2 System using the CO2 System equipment to operate. An acceptance test dated October 3, 1974 for the Halon System in Unit 1 cable vault failed to provide the minis m design concentration for 10 minutes as recommended in NFPA 12A.

this problem was' identified during a July,1982 fire protection audit by a j

fire protection consulting firm.

i i

. ---. r m-

1 k

i Paragraph 4.7.11.3.2.(b) of the draf t has changed with respect to surveillance 3

requirement frequencies and added the minimum acceptable inspection criteria i

l to be used when performing a surveillance inspection per NTPA 12 Appendix A-1 l

11.1.

This was added to improve the inspectability of present Standard Technical Specification section 4. 7.11. 3. 2 (b).

t L

Paragraph 4.7.11.3.2(c) is a surveillance requirement test referenced from 1

NFPA 12, Appendix A-1-11.1(15)(c), "Testing of Systema".

Paragraph 4.7.11.3.3(d) was added in case the CO2 Systes is involved in any event which could affect its operability. In the event a CO2 System is involved in a fire, damage or impatraent of that system or portion thereof alght have occurred and by requiring inspection of the affected CO2 System j

would help assure a reasonable level of safety and reliability.

l i

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PLANT SYSTEKS HALON SYSTEMS LIMITING CONDITION FOR OPERATION 3.7.11.4 The following Halon Systems shall be OPERABLE a.

(Plant dependent - to be listed by name and location.)

b.

c.

APPLICABILITY: Whenever equipment protected by the Halon System is required to be OPERABLE.

l ACTION:

i a.

With one or more of the above required Halon Systems inoperable, 4

within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> establish a continuous fire watch with backup fire suppression equipment for those areas in which redundant systems or components could be damagedi for other areas, establish an hourly fire watch patrol.

4 I

b.

The provisions of Specifications 3.0.3 and 3.0.4 are not applicable.

SL*RVEILI.ANCE RIQUIREMENTS 4.7.11.4 Each of the above required Malon Systems shall be demonstrated l

OPERABLE:

a.

At least once per 31 days by verifying that each valva (manual, power opere'.ed, or automatic) in the flow path is in its correct position.

b.

At least once per 6 months by verifying Halon storage tank weight to be at least 95% of full charge weight (or level) and pressure to be at least 90% of full charge pressure, and l

c.

At least once per 12 monthe by verifying:

l (1) The system valves, associated ventilation equipment and fire door interlocka, time delays, and alarms actuate manually and automatically.

(2) Performance of a flow test through headers and nossles to assure no blockage.

___7-

d.

Ar least once per years by verifyings (1) Tull discharge of the entire design quantity of Halon through i

system piping to ensure that Malon is discharged onto the hasard, and that the concentration is achieved and maintained in the period of time required by the design specifications i

and all pressere operated devices function properly.

i I

j e.

Prior to returning a

• <1on system to functional status following

)

an event which may ha"c. affected its operability, perform a full discharge on the affected halon system.

i

'i

))$7IFICATION FOR PROPOSED CHANCES 4.7.11.4 Paragraph c. has changed with respect to frequsncies and minimum l

acceptable inkpection criteria to be used when performing a surveillance t

inspection per NTPA 12A-1-11.1.

This was added to improve the inspectability l

of present Standard Technical Specification.

4.7.11.4.d. has been added because of present on-going problema axisting at D. C. Cook Nuclear Plant which could be a generic issue. The Unit 1 and 4

~

2 Control Roos Cable Vaults are protected with a combined total flooding Halon 1301 system added after original design to the CO2 Systen using the j

CO2 Systen equipment to operate. An acceptance test dated October 3, 1974 for the Halon System in Unit 1 Cable Vault failed to provide the minimum i

design concentration for 10 minutes as recommended in NFPA 12A. This I

problem was identified during a July,1982 fire protection audit by a fiss i

j

(

protection consulting firm.

I Paragraph 4.7.11.4(e) was added in case the Halon System is involved in any event which could affect its operability.

I I

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4

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PLANT SYSTEMS FIRE HOSE STATIONS I

LIMITING CONDITION FOR OPERATION l

3.7.11.5 The fire hose stations shown in Table 3.7-5 shall be OPERABLE.

APPLICABILITY:. Whenever equipment in the areas protected by the fire hose stations is required to be OPERABLE.

