ML20058M433

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Proposed Tech Specs Re Fire Protection
ML20058M433
Person / Time
Site: Sequoyah  Tennessee Valley Authority icon.png
Issue date: 09/28/1993
From:
TENNESSEE VALLEY AUTHORITY
To:
Shared Package
ML20058M426 List:
References
NUDOCS 9310050220
Download: ML20058M433 (27)


Text

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ENCLOSURE 1 i PROPOSED TECHNICAL SPECIFICATION CHANGE- ' t SEQUOYAH NUCLEAR PLANT UNITS 1 AND 2 DOCKET NOS. 50-327 AND 50-328 (TVA-SQN-TS-93-10) l b 4 LIST OF AFFECTED PAGES Unit 1 ., 3/4 3-58 3/4 7-31 ' 3/4 7-32 3/4 7-33 3/4 7-35 3/4 7-37 3/4 7-41 . B 3/4 7-7 i linit 2 .; 3/4 3-59 3/4 7-43  ; 3/4 7-44

3/4 7-45 i- 3/4 7-47 .

3/4 7-48 3/4 7-52 B 3/4 7-7 i r e a b

 +

1 4 O l 9310050220 930928 7 g% PDR -ADOCK 0500 g P ,

INSTRU. MENTATION FIRE DETECTION INSTRUMENTATION e LIMITING CONDITION FOR OPERATION i 3.3.3.8 As a minimum, the fire detection instrumentation for each fire i detection tone shown in Table 3.3-11 shall be OPERABLE. APPLICABILITY: Whenever equipment protected by the fire detection instrument is required to be OPERABLE.# ACTION: With the number of OPERABLE fire detection instrument (s) less than the minimum l number OPERABLE requirement of Table 3.3-11:

a. Within 1 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 at least once per 8 hours or monitor the containment v air temperature at least once per hour at the locations listed in Specification 4.5.1.5. b 9 e s tore-the-4noperable-4nstruce n t ( s ) t c 0 P EW.B L E s tetes-w4-th4n-I n d ay s c r , i n l i e u o f a ny o t he r r e por t r eq u i rc d-by-Spec i f i c a- . 1 44en44A ,--prepa re a n d s ubm i t a Sp e c i a l Re po r t t o t he C-i s s i o n R'

                       -puesuant--to Spee444tation 6. 9. 2 wi thi r the ncxt 30 days outlining
                       -tAe-ac4+on-4aken3 the cause of the inoperability and the plans and
                       -tehedule-fee--eestoe4ng-tAe-4nstrume nt(s ) tc 0PERABLE s t n t"c b d$

f The provisions of Specifications 3.0.3 and 3.0.4 are not applicable. 1 i SURVEILLANCE REOUIREMENTS l 4.3.3.8.1 Each of the above required fire detection instruments which are ! accessible during operation shall be demonstrated OPERABLE at least once per 6 months by performance of a CHANNEL FUNCTIONAL TEST. Fire detection which , are not accessible during plant operation shall be demonstrated OPERABLE ! by the performance of a CHANNEL FUNCTIONAL TEST during each COLD SHUTDOWN exceeding 24 hours unless performed in the previous 6 months. 1 4.3.3.8.2 The NFPA Code 72D supervised circuits supervision associated with the detector alarms of each of the above required fire detection instruments i shall be demonstrated OPERABLE at least once per 6 months. 4.3.3.8.3 The non-supervised circuits between the local fire protection panels and actuated equipment shall be demonstrated OPERABLE at least once per 6 months.

         "The fire detection instruments located within the containment are not required to be OPERABLE during the performance of Type A Containment Leakage Rate Tests.

November 23, 1984 SEQUOYAH - UNIT 1 3/4 3-58 Amendment No. 36 l I

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                                                                                                                                                                              '    b* cPERAblE fer 2/a.7.11 FIRE SUPMESSION SYSTEMS 3 ufeo                                           2>         *

FIRE SUPPRE53 ION WATER SYSTEM 2, Qifcd:.n g

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LIMITING CONDITION FOR OPERATION 3.7.11.1 The fire sucpression water system shall be OPERASLE with:

a. Two fire suopression pumps, each with a capacity of 16E3 gpm, wita lR70 their discharge aligned to tne fire suppression header, ,
b. An OPERA 3LE flow path capaole of taking suction from the forecay and transferring the water througn distribution cioina with OPERABLE .

sectionalizing control or isolation valves /t .N: ;:rt 97: : t :ur:

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f APPLICAEILITf- At all times. ACTION: MD a. Wita only one pump OPERABLE, restore the inoperable equiement to OPE'!ASLE sta .us wi .hin 7 days or, ' ' :: : ' : r.;. :152- :: . :c _ ' a d '

::':: #:- 5 5 '., ;mp'.m Inc :ut  : ;:c':' Sp -t t: -c g3g
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aqu;;r:-: .; 0FE?." ELE :: . : r :: provide an alternate backup pump or sucoly. The provisions of Scecifications 3.0.3 and 3.0.4 are not t acclicacle. I

c. With tne fire sucaression water system othernise incoerable@

h t,Estaciisn a 'cackup fire succression water system within 2a J hours , +:-s- ne prois<*ons af Sjuc:Sud.b., 3.0. 4 we. nd agldsle, '

2. o
                                                'i au of any other report recuired by Scecification 6. ',1,                                                                                                     !u0              i i                       .
                                                                               . 1xecort in accordanca with a.c e <- - . . 2 1 c n e . 9. .,. :
                                                                              -                                                                                                                                                          e sucmit a 4                                                                                                                                                                               !     .

a) Sy talepnone wit.hin 2a j

) Conf ?- ay .alegracn, maiigram or facs.m.' transmission i ,

l nc la ar than the first working day folicwing tne :  ! I > SEOUOYAH - UNIT 1 3/a 7-31 Amencment No. 36, 56 l January 23, 1988 l 1

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  • PLANT SYSTEMS ,

ACTION: (Continued) c)'Th' writ 4ag ithin 14 days following t entr-tr the action hM+ muse operability and the plan ABLE

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SURVEILLANCE REQUIREMENTS 4.7.11.1 The fire suppression water system shall be demonstrated OPERABLE: , a. At least once per 31 days on a STAGGERED TEST BASIS by starting each i electric motor driven pump and operating it for at least 15 minutes on recirculation flow.

