ML20214Q946

Application for Amend to License DPR-35,consisting of Proposed Change 87-05,revising Tech Specs to Reduce Min Number of Operable Detectors to 51% Per Zone.Fee Paid

ML20214Q946
Person / Time
Site:	Pilgrim
Issue date:	05/22/1987
From:	Bird R BOSTON EDISON CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
Shared Package
ML20214Q949	List: ML20214Q946 ML20214Q951
References
NUDOCS 8706050273
Download: ML20214Q946 (9)

Text

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f 10CFR50.90 J,

aosa msw Executive Of fices 800 Boylston Street BECo 87-082 Boston, Massachusetts 02199 Proposed Change 87-05 May 22, 1987 Ralph G. Bird Senior Vice President - Nuclear U.S. Nuclear Regulatory Commission Attn: Document Control Desk Hashington, DC 20555 License DPR-35 Docket 50-293 Proposed Chance to Fire Protection Technical Soecifications

Reference:

Boston Edison Letter 84-047 dated 3/27/84

Dear Sir:

Pursuant to 10CFR50.90, Boston Edison Company (BECo) proposes revisions to Appendix A of Facility Operating License No. DPR-35. These revisions implement our previous referenced submittal on this subject and are described in Attachment A. For your convenience we have consolidated all the technical specification pages affected by these requests in Attachment B.

An application fee of one hundred and fifty dollars ($150.00) will be electronically mailed to your offices in accordance with the requirements of 10CFR Part 170.

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TAV/ns b Attachments g 1 signed original and 37 copies I cc: See next page l Commonwealth of Massachusetts)

County of Suffolk )

. . :. .. i Then personally appeared before me, Ralph G. Bird, who, being duly sworn,,141,:d '

l state that he is Senior Vice President - Nuclear of Boston Edison Companyd6J1d .. .

l that he is duly authorized to execute and file the submittal containedehey 4.O l

in thesubmittal name and

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areontrue behalf of Boston best of Edison Company and that the statementp*/ c<- .

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, U.S,. Nuclear Regulatory Commission Page 2 cc: U.S. Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19406 Senior NRC Resident Inspector Pilgrim Nuclear Power Station Mr. Robert M. Hallisey, Director Radiation Control Program Massachusetts Dept. of Public Health 150 Tremont Street F-7 Boston, MA 02111 1

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, , Page 1 ATTACHMENT A PROPOSED FIRE PROTECTION AMENDMENT TO TECHNICAL SPECIFICATIONS By various submittals, Boston Edison updated technical specifications reflecting modifications made to Pilgrim Nuclear Power Station as a result of Branch Technical Position APCSB 9.5-1. These included:

SECTION DESCRIPTION BECo Letter 3/4.12A Fire Detection Instrumentation 83.300 12/28/83 3/4.128 Fire Hater Supply System 83.282 11/16/83 3/4.12C Spray and/or Sprinkler System 83.282 11/16/83 3/4.12E Fire Hose Stations 83.282 11/10/83 3/4.12G Alternate Shutdown Panels 83.180 7/11/83 Attachment B incorporates all of the previously submitted changes to the above sections and new changes included in this submittal. All the changes including the previously submitted changes to the existing Technical Specifications are identified by a vertical bar. The changes identified since the previous submittals are listed below:

PROPOSED CHANGES AND REASONS FOR CHANGE

1. Section 3/4.12A: Fire Detection Instrumentation

a. 3.12.A.c: Reference to Section 3.12.E is changed to 3.12.D to reflect correct identification of the Technical Specifications Sections.

b. Table 3.12-1:

The proposed change reduces the minimum acceptable number of operable detectors in each detection zone to 51% of the total number of detectors in the detection zone. No more than 2 adjacent detectors are permitted to be out of service. The change will benefit PNPS in reducing the annual maintenance without any reduction in System adequacy or plant safety. ,

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2. Section 3/4.128: Fire Hater Supply System

a. 3.12.B.3: Reference to Section 3.12.D is changed to Section 3.12.E to reflect correct identification of the Technical Specifications Sections.

b. 3.12.B.b is revised to correct ambiguity in the " Action" Statements.

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3. Section 3/4.12.C: Spray and/or Sprinkler Systems

a. 3.12.C:

The following wet pipe sprinkler systems are added

1) Reactor Building Elev. 23'-0" North Side Het Pipe Sprinkler System

2) Reactor Building Elev. 51'-0" North and South Side Het Pipe Sprinkler Systems

3) Reactor Auxiliary Building Hater Treatment Area Het Pipe Sprinkler System

4) Health Physics Access Area Wet Pipe Sprinkler System These systems are added as a result of the 10CFR50, Appendix R compliance effort.

Standby Gas Treatment System Water Spray System is deleted from 3.12C, and items are renumbered to reflect the additions and deletion.

b. 3.12.C.b: Reference to 3.12.C.5 is changed to 3.12.C.4 to reflect the correct item number in this section,

c. The Exception note associated with 3.12.C is revised to add the following:

"If a zone of the fire area is so designated, one of the following shall apply: 1) If the zone is adequately inspectable from a non-High Radiation Area, the continuous fire watch shall be located in the non-High Radiation Area, or 2) If (1) cannot be accomplished, a fire watch patrol shall enter the High Radiation Area once every eight (8) hours."