ACTION:

a.

With one or more of the fire hose stations shown in Table 3.7-5 inoperable, provide gated wye (s) on the nearest OPERABLE hose station (s). One outlet of the wye shall be connected to the standard length of hose provided for the hose station. The second outlet of the wye shall be connected to a length of hose sufficient j

to provide coverage for the area left unprotected by the inoperable j

hose station. Where it can be demonstrated that the physical routing of the fire hose would result in a recognizable hazard to operating technicians, plant equipment, or the hose itself, the fire hose shall be stored in a roll at the outlet of the OPERABLE hose station. Signs shall be mounced above the gated wye (s) to identify e

the proper hose to use. The above ACTION requirement shall be accomplished withf.n 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> if the inoperable fire hose is the j

primary means of fire suppression; otherwise route the additional hose within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

)

l b.

The provisions of Specifiestion 3.0.3 and 3.0.4 are not applicable.

SURVEILLANCE REQUIREMENTS 4.7.11.5 Each of the fire hose stations shown in table 3.7-5 shall be demonstrated OPERABLE.

a.

At least once per 31 days by visual inspection of the hose stations accessible during plant operations to assure the readiness of the i

hose station. The following shall be minimally inspected while conducting the surveillance:

(1) Verify that the stations (globe) valve, nozzle and fire hose are attached, properly positioned on the rack or reel and ready for use and that the required water pressure is available.

(2) Verify that fire hose stations are free of debris end foreign substance.

t-TABLE 3.7-5 FIRE HOSE STATIONS LOCATION

• ELEVATION HOSE RACK #

/

i

~"List all Fire Hose Stations required to ensure the OPERABILITY cf safety-reiated equipment.

2 0

e 7

e

-.w,

,-,n y

--w.~y,e--,.,m,,.,,,-n,ne.vn-m..r m, r we, +, -,,,,

,,w,

,,mp,.,,,-.,,,,es,

,+,,

,,,,,.,r,--,,-r.,w,,wge-,-

(3) Verify that the interior and exterior of the hose is free of moisture.

(4) Verify that the non-attached equipment and any other required equipment is at the station (spanner wrenches).

(5) Verify as applicable that a pressure reducing devices are installed.

b.

At least once per 12 months by a maintenance inspection of the fire hose stations accessible during plant operations to minimally inspect the following while conducting the surveillance:

(1) Verify that hose is re-racked or re-reeled so that previous folds shall not occur at the same positions.

(2) Verify that all gaskets in hose and standpipe couplings are inspected and any degraded gaskets found are replaced.

(3) Verify that there is no evidence of mildew, rot, damage by chemicals, vermin, and abrasion or cuts to the hose jacket.

(4) Ensure that couplings, nozzles, raci(or reel, and valves for FVivels rotate freely, threads are in gcod condition, obstructions are removed, corrosion deposits are removed, leaks are repaired and verify the proper nozzle for the hazard in the area is attached to the nearest hose (s).

(

i (5) Include items listed in paragraph (a).

s..

At least once per 18 months by a visual and/or maintenance inspection c.

of the fire hose stations not accessible during plant operations to assure items in paragraph (a) and (b) have been satisfied.

d.

At least at intervals not exceeding 3 years after purchase date:

(1) Conduct a hose hydrostatic test at a pressure of 150 psig or at least 50 psig abcve the maximum pressure available at any hose station, whichever is greater.

(2) Partially opening each hose station valve to verify valve operability and no flow blockage.

Prior to returning a fire hose station to functional status following e.

any event which may have affected its operability, repairs, or maintenance perform the requiremente of a, b, e and d above on the affected hose station.

JUSTIFICATION FOR PROPOSED CHANGES Paragraphs 4.7.11.5 a. and b. have changed the surveillance requirement frequencies and added the minimum acceptable inspection criteria to be used when performing a surveillance inspection. This was added to improve the

the inspectability of Present Standard Technical Specifications.