b. At least once per 31 days by verifying that each valve (manual, power operated or automatic) in the flow path is in its correct position. R17
  • c. At least once per 6 months by performance of a system flush.
d. At least once per 12 months by cycling each testable valve in the flow path through at least one complete cycle of full travel.
e. At least once per 18 months by performing a system functional test

} which includes simulated automatic actuation of the system throughout its operating sequence, and:

1. Verifying that each automatic valve in the flow path actuates to its correct position,
           .                                  2.              Verifying that each pump develops at least 1653 gpm at a          R70 system head of 338 feet,
3. Cycling each valve in the flow path that is not testable during plant operation through at least one complete cycle of full travel, and
4. Verifying that the No. 1 fire pump starts to maintain the fire suppression water system pressure greater than or equal to 125 psig and that the No. 2 fire pump also starts automatically within 10 2 seconds when the fire suppression water system is not maintained greater than or equal to 125 psig by the No.1 pump.
f. At least once per 3 years by performing a flow test of the system in accordance with Chapter 5, Section 11 of the Fire Protection Handbook, 14th Edition, published by the National Fire Protection Association.

7 Note: These flushes should coincide with the chlorination of the raw service and fire suppression water system. These flushes should R17 be run, one between April 1 and June 30, and the other between September 1 and November 15. Within the prescribed spring and fall test period, deviation from the six-month performance frequency is authorized. SEQUOYAH - UNIT 1 3/4 7-32 Amendment No.13, 66 Januacy 25, 1988 I l 1 i .

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PLANT SYSTEMS { m s % e,k h .,/er* a ad.nuous er Luc l '\ SPRAY AND/0R SPRINKLER SYSTEMS .j ,ce,,,

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LIMITING CONDITION FOR OPERATION L 3.7.11.2 The following spray and/or sprinkler systems shall be OPERABLE:

a. Reactor Building - RC pump area, Annulus '
b. Auxiliary Building - Elev. 669, 690, 706, 714, 734, 749, 750 ABGTS Filters, EGTS Filters, Cont. Purge Filters, and 125V Battery Rooms.
c. Control Buildina - Eles. 669, Cable Spreading Room, MCR air filters, and operator living area. ,
d. Diesel Generator Building - Corrider Area.
e. Turbine Building - Control Building Wall.

APPLICABILITY: Whenever equipment protected by the spray / sprinkler system is , required to be OPERABLE. ~ ACTION: t f*8 a. With one or more of the above required spray and/or sprinkler systems inoperable, within one hour establish a continuous fire watch with backup fire suppression equipment for those areas in which redundant e systems or components could be damaged: for other areas establish an hourly fire watch patrol.Mc tere the syster to OPER^.BLE ;t *.u; with4- ' ' day:. c r , ir 'icu of any other report -cquired by Speci#ica-tien $.E.1, preparc :nd submit ; Special llcport to the Ocm-i;;ica lR40 pur;ucnt to Epcci'icaticr 5.0.2 within the next 30 day: cutl#"4ng '

                                                       --the action taktn, the cau;c of the 'nopcrobility and the plar.; and
                                                          ;cnedulc for rc;toring thc system to OPE.'*0L: ;tatu;.

1

b. The provisions of Specification 3.0.3 and 3.0.4 are not applicable. l
                                                                                                                                                             )

1 l SURVEILLANCE REQUIREMENTS 4.7.11.2 Each of the above required spray and/or sprinkler systems shall be cemonstrated OPERABLE:

a. At least once per 31 days by verifying that each valve (manual, power operated or automatic) in the flow patn is in its correct position.
b. At least once per 12 months by cycling each testable valve in the 1

flow path through at least one complete cycle of full travel. November 23, 1984  ! SEQUOYAH - UNIT 1 3/4 7-33 Amendment No. 36

(' PLANT SYSTEMS l 1 CO2 SYSTEMS LIMITING CONDITION FOR OPERATION 3.7.11.3 The following low pressure CO systems shall be OPERABLE. 2

a. Computer Room.
b. Auxiliary Instrument Room.
c. Diesel Generator Rooms.
d. Fuel Oil Pump Rooms.
e. Diesel Generator Building Electrical Board Rooms. R100-APPLICABILITY: Whenever equipment protected by the CO 2 systems is required to be OPERABLE.

ACTION:

a. With one or more of the above required C0 systems inoperable, z

i within one hour establish a continuous fi;er watch with backup fire suppression equipment for those areas in which redundant systems or components could be damaged; for other areat, establish an hourly fire watch patrol. -Rectore the systc= te OPEPASLE statu: within li day: cr, in lieu of any other report required by Specification 5.5.1, preparc and submit a Special Rcpert to the Ccrai :icn pursuant R40 to Specification 5.0.2 within thc next 30 day; cutlining the action

                                -t-sken, the cause of the inoperability and the plan cnd schedule fer                 '

rc tering the system to OPERABLE tatus,

b. The provisions of Specifications 3.0.3 and 3.0.4 are not applicable.

SURVEILLANCE REQUIREMENTS , 4.7.11.3.1 Each of the above required CO 2 systems shall be demonstrated OPERABLE at least once per 31 days by verifying that each valve (manual, power operated or automatic) in the flow path is in its correct position. SEQUOYAH - UNIT 1 3/4 7-35 Amendment No.' 36,06 [ January 22, 1989 ' c

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PLANT' SYSTEMS , FIRE HOSE STATIONS i LIMITING CONDITION FOR OPERATION t 3.7.11.4 The fire nose stations shown in Table 3.7-5 shall be OPERABLE. . APPLICABILITY: Whenever equipment in the areas protected by the fire hose ' stations is required to be OPERABLE. i ACTION:

a. With one or more of the fire hose stations shown in Table 3.7-5 inoperable, route an additional equivalent capacity fire hose to the unprotected area (s) from an OPERABLE hose station within 1 hour if the inoperable fire hose is the primary means of fire suppression; otherwise route the additional hose within 24 hours. "estcr; the  !
                          "re h0:e station to OPERABLE-status-within--14-day: or, ia 'ieu of
                        -any-otherweport required-by-Specification S.S.1, prepare and submit
                         ,a-SpecM-Report to the Commission pur-seant te Spec 4f4eation 5.0.2            -
                        -within-the-next-30-day: Outlining-the action taken, the cause Of the           i 4aoperatdlity, and-the-plan: and schedule f0r rectoe4eg--th: :tstion to-OPERABLE-statetr I.
b. The provisions of Specifications 3.0.3 and 3.0.4 are not applicable.
         ~~
            ~ SURVEILLANCE REQUIREMENTS R147 4.7.11.4 Each of the fire hose stations shown in Table 3.7-5 shall be                      ,

demonstrated OPERABLE:

a. At least once per 31 days by visual inspection of the stations  !

