ML19344D517
| ML19344D517 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 02/29/1980 |
| From: | Andognini G BOSTON EDISON CO. |
| To: | Brunner E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| 80-36, NUDOCS 8003120588 | |
| Download: ML19344D517 (3) | |
Text
BOSTON EDISON COMPANY Osmamah Orricas 800 Bov6ston BTess?
BooTose. MaseAcMuserve 03899
- d. CA#b ANOOSMENG sumantuftness07 P,*sC6 CAM Optl,4f*83N4 OSPASTM(MT February 29, 1980 BEco. Ltr. #80-36 Mr. Elden J. Brunner, Chief Reactor Operations and Nuclear Support Branch Office of Inspection and Enforcement Region C U.S. Nuclettr Regulatory Commission 631 Park Avenue King of Priissia, PA.
19406 License No. DPR-35 Docket No. 50-293 Response to IE Inspection #79-21, Deae Sir:
Inspection No. 79-21, dated January 21, 1980, contained one item of noncom-pliance. Boston Edison Company's response to that item is presented as foll.ows :
0.d ici.2ncy Technical Specification 6.8.D states, " Written procedures to implement the Fire P.otection Program shall be established, implemente', and maintained."
d Plant Procedure 1.3.4, " Procedures," Paragraph III. A, states, in part, "...Proce-eiures shall be implemented in accordance with safety standards, Technical Speci-fications, and requirements of regulatory agencies..."
Contrary to the above, the following plant procedures for operation of Fire Pror.ection System:
ro. 2.2.25 " Fire Water System" No. 2. 2.26, " Deluge and Sprinkler Sys tems" No. 2.2.27, " Carbon Dioxide System" No. 2.2.28, " Dry Chemical Systems" No. 2.2.29, " Smoke Detection Sys tems"
\\
did not adequately implement or were not in accordance with various Technical Specification requirements as specified in Technical Specifications 3.12 and 4.12.
k
=___
Go3 TON isolGUN CuMPANY Mr. Klilon J. Brunner, Chief Februac/ 29, 1980 Fage 7 Res ponic The Fire Protection Operating Procedures found to be in noncompliance during the subject NRC Inspection will be revised to implement the requirements of Plant Fcocedure 1.3.4 and Technical Specifications 6.8.D, 3.12 and 4.12.
Fevisions to these procedures incorporating the applicable sections of the euferenced requirements will be completed by April 15, 1980. However, we von 1d like to clarify certain misconceptions with the NRC findings specific to Procedures No. 2.2.25 " Fire Water System" and No. 2.2.26 " Deluge and Sprinkler Systems".
Regarding Procedure No. 2.2.25 the NRC findings state that "the procedure appears to allow Fire System operation between 110-125 psig with no operator or automatic actions.
T.S. 4.12.B states that Fire System operation will be a min' mum of 125 psig."
Unfortunately T.S. 4.12.B has been taken out of con-
- i. ext and tearoperly applied. The entire requirement reads na follows:
"by verifying that each pump starts and delivers at least 2000 gpm while maintaining a system pressure of at least 125 psig."
G;is cequirement applies to the motor driven and engine driven fire pumps only a s denoted in T.S. 3.12.B, while T.S. 4.12B requires that' each pump deliver 2000 gpm ar a system discharge pressure of 125 psig during operation. A jockey pusg to utilized to maintain normal system pressure which prevents the motor drivan fico pump from cycling on and off. A continuous drop in system pressure wt11 activate the fire pumps which will then deliver their rated capacity at rated presaure. The system as currently designed and described does meet the requiremento of 4.12.B and is based on sound fire protection engineering practice and judgement. Therefore, no changes will be made to the procedure regarding this datter.
As to the NRC finding relative to Procedure 2.2.26 in which the Inspector stated;
- 1) " Amendment #35 dated December 21, 1978 required a spray / sprinkler system be laatalled in the Standby Gas Treatment System (SBGT)" and 2) "the current built in spray system in the SBGT may not meet the requirements of T.S. 3.12.C and 4.12.C,"
ue respond as follows:
1)
Cie Consission Safety Evaluation Report (SER) accompanying Amendment #35, clearly identifies the adequacy of the existing automatic water suppression
- 4ystem for protection of fire in the charcoal filters. As stated in Section 5.11 of the SER, the only modification required in this area was the addition of a 25 foot length of hose to the hose station adjacent to this area.
- 2) The function of the SBGT Filte-Spray System as designed, is to cool exothermic reactions within the charcoal filters to prevent radioactive release in the event of an unsuppressed fire. Although it's design is dissimilar to the other spray and/or sprinkler systems listed in T.S. 3.12.C, in that it is not designed to NFPA-13 criteria, the Commission was totally cognizant of this fact at the time of issuance of Amendment #35 and the requirements of T.S. 3.12.C and 4.12.C CD dN
<d Sg
.~
M M M IAL
Wo stun isoman COMPANY Mr. Eldon J. Brunt:
?.ief February 29, 1980 Page 3 as issued were considered appropriate and applicable for this system.
Therefore, no modifications will be made in this area; however, as stated above, operating procedures for this sytem will be implemented in accordance with Plant Procedure 1.3.4 by April 15, 1980.
We trust these actions are responsive to your concerns, however, should you desire additional information please contact us.
Very truly yours, c
Mw l
e l
A..4
& < dat
~
t