Discussions with NRC contractor fire protection consultant (Brookhaven National Laboratory).has indicated fire protection inspection conducted from 1976-1979 (term of the contract) following the "Browns Ferry Fire" (March 22, 1975) had i

demonstrated that little or no fire hose preventive maintenance program were 1

on-going at the cime of their inspections.

The surveillance frequency was updated to follow current nuclear plant practice and to meet NFPA 14, 1962 and ANSI 59.4 Standards.

1 Paragraph 4.7.11.5.c. references those fire hose stations not inspected during the monthly and annual inspection schedule due to their being located in High Radiation Areas.

Paragraph 4.7.11.5.d. has been updated to current NFPA requirements (Pamphlet i

1962, Section 2-3.2).

Regarding Hydrostatic Hose Tests, on May 9-13, 1983 our fire protection inspectors performed a pre-operational inspection at the Enrico Fermi Nuclear Plant, during which they identified 4 of 4 (only plant area completed for inspection) fire hose stations it failed to provide pressure reducing devices as required by NFPA 14 Section 4-2.2.

In addition, on July 12-16, 1982 a fire protection consultir.g firm performed a fire protection audit at the D. C. Cook Nuclear Plant during which they identified the hose stations in safety related areas of the plant were not provided with pressure reducing valves. The function of the hose valves is to regulate the fire hose station pressure to a manageable level so that brigade members can properly handle and maneuver the fire hose.

The present requirement states, "At least 50 PSI above the maximum pressure

-s available at any hose station." Similar wording can be found in NFPA 14 Section 8-1.3 and 4. However, these requirements relate to the permanently non-collapsible standpipe systen piping rather than the remevable and collapsible fire hose attached to the standpipe system.

As stated previously NFPA 14, Section 4-2.2 does not approve of pressures at any standpipe outlet which axceeds 100 PSI for a Class II standpipe system (1 1/2" hose). Thus, the current NFPA requirement for a service test pressure (hydrostatic test) of 150 PSI for 1 1/2" single-jacket hose (hose presently used in nuclear plants) with the applicable acceptance test pressure (factory 3

test) should be the required test pressure. However, we have left the 50 PSI hydrotest pressure the same as Appendix R.

Paragraph 4.7.11.5.e. was added so that in the event a fire hose station is involved in any event which may affect its operability, assurance that the affected hose station (s) will be restored to operability-is specified.

. ~.

PLANT SYSTEMS YA".D FIRE HYDRANTS AND HYDRANT HOSE HOUSES LIMITING CONDITION PgR OPERATION 3.7.11.6 The yard fire hydrants and associated hydrant hose houses shown in Table 3.7-6 sha'l be OPERABLE.

APPLICABILITY: Whenever equipment in the areas protected by the yard fire hydrants is required to be OPERABLE.

i Af; ION:

a.

With one or more of the yard fire hydrants or associate.1 hydrant hose houses shown in Table 3.7-6 inoperable, within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> have sufficient additional lengths of 2 1/2 inch diameter hose located in an adjacent OPERABLE hydrant hose house to provide service to thc unprotected area (s) if the inoperable fire hydrant or associated hydrant hose house is the primary means of fire suppression; otherwise, provide the additional hose within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

b.

The provisions of Specifications 3.0.3 and 3.0.4 are not applicable.

[

SURVEILLANCE REQUIRD'ENTS 4.7.11.6 Each of the yard fire hydrants and associated hydrant hose houses shown in Table 3.7-6 shall be demonstrated OPERABLE:

a.

At least once per 31 days by visual inspection of the hydrant hose house to assure all required equipment is at the hose house. The following shall be minimally inspected while conducting the surveillance:

j i

(1) Inspect each yard hydrant to make sure they are not obstructed by storage, weeds, etc., conveniently accessible, visible, caps in place, and marked according to NF$Q 291, Chapter 2.

(2) Hydrant hose houses shall be free of debris and shall be kept dry inside.

(3) Verify as applicable proper number of nozzles, hydrant wrenches, reducers or gated wyes, and other required equipment are stored in the hose house. Also spare hose coupling gaskets for each size hose shall be verified stored in hose houses.

b.

At least once per 6 month (once during March, April or May end once during September, October or November) by visually inspecting each yard fire hydrant and verifying that the hydrant barrel is

l TABLE 3.7-6 YARD FIRE HYDRANTS AND ASSOCIATED HYDRANT HOSE HOUSES LOCATION *.