4. Section 3/4.12.E: Fire Hose Stations

a. 4.12 E.3.b.2: NFPA No. 198-1972 is changed to NFPA No. 1962-1979

b. 4.12.E.3.b.3: Reference to 4.12.D.3.b is changed to 4.12.E.3.b to reflect the correct Technical Specifications section numbers

5. Section 3/4.12.G: Alternate Shutdown Panels

a. 3.12.G is revised to add a new item 3.12.G.I b to add.us the operability of alternative shutdown panels which are taken credit for as part of the safe shutdown analysis in the event of a fire in areas outside the CSR and CR.

b. 4.12.G.6 revises the test requirement to start and load the diesel generator to reflect only a starting test. The requirement for loading the diesel is deleted.

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Page 3 Safety Evaluations and Determination of No Sionificant Hazards Consideration The Code of Federal Reaulations,10CFR50.91 requires that at the time a licensee requests an amendment, it must provide to the Commission its analysis, using the standards in 10CFR50.92, about the issue of no significant hazards consideration. Therefore, in accordance with 10CFR50.91 and 10CFR50.92 the following analysis has been performed:

A. Section 3/4.12 A Fire Detection Instrumentation and Table 3.12.1

1. The operation of Pilgrim Station, in accordance witii the proposed amendment, will not involve a significant increase in the probability or consequences of an accident previously evaluated.

The proposed amendment constitutes changes that address the various fire detection instrumentation added as a result of BTP APCSB 9.5-1. This addition to the technical specification is considered unlikely to involve a significant hazards consideration because the change only adds further restriction to plant operation not presently included in the technical specification.

The change in Table 3.12.1 for the Fire Detection Instruments, revising the minimum acceptable number of operable detectors to 517. of the existing smoke detectors in any detection zone, will not involve a significant increase in the probability or consequences of a fire in any fire area where smoke detection instruments are installed and maintained.

The analysis which determines the probability or consequences of accidents involving the fire detection instrumentation as listed in the proposed Table 3.12.1 is based on the availability of operable smoke detectors in any detection system. No more than 2 adjacent detectors are permitted to be out of service in a detection zone. Based on the analysis performed, it is concluded that for a conservative situation involving two redundant fire areas in the Reactor Building separated by 20 feet of open area, the operable 3rd detector in the area of fire will detect the fire in a matter of a few minutes, while the fire spread will take hours before affecting the redundant fire area.

Fire areas containing redundant safe shutdown systems are typically separated by fire barriers rated commensurate with the fire hazards expected in those areas. For areas where redundant systems are not separated by a rated barrier, such as the northside of the Reactor Building (elev. 23'-0" and 51'-0"), a wet pipe sprinkler system is provided to assure that a fire affecting one system will be extinguished prior to that fire impacting the redundant system.

Other aspects of Pilgrim's defense-in-depth fire protection design such as strictly controlled ignition sources, closer than normal detector spacing, and redundant detector operation principles, justifies the reduction of operable smoke detectors. Also, the detection system at Pilgrim consists

' . Page 4 of ionization and photoelectric detectors. This mix of detection is designed to provide total coverage of the floor areas by each type of detector, thereby providing early detection for all types of fires.

The reduction of operable detectors as proposed in the amendment will not increase the probability or consequences of fires previously analyzed.

2. The operation of Pilgrim Station, in accordance with the proposed amendment, will not " create the possibility of a new or different kind of accident from any accident previously evaluated."

Reducing the minimum number of operable detectors to 51% of the total detectors in a zone does not alter the detector system operation or the surveillances required for system operation. The status and integrity of the system will still assure that any fire is detected in sufficient time to preclude damage to any redundant system.

No new combustibles (fixed or transient) from the previously analyzed fire situations are assumed under this amendment, and no new combustibles products are created. The area configurations are not altered, nor are plant systems (H'/AC etc.) which affect a fire scenario changed. Hence, the proposed change will not create the possibility of a new or different kind of fire from any previously analyzed.

3. The operation of Pilgrim Station, in accordance with the proposed amendment, will not " involve a significant reduction in the margin of safety."

The detection system at PNPS is laid out on a grid of approximately 20 feet on center, which is conservative. In many areas detectors are spaced at intervals less than 20 feet, covering even less square feet (approximately 300 sq. feet) per detector, without consideration for the overlapping of sensing area coverages. The ceiling heights in most of the safety related areas in the Reactor Building are approximately 17 feet and a few are approximately 30 feet. Most of the combustibles of concern are the electric cables in cable trays which are usually more than 10' above the floor.

The building HVAC system provides approximately 4 air exchanges per hour, assuring desired air movement throughout the safety related fire areas.

These air exchanges reduce the concern for localized air stratification possibilities.

