ML17310A539
| ML17310A539 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde |
| Issue date: | 07/27/1993 |
| From: | Linh Tran Office of Nuclear Reactor Regulation |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 9308170424 | |
| Download: ML17310A539 (45) | |
Text
Docket Nos.
50-528, 50-529, and 50-530 July 27, 1993 0 LICENSEE:
Arizona Public Service Company FACILITY:
Palo Verde Nuclear Generatin Station g
SUBJECT:
SUMMARY
OF MEETING HELD ON JULY 20, 1993 TO DISCUSS THE APPENDIX R REEVALUATION EFFORT On July 20,
- 1993, the NRC staff met with representatives of Arizona Public Service Comoany (APS) to discuss the fire protection program at Palo Verde.
The meeting was held pursuant to a notice issued on July 12, 1993.
Persons attending the meeting are listed in Enclosure 1.
,Viewgraphs presented at the meeting are contained in Enclos~ re 2.
Highlights of the meeting are summarized below.
The purpose of the meeting was to discuss the Appendix R reevaluation effort, plant modifications, and associated schedules for implementation.
Arizona Public Service Company (APS) representatives described the issues identified by the Appendix R reconstitution effort and the plant modifications to be performed.
All the plant modifications are scheduled to be completed by December 1997.
The licensee also described its new and revised Appendix R
deviation requests which were submitted for NRC review and approval.
In addition, the licensee presented information regarding the closure of a justification for continued operation of the Palo Verde fire protection system equipment.
Enclosures:
- 1. Attendance List
- 2. Viewgraphs Ori gina 1 si gned by:
Linh N. Tran, Project Manager Project Directorate V
Division of Reactor Projects III/IV/V Office of Nuclear Reactor Regulation DISTRIBUTION w enclosure 2:
LDocket. File
7 NRC S, Local PDRs PDV Reading File
- KPerkins, RV cc w/enclosures:
See next page THurley/FHiraglia, 12G18 JRoe Tguay LTran
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 July 27, 1993 Docket Nos. 50-528, 50-529, and 50-530 LICENSEE:
Arizona Public Service Company III FACILITY:
Palo Verde Nuclear G'enerating Station
SUBJECT:
SUMMARY
OF MEETING HELD ON JULY 20, 1993 TO DISCUSS THE APPENDIX R REEVALUATION EFFORT On July 20,
- 1993, the.NRC staff met with representatives of Arizona Public Service Company (APS) to discuss the fire protection program at Palo Verde.
The meeting was held pursuant to a notice issued on July 12, 1993.
Persons attending the meeting are listed in Enclosure l.
Viewgraphs presented at the meeting are contained in Enclosure 2.
Highlights of the meeting are summarized below.
The purpose of the meeting was to discuss the Appendix R reevaluation effort, plant modifications, and associated schedules for implementation.
Arizona Public Service Company (APS) representatives described the issues identified by the Appendix R reconstitution effort and the plant modifications to be'erformed.
All the plant modifications are scheduled to be completed by December 1997.
The licensee also described its new and revised Appendix R
deviation requests which were submitted for NRC review and approval.
In addition, the licensee presented information regarding the closure of a justification for continued oper ation of the Palo Verde fire protection system equipment.
Enclosures:
- l. Attendance List
- 2. Viewgraphs cc w/enclosures:
See next page Linh N. Tran, Project Manager Project Directorate V
Division of Reactor Projects III/IV/V Office of Nuclear Reactor Regulation
Arizona Public Service Company Palo Verde CC:
Hr. Steve Olea Arizona Corporation Commission 1200 W. Washington Street
- Phoenix, Arizona 85007 James A. Beoletto, Esq.
Southern California Edison Company P. 0.
Box 800
- Rosemead, California 91770 Senior Resident Inspector Palo Verde Nuclear Generating Station 5951 S. Wintersburg Road
- Tonopah, Arizona 85354-7537 Regional Administrator, Region V
U. S. Nuclear Regulatory Commission 1450 Maria Lane Suite 210 Walnut Creek, California 94596 Hr. Charles B. Brinkman, Manager Washington Nuclear Operations ABB Combustion Engineering Nuclear Power 12300 Twinbrook Parkway, Suite 330 Rockville, Maryland 20852 Hr. Aubrey V. Godwin, Director Arizona Radiation Regulatory Agency 4814 South 40 Street
- Phoenix, Arizona 85040 Chairman Maricopa County Board of Supervisors 111 South Third Avenue
- Phoenix, Arizona 85003 Jack R.
