ML20215C804
| ML20215C804 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 06/10/1987 |
| From: | NEBRASKA PUBLIC POWER DISTRICT |
| To: | |
| Shared Package | |
| ML20215C774 | List: |
| References | |
| NUDOCS 8706180253 | |
| Download: ML20215C804 (25) | |
Text
E 1
l
.6 6
Attachmsnt 1 Revised Technical Specifications for Fire Protection i
Revised'Page:
224 This change is a clarification of the Safety Review and Audit Board fire i
protection audit requirements.
The revised requirements conform to the
)
requirements in the BWR/4 Standard Technical Specifications.
Evaluation of this Revision with Respect to 10CFR50.92 l
A.
The enclosed Technical Specification change is judged to involve no i
significant hazards based on the following:
i 1.
Does the proposed license amendment involve a significant increase j
in the probability or consequences of an accident previously evaluated?
Evaluation:
j i
The purpose of the fire protection program is to establish the fire detection and suppression equipment, procedures, and qualified personnel necessary to minimize the. effects of a fire on equipment important to safety.
The objectives of the fire protection' program are:
- 1) to prevent fires from starting, 2) to detect rapidly, control and extinguish promptly those fires that do occur; and 3) to provide protection for structures, systems, and components important to safety so that a fire that is not promptly extinguished by the
)
fire suppression activities will not prevent the safe shutdown of the plant.
The proposed changes would clarify the requirements for Safety Review and Audit Board (SRAB) fire protection audits.
These SRAB j
audits evaluate the effectiveness of the administrative controls and fire protection equipment, as well as program implementation.
The proposed changes to the audit requirements do not reduce the scope, frequency or personnel qualifications required.
The proposed changes are for clarification and conform to the BWR Standard Technical Specifications.
These changes are purely administrative and, therefore, do not increase the probability or consequences of an accident.
2.
Does the proposed license amendment create the possibility for a new or different kind of accident from any accident previously evaluated?
Evaluation:
The proposed change clarifies the wording of the existing fire protection audit requirements for the Safety Review and Audit Board (SRAB).
No changes to audit frequency, scope, or personnel qualification are proposed.
Therefore, this change will not impact the effectiveness of the SRAB fire protection audits.
Also, the effectiveness of the fire protection program will not be affected, 8706180253 870610
~
hDR ADOCK 0500029s PDR
4 Att chmant 1 since regular evaluation of the program will continue and no changes are proposed to fire detection or fire fighting capabilities.
This change is for clarification and docs not create the possibility for -
any new or different kind of accident.
3.
Does the proposed amendment involve a significant reduction in a margin of safety?
Evaluation:
This proposed change clarifies fire protection audit requirements.
There are no changes to fire protection equipment, procedures or personnel. 'Therefore, the ability to detect and extinguish fires is not affected.
The proposed changes do. not reduce the scope, frequency, or personnel qualifications for fire protection audits.
Therefore, the evaluation of the effectiveness of the fire protection program is not adversely affected.
This change does not involve any reduction in a margin of safety.
B.
Additional basis for proposed no significant hazards - consideration determination:
The commission has provided guidance concerning the application of the standards for determining whether a significant hazards consideration exists by providing certain examples (48CFR14870).
The examples include
"(i) a purely administrative change."
It is the District's belief that the proposed change is encompassed by the above example, i.e.,
there will be no change in requirements as a result of this proposed change.
2-N.
6.2 (cont'd) a.
Verification of compliance with internal rules, procedures i
(for example:
normal, off-normal, emergency, operating, maintenance, surveillance, - test, and radiation control procedures) and applicable license conditions at least once per 24 months.
j j
b.
The training, qualification, and performance-of the-operating staff at least once per 24 months.
c.
The Emergency Plan and. implementing procedures at least once per 12 months.
d.
The Security Plan and implementing procedures at least-once per 12 months.
e.
The fire protection programmatic-controls including the implementing procedures at least once per 24 months by qualified licensee personnel; f.
The protection equipment and program implementation at least once per 12 months utilizing either a qualified' off-site licensee fire protection engineer (s) or an outside independent fire protection consultant.
An outside independent fire protection consultant shall be utilized at least every third year.
g.
Deleted.
h.
The Radiological Environmental Monitoring Program and the Offsite Dose Assessment Manual ~with their implementing procedures at least once every 24 months.
i 1
-224-I i
Attachm:nt 2 Revised Technical Specifications for Fire Protection Revised Page:
216h, 216m There are five changes proposed on pages 216h and 216m.
First, the applicability of operability and surveillance requirements for Fire Barriers and Penetration Fire Seals is changed from all barriers and seals, to only those that protect fire areas containing safe shutdown systems, equipment or components.
This is consistent with the safety objective of the fire protection program - to minimize the effects of a fire on equipment important to safety.
]
l The second proposed change is to change the phrase " fire barrier" to " fire area barrier" in all locations on pages 216h and 216m.
This is an editorial change to clarify the wording and to be consistent with the Cooper Nuclear Station Fire Hazards Analysis.
1 The third proposed change is to allow the use of an hourly fire watch patrol when the integrity of a fire area barrier or penetration fire seal cannot be maintained, provided the operability of fire detectors on at least one side of the nonfunctional barrier can be verified.
This is consistent with the Standard Technical Specifications.
)
i The fourth change is to define Fire Area Barriers on page 216m.
This is an administrative change, purely for clarification.
