ML20209D781
| ML20209D781 | |
| Person / Time | |
|---|---|
| Issue date: | 01/08/1985 |
| From: | Bemis P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Rosa F NRC - FIRE PROTECTION POLICY STEERING COMMITTEE |
| Shared Package | |
| ML20209D558 | List:
|
| References | |
| FOIA-86-274 NUDOCS 8501280097 | |
| Download: ML20209D781 (5) | |
Text
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UNITED STATES NUCLEAR REGULATORY COMMISSION f.
REGION il k,
101 MARIETTA STREET.N.W.
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ATLANTA. GEORGI A 30323
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JAN 6 tE.
MEMORANDUM FOR: Faust Rosa, Chairman Fire Protection Policy Working Group FROM:
Paul R. Bemis, Acting Director Division of Reactor Safety
SUBJECT:
REVIEW 0F PROPOSED CHANGES TO FIRE PROTECTION STANDARD TECHNICAL SPECIFICATIONS As requested by your memorandum of December 7,1984, the Region II staff has reviewed the house Standard Technical Specifications (STSs). proposed changes to the fire prot It is recommended that the enclosed changes be incorporated into the final revision of the subiect STS sections.
Also, it is our opinion that an additional STS section which addresses the limiting conditions of operation and surveillance requirements for the reactor coolant pump oil collection system is required and should be incorporated into the STSs.
If you have any questions, please advise.
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's r Paul R.
mis
Enclosure:
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Comments on Proposed Standard Fire Protection Standard Technical Specifications cc w/ encl:
C. Ancerson, RI W. Little, RIII C. Grimes, NRR V. Benaroya, NRR V. Moore, NRR
- 0. Parr, ASB
- 5. Richardson, IE CONTACT:
T. E. Conlon FTS 242-5537
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r ENCLOSURE COMMENTS ON PROPOSED STANDARD FIRE PROTECTION STANDARD TECHNICAL SPECIFICATIONS The Region II staff has reviewed the proposed revisions to the STSs pertaining to fire protection.
The following recommended changes should be incorporated into the STSs.
3.3.3.8 Action Statement. Revise this section as follows:
a.
With any Function A fire detection instrument in any fire detection zone or fire area shown in Table 3.3-11 inoperable, within the next one 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 located inside the containment, then inspect the containment zone at least once per eight hours (or monitor the containment air temperature at least once per hour at the locations listed in STS 4.6.1.6).
b.
With any Function B fire detection instrument within any fire zone or fire area shown in Table 3.3-11 inoperable, within one hour establish a continuous fire watch with backup fire suppres-sion equipment for those areas in which redundant safe shutdown systems or components could be damaged; for other areas, establish an hourly fire watch patrol, c.
Restore the inoperable instrument (s) to OPERABLE status within 14 days, or in lieu of any other report required by STS 6.9.1, prepare and submit a Special Report to the Commission pursuant to STS 6.9.2 within the next 30 days outlining the action taken, the cause of the inoperability and the plans and sched-ule for restoring the instrument (s) to OPERABLE status.
d.
The provisions of STSs 3.0.3 and 3.0.4 are not applicable.
The basis for adding the additional action statement to the fire i
detection STS is to assure that the action statements of STSs 3.7.11.2, 3.7.11.3 and 3.7.11.4 are implemented.
This is impera-tive, since some types of fixed automatic fire suppressions systems (i.e., pre-action, water spray and deluge sprinkler systems and gaseous C0 and Halogen suppression systems) are actuated or tripped 2
by a fire detection system.
4.3.3.8.2.
Concur.
Enclosure 2
Table 3.3-11. Concur; however, the above recommended change to STS 3.3.3.8 would list the limiting conditions for the Function B detection instruments.
3.7.11.1 Concur.
4.7.11.1.
Do not concur.
Fire protection systems supplied by untreated river 1.d.
and lake water should be flushed at frequent intervals.
For these type systems, a flush once per six months is not considered excessive.
4.7.11.1.
2 & 4 Concur.
1.f (new e).
4.7.11.1.
