ML20151D462

Forwards Revised Fire Protection Tech Spec Change Request 79,per NRC 880325 Draft Technical Evaluation.Specs Cover Reinstating Requirement to Shut Down Reactor When Fire Main Loop Water Supply Inoperable

ML20151D462
Person / Time
Site:	Point Beach
Issue date:	07/14/1988
From:	Fay C WISCONSIN ELECTRIC POWER CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
Shared Package
ML20151D465	List: ML20151D462 ML20151D479
References
CON-NRC-88-067, CON-NRC-88-67 TAC-51550, TAC-51551, VPNPD-88-372, NUDOCS 8807250132
Download: ML20151D462 (3)

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Wisconsin Electnc a comu 231 W MICHIGAN,P O.80x 2046, MILWAUKEE.W153201 (414)221 2345 VPNPD-88-372 NRC-88-067 July 14, 1988 U.S. NUCLEAR REGULATORY COMMISSION Do( ument Control Desk Mail Station Pl-137 Washington, D.C. 20555 Gentlemen:

l DOCKET NOS. 50-266 AND 50-301 i LIRE PROTECTION TECHNICAL SPECIFICATIONS 1 CHANGE REQUEST NO. 79 POINT BEACH NUCLEAR PLANT UNITS 1 AND 2 (NRC TAC NOS. 51550 AND 51551)

By letter dated March 25, 1988, we received the draft technical evaluation of our Fire Protection Technical Specification change request dated April 19, 1983 as amended April 13, 1984, and September 7, 1984. The letter and technical evaluatic noted deficiencies with our proposed technical specificationt We have enclosed herewith a complete package of revised ';echnical specification pages which include changes made in response to the draft evaluation. All changes are identified by a margin bar in i the right hand margin. Details of these changes and other pro-  !

visions of our fire protection program which address the concerns j in your March 25, 1988 letter follows: .

Technical Specification 15.3.14.A.l.d has been added to reinstate the requirement to shut down the reactor when the fire main loop water supply is inoperable. This change is consistent with the standard technical specifications and our present technical specifications. This specification requires i us to be in hot standby within six hours and in cold shutdown '

within the subsequent 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

Technical Specification Table 15.3.14-1 has been changed to include the number of fire detectors required to be operable in each safe shutdown fire area. This change is consistent with the standard technical specifications.

We have evaluated the above changes to our Technical Specifica-tions and license amendment application with respect to the criteria of 10 CFR 50.92 and have determined that these changes will not result in a significant hazards consideration. Thefirstf[p0g 8807250132 890714 J; l PDR ADOCK 05000266 P PDC '

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i Document Control Desk July 14, 1988 Page 2 i

change reinstates the requirement to be in hot standby within six hours and cold shutdown within the subsequent 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> if a backup fire main water supply cannot be provided within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after declaring both fire pumps inoperable. These lin,iting conditions for operation are included in our present Technical Specification 15.3.14.A.3.c. Therefore, it does not constitute an l actual change to our technical specifications and does not involve f a significant hazards consideration.

The second change adds the total number of fire detectors available in each safe shutdown area to Technical Specification Table 15.3.14-1. This change reflects the increased fire detec-  ;

tion capability installed at Point Beach Nuclear Plant as a result l of 10 CFR 50 Appendix R and fire protection system upgrades. The addition of fire detection capability cannot result in a signifi-cant increase in the probability or consequences of an accident  !

previously evaluated or involve a significant reduction in a margin of safety in that this enhanced fire detection capability 1 enables us to more quickly detect, respond to, and mitigate i possible effects a fire may have on safe shutdown systems and components. Likewit., this additional detection capability cannot create a new or different kind of accident from any accident pre-viously evaluated in that these detectors were added to enhance our ability to detect possible fires at Point Beach Nuclear Plant and do not affect the operation of any systems necessary for the safe operation of PBNP. Therefore the addition of a numerical listing of the available firc detectors in safe shutdown areas to Table 15.3.14-1 does not constitute A significant hazard.

We have evaluated the remaining deficiencies noted in your March 25, 1988, letter and technical evaluation taking into consideration the guidance in Generic Letter 86-10, Implementation of Fire Protection Requirements, dated April 24, 1986. Specifi-cally, we noted the guidance in Section F of the generic letter which recommends the incorporation of a fire protection license condition into a plant's operating license and deletion of technical specifications dealing with fire protection require-Dents. As it is our intent to follow this guidance in the future, we do not feel it is necessary to include the below discussed features of our fire protection program for Point Beach Nuclear Plant as specific items of the technical specifications.

First, it was noted that a requirement for performing a fire water sys'.em flush every three years was omitted. The fire water supply mains at PBNP are flushed annually as part of Technical Specifica-tion Surveillance Test TS-74, "Annual Underground Main Flow Test."

This exceeds the frequency requirements of the standard technical specifications.

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Document Control Desk July 14, 1988 Page 3 The second item was the lack of requirements for valve cycling.

Fire water system control valves are currently cycled on an annual basis as part of Technical Specification Surveillance Test TS-73, "Monthly Fire Protection Control V21ve Position Verification," or TS-75, "Service Testing of Fire U;se and Fire Hose Stations."

This meets or exceeds the requirements of the stardard technical specifications.

Third, you noted there were ra inspection requirements for unsupervised fire detection system circuits. "' do not employ unsupervised fire detection circuits at PBNP. all system circuits are wired for Class B supervision. Functional checks are per-formed as required by our Technical Specifications.

The last item concerned inspection requirements for fire doors.

Fire doors in safe shutdown area boundaries are inspected semi-annually in accordance with PC-70, Part 1 "Safe Shutdown Area Fire Door Inspection," which includes a check for proper operation of the fire door supervision system.

It is our intent to maintain these feattaes as part of our overall fire protection program for Point Beach Nuclear Plant. All changes to these features and other aspects of our program are evaluated prior to being implemented to ensure that they do not result in a degradation of the program.

Please contact us if you have any additional questions.

Very truly yours,

(!iv C. W. Fy TGM/jg Copies to NRC Regional Administrator, Region III NRC Resident Inspector R. S. Cullen, PSCW Subscribed and sworn to before me this /5 6 day of July, 1988.

co M * :<t' Notary Public, Statr of Wisconsin My Commisaicn expires II- 2 7- 7 0