The final proposed change would delete extraneous-bases for the Halon System.
These bases do not support any specification in Section 3.0 or 4.0, and are, therefore, being eliminated.
Evaluation of this Revision with Respect to 10CFR50.92 A.
The enclosed Technical Specification change is judged to involve no significant hazards based on the following:
1.
Does the proposed license amendment involve a significant increase in the probability or consequences of an accident previously evaluated?
Evaluation:
a.
The proposed change would revise the applicability of the operability and surveillance requirements for Fire Barriers and Penetration Seals from all to only those protecting Fire Areas containing safe shutdown equipment.
This change would eliminate the need to maintain the integrity or inspect fire area barriers or penetration fire seals that do not protect any safe shutdown equipment.
The fire protection program has as it's objectives:
to prevent fires from starting; to detect rapidly, control and extinguish promptly those fires that do occur; and to protect equipment important to safety so that a fire that is not promptly extinguished by fire suppression activities will not prevent the safe shutdown 1
m
f Attachmsnt 2 of the plant.
The proposed change does not increase the probability-of a fire starting, since this'is a function of z
amount and location. of combustible materials and the presence
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of an ignition source.
Also,.this-proposed change will not
]
affect the ability to detect and extinguish. fires. promptly.
1 This is controlled by detection and suppression equipment, advanced planning and personnel training and availability..
Finally, the proposed change will not affect the ability. to protect equipment important to safety.
In fact, this change focuses the operability and surveillance requirements on only-those fire area barriers and penetration fire seals that do protect safe shutdown equipment, rather than.. all fire area f
barriers and penetration seals. _ This fulfills the objective of the fire protection program and is. consistent with the' intent of. the Standard Technical Specifications.. Those fire area barriers and' penetration fire sealsLthat do not' protect fire-areas containing safe shutdown equipment cannot increase the probability or consequences of an accident, since fires in these areas cannot' impact the ability to safely shut down'and cool down the plant.
Although this change does slightly increase ~ the_ prob' ability that a fire could spread into adj acent areas before being extinguished, it does not increase the probability of damaging any safe shutdown equipment.
Therefore, eliminating the operability and surveillance requirements. for those-fire ' area barriers and penetration fire seals that don't protect any. safe shutdown equipment does not increase the probability or:
consequences of an accident.
This change, therefore, does not increase the probability or consequences of an accident.
b.
This proposed change would. retitle " fire barriers" to " fire area barriers." This change-is purely editorial in nature,_to be consistent throughout the fire protection program.
This change bs no affect on the. areas of the plant protected by fire dc.
M ion & J suppression equipment and no. affect on fire i
fighting methodologies.
Since this is strictly a title change, there is no increase in the probability or consequences-of an accident previously evaluated, c.
This proposed change will allow the use of an hourly fire watch patrol when the integrity of a fire barrier or penetration seal cannot be assured, provided the operability of fire _ detectors-on at least one side of the nonfunctional barrier can be verified.
The current requirement is for a continuous fire watch when the integrity of a fire barrier or penetration seal cannot be maintained.
The net. result of an hourly fire patrol and operable fire detectors instead of a continuous fire watch I
is not judged to be a significant. increase in the probability or consequences of an accident.
The purpose of fire barriers and penetration seals is to confine or retard the spread of fires, to minimize the
-)
possibility of a single fire rapidly involving several areas of-the facility prior to detection and extinguishment.
When the i
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Attachmsnt"2 q
integrity. of a fire barrier or penetration seal cannot be maintained, some compensatory action must be taken to ensure that any fire which does occur in the area would be detected before it spread to. adjacent areas. 'While the use of.an hourly fire patrol instead~of a~ continuous fire watch may result in a slight increase in the probability of an. accident as a result of a fire, this increase is offset by the requirement.to verify
-operable fire detectors on at least one side L of the nonfunctional barrier.
The net result will ' be. continuous monitoring for fires. by the operable fire detectors ~ and an additional hourly fire patrol to provide 'a visual. check for fires.
This change is considered not ' to result-in a.
- 3 1
significant increase in the probability or consequences of an accident'due to a fire.
d.
The bases contain statements concerning the Halon: System which do not support any requirements of Section 3.0 or 4.0 of the Technical Specifications.
Therefore, the proposed. change eliminates these extraneous. bases.
This change is purely administrative.
No changes to the Halon System hardware or operation are proposed.
Therefore.,.this. change does not involve an increase in the probability.or. consequences of an accident previously evaluated.
J e.
A definition of " fire area barriers" is contained in this-proposed change, to identify those components of construction to be included when following the operability and surveillance requirements. This addition is for clarification and is purely administrative.
There is no change in fire detection or fire fighting capability and no change from the'struetures currently considered to be fire area barriers. Those components that are taken credit for in the Cooper Nuclear Station Fire Hazards Analysis as fire area barriers ~ are included in the definition.
This change clarifies that each of these components must be considered and is subject to the operability and' surveillance requirements.
This - clarification does not increase the probability or consequences of any accident previously evaluated.
2.
Does the proposed license amendment create.the possibility for a new or different kind of accident from any accident previously evaluated?
Evaluation:
i a.
This proposed change does not change the nature of the 'esign l
d basis fire in-any fire area and does. not change the fire detection or fire ' suppression equipment for detecting and extinguishing a fire in any area.
Further, this change has no
.I affect on personnel response' or fire fighting methods.