Concur only for those plants which have fire pumps that 1.g (new f) take suction from water tanks which contain potable water. Refer to above comments for item 4.7.11.1.1.d.
4.7.11.1.2.. Concur.
a.(2),
3.7.11.2.
Concur.
4.7.11.2.c.
Concur.
(1)(c).
4.7.11.2.
Concur.
c.(2) 3/4.7.11.3. Concur.
3/4.7.11.4 Concur.
3/4.7.11.5. Concur.
However, for Section 4.7.11.5.a., the reference to "in accordence with an established procedure" does not appear to be needed since STS 6.8.1 requires written procedures to be established, implemented and maintained for the fire protection program implementation.
3/4.7.11.6. Refer to the above comments on STS 3/4.7.11.5.
4.7.12.1 Concur.
3.7.13 Do not concur.
This section only requires the instrumentation, switches and control circuits listed in Table 3.3-x to be operable.
It does not address the operability of pumps, storage tanks, diesel generators, batteries, etc., which are also required for the alter-native / dedicated system to be operable.
This section should be modified accordingly.
3.7.13 Action Statements.
Do not concur.
Safe shutdown equipment being inoperative for 60 days is considered excessive.
This equipment should not be. inoperative for more than seven days.
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Enclosure 3
4.7.13.1 Cdncur.
through 4.
Table 3.3-x Concur.
3.7.14.
Revise Applicability to read:
"At all times."
The fire extinguishers provided within a plant are the first line of defense and should always be available for use in the event of a fire or emergency.
4.7.14.
Concur in part. The following addition to the surveillance require-ment should be made:
ma nufacturers ' recommendations and verifying that each extinguisher is located as designated in the Fire Hazards Analysis."
3.7.15.
Concur.
4.7.15.
Do not concur.
The surveillance requirements for the battery powered emergency powered lighting units should be revised to read:
Each of the above emergency lighting units shall be verified to be OPERABLE:
a.
At least once per 31 days by:
(1) Performing 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 and to verify that the lamps are properly aimed.
(2) Conducting 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.
b.
At least once per 18 months:
(1) By performing an 8-hour capacity illumination test on at least 10% of the lighting units installed.
If any nonconforming lighting units are found, an additional 10% will be functional-ly tested until a 10% sample with no apparent nonconformity is identified.
Samples shall be selected such that each lighting unit will be subjected to a capacity test every 15 years.
(2) By performing an operational and maintenance test of the emergency lighting units not accessible during plant operations to assure their operability.
Enclosure 4
c.
Prior to returning an emergency lighting unit to functional status following any event which could affect its operability, performance of an operational test shall be conducted on-the affected lighting unit.
.If more than one unit is involved an operational test shall be performed on a random sample of at least 10% of the lighting units to verify operability.
Bases 3/4.3.3.7.
Concur.
Bases 3/4.7.11.
Concur.
Bases 3/4.7.12.
Concur.
Bases 3/4.7.13.
Concur.
Bases 3/4.7.14.
Do not concur.
The portable fire extinguisher and emergency lighting section should be divided into two sections as follows:
Portable Fire Extinguishers The portable fire extinguishers are the first line of fire defense and are most effective when fires are in their early stages of devel opment.
Portable extinguishers provide the capability to protect safety-related equipment from fires in their incipient stages, but must be properly distributed throughout the plant and maintained in good operating condition to be effective. When an extinguisher is inoperable, it should be promptly repaired or replaced.
Emergency Lighting Units The 8-hour emergency lighting units are provided in areas needed for operation of safe shutdown equipment and in access and agrees routes thereto. This equipment provides illumination for operators to manipulate required equipment concurrent during plant emergency shutdown operations with the lost of the normal illumination within the area'.
This equipment should be properly maintained and if inoperative should be promptly repaired or replaced consistent with the defense-in-depth philosophy.
6.5.2.8.e We do not understand why the frequency of the Emergency Plan a d and f.
Security Plan reviews is changed from 24 to 12 months unc.~ *.he review of the STS fire protection. sections.
It is suggested t:iat this proposed change not be included with these fire protection comments.
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