accessible during plant operations to assure all required equipment is at the station.

b. At least once per 18 months by:
1. Visual inspection of the stations not accessible during plant operations to assure all required equipment is at the station,
2. Removing the hose for inspection and re-racking, and  ;
3. Inspecting all gaskets and replacing any degraded gaskets in the <acplings.

i

c. ,it f east ' ore per 3 years by:
1. Partia;1y opening each hose station valve to verify valve OPERABILITY and no flow blockage.
2. Conducting a hose hydrostatic test at a pressure of 150 psig or at least 50 psig above maximum fire main operating pressure, whichever is greater.

SEQUOYAH - UNIT 1 3/4 7-37 Amendment No. 36, 114, 143 , July 31, 1990 ) l

f PLANT SYSTEMS {" , 3/4.7.12 FIRE BARRIER PENETRATIONS r LIMITING CONDITION FOR OPERATION 3.7.12 All fire barrier penetrations (including cable penetration barriers, . firedoors and fire dampers) in fire zone boundaries protecting safety related areas shall be functional. APPLICABILITY: At all times. ACTION:

a. With one or more of the above required fire barrier penetrations non-functional, within one hour either, establish a continuous fire l watch on at least one side of the affected penetration, or verify the OPERABILITY of fire detectors on at least one side of the non-  ;

functional fire barrier and establish a hourly fire watch patrol. -l' Re tert the acn- f-unctional '4-^ bar-icr penetratien( ) te functional

                           -&tato    ithir ' days.ar, ia 'ieu ef any other repert required by              !

Specification-S.S.1, prepare and submit a Special Report to the _lR40 assmaiscien pursuant to Specification S.9.2 ithin the next 30 day; eutlining-the-actier taken, the cauce of the non-functional pene- , tratier and plan: and schbdule for rc tering the #irc bcrrier

  !,                        penetratien(s).to functiers' ctatuc.

j 4mm/ ,

b. The provisions of Specifications 3.0.3 and 3.0.4 are not applicable. ,

t SURVEILLANCE REQUIREMENTS 1 4.7.12 Each of the above required fire barrier penetrations shall be verified to be functional: i

a. At least once per 18 months by a visual inspection
b. Prior to returning a fire barrier penetration to functional status  !

following repairs or maintenance by performance of a visual inspec-tion of the effected fire barrier penetration (s).

                                 ~

i u l l November 23, 1984 SEQUOYAH - UNIT 1 3/4 7-41 Amendment No. 36

PLANT SYSTEMS [ BASES SNUBBERS (Continued) R43 location, etc.), and the recommendations of Regulatory Guide 8.8 and 8.10. The addition or deletion of any hydraulic or mechanical snubber shall be made in accordance with Section 50.59 of 10 CFR Part 50. 3/4.7.10 SEALED SOURCE CONTAMINATION The limitations on removable contamination for sources requiring leak test-ing, incluaing alpha emitters, is based on 10 CFR 70.39(c) limits for plutonium. This limitation will ensure that leakage from byproduct, source, and special nuclear material sources will not exceed allowable intake values. Sealed sources are classified into three groups according to their use, with surveil-lance requirements commensurate with the probability of damage to a source.in that group. Those sources which are frequently handled are required to be tested more often than those which are not. Sealed sourc?s which are continu-ously enclosed within a shielded mechanism (i.e., sealed sources within radia-tion monitoring or boron measuring devices) are considered to be stored and need not be tested unless they are removed from the shielded mechanism. 3/4.7.11 FIRE SUPPRESSION SYSTEMS The OPERABILITY of the fire suppression systems ensures that adequate fire suppression capability is available to confine and extinguish fires g occuring in any portion of the fscility where safety related equipment is I located. The fire suppression system consists of the water system, spray and/or sprinklers, CO2 , 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. 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 inoperable equipment is restored to service. When the inoperable fire fighting equipment is intended for use as a backup means of fire suppression, a longer period of time is allowed to provide an alternate means of fire fighting than if the inoperable equipment is the primary means of fire suppression. The surveillance requirements provide assurance that the minimum OPERABILITY requirements of the fire suppression systems are met. In the event the fire suppression water system becomes inoperable, immediate corrective measures must be taken since this system provides the maior fire suppression capability of the plant. lThPrequ'rement for alWenty(- our hour repor the CommM s'on provides-f q rompt eva u hof the acceptabiMtys , of the corr etive measur provide adequate fire supprDonea ability for M ntinued pEitecQ on of the lear plant ( June 20, 1985 lR43 SEQUOYAH - UNIT 1 B 3/4 7-7 Amendment No. 39-

['T INSTRUMENTATION 8

   \~ ')   FIRE DETECTION INSTRUMENTATION LIMITING 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: i With the number of OPERABLE fire detection instrument (s) less than the minimum . number OPERABLE requirement of Table 3.3-11:

a. Within 1 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 at least once per 8 hours or monitor the containment air temperature at least once per hour at the locations listed in Specification 4.6.1.5.
                   -b     Restore-the-inoperable instrument (s) to OPERABLE :tetes-w4-th4*-
                        -14 day    cr, in-44eu-of--any-ethee-report-required-by Speci fica---
                        --ticn 6. Wrepare--and-submit-a-Spec-ial-Report-to-the40mmissioa-                 lR:
 ,                       pu r suant-to-Speci fi c a tion 4r9 r2-wi thi n-the-nex t-30-days-out14*ieg-(                     -the-action-taken, the cause-cf the inoperat>ility end thethir-one-
                         -sc.he dul e-f or-re sto r4 ng-the-i n st rument(+)-to-OPERAB EE-stotest b f.      The provisions of Specifications 3.0.3 and 3.0.4 are not applicable.