- Newman, Esq.
Newman L Holtzinger, P.C.
1615 L Street, N.W., Suite 1000 Washington, D.C.
20036 Hr. Curtis Moskins Executive Vice President and Chief Operating Officer Palo Verde Services 2025 N. 3rd Street, Suite 220
- Phoenix, Arizona 85004 Roy P.
Lessey, Jr.,
Esq.
Bradley W. Jones, Esq.
Akin, Gump, Strauss, Hauer and Feld El Paso Electric Company 1333 New Hampshire Ave., Suite 400 Washington, D.C.
20036 Hr. Thomas R. Bradish, Hanager Nuclear Regulatory Affairs Arizona Public Service Company P. 0.
Box 52034
- Phoenix, Arizona 85072-2034 Hr. William F.
Conway Executive Vice President, Nuclear Arizona Public Service Company Post Office Box 53999
- Phoenix, Arizona 85072-3999
Name D. Daily J. Fisher F. Garrett J. Irwin M. Powell P.
Madden C. Trammell L. Tran Jul 20 1993 Fire Protection Meetin List of Attendees Enclosure 1
Or anization APS APS APS APS APS NRR/SPLB NRR/DRPW NRR/DRPW
Presentation to Nuclear Reactor Regulation (NRR}
on the 4x r,
<cei P~ M July 20, 1993 C7 C
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Appendix R Reconstitution Project Issues Identified
- IssU'e'P1,'
- :.',.;;,';,',Lo'ss,'of,':RCP..;.',Seal,,;lit'je'etio'ii:,,:;;:,';.
jt Evaluation Findin s:
- 1) A Potential loss of RCP Seal Cooling could occur resulting in seal damage such that RCS leakage ) available charging capacity (1 CH Pump, 44 gpm).
Fire-induced faults could cause a loss of RCP Seal Injection and the ability to isolate Controlled Seal bleed off. Nuclear Cooling Water would also be lost (due to LOP).
P interim Measures:
- 1) Established a Fire Watch for the unprotected CH circuits in Fire Zone 42C (corridor south of CH pump rooms).
P Lon -Term Corrective Actions aken:
- 1) Revised "Control Room Fire" Procedure, 4xAO-xZZ44, and Pre-Fire Strategies Manual to include Operator Actions required to restore cooling to the RCP Seals.
- 2) Revised "Locked Valve and Breaker" Procedures to lock open power supply breakers to RCP Seal In ection HP Cooler Isolation Valves, which could spuriously close (Contro Room Fire) and isolate Seal Injection.
P Lon -Term Corrective Actions Remainin 1)
PCR 91-13-CH-004:
Wraps the "B"Train CH circuits located in the corridor south of the Charging Pump rooms.
PVNGS Pre-Fire Strategies Manual AuxiliaryBuilding Elev. 100' 0"
Plant North Elec. Penetration Room Channel 'C' Non-Safety H2 Elec. Penetration Recomblner Room Channel 'B'xhaust
&Non-Safety Unit
Fuel Bldg.
ts Elev SP45 Load Center MCC s
Elec.
Chase Below
<<35 Relay Cabinet 7
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~ ll ECW Heat Exchan er ECW Heat Exchanger Post LOCA
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sp 52 SP-53 H2, Hinged Letdown Crud Crud Steel Heat Pump
'ink Hatch Exchanger Hinged
<<32 Chase Steel Hatch Rev. 6 December 1992
Appendix R Reconstitution Project Issues Identified
,Issue,42.;.',Loss of Essential,.HYAC:;-',;;DC,'E ui ment'.,ROoms':.";,
It'valuation Findin s:
- 1) For a fire in the Control Room, PVNGS relies on Train B equipment to achieve and maintain Safe Shutdown (SSD). Since one of the B Train Essential Air Handling Units (AHU) is not isolated from the Control Room, potential loss of B train SSD equipment may occur due to loss of the AHU and subsequent excessive temperature in the DC Equipment Rooms.
P Interim Measures:
- 1) Performed a calculation to determine critical time constraints for restoration of cooling to DC Equipment rooms in the event Essential AHU is lost.
- 2) Revised "Control Room Fire" Procedure, 4xAO-xZZ44, to provide Operator Actions (open DC Equipment Room doors, liftleads and install jumper in Essential AHU breaker cubicle) required to restore cooling to the DC Equipment rooms.