This proposed change could have an affect on the ability to retard the spread of fires in fire areas that do not'contain' safe shutdown equipment. However, since this. change does not affect the ability to safely shut down the plant and maintain it in a safe shutdown condition, the change does not create the possibility of any new or different kind of accident.
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Attachm:nt 2 l
l b.
This proposed change retitles " fire barriers" to fire area j
barriers." This has no affect on the design. basis fire in any fire area, no affect on the combustible loading in any area, no affect on fire protection equipment, personnel or methodologies.
This change is purely editorial and, therefore, does not create the possibility of any new or different kind of accident.
1 c.
This proposed change only permits the use of an hourly fire watch patrol instead of a continuous fire watch,'provided fire detectors are operable on at least one side of an inoperable-j fire barrier.
This change does not alter the nature of the I
design basis fire, the amount of combustible material in an area or the mode of initiation of a fire.
The only affect this change can have on an accident is the potential to allow a fire to propagate from one area to another through an inoperable fire barrier.
This could lead to damage to unassociated f
equipment important to safety in two adjacent areas leading to j
a loss of equipment. important to safety not ' previously l
evaluated.
The combination of operable fire detectors and an j
hourly fire patrol is considered to provide protection against fire propagation equivalent to a continuous fire watch.
Therefore, this change does not create the possibility for a new or different kind of accident.
1 s
d.
The removal of extraneous bases for the Halon System is purely administrative.
This proposed change will have no affect on the design basis fire or the method of detecting or fighting a fire.
This change is only for clarification and streamlining and does not create the possibility for a new or different kind of accident.
)
i l
e.
The proposed addition of a definition of fire area barrier clarifies the components that must be considered subject to the operability and surveillance requirements.
This does not constitute a change in current practice, but is instead clarification of the Technical Specification Bases.
This definition will not alter the design basis fire or the function i
of the fire area barriers in any way.
This change will not create the possibility of a new or different kind of accident from any accident previously evaluated.
3.
Does the proposed amendment involve a significant reduction in a margin of safety?
Evaluation:
a.
The proposed change would eliminate operability and surveillance requirements for fire area barriers and penetration fire seals that do not protect fire areas containing safe shutdown equipment.
This change could slightly affect the propagation of a fire in fire areas that do not contain equipment important to safety.
- However, the operability and surveillance requirements would remain in effect for, and be focused on, those fire area barriers and 4-
Attachm:nt 2 i
penetration fire seals that do protect equipment important to safety.
It is the ultimate objective of the fire protection program to ensure that the plant can be safely shut down, even if a fire is not promptly extinguished.
This change has no j
1 affect on the margin of safety for meeting this objective.
Therefore, this change does.not involve a significant reduction in a margin of safety.
b.
This proposed change would retitle " fire barriers" to " fire area barriers."
The change - is for consistency with the Fire Hazards Analysis and is purely editorial.
This has no affect on the ability to detect and extinguish fires, prevent the spread of fires, or protect equipment important to safety from -
the affects of fires.
Since this change is purely editorial, j
it does not involve a reduction in the margin of safety.
c.
The proposed change to an hourly fire watch patrol, provided fire detectors are operable on at least one side of an inoperable fire barrier, does not reduce any margin of safety.
The combination of continuous fire detection and hourly patrols is considered to provide a margin of safety against fire.
l propagation equivalent to a continuous fire watch.
Therefore, this change does not reduce any margin of safety.
d.
The proposed elimination of Halon System bases will not affect any margin of safety.
The fire suppression capability of the Halon System will not be affected since no hardware changes or changes in mode of operation are proposed.
This change only eliminates extraneous bases, and therefore, does not affect any J
margin of safety.
e.
The proposed addition of a definition for fire area barriers has no affect on any margin of safety.
This addition specifies which structures constitute a fire area barrier, and are i
therefore subject to fire area barrier operability and surveillance requirements.
This has no affect on the ability to detect or fight fires.
The fire area barriers will continue to retard the spread of fires and will continue to be subject to routine inspections.
This change has no effect on any margin of safety.
B.
Additional basis for proposed no significant hazards consideration determination:
The commission has provided guidance concerning the application of the standards for determining whether a significant hazards consideration exists by providing certain examples (48CFR14870).
The examples include
"(vi) a change which may result in some increase to the probability ior consequences of a previously-analyzed accident But where the results of the change are clearly within all acceptable criteria.
It is the District's belief that the proposed change to an hourly fire watch patrol is encompassed by the above example, i.e, the clear acceptability of the change is demonstrated by the use of similar criteria in the Standard Technical Specifications.
Retitling " fire barriers" to " fire area barriers," the elimination of the extraneous Halon' System bases and the addition of a definition of fire barriers fit within the example:
"(i) a purely administrative change." -
i
d 9
i LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS l
l b)
Conducting a hose hydrostatic test at a pressure at least 50 psig greater than the maximum.
pressure available at that hose station.
l 3.19 FIRE AREA BARRIERS AND PENETRATION 4.19 FIRE AREA BARRIERS AND PENETRATION 4
FIRE SEALS FIRE SEALS
)
APPLICABILITY APPLICABILITY
' Applies to the integrity of Fire Area Applies to the integrity of Fire Area Barriers and Penetration Fire Seals Barriers and Penetration Fire Seals protecting Fire Areas containing safe protecting Fire Areas containing safe shutdown systems, equipment, or shutdown systems, equipment, or components.
components.