SURVEILLANCE REQUIREMENTS . 4.3.3.8.1 Each of the above required fire detection instruments which are accessible during operation shall be demonstrated OPERABLE at least once per 6 months by performance of a CHANNEL FUNCTIONAL TEST. Fire detection which are not accessible during plant operation shall be demonstrated OPERABLE by the performance of a CHANNEL FUNCTIONAL TEST during each COLD SHUTDOWN exceeding 24 hours unless performed in the previous 6 months. 4.3.3.8.2 The NFPA Standard 72D supervised circuits supervision associated with the detector alarms of each of the above required fire detection instru-ments shall be demonstrated OPERABLE at least once per 6 months. i

4.3.3.8.3 The non-supervised circuits between the local fire protection panels and actuated equipment shall be demonstrated OPERABLE at least once per 6 months.

The fire detection instruments located within the containment are not required to be OPERABLE during the performance of Type A Containment Leakage Rate Tests. November 23, 1984 SEQUOYAH - UNIT 2 3/4 3-59 Amendment No. 28 l

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                                                                                                    /lr Ir.Ner           em N PLANT SYSTEMS a[< r ;.,)a
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3/a.7 11 FIRE SUPPRESSION SYSTEMS gjf, , 77 u. 2. , o r-Io FIRE SUPPRESSION WATER SYSTEM m 3f,, /pc (5) rr <re fe 6M/n&Eper hee: *cA f 7 II Y LIMITING CONDITION FOR OPERATICN 3.7.11.1 The fire suppression water system shall be OPERABLE with:

a. Two fire suppression pumps, each with a cacacity of 1653 gpm, g with their distnarge aligned to the fire suppression header, and  ;
b. An OPERABLE flow path capable of taking suction from the forebay and transferring the water through distribution cioing with OPERABLE .

sectionalizing control or isolation valves.' 3 n ;;r ycr:n cu-o

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en :;r# "' - : "::: :tendpi;c , 2nd tt: 'n "i": :"e:d o' P a
                                        .:'.; :r :: b         'ug: : :p r:;. ;j:::               ;;u: :d : b; OPE.'!,*3LE c ' ;;. r;._.
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APPLICABILITY- At all times. ACTICN: } . . . With only one pumo OPERABLE restore the incoerable ecuipment to RM$ a. CPEP,ABLE status within 7 days or, " :u :' :r. Other : pert l ., ., g l

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                         -4;crt t ? : r-i::': ;ur:u nt *.; !;caicati:: 5 2.^ #P" n: ~:": 20 d:y: :u '" ".g Me ;':n: :nd ;rce: dure: to t: :d
                         -+c      e .:       t"c 'ne;;r::'        :quipr:-t t: OPE"3LE :::tu: :_-                                              ,

provice an alternate backuo pump or supply. The provisions of Specifications 3.0.3 and 3.0.a are not apolicable.

b. With the fire suopression water system otherwise inoceracie$

W e,/.stacla sn a backuo tire suopression water gvs .em within3.o.4 are out. affl<cnbre 24 hours , -er,4- % pods'ohnS oS .)ec;dczfo,, f

u. 7n lieu of any other recor required by Specification 6 u.1, sucm W _cecial c Report in accordance with Soed Ton 6.9.2:

a) By teleonone wE. .. a h ' . , , b) Confirm d . .alecraoh, mailgram a simile transmission

                                           "         ter th'an tne first working day folMe event,
                                                                      ~

and 3/4 7-43 AmencmenL No. 22,53 SEQUCYAH - UNIT 2 Januarf c.o, 1908 1

PLANT SYSTEMS , ACTION: (Contircec) -

                         ~ - - .                                                     p.
 ,                         c)     In writThrfvithim14.Jiays f ollowinglhe-event %tlining the
 !                                actir n taken, th;_rause-WfW~inoperability and the plans

__ .___.and.4ehemfle E restering the system to DPERA8t SURVEILLANCE REOUIREMENTS I 4.7.11.1 The fire st.ppression water system shall be demonstrated OPERABLE:

a. At least or.ce per 31 days on a STAGGERED TEST BASIS by starting each electric motor driven pumo and operating it for at least 15 minutes on recirculaticn flow.
b. At least cr.ce per 31 days by verifying that each valve (manual, power operated or automatic) in the flow path is in its correct position.
              ^ c. At leact ence pc- E morth b r parformance of a system flush.                  R4       r
d. At least once per 12 months by cycling each testable valve in the flow path throt.gh at least one complete cycle of full travel.
e. At least once per 18 months by performing a systern functional test which includes simulated automatic actuation of the system throughout its operating sequence, and:
1. Verifying that each autematic valve in the (low path actuates to itr ccrrect position,
2. Verifying that each pump develops at least 1653 gpm at a system head of 338 feet, R58
3. Cycling each valve in the flow path that is not testable during piant operatica tnrough at least one complete cycle of full travel, and 4 Verifying thst the No.1 fire pump starts to maintain the fire suppression water system pressure greater than or equal to 125 psig, and that the No. 2 fire pump starts automatically within 10 2 seconds if tne fire suppression water system is not maintained at groater thaq or eaual to 125 psig by the No. 1 pump.
f. At least once par 3 years by performing a flow test of the syst'em in accordance wita Chapter 5, Section 11 of the Fire Protection Handbook, 14th Ecition. published by the National Fire Protection Association.
  • Note: Theseflushessho;ldcoincidehiththechlorinationoftherawservice and fire suopression water system. These flushes should be run, one R4 between Apr l 1 and hoe 39, and the other between September 1 and i

November 15. Within the pi escribed :-criag ana f 211 test period, deviation from the 1 six-month performanc2 "eacenty is authetized.

                                                                                                         }

i SEQUOYAH - UNIT 2 3/4 7-44 Amendment No. 4,58 January 25, 1988

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ur *** be e.Wle SUwS NIShle.. { ,, hf< "- t"c,,h ;,, , ulk/ are ks fa lmle. 4 S , y ,f aphie fre "#dAsk

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                   ?LANT SYSTEMS f}g    &cl, Y wb 5 "E 6
  • i SPRAY AND/0R SPRINKLER SYSTEr45 g.y.& krw rg.<~[gg yg . . . ,
                                                                                                                       ;(

3.33.2 f LIMITING CONDITION FOR OPERATION f i 3.7.11.2 The following spray and/or sprinkler systems shall be OPERABLE:

a. Reactor Building - RC pump area, Annulus l
b. Auxiliary Building - Elev. 669, 690, 706, 714, 734, 749, 759, ABGTS Filters, EGTS Filters, Cont. Purge Filters, and 125V Battery Rooms.
c. Control Building -

Elev. 669, Cable Spreading Room, MCR air filters, and operator living area.

d. Diesel Generator Building - Corridor Area. <

{ l

e. Turbine Building - Control Building Wall.