HYDRANT NUMBER o

=

(

w i

.d i

i l

I

• List all Yard Fire Hydrants and Hydrart Hose Houses required to ensure the OPERABILITY of safety-related equipmer.t.

r,

-7,

,.--,-r-,,--r- - -,n

, -. < -, m n w,-

-re-.

,----.,--,-w

1 I

dry and that the hydrant is not damaged.

l c.

At least once per 12 months by a maintenance inspection of hydrants and hydrant hose houses to minimally inspect the following:

(1) Conduct a hose hydrostatic test at a pressure of 150 PSIG or at least 50 PSIG above the maximum fire mein operation pressure, whichever is greater.

(2)

Inspect all gaskets and replace any degraded gaskets in the couplings.

j (3) Examine the hose to assure there is no evidence of mildew, rot, damage by chemicals, vermin, and abrasion or cuts to the jacket.

(4)

Inspection couplings, nozzles, rack or reel, and valves for swivels rotating freely, threads in good condition, obstruc-tions, corrosion, leaks, and verify the proper nozzle for the 1

hazard the hose is to protect is available for use.

(5) Verify that the station including (globe or angle) valves nozzle and fire hose are attached, properly positioned on the rack or reel and ready for use.

(6) Verify that the fire hose station is free of debris.

['

(7) Verify that the interior and exterior of the hose if free of E.

moisture.

(8) Verify that non-attached equipment and any other required equipment is at the station.

(9) Perform a flow check of each hydrant to ensure proper operation.

drainage, no obstructions in waterway and it is properly lubricated.

(10) Verify each hydrunt is protected to prevent mechanical damage.

(11) Verify fire department connection caps are in place, threads in good condition, ball drip or drain in order, and check valves not leaking.

B d.

Prior to returning yard fire hydrants and hydrant hose houses-back to a functional status following any event which may have affected their operability, perform the actions specified in paragraphs a, b and e above.

JUSTIFICATION FOR PROPOSED CHANGE

,,,e--,.

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=n

4 SdRVEILLANCE REQUIREMENTS s

Paragraph 4.7.11.6(a), (b) and (c) of the draf t have changed the surveillance requirement frequencies and added minimum acceptable inspection criteria i

to be used when performing a surveillance inspection. This was added to further expand on the one inspection criteria example given in present Standard Technical Specification Section 4.7.11.6(c)(2).

As indicated in the fire hose section, discussions with NRC contractor fire protection consultant (Brookhaven National Laboratory) indicated fire pro-tection inspections conducted from 1976-1979 following the "Browns Ferry Fire" had demonstrated that little or no fire hose (interior and exterior hose is interchangeable) preventive maintenance programs were on-going at the time of their inspections.

This included yard hydrants missing caps and control valves turned off. Hydrant hose houses were found in poor condition.

Examples of this are gaskets missing, from hose, nozzles, hose and other equipment missing from the hose house while equipment remaining in the houses rusting and home was mildewing and rotting without care.

The surveillance frequency and inspection criteria was referenced from NFPA 13A, 14, 24, 26, 1962 and ANSI 59.4 Standards.

I Paragraph 4.7.11.6(d) was added so that in case the yard hydrant or hydrant hose house is involved in any event which could affect its operability.

l

PLANT SYSTEMS 3/4.7.12 FIRE RATED ASSEMBLIES LIMITING CONDITION FOR OPERATION-3.7.12 All fire rated assemblies (walls, floor / ceilings, cable tray enclosures and other fire barriers) separating safety-related fire areas or separating portions of redundant systems important to safe shutdown within a fire area i

and all sealing devices in fire rated assembly penetrations (fire doors, fire windows, fire dampers, cable, piping, and ventilation duct penetration seals shall be OPERABLE.

APPLICABILITY: At all times.

j ACTION:

a.

With one or more of the above required tire rated assemblies and/or sealing devices inoperable, within one hour either establish a continuous 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 and establish an hourly fire watch patrol.

b.

The provisions of Specifications 3.0.3 and 3.0.4 are not applicable.