OBJECTIVE To assure the integrity of Fire Area Barriers and Penetration Fire Seals protecting Fire Areas containing safe shutdown systems, equipment, or components.
SPECIFICATIONS SPECIFICATIONS l
l A.
Fire Area Barrier and Penetration A.
Fire Area Barriers and Penetration Fire Seal integrity shall be Fire Seals shall be verified to maintained, be functional by:
B.
If the requirement of 3.19.A cannot 1.
At least every 18 months visually be met, a continuous fire watch shall inspect each side of each Fire be established on at least I side of Area Barrier and Penetration Fire the penetration within I hour, or Seal (where possible), and verify the operability of fire detectors on at least one side of the 2.
A visual inspection of a Fire AreaBarrierandPenetrationFirel non-functional fire barrier and establish an hourly fire watch Seal prior to declaring a patrol.
penetration or fire area barrier l functional following repairs or maintenance.
-216h-
3.14-3.19/4.14-4.19 BASES 3.14/4.14 FIRE DETECTION INSTRUMENTATION OPERABILITY of the fire detection instrumentation ensures that_ adequate warning capability is available for the prompt detection of fires. This cap-ability is required in order to detect and locate fires in their early stages.
Prompt detection of fires will reduce the potential for damage to safety related equipment and is an integral element in the overall facility fire protection program.
In the event that a portion of the fire detection instrumentation is in-operable, the establishment of frequent fire patrols in the affected areas is required to provide detection capability until the inoperable instrumentation is returned to service.
3.15-3.18/4.15-4.18 FIRE SUPPRESSION SYSTEMS THE OPERABILITY of the fire suppression systems ensures that adequate fire suppression capability is available to confine and extinguish fires occurring in any portion of the facility where safety related equipment is located.
The fire suppression system consists of the water system, spray and/or sprinklers, CO '
2 Halon 1301, and fire hose stations. The collective capability of the fire suppression systems is adequate to minimize potential damage to safety related equipment and is a major element in the facility fire protection program. The Halon Fire Suppression System consists of two storage tanks, each exceeding the design capacity required for extinguishment of a fire in the service water pump room in accordance with the National Fire Protection Association Standards.
In the event that portions of the fire suppression systems are inoperable, alternate backup fire fighting equipment is required to be made available in the affected areas until the affected equipment can be restored to service.
In the event the fire suppression water system becomes inoperable, im-mediate corrective measures must be taken since this system provides the major fire suppression capability of the plant. The requirement for twenty-four hour report to the Commission provides for prompt evaluation of the acceptability of the corrective measures to provide adequate fire suppression capability for the continued protection of the nuclear plant.
3.19/4.19 FIRE AREA BARRIER PENETRATION SEALS The functional integrity of the fire area barrier penetration seals ensures that fires will be confined or adequately retarded f rom spreading to adjacent portions of the facility. This design feature minimizes the possibility of a single fire rapidly involving several areas of the facility prior to detection and extinguish-ment. The fire area barrier penetration seals are a passive element in the facility l
fire protection program and are subject to periodic inspections.
During periods of time when the seals are not functional, a continuous fire watch is required to be maintained in the vicinity of the affected seal, or an hourly fire watch patrol can be established once the operability of a fire detector on at least one side of the affected fire barrier has been verified.
A watch or patrol will be maintained until the seal is restored to functional status.
Fire area barriers are those components of construction which establish the boundaries of the fire areas described in the CNS Fire Hazards Analysis (current revision). They consist of those components including walls, floors, and supports (Beams, joists, columns), penetration seals or closures, fire doors, and fire dampers that are rated by approving laboratories in hours of resistance to fire and are used to prevent the spread of fire.
Fire area barrier penetration seals include cable penetration barriers, fire j
doors, and fire dampers.
-216m-
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.1 i
Revised Technical Specifications for-Fire Protection Revised Page:
216b Section 4.14.B of the CNS Technical Specifications uses the terminology'"NFPA Code" regarding the' supervised circuits associated with the fire ; detector -
j alarms.
The correct terminology is "NFPA Standard" and page 216b is being
)
revised to reflect this.
The same specification also refers to " Class B J
supervised circuits supervision" with the word supervision,being redundant.
The District proposes to eliminate thisLword to avoid confusion. 'At the time the specification was written,. the ' District had only1 Class B supervised
'l circuits associated with the detector alarms. A Class B circuit has just one wire loop.between the detector and alarm box, so.that while'any discontinuity in the circuit would give a trouble alarm, the alarm function would.be lost.
Recently, the District installed a Class A supervised circuit in the Service Water Pump Room (SWPR) for the Appendix R program.
A Class A supervised circuit has two wire loops between the detector and alarm box, so that a break in one loop would still give a trouble alarm, yet the_ detection / alarm' function will still be available.
The District proposes to revise Specification 4.14.B
-l to include Class A circuits as well as Class B.
1 Evaluation of this Revision with Respect to 10CFR50.92 j
A.
The enclosed Technical Specification change is judged to involve no significant hazards based on the following:
1.
Does the proposed license amendment involve a significant increase in the probability or consequences of an accident previously evaluated?
Evaluation:
b The accident under consideration here is a station fire which, J
through material damage or rendering spaces.
equipment and inaccessible would prevent the carrying out of mitigating activities in coping with one of the design basis accidents ' discussed in.