Het pipe sprinkler systems are provided on the north side of the Reactor Building (elev. 23'-0" and 51'-0") in lieu of a rated fire barrier separating redundant fire zones. These sprinkler systems assure that redundant systems are protected from any fire originating in either side of the sprinkler system. In other locations, rated fire barriers separate redundant fire areas.

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, . Page 5 Using the ceiling height and spacing guidelines of NFPA-72E, transient fires or combustible liquid fires could be effectively detected by smoke detectors at a spacing of 40 feet. This is in excess of the maximum spacing at PNPS, even with the reduced level considered in this request.

The reduced number of operable detectors still covers the same detection area (s) that other facilities have used for their designated spacing (ie) 30 feet.

In addition, for a fire involving one of the redundant fire areas in the Reactor Building the operable third detector in the area of fire will detect the fire ahead of the time it would take for the fire to spread to the redundant fire area, ie: 20 feet away and no rated barrier separating the two fire areas. At PNPS, as an added protection, wet pipe sprinkler systems are being installed at these locations.

Hence the proposed amendment will not involve a significant reduction in the margin of safety.

B. Section 3/4.12C Sorav and/or Sorinkler System The proposed amendment involves the addition of four new wet pipe sprinkler systems to Section 3.12C as a result of plant design changes to meet Appendix R requirements. This addition to the technical specifications is considered unlikely to involve a significant hazards consideration as the change only adds restrictions to plant operation.

These restrictions are not presently included in the technical specifications.

The proposed amendment will not involve a significant reduction in the margin of safety because there is no safety related equipment located at the locations where the wet pipe sprinkler systems are being installed.

Provisions are made to prevent the discharged water from impacting any safety equipment. '

The proposed amendment also includes the deletion of the Standby Gas Treatment System (SGTS) water spray system from the technical specifications. A significant hazards consideration analysis to support this change is given below.

1. The operation of Pilgrim Station in accordance with the proposed amendment I will not " involve a significant increase in the probability of consequences of an accident."

The proposed amendment which deletes the standby gas treatment system water spray system from the technical specifications will not significantly increase the probability or consequences of a charcoal fire.

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The charcoal filters in the SGTS are designed to adsorb and retain radioactive material from primary and secondary containment. The radioactive materials release decay heat while entrained by the charcoal.

This decay heat must be removed for two reasons:

1. The charcoal will de-adsorb radioactive materials at temperatures l between 200* and 300*F.

l 2. The charcoal will ignite at above 670*F.

In order to achieve decay heat removal, the design specificat' ion of the SGTS initially utilized a water spray system. However, when the equipment l was installed as an atmospheric cleanup system, an additional cooling i

method was provided by a cross connection air cooling feature. The air cooling system as designed will prevent unacceptable decay heat build up.

The temperature within the charcoal will not reach 670'. Hence no ignition of the charcoal will occur.

In addition, the deletion of the SGTS water spray system from the technical specifications will not impact environments outside the SGTS Train as there are protective devices such as air space, sheet metal and concrete blocks protecting each SGTS Train. Furthermore, there are no combustible materials normally in the area and administrative controls, including a locked door, are in place to eliminate the possibility of transient combustibles being brought into the area.

! It can therefore be concluded that the proposed amendment deleting the l water spray system will not involve a significant increase in the probability of a fire in the charcoal or outside the SGTS Train.

2. The operation of Pilgrim Station in accordance with the proposed amendment I will not " create the possibility of a new or different kind of accident I from any accident previously evaluated."

The existing technical specifications require maintaining the water spray system in the SGTS for fire protection purposes related to a projected l fire in the charcoal filter train.

As stated in Item 1, the SGTS Hater Spray System is neither necessary for l decay heat removal nor for fire protection purposes. This is further supported by a review of the original PNPS FSAR Section 10.8. The review concludes that the water spray system was not credited as a fire protection system for the SGTS. Instead, the fire protection was in the form of general plant fire protection features which included 1) control l of ignition sources, 2) limited combustible materials, 3) portable fire l extinguishers, 4) local hose reels and 5) an on-site fire brigade. None l of these features have been altered or removed as a result of the proposed l amendment.

Hence the proposed amendment will not have any impact on the operation of l the SGTS and will not create the possibility of a new or different kind of accident.

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3. The operation of Pilgrim station in accordance with the proposed amendment will not involve a significant reduction in the margin of safety.

The proposed amendment deletes the SGTS deluge system from the Technical Specifications as the evaluation has concluded that it does not contribute to the operation of the SGTS. The deluge system has both decay heat removal and fire suppression attributes. However, neither attribute is necessary to assure a functional SGTS system.

The single failure proof cross connection air flow cooling system will provide the decay heat removal function. As a result, the temperature of the charcoal is always kept far below the 670*F which is the ignition temperature of the charcoal. Hence removing the deluge system from the Technical Specifications will not create a situation where the margin of

, safety is reduced as the SGTS operation stays the same as before the deletion of the deluge system.

This proposed amendment has been reviewed and approved by the Ope' rations Review Committee and reviewed by the Nuclear Safety Review and Audit Committee, t Schedule of Chanag This change will become effective within 30 days after BECo's receipt of approval by NRC.