ML20210D167
| ML20210D167 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 09/12/1986 |
| From: | LOUISIANA POWER & LIGHT CO. |
| To: | |
| Shared Package | |
| ML20210D148 | List: |
| References | |
| NUDOCS 8609190068 | |
| Download: ML20210D167 (10) | |
Text
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DESCRIPTION AND SAFETY ANALYSIS OF PROPOSED CHANGE NPF-38-39 This is a request to revise Technical Specification 3.3.3.8, " Fire Detection Jnstrumentation", and the associated Table 3.3-11.
Existing Specification See Attachment A.
Proposed Specification See Attachment B.
Description The proposed change to Table 3.3-11 will divide the present annulus fire zone RCB 1-1 into two distinct fire zones RCB l-1 and RCB 1-2, with each zone con-taining approximately half of the smoke detectors presently assigned to RCB 1-1.
This change.is reflected in a new ACTION statement "c" in Technical Specifica-tion 3.3.3.8 which will require that with less than one annulus zone of smoke detectors operable one zone must be restored to operable status within one hour or an eight hour fire watch must be implemented.
The annulus is an open area, approximately four feet wide, located between the primary containment steel wall and the secondary containment concrete wall of the Reactor Containment Building (RCB).
Its function is to prevent escape of contaminants by providing a space which can be maintained at a negative pressure around the primary reactor area.
Equipment within the annulus consists of the smoke detection system, communica-tion and lighting fixtures, and the piping and ventilation ducts of the annulus negative pressure system. All of the electrical cables for these systems are routed in conduit.
Other components within the annulus are those which pass through from an adjoining building into the primary containment area.
Such components include the fuel transfer canal from the Fuel Handling Building, personnel accessways from the Auxiliary Building and piping from the main steam, feedwater and purge systems.
Electrical components including power, instrumen-tation and control cables are enclosed within metal sleeves.
The only insitu combustibles within the annulus are the smoke detectors them-selves which represent a negligible combustible loading.
All cable in the annulus is routed in conduit or metal sleeves.
All cabling meets non-combustible test requirements of IEEE Standard 383, "IEEE Standard of Type Test of Class 1E Electrical Cables, Field Splices and Connections for Nuclear Power Generating Stations". All insulation and jacketing material for piping penetration assem-blies passing through the annulus is non-combustible.
Transient combustibles during repair or maintenance operations are strictly controlled by administrative procedure.
8609190068 860912 NS41175 PDR ADOCK 0D000392 P
PDP a
The annulus is void of heat and/or electrical spark generating equipment, i.e.,
potential ignition sources are absent.
Maintenance and/or repairs which involve hot work are strictly controlled in accordance with administrative procedure.
An ionization smoke detection system is provided within the annulus.
The system consists of 23 detectors encircling the -4' elevation, 23 detectors encircling the +21' elevation and 23 detectors encircling the +46' elevation.
Detection alarm and trouble annunciation is provided in the Control Room on a local panel and the Master Remote Control Panel.
The proposed change will divide the detec-tion zone listed in Table 3.3-11 into two fire zones.
One zone will consist of the upper (+46') string of detectors and half of the middle (+21') string.
The second zone will comprise the lower (-4') string of detectors and half of the middle (+21') string.
The annulus smoke detectors, particularly the upper string, have a tendency to spuriously alarm.
This problem may be caused by dust accumulating on the detec-tors.
Due to the high radiation environment at the upper string during power operation, the actual cause and resolution of the spurious alarms cannot be determined until the first refueling outage.
The proposed change is requested for two reasons.
First, during plant operation the environment within the annulus is not recommended for personnel entry.
Temperatures range from 100 F to 120 F, radiation dose levels can be in excess of 100 mrem /hr., airborne contamination exists and oxygen levels are reduced to a level requiring SCBAs to be worn.
ALARA and other personnel safety concerns argue against an eight hour fire watch in an area with no combustible loading or ignition sources when half the smoke detectors are operable.