Section XIV of the Cooper Nuclear Station Updated Safety ' Analysis Report Material damage due to a fire in and of-itself could also cause equipment to perform in a deleterious manner that could place
- the plant in an unanalyzed condition.
The proposed change will perform the following to Specification'4.14.B:
a.
Change the phrase "NFPA Code" to "NFPA Standard."
b.
Delete the redundant word " supervision" in the first sentence of 4.14.B.
c.
Add Class A supervised circuits.
The changes above will not significantly increase the probability of the occurrence of a fire from that previously evaluated since.
Changes #1 and #2 are administrative in nature and Change #3 will add no significant amount of combustibles or fire sources to the <
9 Attachmsnt 3-plant.
Changes'.#1 and #2 will have no effect on the consequences of.
a fire due'to their administrative nature. The addition of Class A supervised circuits will potentially1 reduce the consequences'due to the. higher fire detector reliability it.provides over the. Class B circuits.
The proposed amendment will not. involve a significant increase in. the probability or' consequences of an accident previously evaluated.
2.
Does the proposed. license amendment create the possibility.for a new or different kind of accident from any accident previously-evaluated?
Evaluation:
- Two of the proposed changes are administrative ~in-nature and will not make any changes.to the present mode of' operation.
The Class A circuits are similar in function to the previously evaluated Class B detector circuits ' approved in Amendment 42 to the CNS Facility Operating License on February 24,.1978.
The proposed amendment will-not create the possibility for a new or different kind of accident from any accident previously evaluated.
3.
Does the proposed amendment involve' a significant. reduction'in'a margin of safety?
Evaluation:
The proposed amendment concerns the Fire Protection System at CNS and is administrative in nature or adds. Class A supervision:
circuitry which is more reliable than the present Class B circuitry.
The amendment involves no change in any plant operating setpoint and does not involve a significant reduction in a margin of safety..
8 f
. LIMITING CONDITIONS FOR OPERATI0'N-SURVEILLANCE REQUIREMENTS J
' 3.14 FIRE DETECTION SYSTEM-4.14 FIRE DETECTION SYSTEM
' APPLICABILITY
-APPLICABILITY Applies to the operational. status of the Applies to the operational status of.the Fire Detection System.
- Fire Detection System.
OBJECTIVE
' To assure continuous automatic surveillance throughout the Main Plant.
SPECIFICATIONS
. SPECIFICATIONS A.-
The Fire Detection System instrumen-
'A.
Each detector.on Table 3.14 shallibe tation for each fire detection zone
' demonstrated operable every 6 months shown in Table 3.14 shall be
.by performance of a channel functional operable.
test.
B.
The NFPA Standard 72.D Class'A or B.
B.
With one or more of the. fire supervised circuits assoc 1'ated withi detection instrument (s) shown in the detector' alarms of each.oi the Table 3.14 inoperable:
above required: fire detection instruments shall be demonstrated-
- 1. 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 OPERABLE at'least once per 6 months.
watch patrol.co inspect the zone (s) with the inoperable instrument (s) at least once per hour, and
- 2. Restore the inoperable instrument (s) to OPERABLE status within 14 days or prepare and j
submit a Special Report to the
]
Commission within-the next 30 days outlining the action taken, the cause of the inoperability and the plans and schedule for restoring the 4.15 FIRE SUPPRESSION WATER SYSTEM instrument (s) to OPERABLE status.
APPLICABILITY 3.15 FIRE SUPPRESSION WATER SYSTEM Applies to the availability of-water APPLICABILITY for fire fighting purposes.
Applies to the availability of water for fire fighting purposes.
OBJECTIVE To assure a continuous operable water supply for fire fighting systems from 2 fire pumps.
-216b-
L l
-I Attachmont 4 Revised Technical Specifications for 4
Fire Protection Revised Page:
216d j
1 The current CNS Technical Specification Requirement for fire pump diesel. fuel storage tank inventory is 150 gallons (or 250 gallons when the clean water
)
fire protection system becomes operable).
This decision is controlled by a footnote on page 216d.
The clean water fire protection system has been j
operable for some time and the inventory requirement has been established-at 250 gallons.
This proposed change sets the requirement at 250 gallons and deletes the footnote.
Evaluation of this Revision with Respect to 10CFR50.92 A.
The enclosed Technical Specification change is judged to involve no q
significant hazards based on the following:
j 1.
Does the proposed license amendment involve a significant increase.
in the probability or consequences of an accident previously evaluated?
i Evaluation:
The current requirement states that the diesel fire pump fuel storage tank must contain at least 150 gallons, but shall contain 250 gallons when the clean water fire protection system becomes operable.
The clean water fire protection system has been operable for some time and the 250 gallon requirement has been in effect.
This change would eliminate the previously acceptable option of maintaining only 150 gallons of fuel.
Although there is a slight increase in the administrative limit on fuel in the tank (from the previous 150 gallon option), this does not significantly affect the design basis fire in the diesel oil tank room. The room is designed for the storage of oil and has the necessary detection and suppression equipment and construction to mitigate an oil fire involving the 250 gallons of oil.
Also, there are no safe shutdown systems in this room and fire propagation to adjacent zones will not be affected by this change.
This change is essentially editorial in that it eliminates an invalid option, since the 250 gallon requirement exists in the current technical specifications and has been in effect since the clean water fire protection system became operable.
Therefore, this change does not increase the probability or consequences of an accident previously evaluated.
2.