4 Lon -Term Corrective Actions Remainin 1)
PCR 91-13-HJ-003:
Installs a Remote/Local Switch to controi M-HJB-Z04 to alleviate "hot shutdown repair".
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Emergency Equipment Cabinet Plant North Auxiliary Building JA Cable Shaft HVAC Chase JB Jc Battery Room Channel'C'oom DC Channel Equip.
'D'oom JD Cable Shaft Chase JE QJI-Radwaste Building QJa-Switchgear 4A tate 8
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,MCCOY 'i y 101 4B Elevator HS $89 Load Centers QJS ESF Switchgear Room, Train A Cable Shaft HVAC Chase J4 U
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proof Battery HS 888
~ Door Room Channel'A'a'tte ante Room Outside SP'ea Shutdown Remote S NOS Rooms ESF Switchgear Room. Train B Switchgear HVACChase Rev. 6 December 1992
Appendix R Reconstitution Project Issues Identified issue Ã3 - 'oss of RCS Sam lin Ca abilit "
P Evaluation Findin s:
1} For a fire in the Control Room, PVNGS relies on Train B equipment to achieve and maintain Safe Shutdown (SSD). RCS Sampling is utilized in lieu of direct indication of the reactivity control function at the Remote Shutdown Panel. In order to obtain samples, both A and B Train Boron Sampling Containment Isolation Valves must be opened. The power supply batteries for the A Train valve may not be available continuously until Hot shutdown is achieved.
I}'nterim Measures:
- 1) Performed a "Constant Volume RCS Boration" calculation that demonstrates that adequate shutdown margin exists, based on the Control Room Fire Procedure (4xAO-xZZ44). RCS Samples are not mandatory to achieve Safe shutdown.
f Lon -Term Corrective Actions Remainin 1} PCR 92-13-SS-001:
Provides a dedicated power supply to the A Train sampling valve to ensure RCS sampling capability. (Note: FP Engineering plans to review A Train Class 1E Battery capacity, without Essential Cooling, to determine the potential for obtaining samples for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> into the event; i.e.: Hot Shutdown).
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Appendix R Reconstitution Project Issues Identified Issue N4 - ",A 8. 8,;.Train-Cables:in DG,StairwelI.*'-'::
P Evaluation Findin s:
- 1) The control circuits for the A Train Diesel Fuel Oil Transfer Pump are physically located in the same stairwell as power cables for the B Train Diesel Generator Room Essential Exhaust Fan. Both are Safe Shutdown Components. These cables are separated by a barrier that is not currently fire rated.
4 Interim Measures:
- 1) A Fire Hazards Analysis performed for this condition determined the following: The cables are in conduits that are physically separated by approximately 30 ft. horizontally and 30 ft.
vertically. In addition, a heavy concrete floor and wall (with no openings except a 1 (/2 label fire door) also separate the conduits.
The combustible loading in the DG stairwell is negligible.
- 2) Compensatory Measures (Fire Watches) were established for the DG Buiding Stairwelll.
P Lon -Term Corrective Actions Remainin PCR 92-13-FB-001:
Upgrades the existing Fire Door and non-rated concrete floor and wall to 3-hour fire rating to comply with Appendix R Section III.G;2.
71595 6SUr ~
Auxiliary Building Neutral Grd. Transfer Diesel Control Diesel Console HS ¹108 Building Engine Console PVNGS Pre-Fire Strategies Manual Diesel Generator Building Elev. 100' 0"
Plant North G1 G2 High Voltage Control Panel SP 75 22A o
o 22B >~
~ 6 Neutral Grid Iiansfer High Voltage Control Panel Sump Sump Diesel Generator Train 'A" Diesel Generator Train "B'3 Missile Proof Door Missile Proof Door GA GB GC Rev. 6 December 1992
PVNGS Pre-Fire Strategies Manual Diesel Generator Building Elev. 131' 0"
Plant North Auxiliary Building GB GC Control Building QG1 QG2 Fuel Oil Day Tank 25A 25B sp.
Combustion AlrIntake Exhaust Silencer Exhaust Fan AirDryer QG3
.9.",(4r';
2 B Starting Air Package Room Air Intake Rev. 6 December 1992
Appendix R Reconstitution Project Issues Identified Issue::I(f5,;,::
!Loss; of::,EW, S, stem::Inveiitoi,,!:,';.,:,::.-;"
P Evaluation Findin s:
1} During shutdown from a fire in the Control Room, B Train Essential Cooling Water (EW) will be "cross-tied" to Nuclear Cooling Water {NC). It was determined that ATrain EW cross-tie Motor Operated Valves {IIOVs)could spuriously open. This con-dition could result in loss of EW inventory through the Surge Tank.
