ML20236L584

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Submits Interpretation of TS Requirement Re Fire Protection for Indian Point Unit 2 Per 940719 Memo
ML20236L584
Person / Time
Site: Indian Point Entergy icon.png
Issue date: 11/09/1994
From: Zwolinski J
Office of Nuclear Reactor Regulation
To: Cooper R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20236J990 List: ... further results
References
FOIA-98-155 NUDOCS 9807130082
Download: ML20236L584 (3)
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Text

t R. Cooper November 9, 1994 an alternate fire protection system shall be established within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; such action would be fulfilled by having satisfied the action requirements of TS 3.13.E.2.a for inoperable hose stations that is to be implemented within one hour as stated above. The fact that at least some portion of the high pressure water fire protection system was operable is not immaterial with respect to the need to comply with the action requirements for hose stations just because the licensee elected to declare the entire high pressure water fire protection system to be inoperable. Compliance with a system level TS action is not justification for not complying with component level TS action.

The staff does not agree with the licensee'.s argument that one TS may be followed to the exclusion of another as suggested in the June 9, 1994, letter to Region 1, nor does the staff agree with the licensee's analogy to the containment spray system. Valves in the containment spray system are not inoperable solely on the basis that the associated containment spray pump is inoperable.

Had the licensee acted on the staff guidance provided in Generic Letter 88-12,  ;

the fire protection system requirements could have been relocated from the TS l to the fire protection program plan, under which changes to the program would be reviewed in accordance with 10 CFR 50.59 for unreviewed safety questions.

Alternatively, the licensee could have requested enforcement discretion or a license amendment to reconcile what was considered as an inconsistency between the required actions. It is noted that on June 16, 1994, the licensee ,

i submitted a proposed amendment to relocate the fire protection requirements from the TS to the fire protection program plan. The amendment is being <

processed and is expected to be issued in February 1995.

DISTRIBUTION: s OTSB R/F DORS R/F Central Files NOTSB Background Book BKGrimes CIGrimes FMReinhart WDean, EDO JZwolinski LMarsh MWilliams CVogan JLieberman 4

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November 9, 1994 MEMORANDON TO: Richard W. Cooper II, Director Division of Reactor Projects Region I 1

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FRON: John A. Zwolinski, Deputy Director' Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation

SUBJECT:

REQUEST FOR TECHNICAL ASSISTANCE ON INDIAN POINT 2 FIRE PROTECTION TECHNICAL SPECIFICATIONS Your memorandum of July 19, 1994, requested an interpretation of the technical specification (TS) requirement for the Indian Point 2 facility. The scenario described was the following:

Consolidated Edison Company of New York, Inc. (CON ED) initiated elective maintenance to replace the root valve for a fire protection hose reel in the Primary Auxiliary Building (PAB) at the Indian Point 2 facility. Since the hose reel valve is not isobble from the high pressure fire water header, it was planned to iso 1 ate the entire high pressure header in the PAB. CON ED Nuclear Safety and Licensing (NS&L) personnel advised that the appropriate action would be to declare the entire site fire protection system inoperable. NS&L also advised the operating crew that since the LCO allowed 24-hour system outage before compensatory action was required, and the valve replacement was expected to be accomplished in 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, no alternate fire protection system would need to be established.

This matter was reviewed by the Technical Specifications Branch which concurs with the regional staff that remedial actions of TS 3.13.E for hose stations apply when the affected hose stations are inoperable as a result of isolating the high pressure fire water header in the PAB.

Since the planned maintenance was expected to take 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> to complete, it would have been appropriate for the licensee to have implemented the action required to route additional equivalent capacity fire hoses to the affected areas from an operable hose station or hydrant before isolating the PAB fire water header, as required by TS 3.13.E.2.a within I hour of isolating the PAB fire water header.

The isolation of the PAB fire header also constitutes a failure to satisfy the requirements of TS 3.13.A.I.c that requires all piping and valves to be operable as necessary for proper fun.tioning of any portion of the high pressure water fire protection system required for the protection of safe shutdown systems. While the action requirements of TS 3.13.A.3.a state that CONTACT: T. G. Dunning, OTSB/NRR 504-1189

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R. Cooper November 9,1994 an alternate fire protection system shall be established within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; such action would be fulfilled by having satisfied the action requirements of TS 3.13.E.2.a for inoperable hose stations that is to be implemented within one hour as stated above. The fact that at least some portion of the high pressure water fire protection system was operable is not immaterial with respect to the need to comply with the action requirements for hose stations just because the licensee elected to declare the entire high pressure water fire protection system to be inoperable. Compliance with a system level TS action is not justification for not complying with component level TS action.

The staff does not agree with the licensee's argument that one TS may be i followed to the exclusion of another as suggested in the June 9,1994, letter to Region 1, nor does the staff agree with the licensee's analogy to the containment spray system. Valves in'the containment spray system are not inoperable solely on the basis that the associated containment spray pump is inoperable.

Had the licensee acted a the staff guidance provided in Generic Letter 88-12, the fire protection system requirements could have been relocated from the TS j to the fire protection program plan, under which changes to the program would 1 be reviewed in accordance with 10 CFR 50.59 for unreviewed safety questions. l Alternatively, the licensee could have requested enforcement discretion or a l license amendment to reconcile what was considered as an inconsistency between I the required actions. It is noted that on June 16, 1994, the licensee  !

submitted a proposed amendment to relocate the fire protection requirements i from the TS to the fire protection program plan. The amendment is being processed and is expected to be issued in February 1995.

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