ML20209D784
| ML20209D784 | |
| Person / Time | |
|---|---|
| Issue date: | 01/23/1985 |
| From: | Little W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Rosa F NRC - FIRE PROTECTION POLICY STEERING COMMITTEE |
| Shared Package | |
| ML20209D558 | List:
|
| References | |
| FOIA-86-274 NUDOCS 8501280103 | |
| Download: ML20209D784 (2) | |
Text
.
e Mc UNITED STATES l
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g%,
g NUCLEAR REGULATORY COMMisslON b"
,,., 3 REGION 111 c
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'[,8 SA cLEN ELLYN, ILUNO15 60137
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- b, MEMORANDUM FOR:
F. Rosa, Chairman, Fire Protection Policy Working Group FROM:
W. S. Little, Chief, Operations Branch
SUBJECT:
PROPOSED CHANGES TO THE STANDARD TECHNICAL SPECIFICATIONS ON FIRE PROTECTION We have reviewed the proposed STS on fire protection transmitted by your memorandum of December 7,1984 and our comments are in the enclosure. In general we believe that the proposed STS are a significant improvement over previous drafts, and will provide reasonable assurance that fire prevention /
protection equipment will protect safety related equipment throughcut the lifetime of the plant.
We have reviewed the draft Working Group memorandum to the Steering Committee in your Enclosure 2 and have no substantive coments.
in ;
7
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W. S. Little, Chief Operations Branch cc:
R. H. Vollmer, NRR J. N. Grace, IE T. T. Martin, RI W. J. Olmstead, ELD J. A. Olshinski, RII C. J. Anderson, RI V. Benaroya, NRR T. E. Conlon, RII C. I. Grimes, NRR V. A. Moor, NRR S. D. Richardson, IE W. M. Shields, ELD R. L. Spessard, RIII T. Wambach, ORB 5 E. Butcher, TAPMG
- 0. Parr, ASB J. Wermiel, ASB R. W. Houston, AD/RS W. G. Guldemond, RIII J. Ulie, RIII C. Ramsey, RIII L. A. Reyes, RIII E &.l f li l b 49
ENCLOSURE Concents on Fire protection S.T.S.
1.
3.3.3.8 Action a. should have a minor wording change to read as follows:
With one or more of the fire detection instruments shown in Table 3.3-11 inoperable.....
2.
4.3.3.8.1 The requirement to test inaccessible detectors during each cold shutdown exceeding 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> unless performed during the previous 6 months is too restrictive. This requirement may force an otherwise unwarranted containment entry with associated air lock leakage testing. This has the potential for degrading primary containment as well as unnecessarily extending an outage. As an alternative, a refueling outage frequency is suggested with a provision that if failures are experienced, the interval be as now stated until two successive intervals show no failures.
3.
Function B Instrumentation (See Table 3.3-11, - LC0's 3.3.3.8, 3.7.11.2, 3.7.11.3,3.7.11.4)
It is not clear to us whether LC0 3.3.3.8 or 3.7.11.2,
.3, or
.4 would be imposed for an inoperable Functin B detector (one used to actuate a suppression system). We believe the action statements for 3.7.11.2,
.3, and
.4 to be too restrictive for an inoperable Function B detector and believe the action statement for 3.3.3.8 to be more appropriate.
I would suggest deletion of the proposed addition to the footnote on Table 3.3-11, and the addition of a clarifying statenent to the the action statement of 3.7.11.2,
.3 and
.4 to state that for only a Function B detector inoperable the action statement of 3.3.3.8 is applicable.
4.
Bases 3/4.7.11 - There has been some confusion over the definition of an acceptable backup pump or supply required by 3.7.11.1.
We recommend that the bases state that an acceptable backup pump or supply is one that will:
4 (a) Meet the maximum fire suppression system demano plus hose streams.
(b) Not otherwise affect the nuclear safety of the plant when in use.
~
5.
3.7.11.6 Action a.
This spec is more restrictive than 3.7.11.5 Action a as rewritten for no apparent reason. ;1t is suggested that the action statement be rewritten to be the same as 3.7.11.5 Action a.
6.
3.7.12 The applicability should be whenever equipment separated by the fire rated asseablies is required to be operable.
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