P Interim Measures:
1} Emergency Lighting Compensatory Measures are in effect for the A Train EW MOVs (which do not have fixed 8-hour Emergency Lighting).
IP Lon -Term Corrective Actions Taken:
- 1) Revised "Control Room Fire" Procedure, 4xAO-xZZ44, to include Operator Actions to ensure the A Train EW MOVs are closed and de-energized prior to establishing the EW/NC cross-tie.
4 Lon -Term Corrective Actions Remainin 1} PCR 91-13-QD-002:
Will provide 8-hour Emergency Lighting for the A Train EW MOVs.
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Appendix R Reconstitution Project Issues Identified Issue P6 - 'P. Panel Control Circuits/:::,:,;.,:.';.:-::
- .,Damper Closure in.,Opposite. Train".:.:-
P Evaluation Findin s:
- 1) Control Bldg. El. 100'ire Protection (FP) Control Cabinets and associated wiring are configured such that the cabinets process suppression and detec-tion signals for both Safe Shutdown (SSD) Trains. The circuits for both trains are not separated by a fire barrier. Afire in eithier Train could cause spurious actuation of the C02 suppression system and close fire dampers in the opposite Train. This could result in the loss of Essential (HVAC)cooling supporting operability of SSD Equipment.
4 Interim Measures:
- 1) Inactivated the automatic function of the A Train Suppression System (Control Bldg. El. 100').
2)
Revised the Pre-Fire Strategies Manual to provide Operator Actions for an A Train Fire:
A) To manually activate the C02 suppression for a fire in the A Train ESF Switchgear Room.
B) To restore Essential HVACcooling (open doors and dampers) in the B Train (for a fire in the A Train ESF Switchgear Room, Channel A DC Equipment Room, Channel A Battery Room, and Stairwell "C".
3)
Established a Fire Watch for the unprotected Fire Panel circuits on the A Train side of Control Bldg. El. 100'. (ATrain ESF Switchgear Room, Channel A DC Equipment Room, Channel A Battery Room, and Stairwell "C").
4 Lon -Term Corrective Actions Remainin PCR 92-1 3-FP-001:
Re-configures the existing Fire Detection/Suppression system (Fire Panels and associated wiring) for the Control Bldg. El. 100'o provide full Train separation) 7139$
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PVNGS Pre-Fire Strategies Manual Control Building Elev. 100' 0"
Emergency Equipment Cabinet Plant North Auxiliary JA Building cable Shalt HVAC Chase J8 Jc Room DC Channel Battery Room Equip.
'D'hannel'C'oom JD JE Cable HVAC Chase QJt-Radwaste Building Switchgear 4A S
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10B a4 Remote Sr 98 Sh td Salas Rooms ESF Swltchgear Room. Train B Switchgear HVACChase Rev. 6 December 1992
Appendix R Reconstitution Project Issues Identified
,Issue/?:.:-..::;.,;:.-;;As'sociate'tI;-;.Cir'cuits:,;.Conini'on:;PovIIer, P Evaluation Findin s:
1)
For fires both inside and outside the Control Room, Non-Safe Shutdown (NSSD "associated" circuits that share a common power source with Safe Shutdown (SSD equipment were found that do not have coordinated isolation devices (re ays, fuses, or circuit breakers) in each leg of the circuit. This condition could cause a loss of power to the SSD equipment if a fire-induced fault occurs in the "un-fused" leg of the NSSD circuit.
Based on the lack of electrical protection in the associated NSSD circuits, a single fire could potentially disable both Trains of SSD Components.
P Interim Measures Taken:
- 1) Compensatory Measures (Fire Watches) have been established for all Fire Zones where both A and B Train cables are routed.
- 2) An evaluation of all affected panels has been performed to determine the extent of the condition and whether:
2A) A Design change (to add electrical protection) is required 2B) Operator actions willmitigate the consequences of a fire 2C) lfthere is no impact to Safe Shutdown (SSD)
- 3) Revised the "Control Room Fire" Procedure, 4xAO-xZZ44.