Does the proposed license amendment create the possibility for a new or different kind of accident from any accident previously evaluated?
Evaluation:
The proposed change does not affect any fire detection or fire suppression equipment or any fire fighting methods or personnel.
Although there is a slight increase in the minimum amount of combustible material in the diesel tank room, this has been Att: chm:nt 4 considered in the design of the room and the fire detection and suppression systems.
Further, the minimum 250 gallon requirement i
has been in effect for some time, since the clean water fire protection system became operable.
This proposed change eliminates the inadequate 150 gallon fuel storage option and, therefore, does
'j not create the possibility for a new or different kind of accident.
3.
Does the proposed amendment involve a significant reduction in a l
margin of safety?
j l
Evaluation:
This change does not affect the type of fire in the diesel oil' tank room or the method or equipment required to extinguish the design basis fire.
Although 250 gallons of oil would lead to a slightly longer fire, the room and suppression systems have been designed to accommodate this fire, since this requirement has been in effect for some time.
Therefore, since this is an editorial change to l
eliminate the 150 gallon option, it does not involve a significant j
reduction in a margin of safety.
I
{
B.
Additional basis for proposed no significant hazards consideration determination:
The commission has provided guidance concerning the application of the standards for determining whether a significant hazards consideration exists by providing certain examples (48CFR14870).
The examples include
"(i) a purely administrative change" and "(ii) a change that constitutes an additional limitation It is the District's belief that the i
proposed change is encompassed by the above examples.
. 1
p-I,,
f.'
1
'1
. LIMITING' CONDITIONS FOR OPERATION SURVEILLANCE' REQUIREMENTS-j-
1 4.15L(cont'd);
d c)
Cycling each valve <in the': flow path that?is not' testable during 1
plant operationthroughLat least one; complete. cycle or full travel,'and d)' ~ Verifying, that each.high' pres--
sure pump starts (sequentially)
't'o maintain.:the fire suppression j
. water system pressure > 65 psig' J
5.
At least once per 3 years by; performing:aiflow test of the; system in accordance:with Chapter'5,.
Section'll of:the Fire Protection Handbook,.14th Edition, published'by-il the National Fire Protection
-f
' Association. :
~
-6.
.The fire pump diesel engine.shall be
)
demonstrated OPERABLE::
a)
At least once per'.31' days by verifying; 1).
The fuel storage' tank contains at.least 250:
l gallons of fuel, and 2)
The diesel starts from ambient' conditions and operates for at least 15 minutes.
b)
At least once per 92 days by verifying that a sample.of diesel fuel from the fuel storage tank, obtained in accordance with ASTM-D270-65, is?
within the acceptable' limits specified.in Table 1 of ASTH-D975-74 for viscosity water content and sediment.
c)
At least once per:18 months b':
y 1).
Subjecting the diesel to an inspection in accordance.
.with procedures prepared in conjunction with its manufacturer's' recommendations for the class of service, and-
.q j
-216d-1
1 Attachmsnt 5 Revised Technical Specifications for Fire Protection Revised Pages:
iii, 2161 l
i I
Specification 3/4.20 for Yard Fire Hydrant and Hydrant Hose House was added to the CNS Technical Specification by License Amendment 66 as part of the closure for Appendix A to Branch Technical Position (BTP) 9.5-1.
This Specification addressed the fire protection system configuration which consisted at that time of two electric fire pumps and a diesel driven fire pump located in the Service Water Pump Room of the intake structure which also housed the four station service water pumps.
Concern was expressed in the CNS Fire Protection Safety Evaluation Report (contained in Amendment 56) that an unmitigated fire in the area would affect all the service water pumps and all three fire pumps.
Various design modifications were initiated to mitigate the effects of a fire in the Service Water Pump Room and Specification 3/4.20 was added by Amendment 66 as well.
l The fire protection configuration is now different than what was evaluated for conformance to Appendix A of BTP 9.5-1 in 1980.
CNS now has a separate fire pump house which contains an electric and diesel-driven fire pump located in separate rooms in addition to a jockey pump which maintains fire water header pressure.
A back-up electric fire pump which actuates at a lower header pressure than the other two pumps remains in the intake structure.
In addition, the Service Water Pump Room is now protected by a Halon 1301 Suppression System with additional detection capability which was added to CNS Technical Specifications in Amendment 98 to the Facility Operating License.
The District believes that with the present configuration and the addition of the Halon 1301 System the concerns that necessitated adding Sections 3/4.20 to the Technical Specifications have been removed and that these sections can be deleted from Technical Specifications.
Accordingly the District requests to revise the Technical Specifications by:
1.
Deleting Sections 3.20 and 4.20 on page 2161.
2.
Reflecting the above in the Table of Contents on page 111.
Evaluation of this Revision with Respect to 10CFR50.92 A.
The enclosed Technical Specification change is judged to involve no significant hazards based on the following:
1.
Does the proposed license amendment involve a significant increase in the probability or consequences of an accident previously evaluated?
Evaluation:
The accident under consideration here is a station fire in the intake structure which will damage or render inoperable the station service water pumps which are required to mitigate the effects of the design basis Loss of Coolant Accident, as analyzed in l
}
l 1 4
I l
l Attechmsnt 5 1
f Section XIV of the CNS Updated Safety Analysis Report and the fire water pumps.