Second, the requirement for an eight hour fire watch conflicts with other Techni-cal Specification surveillance requirements that could ultimately force the plant to shut down due to a spurious fire alarm.
Specifically, Surveillance Requirement 4.6.6.1 requires that the shield building ventilation system be demonstrated oper-able.
This surveillance, to be performed once every 31 days, requires the con-tainment building to remain closed for ten continuous hours.
Should the annulus fire detectors be spuriously in alarm near the end of such a 31 day period (and cannot be repaired due to the high radiation environment) the eight hour fire watch will not allow a continuous 10 hour1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> period for the shield building venti-lation system test, thus mandating a plant shutdown in conformance with Technical Specification 3.6.6.1.
This situation nearly occurred at Waterford 3 in early September, 1986.
Only the presence of an unscheduled reactor trip (which allowed for smoke detector repairs) prevented the situation.
Safety Analysis The proposed change described above shall be deemed to involve a significant hazards consideration if there is a positive finding in any of the following areas:
1.
Will the operation of the facility in accordance with this proposed change involve a significant increase in the probability or consequences of any accident previously evaluated?
Response
No.
The proposed change will still require that approximately half of the annulus smoke detectors remain operable in the absence of an eight hour fire watch.
The annulus region contains no combustibles (with the excep-tion of the smoke detectors, themselves) nor does it contain potential ignition sources.
Therefore, the proposed change will not significantly
. increase the probability or consequences of an annulus fire.
2.
Will operation of the facility in accordance with this proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?
Response
No.
The proposed change maintains fire detection capability within the annulus when a fire watch is not required.
No combustible or ignition sources are introduced by the change, nor are new components or modes of operation introduced.
Therefore, the proposed change will not create the possibility of a new or different kind of accident from any accident previously evaluated.
3.
Will operation of the facility in accordance with this proposed change involve a significant reduction in the margin of safety?
Response
No.
The proposed change preserves the capability to detect annulus fires through half of the existing smoke detectors.
Coupled with the absence of combustible and ignition sources, the proposed change will not involve a significant reduction in the margin of safety.
Safety and Significant Hazards Determination Based on the above Safety Analysis, it is concluded that (1) the proposed change does not constitute a significant hazards consideration as defined by 10 CFR 50.92; (2) there is a reasonable assurance that the health and safety of the public will not be endangered by the proposed change; and (3) this action will not result in a condition which significantly alters the impact of the station on the environment as described in the NRC Final Environmental Statement.
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NPF-38-39 ATTACHMENT A
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INSTRUMENTATION
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FIRE DETECTION INSTRUMENTATION LINITING CONDITION FOR OPERATION 3.3.3.8 As a minimum, the fire detection instrumentation for each fire detection zone shown in Table 3.3-11 shall be OPERABLE.
APPLICABILITY: Whenever equipment protected by the fire detection instrument is required to be OPERABLE.
ACTION:
a.
With any, but not more than one-half the total in any fire zone Function A fire detection instruments shown in Table 3.3-11 inoperable, restore the inoperable instrument (s) to OPERABLE status within 14 days or within the next I hour establish a fire watch patrol to inspect the zone (s) with this inoperable instrument (s) at least once per hour, unless the instrument (s) is located inside the containment or annulus, then inspect that containment or annulus zone 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 for the containment, monitor air temperature at least once per hour at the locations listed in Specification 4.6.1.5.
b.
With more than one-half of the Function A fire detection instruments in any fire zone shown in Table 3.3-11 inoperable, or with any Function B fire detection instruments shown in Tabla 3.3-11 inoperable, or with any two or more adjacent fire detection instruments shown in Table 3.3-11 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 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 contain-ment or annulus, then inspect that containment or annulus zone 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 for the containment, monitor air temperature at l
1 east once per hour at the locations listed in Specificat.iun 4.6.1.5.
c.
The provisions of Specification 3.0.3 and 3.0.4 are not applicable.
1 SURVEILLANCE REQUIRENENTS 4.3.3.8.1 Each of the above required fire detection instruments which are accessible during plant operation shall be demonstrated OPERABLE at 1 east once
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per 6 months by performance of a CHANNEL FUNCTIONAL TEST.