P interim Measures Remainin
- 1) A revision is in process to the Pre-Fire Strategies Manual to provide Operator Actions (fuse replacement in some cases) required to restore power to affected SSD components.
P Lon -Term Corrective Actions Remainin PCR 93-13-ZZ-001:
Re-configures (adds fuses) to (4) AuxiliaryRelay Cabinets to ensure availability to power for SSD loads.
Issue 47 - Associated Circuits/Lack of Fuses "Typical Circuit Configuration" Causing Loss of Both Trains of SSD Equipment From a Single Fire Train "8" DC Control Center This breaker could trip causing loss of power to safe shutdown load Fuse is needed here Postulated Fire in Train "A" Fire Zone Fire-induced fault t
In' Lnn
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-- " Shutdown Load 7/I2IIO bwo 7
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Appendix R Reconstitution Project Issues Identified Issue ¹8.;.-;;:::.'..'Loss',of;:Essential;;HVAC to:A::;Train=:,:;:::,'.
IIt'valuation Findin s:
- 1) For a fire (concurrent with a LOP) in MSSS Bldg. El.
100'120'Fire Zone 74B), rendering the B Train AF Pump inoperable, PVNGS relies on the A Train Turbine Driven AF Pump to achieve Safe Shutdown (SSD). An unprotected (electrically or physically) control cable, associated the the A Train Essential ACU, is also located in Fire Zone 748. A short to ground in the circuit can cause loss of cooling to the A Train AF Pump Room, potentially rendering the pump inoperable in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> 30 minutes.
P Interim Measures:
1} Compensatory Measures (Fire Watch) has been established for the unprotected control circuit in Fire Zone 74B.
- 2) The Pre-Fire Strategies Manual has been revised to include Operator Actions (fuse replacement) to restore power to the A Train AF Pump Room Essential ACU.
P Lon -Term Corrective Actions Remainin 1} PCR 88-1 3-HA-003, DCP 13FE-HA-046:
Re-configures the control circuitry (additional fuse) for the A Train AF Pump Room Essential ACU.
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PVNGS Pre-Fire Strategies Manual Main Steam Support Structure Plant North Elevation 100' 0"
Turbine Driven Pump Aux. Feedwater carbine Package Motor Driven Pump 73 3 Hour Watertight Doors 24" 0 Main Feedwater Emergency Hatch From Auxiliary Feedwater Pump Elevation 120' 0"
Elevation 140' 0"
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Appendix R Reconstitution Project Issues Identified Issue:,¹S.;-:;.;:,:Loss;,:of::,.8,;;:Tr'airi v4 ">',~~'...y'~'>.'>
P Evaluation Findin s:
- 1) For a fire in the Control Room (concurrent with a LOP) fire-induced faults could occur in control power circuits prior to re-positioning transfer switches at local stations to isolate B Train Safe Shutdown (SSD) Control Room circuits. This condition could cause loss of control power to the B Train DG Output Breaker, DG Control Panels and DG Room Essential Exhaust Fan. The B Train Diesel is relied upon to achieve and maintain SSD for a Control Room Fire.
P Interim Measures:
- 1) Revised "Control Room Fire" Procedure, 4xAO-xZZ44, to instruct Operators to make the Diesel Genertor Train B Transfer Change-overs as some of the first Operator Actions performed after evac-uation of the Control Room. In addition, Operator Actions required to manually close breakers to restore the B Train Diesel Generator and Essential Exhaust Fan were provided.
IP Lon -Term Corrective Actions Remainin
- 1) PCR 93-13-PE-001:
Re-configures the circuitry (adds fuses) to isolate the B Train DG Breaker, DG.Control Panel, and DG Essential Exhaust Fan from the Control Room.
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Appendix R Reconstitution Project Issues Identified
- Issue 410.::-:.Additi'onal:Emeige'nc j::Lightin'g'Re 'Uirements P Evaluation Findin s:
- 1) Calculation13-MC-FP-316, "Manual Action Feasibility", generated during the Appendix R Reconstitution, determined two conditions exist that require additional fixed 8-hour Emergency Lighting to perform Safe Shutdown actions:
1A) ln order to perform a symmetric cooldown using Train B Aux.
Feedwater (AF) System, 1 of the 4 Train A AF discharge valves needs to be closed and it's power supply breakers opened. The breakers can be opened in either the Channel A or Channel C DC Equipment Rooms (Fire Zones 7A or 6A resp.). Emergency Lights for these Fire Zones are powered from the same circuit breaker.