The proposed amendment would delete Sections 3.20 and 4.20 from the current plant Technical Specifications. The objective i
of these sections is to- " assure continuous manual fire fighting capability for the fire water pumps and service water pumps in the Intake' Structure provided by the. existing yard fire hydrant, HT-1, and the associated hydrant hose house." The proposed amendment will not increase the probability of a fire occurring and instead could reduce the probability because the diesel driven fire pump with its attending combustibles, like fuel oil, is no longer present in the intake structure and so. no longer presents a potential source of fire.
The proposed amendment will not involve a significant increase in. the. consequences of a fire because the i
Halon 1301 Suppression System contained in Specifications 3/4.17 and i
the fire detectors listed in Table 3.14 provide adequate fire
)
protection to the Service Water Pump Room taking the place of yard fire hydrant HT-1 and its associated hydrant hose house.
i 2.
Does the proposed license amendment create the possibility for a new J
or different kind of accident from any accident previously evaluated?
Evaluation:
1 The proposed amendment will delete the Specification for a specific yard fire hydrant and hose house and does not permit any plant operation or practice that will create the possibility for a new or different kind of accident from any accident previously evaluated.
The safety-related components the hydrant, protects (the station service water pumps)' have been supplied with other means of protection and evaluated in the District's Appendix R program.
j 3.
Does the proposed amendment involve a significant reduction in a margin of safety?
Evaluation:
The proposed amendment does not affect any plant operating setpoint or allow new plant operating limits as it deletes a Limiting Condition for Operation and Surveillance Requirements on a yard fire hydrant.
The station service water pumps are protected by other means included in the Technical Specifications, so a significant reduction in a margin of safety is not involved.
2-
l TABLE OF CONTENTS (cont 'd).
Page No.
SURVEILLANCE-LIMITING CONDITIONS FOR OPERATION REQUIREMENTS 3.12 ADDITIONAL SAFETY RELATED PLANT CAPABILITIES 4.12 215 - 215f j
A.
Main Control Room Ventilation A
215 B.
Reactor Building Closed Cooling Water System B
215b j
C.
Service Water System C
215e l
D.
Battery Room Vent D
215c 3.13 RIVER LEVEL 4.13 H216 3.14 FIRE DETECTION SYSTEM 4.14 216b i
3.15 FIRE SUPPRESSION WATER SYSTEM 4.15 216b 1
3.16 SPRAY AND/OR SPRINKLER SYSTEM (FIRE PROTECTION) 4.16 216e 3.17 CARBON DIOXIDE AND liALON SYSTEMS 4.17 216f 3.18 FIRE Il0SE STATIONS 4.18
'216g 3.19 FIRE BARRIER PENETRATION FIRE SEALS 4.19 216h 3.20 DELETED 2161 3.21 ENVIRONMENTAL / RADIOLOGICAL EFFLUENTS 4.21 216n A.
Instrumentation 216n B.
Liquid Effluents 216x C.
Gaseous Effluents 216a4 D.
Effluent Dose Liquid / Gaseous 216all E.
Solid Radioactive Waste 216al2 F.
Monitoring Program 216a13 G.
Interlaboratory Comparison Program 216a20 3.22 SPECIAL TESTS / EXCEPTIONS 4.22 216bl A.
Shutdown Margin Demonstration 216bl B.
Training Startup 216b2 C.
Physics Tests 216b3 D.
Startup Test Program 216b3 J
5.0 MAJOR DESIGN FEATURES 5.1 Site Features 217 5.2 Reactor 217 5.3 Reactor Vessel 217 5.4 Containment 217 5.5 Fuel Storage 218 5.6 Seismic Design 218 5.7 Barge Traffic 218 6.0 ADMINISTRATIVE CONTROLS l
6.1 Organization' 219 6.1.1 Responsibility 219 6.1.2 Offsite 219 6.1.3 Plant Staff - Shift Complement 219 6.1.4 Plant Staff - Qualifications 219a
-111
- f..
LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS I
3.20 - DELETED.
4.20 - DELE'IED i
l 1
i I
l l
1 i
i 1
i
-2161-
Attachmsnt 6 Revised Technical Specifications for Fire Protection i
Revised Page:
216k1 l
A recent Appendix R audit at Cooper Nuclear Station indicated that an J
additional smoke detector was deemed necessary to assure an adequate level of fire protection exists in the auxiliary relay room.
Inspection j
Report 50-298/86-15 stated that with the only installed smoke detector, one beam pocket was left without adequate detection capability.
Accordingly, the District requests to add smoke detector FP-SD-15-10 to Table 3.14 on page 216k1 to address this concern.
j Evaluation of this Revision with Respect to 10CFR50.92 I
A.
The enclosed Technical Specification change is judged to involve no significant hazards based on the following:
1.
Does the proposed license amendment involve a significant increase in the probability or consequences of an accident previously evaluated?
Evaluation:
The accident under consideration here is a station fire which through material damage or rendering spaces and equipment inaccessible would prevent the carrying out of mitigating activities in coping with one of the design basis accidents discussed in Section XIV of the CNS Updated Safety Analysis Report.
Material damage due to a fire in and of itself could also cause equipment to perform in a deleterious manner that could place the plant in an unanalyzed condition. The proposed amendment will add a new smoke detector to the list of fire detectors required to be operable throughout the plant. As such, it will not involve an increase in the probability of a fire occurring and will potentially reduce the l
consequences of any fire in and around the auxiliary relay room by providing enhanced detection capability.
The proposed amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated.
2.