APPLICABILITY: Whenever equipment protected by the spray / sprinkler system is

  ;                required to be OPERABLE.                                                                              i ACTION:                                                                                               l h                                                                                                                         {
a. With one or more of the above required spray and/or sprinkler systems  :

inoperable, within one hour establish a continuous fire watch with  ! backup fire suppression equipment for those areas in which redundant i systems or components cauld be damaged; for other areas establish an l hourly fire watch patrol. /Rc tere the y ter to CPER^3LE tatu;- ' within 11 day: or, 4a 'ieu cf aay ether repert required by Speci'ica-t4an E E.1, prepare and submit ? Special Repeet to the Cc--issio^ lR26 pu"ruant to Speci'irrtica E.9.2 'ith4a the aext 30 days outl'a49g  ; t'e ctier take", the cause of the 4 noperability and the plans =ad

                                                                                                                         }
                              -x hedule fe rector'ng the :yttem te OPERASLE :::tas..                                     l
 ,                       b. The provisions of Specification 3.0.3 and 3.0.4 are not applicable.                       j t

SURVEILLANCE REOUIREMENTS i

                                                                                 ~                                       i f

4.7.11.2

                                                                                              ~

Each of the above required spray and/or sprinkler systems shall be  : demonstrated OPERABLE:  !

a. At least once per 31 days by verifying that each valve (manual, power operated or automatic) in the flow path is in its correct position.
b. At least once per 12 months by cycling each testable valve in the i

flow path througn at least one complete cycle of full travel. November 23, 1984 SEQUOYAH - UNIT 2 3/4 7-45 Amendment No. 28 tl - l

    ..                                                                                                                     i i

t l .. . i .

                                                                                                                        .1 PLANT SYSTEMS s )        C0 SYSTEMS 2

i LIMITING CONDITIch FOR OPERATION l 3.7.11.3 Th's following low pressure CO systems 2 shall be OPERABLE.

a. Computer Room i
b. Auxiliary Instrument Room  ;
c. Diesel Generator Rooms
d. Fuel Oil Pump Rooms
e. Diesel Generator Building Electrical Board Rooms lR85 APPLICABILITY: Whenever equipment protected by the CO systems is required to be OPERABLE. 2 i ACTION:

a. g With one or more of the above required C0 systems inoperable, 1 withinonehourestablishacontinuousfifewatchwithbackupfire suppression equipment for those areas in which redundant systems or L components could be damaged; for other areas, establish an hourly fire watch patrol. Rester: th: ;y;ter to OPERABLE ; tate: withi- 'd 4ays4r,-4n 'ieu of any4ther report required by Spccificatica i

                                  -6.5.1, prepare end submit e Specie! Report to the Ce=nission                          ,

( t p'r" "ent to Specification 6.9.2 within the next 30 dayc cutli-ing the action-taken, the cause of the inoperebi'ity and the plan: and Schedule fer-R28 V

                                  -eester4ng the systc= to CPERABLE ;tatus.

b. The provisions of Specifications 3.0.3 and 3.0.4 are not applicable. i+ SURVEILLANCE REOUIREMENTS 4.7.11.3.1 Each of the above required CO, systems shall be demonstrated OPERABLE at least once per 31 days by verifying that each valve (manual, power operated or automatic) in the flow path is in its correct position. 4.7.11.3.2 Each of the above required low pressure CO 2 systems shall be i demonstrated OPERABLE:

a. At least once per 7 days by verifying the C07 storage tank level to be greater than 50% and pressure to be greater than 270 psig, and
b. At least once per 18 months by verifying:
1. The system valves and associated ventilation dampers and fire door release mechanisms actuate manually and automatically, upon receipt of a simulated actuation signal, and
2. Flow from each nozzle during a " Puff Test."

SEQUOYAH - UNIT 2 3/4 7-47 Amendment No. 28, 85 January 22, lyS9 t e C

t ,

                                                                                                     ~
                                                                                                               ~

PLANT SYSTEMS FIRE HOSE STATIONS LIMITING CONDITION FOR OPERATION }. 3.7.11.4 The fire hose stations shown in Table 3.7-5 shall be OPERABLE. 3 APPLICABILITY: Whenever equipment in the areas protected by the fire hose stations is required to be OPERABLE. ACTION: a. With one or more of the fire hose stations shown in Table 3.7 inoperable, route an additional equivalent capacity fire hose to the unprotected area (s) from an OPERABLE hose station within 1 hour if the inoperable fire hose is the primary means of fire suppression; other-wise, route the additional hose within 24 hours. -Rc;tcre the #4re h000

                            + tat 4on--to-OPERABLE-state: ithi- Id day; cr, i- 'icu Of any other
                            -report-required by Specification 6. 5.1, prepare and submit :-Spec-ial Deport to the Ce-ission-pur4uant te Specificatica 6.9.2 with4n the
                           -next 30 days eutlining the :ction taken, the cauce 'of the ni operability, and plans-and schedu!e fer-rectoring the station tc OPER^.BLE state
b. The provisions of Specifications 3.0.3 and 3.0.4 are not applicable.

SURVEILLANCE REQUIREMENTS 4.7.li.; r ' ach of the fire hose stations shown in Table 3.7-5 shall be demonstratec OPERABLE;

a. At 'ea
,t once per 31 days by a visual inspection of the fire hose i stacions accessible during plant operations to assure all required equipment is at the station.
b. At least once per 18 months by:
1. Visual inspection of all the stations not accessible during plant operations to assure all required equipment is at the station.
2. Removing the hose for inspection and re-racking, and
3. Inspecting all gaskets and replacing any degradad gaskets in the couplings.
c. At least once per 3 years by:
1. Partially opening each hose station valve to verify valve OPERABILITY and no flow blockage.
2. Conducting a hose hydrostatic test at a pressure of 150 psig or R32 at least 50 psig above maximum fire main operating pressure, '

whichever is greater. June 25,1985 SE000YAH - UNIT 2 3/4 7-48 Amendment No. 32 '

                                                                                                          .      ,A'
                                                                                                         .,[i

1

         .                                                                                                 i
                                                                                                   -      i j