Although Fire Zone 6A is equipped with an additional "bug-eye",
a fire in 6A could disable Emergency Lighting in 7A, where the manual Operator action would be required.
1B) To achieve Safe Shutdown for fires outside the Control Room, the main power switch supplying the Pressurizer Spray Control valves must be opened in the Control Room to fail the valves closed. No fixed 8-hour Emergency Lighting exists at the panel housing the main power switch.
'j'nterim Measures:
- 1) The "Control Room Fire" Procedure, 4xAO-xZZ44 and the Pre-Fire Strategies Manual contains guidance for Operators to carry portable lanterns for outside areas and in the event fixed Emergency Lighting may not be available.
Lanterns are staged in the Units and inspected on a monthly basis.
P Lon -Term Corrective Actions Remainin 1)
PCR 93-13-QD-001:
1A) Re-configures circuitry (to provide separation for the Emergency Lighting located in Fire Zones 6A and 7A).
1B) Provides 8-hour fixed Emergency Lighting for the Pressurizer Spray Control valve's main power switch located in the Control Room.
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Emergency Equipment Cabinet Plant North.
Auxiliary JA Building cable HVAC Chase JB Jc Battery Room Channel'C'oom DC Channel Equip.
'D'oom JD JE Cable HVAC Chase QJ1 Radwaste Building QJ2-Switchgear SP48~< >r,",( ~<~//".(1 tibet C /
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Mlssile-Proof Battery HS 888 Door Room Channel t40 Bette DC sn to?
Room Outshfe Roo 1 OB 'B'h e4 Remot ~
S 4108 sn 88 Shutdown Rooms Cable Shaft ESF Swltchgear Room. TraIn B Swltchgear HVACChase Rev. 6 December 1992
PVNGS Pre-Fire Strategies Manual Control Building Elev. 140' 0"
Plant North D
HVAC Chase Cable Chase Main Control Room Emergency Equipment Cabinet J1 CIIII 15 "A"
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~F.1 0 SP 117 P.11 Shift Supv.
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Radwaste Building Spare SCBA Bottles HVA h
Computer Room
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Appendix R Reconstitution Project Scheduled Implementation Window of Plant Modifications tss'ue If/Subject
- 1. Loss of RCP Seal injection
- 2. Loss of Essential HVACEquipment Rooms
- 3. Loss of RCS Sampling Capability
- 4. A8 B Train Cables in DG Stairwell
- 5. Loss of EN System inventory
- 6. Fire Panel Control Circuits/Damper Closure in Opposite Train
- 7. Associated Circuits, Common Power Supply/Lack of Fuses L Loss of Essential HVACto A Train AF Pump Room
- 9. Loss of B Train Diesel Generator Control Room Fire Repohability LER 91-008 LER 9141 1 Not Reportable Not Reportable Not Reportable LER 92410 LER 93405 (Being processed)
LER 92415 PCR fi 91-13CH404 91-13-HJ 92.13-SS401 92.13.FB401 92.13.FP401 93 13.ZZ401 6615HA 9313 PE401 cycle 1NS U1 2NS U2 3NS U3 1RS Ui 285 U2 3RS U3 1R6 U1 2R7 U2 3R6 U3 1NS U1 2N6 U2 3NS U3 1H4 U1 2NS U2~
3H4 U3 1N6 U1 2H6 U2 3HS U3 1RS U1 2R6 U2 3RS U3 1N5 U1 2NS U2 3NS U3 1RS U1 2RS U2 3RS U3 il94 NI 1i9J 1$
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2J96 997 3J97$ 556ia 6l97
- 10. Additional Emergency Ughting Requirements 931%8401 1HS U1 2H5 U2 3NS U3 61666 SCHE01
Appendix R Reconstitution Project Page1 of 2 New and Revised Appendix R Deviation Requests Pending NRC Approval Following is a summary of the new and revised deviations listed by the applicable UFSAR section.
P 98.2.0.F:
(Submitted to NRC April 29, 1993)
A new generic deviation. During the post-fire shutdown reactor coolant system process variables may exceed the limits de-scribed in 10 CFR 50 Appendix R, Section III.Land the guidance provided by Generic Letter 86-10. There is no adverse effect on the ability to achieve and maintain safe shutdown in the event of any postulated fire as a result of this deviation.