Fire detectors which are not accessible during plant operation shall be demonstrated OPERA 8LE by the performance of a CHANNEL FUNCTIONAL TEST during each COLD SHUTDOWN exceeding 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> unless performed in the previous 6 months.
4.3.3.8.2 The NFPA Standard 72D supervised circuits supervist'n associated o
with the detector alarms of each of the above required fire detection instruments which are accessible during plant operation shall be demonstrated OPERA 8LE at least once per 6 months.
Circuits which are not accessible during plant opera-tion shall be demonstrated OPERABLE during each COLD SHUTDOWN exceeding 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> unless performed in the previous 6 months.
a WATERFORD - UNIT 3 3/4 3-49
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l TA8LE 3
-1 (Continued)
FIRE DETECTION INSTRUMENTS TOTAL NUpWER OF INSTRUMENTS
- ELEVATION HEAT FLAME SMOKE s
ZONE ROON NAME/ NUMBER (ft)
M g (x/y) b l
2.
REACTOR CONTAINNENT BUILDING **
l RCB 1-1 Annulus /420
- 4, +21 69/0
& +46 RCS 2 Electrical Penetration Area A
+21 24/0 l
RCB 3 Electrical Penetration Area 8
+21 21/0 RCE 4 Reactor Cable Trays
+46 16/0 CT 1&3 Wet & Ory cooling Tower "A" Cable Tray 1/0 CT 2&4 Wet & Dry Cooling Tower "B" Cable Tray 1/0 3.
FUEL HANDLING BUILDING FH8 2 Purification Pump Room /8155, Fuel Pool
+1 10/0 Pump "A"/8157, Fuel Pool Pump "8"/
8156, Fuel Pool Heater Exchanger /
B158 and Access Area /8-161 Emergency Filter Train Unit /8152
+1 6/0 Emergency Elect. Equip. Room /8151
+1 1/0 FH8 4 Operating Floor /361
+46 15/0 4.
CHARCOAL AIR FILTER UNITS E-35 (3A-5A) FHB Emergency Filter Train Unit
+1 1/0 E-35 (38-58) FH8 Emergency Filter Train Unit
+1 1/0 E-17 (3A-5A) Shield Building Ventilation
+46 1/0 System "A" E-17 (38-58) Shield Building Ventilation
+46 1/0 System "B" E-23 (3A-5A) Controlled Ventilation Area
+46 1/0 System Filter Train "A" E-23 (3A-58) Controlled Ventilation Area
+46 1/0 System Filter Train."8" S-8 (3A-5A) Control Room Emergency Unit "A"
+46 1/0 5-8 (38-58) Control Room Emergency Unit "B"
+46 1/0 TABLE NOTATIONS
- (x/y):
x is the number of Function A (early warning fire de'tection and notification only) instruments.
y is the number of Function 8 (actuation of fire suppression systems and early warning and notification) instruments.
- The fire detection instruments located within the containment are not required to be OPERA 8LE during the performance of Type A containment Isakage rate tests.
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v 3.3.3.8 As a minimum, the fire detection instrumentation for each fire detection zone shown jn Table 3.3-11 shall be OPERABLE.
APPLICABILITY: Whenever equipment protected by the f-detection instrument j
is required to tre OPERABLE.
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With any, but not. more than one-half the total in any fire zone a.
function A fire detection instruments shown in Table 3.3-11 inoperabl r,estore the ir.sperable instrument (s) to OPERABLE status within 14 days or within the next I hpur establish a fire watch patrol to inspect the zone (s) with the inoperable instrument (s) at least once prer hour, unless the instru.nent(s) is located inside the containment
+e-aa.wles, then inspect that containment = ;mch zone 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 f:- t.: c = telementy monitor mir temperature at f
least once per hour at the locations Ifsted in Specification 4.6.1.5.
b.