Does the proposed license amendment create the possibility for a new or different kind of accident from any accident previously evaluated?
Evaluation:
The proposed amendment will not allow any new mode of plant J
operation that will create the possibility for new or different kind of accident from any accident previously evaluated since it only involves the addition of a single smoke detector.
1
Attachm:nt 6 3.
Does the proposed amendment involve a significant reduction in a margin of safety?
Evaluation:
The proposed amendment does not affect any plant operating setpoint or allow new plant operating limits as it only adds a single smoke detector to the list of detectors required to be operable.
The proposed change does not involve a significant reduction in the margin of safety.
B.
Additional basis for proposed no significant' hazards consideration determination:
The commission has provided guidance concerning the application of the standards ' for determining whether a significant hazards consideration exists by providing certain examples (48CFR14870).
The examples include
"(ii) a change that constitutes an additional.
. control not presently included in the Technical Specifications.
." And "(vii) a change to make a license conform to changes in the regulations.
It is the District's belief that the proposed change is encompassed by the above
- examples, s
I I
I j
4 j
I INSTRUMENT LOCATION INSTRUMENT ID NO.
i 1
8 Safety Related Equipment not in Reactor Building RHR Service Water Booster Pumpsi FP-SD-14-3 Emergency Condensate Storage Tanks FP-SD-14-1 Service Water Pumps FP-SD-32-1 FP-SD-32-2 FP-SD-32-3 FP-SD-32-4 FP-FD-32-5 FP-FD-32-6 1
IISW-S0-Ill i
HSW-SD-Il2 I
llSW-Sl'-H3 IISW-SD-H4 l
.IISW-SD-H5 j
llSW-SD-H6 HSW-TD-Hil llSW-TD-lil 2
)
HSW-TD-H13
]
' HSW-TD-lil4 HSW-TD-H15 l
' llSW-TD-lil 6 4
9 Auxiliary Relay Room & Reactor Protection System Rooms 1
Auxiliary Relay Room FP-SD-15-9 1
FP-SD-15-10 l-Reactor Protection System Room 1A FP-SD-15-7
~j d
Reactor Protection System Room IB FP-SD-15-8 l
1 l
)
-216ki'-
I Attachmsnt 7 Revised Technical Specifications for Fire Protection Revised Page:
216j 1
A previous Technical Specification Amendment added smoke detectors and thermal I
detectors in the intake structure for the Service Water Pumps.
The acronym "SW" was not defined.
This proposed change would define "SW" as Service Water.
I Evaluation of this Revision with Respect to 10CFR50.92 i
A.
The enclosed Technical Specification change is judged to involve no significant hazards based on the following:
1.
Does the proposed license amendment involve a significant increase in the probability or consequences of an accident previously evaluated?
Evaluation:
The proposed change adds a definition to the legend on page 216j.
The acronym "SW" is defined as Service Water, since it is used in the Instrument ID No. column of Table 3.14.
This is strictly administrative and does not increase the probability or consequences l
of an accident previously evaluated, j
2.
Does the proposed license amendment create the possibility for a new or different kind of accident from any accident previously evaluated?
Evaluation:
The proposed change is purely administrative in that it defines an acronym used in an instrument number that was not previously
]
defined.
This does not create the possibility for a new or different kind of accident.
3.
Does the proposed amendment involve a significant reduction in a margin of safety?
Evaluation:
This proposed change adds a definition to clarify the use of an arronym.
This change is for consistency and, therefore, does not involve any reduction in a margin of safety.
B.
Additional basis for proposed no significant hazards consideration determination:
The commission has provided guidance concerning the application of the standards for determining whether a significant hazards consideration exists by providing certain examples (48CFR14870).
The examples include:
"(i) a purely administrative change."
It is the District's belief that the proposed change is encompassed by the above example.
1
' TABLE 3.14 i
FIRE DETECTION INSTRUMENTS INSTRUMENT ID NO.
I i
Reactor Building 859 6 881 Elev.
FD-TD-18-2 (Covers RCIC, FP-TD-18-3 Core Spray, RHR, and FP-TD-19-2 HPCI Pumps)
FP-TD-19-3 FP-TD-20-2 FP-TD-20-3 FP-TD-20-4 FP-TD-20-5 FP-TD-21-2 FP-TD-21-3 903 Elev.
FP-SD-18-1 FP-TD-18-4 FP-SD-19-1 FP-SD-20-1 FP-SD-21-1 931 Elev.
FP-SD-23-1 FP-SD-23-2 FP-SD-23-3 FP-SD-23-4 958 Elev.
FP-SD-24-1 FP-SD-24-2 FP-SD-24-3 FP-SD-24-4 FP-SD-24-5 FP-SD-24-6 976 Elev.
FP-SD-26-1 1
Covers Standby FP-SD-26-2 Liquid Control Pump and FP-SD-25-1 Standby Gas Treatment FP-SD-25-2 FP-SD-25-3 FP-SD '25-4 FP-TD-25-5 1001 Elev.
FP-TD-26-3 Also Fuel FP-TD-26-4 Storage Area FP-TD-25-6 FP-TD-25-7 Legend FP = Fire Protection H = Halon 1301 TD = Thermal Detector CO2 = Carbon Dioxide FD = Flame Detector DG = Diesel Generator SD = Smoke Detector 1st Digit Instr. ID No. = Zone SW = Service Water 2nd Digit Instr. ID No. = Instr. No.
-216j-I