4 98.2.1.8.5:
(Submitted to NRC April 29, 1993)
Adds detail regarding circuit separation between two Fire Zones (Fire Zone 86A and 86B), in the dead space compartment between the AuxiliaryBuilding and Control Building. The Fire Barrier separating these two zones remains unchanged and provides adequate separation.
te 98.2.2.8.2:
(Submitted to NRC April 29, 1993)
Clarification to the deviation for the Train B, Zone 86B, east wall adjacent to the Corridor Building providing more detailed information in circuits located in the Corridor Building. Barrier separation remains the same.
P 98.2.3.8.3:
(Submitted to NRC April 29, 1993)
Credits one additional operator action (isolation of main steam) in the Control Room on the same control board as the reactor trip, prior to Control Room evacuation. This additional action prevents a very unlikely series of events, which includes spurious actuation and failure of specific automatic functions.
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Appendix R Reconstitution Project Page 2 of 2 New and Revised Appendix R Deviation Requests Pending NRC Approval it: 98.2.15.8.2:
(Submitted to NRC April 29, 1993)
Discusses the addition of the Train E charging pump to the analysis. The separation of the Train E Pump Room is the same as that for the Trains A & B Pump rooms.
h': 98.2.15.8.8:
(Submitted to NRC April 29, 1993)
Provides clarifications on details of the AuxiliaryBuilding separation and protection within Fire Area XV. Credit is taken for the 100'loor as a barrier. Combustible loading in pipeway below at 88's very low such that it does not present an exposure fire hazard to cables and equipment required for safe shutdown located at the 100'levation.
4 98.2.2..1.C:
(Submitted to NRC June 29, 1992)
The fire suppression system in Fire Area II, Fire Zone 14, Lower Cable Spreading Room, is installed for the protection of cable trays, but not at the ceiling level for full are protection.
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FIRE PROTECTION QUALITYASSURANCE JCO CLOSURE OVERVIEW I.
"Following the issuance of the referenced inspection
- report, an NRC/APS Enforcement Conference regarding emergency lighting was held on July 10, 1990.
During the course of the meeting the NRC had questions regarding the application of quality assurance requirements to the PVNGS Fire Protection Systems.
As a result, APS was requested to provide a justification for continued operation of the PVNGS Fire Protection System Equipment."
"NRC questioned the application of quality assurance requirements to the PVNGS Fire Protection Systems and equipment.
The essence of these questions is that the Quality Assurance program for fire protection systems that are described in UFSAR Section 9.5.1 has been applied inconsistently..."
(Quote from APS Letter 161-03338-WFC/RAB to NRC Region V dated 7/13/90 which transmitted preliminaiy response to JCO request.)
In conclusion, the JCO was issued because Quality Assurance Program for fire protection systems was applied inconsistently.
II.
The JCO identifies programmatic deficiencies in application of quality assurance to fire protection systems.
The quality assurance requirement for fire protection program is identified in Appendix A to BTP 9.5-1.
UFSAR identifies methods by which APS complies with BTP 9.5-1 QA criteria.
The foHowing systems and equipment fulfillAPS commitments for fire protection:
1.
2, 3.
4.
5.
6.
7.
8.
9.
Fire Protection Suppression and Actuation System.
Fire Detection and Alarm System.
Lube Gil Collection System.
Emergency Lighting System.
In-Plant Communication System.
Lightning Protection.
Ventilation.
Manual Firefighting Equipment.
Deficiencies between the fire protection quality assurance program and quality assurance program stated in Appendix A to 9.5-1 for each system was identified in the JCO.
Fire Protection Quality Assurance JCO Closure Overview Page 2 of 5 III.
Classification ofPVNGS Fire Protection Systems at the Time ofInitiation ofthe FP QA JCO.
The following table provides the quality classification for PVNGS fire protection systems/equipment at the time of initiation of the JCO.
~Eui ment uali Class Fire Protection Suppression and Actuation System Fire Detection and Alarm System Equipment Fire Barriers Lube Oil Collection System Emergency Lighting System In-Plant Communications System Lightning Protection Ventilation Manual Firefighting Equipment QAG'"
QAGQx3)
QAG" QAG'"
QAG'"
NQR NQR NQR NQR Hoses & Nozzles Self-Contained Breathing Apparatus (SCBA)
Fire Extinguishers Portable Fire Protection Equipment With the exception of fire hydrants, some remote/manual controls and indication circuits and water storage tanks which are NQR.
With the exception of security system portions of the alarm system.