(

SURVEILLANCE REQUIREMEh7S 4.7.12.1 At least once per 18 months the above required fire rated assemblies and penetration sealing devices shall be verified OPERABLE by performing a visual inspection of:

At least 20% of each type of sealed penetration against established a.

acceptance criteria based on accepted test configurations. If apparent changes in appearance or 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 troy enclosure / conduit wrap and associated hardware.

During cold shutdown by visual and/or operational inspection of the c.

fire rated assemblies not accessible during plant operations to assure their operability.

4 4.7.12.2 At least once per 6 months verify by a maintenance inspection that the fire doors and fire dampers (accessible during plant operation) are OPERABLE by:

a.

Inspecting the chains employed on suspended doors to look for excessive wear and stretching, b.

Lubricating guides and bearings to facilitate operation.

c.

Examining hardware (hinges, moving parts) and any parts found to be inoperative shall be replaced immediately.

l d.

Ensuring that door openings and the surrounding areas are kept free of all obstructions.

j e.

Ensuring that fusible links or other heat actuated devices are-kept free of foreign subscances.

f.

Ensuring that caro is taken to prevent paint accumulation on stay rolls.

g.

Ensuring that any breaks in the face covering of doors shall be repaired immediately.

CLEAR OF h.

Ensuring that combustible material are kept 20 f..; ;

1, fr =

openings.

4.7.12.3 Ensure each of the above required fire doors are OPERABLE in case of fire by:

(

a.

Verifying daily that electrically supervised fire doors are kept closed and in the latched position.

l b.

Performing a daily visual inspection of self-closing fire doors that are not electrically supervised to verify that they are kept closed and in the latched position c.

Performing a weekly visual inspection of automatic closing fire doors that are not electrically supervised to verify that their j

automatic hold-op.en and release devices will permit them to i

automatically close in the event of a fire, 4.7.12.4 Prior to returning a fire rated assembly to functional status following any event which may have affected the operability of fire rated assemblies by performance of a visual inspection of the affected fire rated assembly (ies).

JUSTIFICATION FOR PROPOSED CHANGES j

SURVEILLANCE REQUIREMENTS Paragraph 4.7.12.1.

changed the surveillance frequency and added j

minimum acceptable acceptance criteria to be used by the licensee.

Specifically, paragraph a. incorporates our LaSalle experience regarding the need of an acceptance criteria which 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 4.7.12.2 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 ANST l

inspection frequencies have been included. The term "visual inspection" alone 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 requirements and a more thorough inspection.

In our draft copy, we have used the terms "operational" or "maintenance" inspection for clarification in describing a more ir.-depth surveillanceg inspection in addition to the term "visual inspection".

During a recent fire protection inspection at the Big Rock Point Nuclear Plant, a surveillance procedure existed to inspect fire dampers only once every 3 years.

It was felt by the inspectors that this surveillance require-ment was too infrequent resulting in an open item in the inspection report 1

(50-155/82-13(DE)). No violation could be cited due to Big Rock Point's

/

Technical Specification Bases section which up until recently stated, "The penetration fire barriers are a passive element in the facility fire l

protection program."

Paragraph 4.7.12.2&3 is from field experience which as demonstrated the present surveillance requirement of 18 months is not common fire protection practice. Nor is this requirement in accordance with current ^;re protection industry standards. Discussions with licensee personnel indicate present plant's practice to conduct routine inspections of the penetrction fire barriers while the plant is operating and on a semi-annual to annual basis for operational type inspections.

On July 12-16, 1982, a fire protection consulting firm performed a fire protection audit at the D. C. Cook Nuclear Pignt during which they identified 11 of 45 (2dID) fire doors inspecte.d during the inspection contained deficiencies and this occurred within six months of the previous inspection. Also during this inspection 13 of 140 (10%) fire damp $ers inspected during a operational test failed to operate during a 18 month surveillance inspection.

Dur draf t surveillance requirements have 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 4.7.12.4 states that in the event a fire rated assembly is involved in a fire, damaged or impaired in some way, sarveillance of the affected assembly and their operability would be verified (defense in-depth),

l

.,.. - - ~

PLANT SYSTEM j

PORTABLE FIRE EXTINGUISHERS LIMITING CONDITION FOR OPERATION All hand-held portable fire extinguishers (including water-based types, drys chemical, carbon dioxide, halon, loaded stream and dry powder extinguishers) j in fire t.one boundaries protecting safety related areas shall be functional.