PLANT SYSTEMS 3/4.7.12 FIRE BARRIER PENETRATIONS LIMITING CONDITION FOR OPERATION 3.7.12 All fire barrier penetrations (including cable penetration barriers, firedoors and fire dampers) in fire zone boundaries protecting safety related areas, shall be functional. APPLICABILITY: At all times. ACTION:

a. With one or more of the above required fire barrier penetrations non-functional, within one hour either, establish a continuous fire watch on at least one side of the affected penetration, or verify the OPERABILITY of fire detectors on at least one side of the non-functional fire barrier and establish a hourly fire watch patrol.
                       -Resteee-the non-function 1 fiee-- bar-icr penetration (s) to functienal
                      -status-within ' day; cr, 4- 'ieu cf any Other repcrt required by

_ Spec 4ficatian 6 6 1, prepare and submit e Special Deport to the {R28

                      -Commi;;ica pur uant te Spec-44+ eat 4en S.9.2 within the nc*t 30 day; cutlining the action taken, the cause of the non-functional panes
                      -Leation and plan and schedule for restoring the fire barrier
                      -penetration (s) to functional statur.                                         .
b. The provisions of Specifications 3.0.3 and 3.0.4 are not applicable.

SURVEILLANCE RE0VIREMENTS 4.7.12 Each of the above required fire barrier penetrations shall be verified te be runctional:

a. At least once per 18 months by a visual inspection.
b. Prior to returning a fire barrier penetration to functional status following repairs or maintenance by performance of a visual inspection of the affected fire barrier penetration (s).

l l 1 i I November 23, 1984 , SEQUOYAH - UNIT 2 3/4 7-52 Amendment No. 28 l l (.

                                                                                                      \

f PLANT SYSTEMS ' BASES 3/4.7.11 FIRE SUPPRESSION SYSTEMS The OPEPABILITY of the fire suppression systems ensures that adequate fire suppression capability is available to confine and extinguish fires 3 occuring in any portion of the facility where safety related equipment is r located. The fire suppression system consists of the water system, spray and/or sprinklers, C07 , 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.
  • 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 inoperable equipment is restored to service. , j When the inoperable fire fighting equipment is intended for use as a backup means of fire suppression, a longer period of time is allowed to provide an I alternate means of fire fighting than if the inoperable equipment is the primary means of fire suppression. i The surveillance requirements provide assurance that the minimum OPERABILITY

 ;     requirements of the fire suppression systems are met.

t In the event the fire suppression water system becomes inoperable, immediate l l corrective measures must be taken since this system provides the maior fire , c suppression capability of the plant. jThe/requi emen1 for twe ty-fo hou ~ re rt to the C mmissi n pro des or pr mpt e alua ;on o the ccept bili s o the rrec ve me ures pro ide a equat fire suppr ssio capa ility for

 !      he co tinue prote . ion o the uclea plan .
  • I j All hourly fire watch patrols require that a trained individual be in the i

specified area at intervals of 60 minutes with a margin of 15 minutes. A continuous fire watch requires that a trained individual be in the specified area at all times, that the specified area contain no impediment to ' restrict the movements of the continuous fire watch, and that each compartment BR-4 within the specified area is patrolled at least once every 15 minutes with a > margin of 5 minutes. A specified area for a continuous fire watch is one or more fire zones within a single fire area, which are easily accessible to each other and can be patrolled within 15 minutes. Easy access is defined as: no locked doors )

or inoperable card reader, no C-Zone entry required, or no hazards that will  ;

) interfere with the continuous fire watch activity being performed within the j i 15-minute period. I 1 l S t SEQUOYAH - UNIT 2 B 3/4 7-7 November 25, 1992 L 4 _ --

  .                                                                       i i
                           ' ENCLOSURE 2 PROPOSED TECHNICAL SPECIFICATION CHANGE                        I SEQUOYAH NUCLEAR PLANT UNITS 1 AND 2                         ,

DOCKET NOS. 50-327 AND 50-328 i (TVA-SQN-TS-93-10)- . i DESCRIPTION AND JUSTIFICATION FOR AMENDING LIMITING CONDITION FOR OPERATION r (LCO) 3.7.11.1.b, ACTION STATEMENTS FOR LCOs 3.7.11.1, 3.7.11.2, 3.7.11.3,  ; 3.7.11.4, 3.7.12, 3.3.3.8, AND I BASES 3/4.7.11 l e i i c

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           .                                                                                .I
 ,   .                                                                                      -r DEEaription of Change TVA proposes to modify the Sequoyah Nuclear Plant (SQN) Units 1 and 2         ,

technical specifications (TSs) to amend the following fire protection specifications: (1) Fire Suppression Systems Specification 3/4.7.11, , (2) Fire Barrier Penetration Specification 3/4.7.12, and (3) Fire l Detection Instrumentation Specification 3/4.3.3.8. A description of  : SQN's fire protection program is provided in Section 9.5.1 of the Final Safety Analysis Report. TVA's proposed amendment is divided into three parts. The first part revises Limiting Condition for Operation (LCO) 3.7.11.1.b that governs , the operability requirements for the fire suppression water system flow path. SQN LCO 3.7.11.1.b currently states:

                    "An OPERABLE flow path capable of taking suction from the                ;

forebay and transferring the water through distribution piping - with OPERABLE sectionalizing control or isolation valves to the - yard hydrant curb valves, the last valve ahead of the water pressure alarm device on each sprinkler or hose standpipe, and the last valve ahead of the deluge valve on each deluge or spray system required to be OPERABLE per Specifications 3.7.11.2 and 3.7.11.4." s TVA's proposed change deletes the words "to the yard hydrant curb valves, the last valve ahead of the water pressure alarm device on each sprinkler-or hose standpipe, and the last valve ahead of the deluge valve on each deluge or spray system required to be OPERABLE per Specifications c 3.7.11.2 and 3.7.11.4" and modifies the remaining words to read as > follows:

                    "An OPERABLE flow path capable of taking suction from the forebay and transferring the water through distribution piping           !

with OPERABLE sectionalizing control or isolation valves up to the first valve off the loop header that isolate: l

1. Spray and/or sprinkler system (s) required to be OPERABLE per Specification 3.7.11.2, or ,
2. Hose standpipe (s) required to be OPERABLE per Specification 3.7.11.4."