The equipment was NQR but upgraded to QAG prior to the JCO.
IV.
Activities Completed to Meet the BTP 9.5-1 QA Criteria 2.
Developed Operations QA Plan which identifies QA requirements for fire protection and cross references to BTP 9.5-1. (Appendix F-1)
I Developed Fire Protection Progiam procedure to establish organization and administrative responsibilities for the program.
3.
Updated UFSAR Table 9.5-1 to reference Operations QA Plan and to clarify PVNGS compliance to BTP 9,5-1 Appendix A requirements.
4.
Developed ten (10) Engineering Studies to determine the quality classification for fire protection equipment and components and to address actions required to bring the appropriate equipment into compliance with the QA requirements.
'Fii'e Protection Quali surance JCO Closure Overview Page 3 of 5 5.
Implemented actions required by the ten (10) studies to bring the fire protection systems into compliance with QA requirements.
These actions include the following:
ao Updated SIMS with the correct quality classification for the fire protection systems and components. (CAR 90-0010) b.
Updated applicable design and vendor documents (included but not limited to drawings, vendor
- manuals, specifications, procurement specifications) to the correct quality classification for the fire protection systems and components.
C.
Updated UFSAR Table 3.2-1 to reflect the correct quality assurance criteria for fire protection systems and components.
(CAR 90-0020) d.
Reviewed Outstanding Design Changes to ensure correct quality classification is utilized. (CAR 90-0020) e.
Reviewed open work document to ensure correct quality classiGcation is implemented.
Developed a comprehensive fire test program to ensure that Gre protection systems are inspected and/or tested in accordance with the requirements of Appendix A to BTP 9.5-1 and the applicable NFPA codes.
Revised fire protection Impairment Program to include applicable fire protection system components.
(CAR 90-0020) h.
Revised and/or developed Preventive Maintenance procedures to reflect the correct quality classification.
Implemented Design Changes as necessary to meet the requirements of Appendix A to BTP 9.5-1.
This is specific to Emergency Lighting only.
~Performed Adequacy Assessment Walkdowns as necessary to determine if the systems are designed and installed to perform their intended function.
k, Completed identification of fire barriers in SIMS. (CAR 90-0007)
Completed a safe shutdown/spurious actuation analysis.
I e
>Fil'e Protection Quali surance JCO Closure Overview Page 4 of 5 m.
Revised the Design Change process to involve fire protection engineering whenever FP systems or components are affected or when the fire hazards analysis is impacted.
n.
Revised Fire Department training procedures to meet the requirements of BTP 9.5-1, Appendix A (14DP-OTROI).
o.
Performed FTs or PMs as applicable to verify adequacy of fire protection systems and components to perform its intended function.
P.
Closed technical issues identified within the body ofthe JCO letter 161-00349-WFC/RAB. These technical issues were:
1) 2)
3) 4)
5)
Diesel fire pump fuel freeze protection.
Preventive maintenance on charcoal filter temp. sensors.
Resolution of compliance with IN 89-52.
Completion of CAR 90-0007.
Adequacy of periodic testing of lightning protection system.
q.
Responded to QA JCO assessment recommendations.
V.
Validation Effort Closure documents associated with JCO were reviewed or sampled for adequacy of closure by an integrated team of QA, Fire Protection, and Engineering personnel.
2.
This included 195 RCTS actions and 352 Study Actions.
3.
Inconsistent or unacceptable closures were addressed or put on a corrective action document for further evaluation.
4.
Compensatory measure in accordance with fire protection program has been put in place as necessary for the open items affecting the functionality of the equipment.
5.
Provided documented justification for why each remaining open item did not prohibit the liftingof the JCO.
"Fi7e Protection Quali surance JCO Closure Overview Page 5 of 5 VI.
Conclusion Programmatic Issues associated with application of quality assurance program to the Gre protection system and components have been resolved.
Any open issue associated with the fire protection system or component is being followed via a corrective action document in accordance with the FP quality assurance program.
Compensatory measures in accordance with the requirements of fire protection program for an impaired equipment has been placed for the open issues as applicable.
Fire testing and PMs have demonstrated adequacy of the systems to perform their functions.
In conclusion, the JCO which was issued due to inconsistent application of quality assurance program to the fire protection systems and components is no longer necessary.
The JCO was lifted on March 26, 1993, following review and approval by the Plant Review Board and the Director, Nuclear Regulatory & Industrial Affairs.
e' v.
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