APPLICABILITY: At all times.

e ACTION:

a.

With one or more of the above required portable fire extinguishers inoperable, within eight hours replace with a portable fire extin-guisher having the same classification and at least equal rating.

b.

The provisions of Specifications 3.0.3 and 3.0.4 are not applicable.

l SURVEILLANCE REQUIREMENTS i

[

Each of the above required portable fire extinguishers shall be verified to be functional:

m a.

At least once per 31 days by visual inspection of the portable fire extinguishers accessible during plant operations to assure operabil-ity. The following shall be minimally inspected while conducting

)

the surveillance:

)

i (1) Verify extinguisher is in its designated location and unobstructed, that tamper indicators are in place, and that the extinguisher is not damaged, impaired, leaking, under or overcharged, or has any obvious corrosion, b.

At least once per 12 monthe by a maintenance inspection of the portable fire extinguishers accessible during plant operations to assure operability, The following shall be minimally inspected while conducting the surveillance:

(1) Verify gage shows proper pressure. Extinguishers not using a gg)e shall be visually inspected for proper level and weighed.

(2) Examine nozzle and hose or horn for obstructions and any cracks. Aldo verify operability of components in those that can be tested by movement.

(3) For dry chemeial extinguishers determine that extinguishing agent is in a free-running condition. Verify that the contents of the extinguisher match the nameplate and manufacturer's reconsnendations of weight. including cartridge; &lso inspect gaskets and replace any degraded gaskets.

(4)

Include items listed in paragraph (a).

c.

At least once per 12 months by recharging foam, pump tank water, and pump tank calcium chloride base antifreeze type fire extin-guishers to assure their operability.

d.

At least once per 18 months.by maintenance inspection of the portable fi,i extinguishers not accessible during plant operations to assure extinguisher operability.-

i e.

At least once per 6 years, stored pressure dry chemical extinguishers that require a 12-year hydrostatic test shall be emptied and subjected to the applicable veintaance procedures to assure their operability.

f.

Portable fire extinguishers shall be hydrostatically tested at intervals not exceeding those specified in the following table:

Extinguisher Type Test Interval (years)

Soda Acid 5

Cartridge operated Water and/or Antifreeze 5

Stored Pressure Water and/or Antifteeze 5

f Wetting Agent 5

Foam 5

AFFF (Aqueous Film Forming Foam) 5 Load Stream 5

Dry Chemical with Stainless Steel Sheels 5.

Carbon Dioxide (Wheeled-Unit Hose Assembly Pressure 1250f) 5 Dry Chemical, Stored Pressure, with Hild Steel Shells, Brazed Brass Shells, or Aluminum 12 Shells Dry Chemical, Cartridge or Cylinder Operated, with Hild Steel Shells 12 Bromotrifluoromethane - Halon 1301 12 Bromochlorodifluoromethane - Halon 1211 12 Dry Powder, Cartridge or Cylinder Operated, with Mild Steel Shells 12 Compressed Gas Cylinders - Wheeled Units 5

g.

At least once per 12 years by hydrostatic test at 300 psi for dry chemical cartridge operated extinguisher hose assemblies to assure their operability.

h.

Prior to returning a portable fire extinguisher to functional status following repairs or maintenance by performance of a visual inspection of the affected portable fire ext!.nguisher.

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Prior to returning a portable fire extinguisher to functional i

status following any event which could have effected its structural integrity and/or operability by performance of a hydrostatic test to the affected extinguishers.