In addition to the above changes, an exemption to the provisions of , TS 3.0.4 has been added to Action Statement (b) of 3.7.11.1. t The second part of TVA's proposed amendment involves a change to Action Statement (a) of LCO 3.7.11.2 for spray and/or sprinkler systems. The . proposed change provides additional guidance within the action that l obviates the requirement for maintaining continuous or hourly fire watch inside containment (i.e. , reactor building - reactor coolant [RC] pump 3 area). The proposed words that are being added are as follows: 6 w

         - -                    ~                                                 = , .

c.- _2_ l "For spray and/or sprinkler systems inside containment which are inoperable as a result of inoperable fire detection instrumentation, t a continuous or hourly fire watch is not required when complying with the ACTION requirements of Specification 3.3.3.8." The third part of TVA's proposed TS change is an administrative change to delete various reporting requirements associated with SQN's fire i protection systems. The current action statements of Specifications 3/4.7.11, " Fire Suppression Systems"; 3/4.7.12, " Fire Barrier Penetrations"; and 3/4.3.3.8, " Fire Detection Instrumentation," contain requirements for submitting a special report to the Commission when fire protection deficiencies occur. The current bases for Fire Suppression System Specification 3/4.7.11 also make reference to special reporting requirements. TVA's proposed amendment deletes these special reporting requirements from SQN's fire protection TSs. i i Reason _Isr Change i SQN's current requirements for LCO 3.7.11.1.b (fire suppression flow path) specify operability boundaries for the various fire protection end L devices such as spray and/or sprinkler systems and hose standpipes. The l current wording in -LCO 3.7.ll.l.b has resulted in unnecessary entries into the flow path LCO when isolation of the various fire protection end devices for preplanned testing or when maintenance is required. The  ! proposed change to the boundaries would not affect overall fire  ! suppression operability. Accordingly, TVA's proposed change to l LCO 3.7.11.1.b provides needed revision and clarification to the flow path operability boundaries and reduces the potential for any misinterpretation or misapplication of LCO requirements. Also, the addition of a TS 3.0.4 exemption is being provided to allow mode changes while relying upon Action Statement (b ) .  ! The proposed change to Action (a) of LCO 3.7.11.2 is necessary to provide I clarification and guidance to the operator for a specific case involving inoperable fire detection instrumentation inside containment. SQN LCO 3.3.3.8 contains operability requirements for fire detection instrumentation. The action statement associated with LCO 3.3.3.8  ! (specifically Action [a]) distinguishes between actions necessary for inoperable fire detection instrumentation located inside and outside  ; containment. In the event fire detection instrumentation becomes  ! inoperable inside containment (specifically the fire detection instrumentation associated with the reactor building - RC pump area), i under the current TS the associated spray or sprinkler syscem for the RC pump area would be declared inoperable and Action (a) of LC0 3.7.11.2 i would apply. Action Statement (a) of LCO 3.7.11.2 does not currently make the distinction as to appropriate actions for an inoperable system inside containment. Consequently, a change to Action (a) of LCO 3.7.11.2 is necessary to clarify the action requirements for the spray and/or sprinkler systems inside containment. TVA also proposes to eliminate the special reporting requirements contained in SQN's fire protection TSs and TS bases. Removing the special reporting requirements f rom SQN TSs reduces the regulatory burden.

o-hatilisation for Change TVA's proposed change to LCO 3.7.11.1.b clarifies the boundary for an operable flow path by establishing the boundary at the first valve off the header (i.e. , yard loop or building loop) leading to the particular end device (s) (i.e., spray and/or sprinkler system, or hose standpipe) rather.than the last valve ahead of the particular end device (s). Figure 1 provides a representation of SQN's fire protection piping configuration. The boundary for an operable flow path that currently exists in LCO 3.7.11.1.b has resulted in an unnecessary overlap between TS LCO requirements for both the end device (s) and the flow path. This is an undesirable condition that leads to multiple LC0 entries and action requirements for cases when preplanned maintenance and testing of SQN's fire protection system do not affect the flow path (i.e., only the end device [s] has been removed from service). An example of this problem is illustrated in Figure 2. When a sprinkler system valve (Valve No. 37) is closed, the operator is required to enter the LCO for the end device (i.e., LCO 3.7.11.2 for the affected sprinkler). However..if Valve No. 34 were to be closed to perform repair on the piping, the operator would be required to enter the flow-path LCO (LCO 3.7.11.1.b) and the sprinkler-system LCO (LCO 3.7.11.2) under SQN's current TS requirements. Since the loop flow path is unaffected by the isolation of Valve No. 34, entry into LCO 3.7.11.1.b for flow path is inappropriate and results in multiple TS action requirements. TVA's proposed change would establish appropriate flow-path operability boundaries that would result in a more appropriate application of TS LCOs for SQN's fire protection systems. It should be pointed out that in this i example, isolation of Valve Nos. 26 and 27 would have the same net effect , as isolating Valve No. 34. TVA realizes that other valve configurations  ! may exist that will have the same net effect as taking credit for the first valve off of the header that will also not affect the fire suppression water system's capability. However, difficulty remains in generically defining the boundaries for these other potential valve configurations. The proposed change to add the exemption to TS 3.0.4 is consistent with guidance provided in Generic Letter (GL) 87-09, " Sections 3.0 and 4.0 of l the Standard Technical Specifications (STSs) on the Applicability of Limiting Conditions for Operation and Surveillance Requirements." The GL states: "For an LCO that has action requirements permitting continued operation for an unlimited period of time, entry into an operational mode or other specified condition of operation should be permitted in j accordance with these action requirements." The proposed change to Action (a) of LCO 3.7.11.2 for spray and/or sprinkler systems is justified based on the current guidance given in Action (a) of LCO 3.3.3.8 for fire detectors. In the event fire detection instrumentation becomes inoperable, Action (a) of LCO 3.3.3.8 requires monitoring the containment air temperature at least once every hour for the affected locations. This action is appropriate for the detection of a fire inside containment and precludes establishing an hourly fire watch patrol to inspect the zone (s) with the inoperable fire

e- , g . _4_ detection instrumentation inside containment. TVA's proposed change to Action (a) of LCO 3.7.11.2 provides similar guidance for distinguishing appropriate actions for an inoperable spray and/or sprinkler system located inside containment _(inoperable solely because of inoperable , detection instrumentation). -{ A review of standard TSs (Revision 4A) for Westinghouse Electric Corporation pressurized water reactors and other utility TSs indicates that there are no special reporting requirements associated with fire protection systems. SQN's TSs currently contain special reporting requirements in the action statements of the following LCOs:

1. LCO 3.7.11.1, Fire Suppression Water System
2. LCO 3.7.11.2, spray and/or Sprinkler Systems
3. LCO 3.7.11.3, C02 87 8te"8
4. LCO 3.7.11.4, Fire Hose Stations
5. LCO 3.7.12, Fire Barrier Penetrations
6. LCO 3.3.3.8, Fire Detection Instrumentation .

