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BASES
REQUIRED LCO 3.1 will not be met if the Flow Alarm Transmittal System is not
ACTION D.2 OPERABLE for Riser System B. The absence of the fire detection and alarm
hction in the BUILDING 991 COMPLEX waste container storage areas covered
by Riser. System B reduces the likelihood that the Fire Department will be notified
that a fire and/or actuation of the Automatic Sprinkler System has occurred. The
Fire Department serves a DEFENSE-IN-DEPTH protection function in mitigating
fires in the facility. The Fire Department also serves to mitigate facility flooding
and water damage due to actuation of the Automatic Sprinkler System. Without
the fire detection and alarm function, the likelihood of Fire Department response
is decreased. The loss of this DEFENSE-IN-DEPTH mitigation hction tends to
slightly increase the likelihood of large fires. The kility is still protected if the
Likelihood of fire initiation is decreased to offset the slightly increased likelihood
of &ge fires.
Revision 1
Scptmber 1999
Ifthe Flow Alarm Transmittal System is not OPERABLE for Riser System B, the
facility shall SUSPEND OPERATIONS in the AFFECTED AREAS within
four-hours. The SUSPEND OPERATIONS REQUIRED ACTION is a measure
to reduce the likelihood of fue initiation in the AFFECTED AREAS. The
suspension of operations does not replace the fire detection and alarm functions of
the Flow Alarm Transmittal System but attempts to maintain an equivalent risk by
reducing fire fkquency. The suspension of operations does not preclude fire
initiation. Energized electrical systems in the fidity always have the potential to
initiate fires. 'Therefore, REQUIRED ACTION D.l is identified to provide some
fire detection and alarm capability while the DEFENSE-IN-DEPTH mitigation
function is not OPERABLE. The fire watch established in REQUIRED
ACTION D.l can continue to veri@ tha$ operations are suspended while
performing tours.
The four-hour COMPLETION TIME associated with the .SUSPEND
OPERATIONS REQUIRED ACTION provides adequate time for facility
management to inform the workers of the required termination and for the workers
to safely terminate the work. The termination of these activities does not negate
any fue watch requirements associated with the original activity. That is, if the
hot work permit stipulated a continuous fire watch for eighthours to monitor
equipment while it is cooling, the tennination of the activity would not relax the
requirement for a continuous fire watch.
The four-hour COMPLETION TIME does not result in undue risk due to the low
initiation fkquency of a fire, particularly in waste container storage areas, and due
to the already continuous monitoring of the activities by the workers involved in
the activities. However, the REQUIRED ACTION to SUSPEND OPERATIONS
in AFFECTED AREAS is expected to be implemented as soon as reasonably
achievable, even if this is significantly less than the assigned COMPLETION
TIME. The four-hour COMPLETION TIME should not be used for operational
convenience.
A-39 Building 99 1 Complex FSAR
Appendix A