JUSTIFICATION FOR REQUESTED CHANGE Presently no standard technical specification exist for portable fire extin-guishers. Since prompt extinguishment of fires is important to reactor safety, the application of portable fire extinguishers rather than automatic suppression systems should be preferred. Properly maintained portable fire extinguishers along with a trained fire brigade (present NRC requirement) should control and extinguish fires while in the incipient stage. The purpose of portable fire extinguishers and hose stations is to control and/or extinguish fire before it gains in magnitude to affect safety related equip-ment and also to reduce the need for automatic suppression system actuation causing additional safety related concerns. This has been referred to as i

"Fire Suppression System Interaction Lines of Inquiry" resulting in safe shutdown equipment failure or env'ronmental qualification problems presently under technical review by NRR.

i Also, the Electric Power Research Institute has furnished a test report to the NRC titled, "Water as a Means of Cable Fire Protection and Operational Effects Experience" (EPRI NP-1193) dated October 1979. This report describes industry experiences with the use of water as an extinguishant and points out the potential for initiating additional hazards from the operation of water sprays.

A[' w4t In 1976, the U.S. Department of Labor, Occupational Safety and Health, AWh51R AT/or Association of Fire Equipment Distributors (NAFED) performed an in-depth broadebase study on the use of portable fire extinguishers. The ocope of this study examined the performance of 14.091 fire extinguishers on 5,400 fires. The report concluded that 327 of 5,400 fires were not extinguished while attempting to use portable fire extinguishers. Retsons given for not extinguishing the fires included extinguishers which had been previously discharged and left in services in a empty or near empty condition, broken syphons, caked chemical, foreign objects lodged in horn, clogged hoses, damaged extinguishers, frozen extinguishers, etc.

Surveillance requirements are referenced from NFPA Pamphlet 10, ANSI /ANS 59.4 - 1979 titled, "Generic Requirement for Light Water Nuclear Power Plant Fire Protection", and from discussions with licensees present practice for surveillance requirements on portable fire extinguishers.

SURVEILLANCE REQUIREMENTS Paragraphs (a), (b), and (c) were included for the purpose of performing an operational test to give reasonable assurance that the extinguisher is fully charged and operable. These requirements are in accordance with NFPA 10, Sections 4-3, 4-4 and 4-5.2, respectively.

Paragraph (e), (f), and (g) were included for the purpose of performing a maintenance test which includes a thorough examination, any necessary

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i repair or replacement and the need for a hydrostatic test. These require-ments are in accordance with hTPA 10, Sectioas

'.-4.1.1, 5-3 and 5-4.4, respectively.

Paragraph (1) was added to give assurance that the extinguisher Juld be I

i hydrostatically tested prior to being put back in service if invo10ed in any event which could affect its structural integrity. This requirement i

is in accordance with NFPA 10, Section 5-1.3(d).

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PLANT SYSTEMS DERGENCY LIGHTING UNITS LIMITING CONDITION FOR OPERATION All Emergency Lighting Units in fire zone boundaries protecting safety related areas shall be functional.

APPLI_CABILITY: Modes 1. 2, 3 and 4 AC IO' :

d a.

With one or more of the above required emergency lighting units inoperable, within eight hours the unit shall be replaced with a operable emergency lighting unit.

b.

The provisions of Specifications 3.0.3 and 3.0.4 are not applicable.

SURVEILLANCE REQUIREMENTS Each of the above required emergency lighting units shall be verified to be functionals a.

At least once per 31 days by an operational test (to include verifying unit operation, electrolyte level and position of hydrometer discs (lead acid only) of the emergency lighting units accessible during plant operations to assure their operability. h*4 b.

At least once per 6 months by a maintenance test (to include cycling battery and checking change-over setting) of the emergency lighting units accessible during plant operations to assure their operability.

j c.

At least once per 18 months by maintenance test of the emergency lighting units not accessible during plant operations to assure their operability.

i d.

Prior to returning a emergency lighting unit to functional 4

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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e 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 systems. 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 Appendix R to 10 CFR Part 50, requires at 1 east an 8-hour battery power supply be provided. However, no emergency lighting 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 Requirements for Light Water Nuclear Power Plant Fire Protection" and from discussions with teledyne %ig Team emergency lighting unit manu-P facturer representatives.

1 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 ths Hydrometer Discs (Lead Acid Only).

Paragraph (b) requires a semi-annual inspection according to ANSI 59.4,

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Table 2 and manufacturer recommendations to cycle the battery, checking

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the change-over setting and verifying items lieted in paragraph (a).

"2ragraph (c) is a standard paragraph from S.T.S. to assure emergency lighting units in high radiation areas will be inspected within a reasonable 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.

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