These special reporting requirements result in an unnecessary regulatory burden when preplanned maintenance or testing activities are conducted on SQN's fire protection systems and backup fire suppression equipment and ' fire watch patrols (if applicable) are established and are available. Reporting requirements should be applicable to cases when there is an ' uncompensated loss-of-fire protection. In these cases, the reporting criteria of 10 CFR 50.72 and 10 CFR 50.73 may be applicable. TVA's proposed change to remove the special reporting requirements is consistent with the guidance provided in NRC GL 86-10, " Implementation of Fire Protection Requirements" (reference Item E), and Generic Letter , 88-12. " Removal of Fire Protection Requirements From Technical Specifications." i Envirnnmental_hnJact Evaluation  ! The proposed change request does not involve en unreviewed environmental question because operation of SQN Units 1 and 2 in accordance with this change would not: i

1. Result in a significant increase in any adverse environmental impact previously evaluated in the Final Environmental Statement (FES) as modified by the staff's testimony to the Atomic Safety and Licensing Board, supplements to the FES, environmental impact appraisals, or decisions of the Atomic Safety and Licensing Board.
2. Result in a significant change in effluents or power levels.
3. Result in matters not previously reviewed in the licensing basis for SQN that may have a significant environmental impact.

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 '( , 4 Enclosure 3 PROPOSED TECHNICAL SPECIFICATION CHANGE SEQUOYAH NUCLEAR PLANT UNITS 1'AND 2 DOCKET NOS. 50-327 AND 50-328 (TVA-SQN-TS-93-10)

DETERr1INATION OF NO SIGNIFICANT HAZARDS CONSIDERATION

a *

              .                      Significant Hazards Evaluation TVA has evaluated the proposed technical specification (TS) change and        l has determined that it does not represent a significant hazards               ;

consideration based on criteria established in 10 CFR 50.92(c). Operation of Sequoyah Nuclear Plant (SQN) in accordance with the proposed amendment will not: i

1. Involve a significant increase in the probability or consequences of [

an accident previously evaluated. l TVA's proposed TS change is a three-part change. The first part l provides a clarification to the requirements of the existing fire suppression system flow path operability (Limiting Condition for Operation [LC0] 3. 7.11.1.b ) . The current LCO wording leads to  ; misinterpretations and misapplication of the LCO requirements associated with flow path when isolating portions of SQN's fire protection system for preplanned maintenance or testing. This has resulted in unnecessary entries into multiple fire protection LCOs  : and multiple action requirements. TVA's proposed amendment modifies  ; LCO 3.7.11.1.b to establish clear boundaries for maintaining i flow-path operability and provides a more appropriate application of  ; the LCO requirements. The second part of TVA's proposed amendment involves a change to Action Statement (a) of LCO 3.7.11.2 for spray and/or sprinkler systems. The proposed change provides additional guidance within the action that obviates the requirement for maintaining continuous or i hourly fire watch inside containment (i.e., reactor building - t reactor coolant [RC] pump area). The activation of the spray and/or sprinkler cystem in the RC pump area (inside containment) is dependent upon operable fire detection instrumentation in this area. The TS that governs operability requirements for the fire detection instrumentation is governed by Specification 3.3.3.8. The action requirements of Specification 3.3.3.8 are based on the location of the inoperable fire detection instrumentation (outside containment versus inside containment). TVA's proposed change applies the

                " location-based" action requirements of Specification 3.3.3.8 to the action requirements of Specification 3.7.11.2 when a spray and/or sprinkler system inside containment becomes inoperable solely because of inoperable fire detection instrumentation.

The third part of TVA's proposed change is the elimination of special reporting requirements from SQN's fire protection TSs. SQN TSs currently contain special reporting requirements in the action , statement of the following LCOs: l

1. LCO 3.7.11.1, Fire Suppression Water System
2. LCO 3.7.11.2, Spray and/or Sprinkler Systems
3. LCO 3.7.11.3, CO2 Systems
4. LCO 3.7.11.4, Fire llose Stations j
5. LCO 3.7.12, Fire Barrier Penetrations
6. LCO 3.3.3.8, Fire Detection Instrumentation i

4 A., . 2 . The elimination of the special reporting requirements reduces an unnecessary regulatory burden and is consistent with the guidance provided in NRC Generic' Letter 86-10. " Implementation of Fire Protection Requirements" (reference Item E), and Generic

  • Letter 88-12, " Removal of Fire Protection Requirements from Technical Specifications."

TVA's-proposed amendment, as described above,.is administrative in - nature and does not affect SQN's ability to maintain fire protection at the site or achieve and maintain safe shutdown in the event of a fire. Consequently, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Create the possibility of a new or different kind of accident from any previously analyzed.  !

TVA's proposed TS change to the fire suppression system flow-path boundaries in LCO 3.7.11.1.b does not alter the protective functions or reduce the level of fire protection required by TSs. The proposed , change to Action (a) of LCO 3.7.11.2 for spray and/or sprinkler systems provides consistency with a related action for fire detection instrumentation (Action [a] of LCO 3.3.3.8). The proposed change to remove the special reporting requirements from SQN TSs is an administrative change that reduces the regulatory burden for TS compliance. TVA's proposed change does not result in any new scenarios that would I affect SQN's fire protection program. Consequently, the change does not create the possibility of a new or different kind of accident from any previously analyzed, t

3. Involve a significant reduction in a margin of safety.

TVA's proposed TS amendment continues to maintain TS operability requirements for SQN's fire detection instrumentation, the fire suppression water system, the spray and/or sprinkler systems, the CO2 systems, the fire hose stations, the yard fire hydrants, and the fire barrier penetrations. The performance of surveillance requirements to ensure operability of these systems is retained in TSs. The ability to achieve and maintain safe shutdown in the event of fire has not been affected by the proposed TS change. Accordingly, the , proposed change will not involve a reduction in the margin of safety. I i}}