With ere then one-half of the Function A fire de tion instruments in any fira zor,e shown jn Table 3.3-11 inoperabl or with any function S fJr.e detection instruments shown in Ta le 3.3-11 inoperable, or with any two or more adjaunt fire detection instruments shown in f
Table 3.3-11 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 fire watch patrol to insp6ct the zone (s) with the inoperable instrument (s) at least once per hour, unless the instrument (s) is located inside the contain-ment er m;Avs, then inspect that containment = rnd;; zone at least I
once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> cr fsr th: ; x t.f a zty monitor air temperature at 1
least cnce per hour at the locations listed in Specification 4.6.1.5.
d /.
The provisions of Specification 3.0.3 and 3.0.4 are not applicable.
SURVEILLANCE REQulkEMENTS l
4.3.3.9.1 Each of the above required fire detection instruments which are accessible during plant operation shall be demonstrated OPERABLE at least once per 6 months by performance of a CHANNEL FUNCTIONAL TEST.
Fire detectors which are not accessible during plant operation shall be demonstrated OPERABLE by the performance of a CHANNEL FUNCTIONAL TEST durin2 each COLD SHUTDOWN exceeding 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> unless performed in the previous 6 months..
4.3.3.8.2 The NFPA Standard 720 supervised circuits supervision associated with the detector alarms of each of the above required fire detection instruments which are accessible during plant operation shall be demonstrated OPERA 8tE at i
least once per 6 months.
Circuits which are not accessible during plant opera-tion shall be demonstrated OPERABLE during each COLD SHIJTDOWN exceeding 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> unless performed in the previous 6 months.
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WATERFORD - UNIT 3 3/4 3-49
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I FJRE DETECTK44 INSTRUMENTS TOTAL NLE8ER OF INSTKUNENTS*
ELEVATICN WEAT Ft.ANI SMXE
_ ft) g (t/y) 6/yj ZONE ROOM NAME/ NUMBER
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2.
REACTOR CONTAIhMENT' BUILDING **
.:IS/=
RCB 1-1 Annulu./420
- & sfi % *21---
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RCS 2 Electrical Penetration Area A
+21 24/0
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RC8 3 Electrical Penetration Area 8
+21 21/0 RCB 4 Reactor Cable Trays
+46 16t0 CT 1&3 Wet & Dry Cooling Tower "A" Cable Tray 1/0 CT 2&4 Wet & Dry Cooling Tower "B" Cable Troy 1/0 e
3.
FUEL HANDLING BUILDING FHB 2 Furification Pump ilcom/B155, Fuel Pool
+1 10/0 Pump "A"/B157. Fuel Pool Pump "B"/
.B156, Fuel Pool Heater Exchanger /
B158 and Access Ares /E-161 Emergency Filter Train Unit /8152
+1 6/0 Emergancy Ele:t. Eoutp. Room /B151
+1 1/0 FHB 4 Operating Floor /361
+46 15/0 t
4.
CHARCOAL ' AIR FILTER UNITS E-35 (3A-5A) FHB Emergency Filter Train Unit
+1 1/0 E-35 (38-58) FHB Emergercy Filter Train Unit
+1 1/0 E-17 (3A-5A) Shield Building Ventilation
+46 1/0 System "A" E-17 (3B-58) Shield Building Ventilation
+46 1/0 System 'B" E-23 (3A-5A) Centro 11ed Ventilation Area
+46 1/0 System Filter Train "A" E-23 (3A-58) Controlled Ventilation Area
+46 1/0 Systan Filter Train '.'B" 5-8 (3A-5A) Control Roam Emert,ency' Unit,"A"
+46 1/0 S-8 (38-58) Control Room Emergency Unit "B"
+46 1/0 1ABLE NOTATIONS
- (x/y):
x is the number of Function A (ear 19 warning fire detection and notification enly) instruments.
y is the number of Function 8 (actuation of fire suppression systems and early warning and notification) instruments.
- The fire detection instruments located within the containment are not ra:1uired to be OPERA 8LE durir:g the performance 'of Type' A containoant leakage rate tests.
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