ML20024E191
| ML20024E191 | |
| Person / Time | |
|---|---|
| Site: | Bellefonte  |
| Issue date: | 07/07/1983 |
| From: | Mills L TENNESSEE VALLEY AUTHORITY |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20024E184 | List: |
| References | |
| NUDOCS 8308090384 | |
| Download: ML20024E191 (10) | |
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TENNESSEE VALLEY AUTHdWty9C FFGiON lI An.pae G EOR GI A s
CHATTANOOGA, TENNESSEE 37401 400 Chestnut Street Tower II July 7,19631 Jul. m n 9 : 3 9 U.S. Nuclear Regulatory Commission Region II Attn: Mr. James P. O'Reilly, Regional Administrator 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30303
Dear Mr. O'Reilly:
BELLEFONTE NUCLEAR PLANT UNITS 1 AND 2 - RESPONSE TO DEVIATIONS 50-438/83-10-01, 50-439/10-01, PORTIONS OF THE FIRE PROTECTION SYSTEMS DO NOT CONFORM TO THE DESIGN CRITERIA 0F THE APPLICABLE NFPA CODE -
50-438/83-10-03, 50-439/10-03, EXTERIOR FIRE PROTECTION WATER SYSTEM WAS NOT INSTALLED UNDER A QA/QC PROGRAM 438/83-10-05, 50-439/83-10-05, IMPROPER FIRE DAMPER INSTALLATION This is in response to R. C. Lewis' letter dated May 23, 1983, report numbers 50-438/83-10, 50-439/83-10 concerning activities at the Bellefonte Nuclear Plant which appeared to have been in violation of NRC regulations.
Enclosed is our response to the citations. A two-week extension on the submittal of these responses was discussed with Inspector P. Fredrickson of NRC Region II on June 24, 1983 TVA has denied deviation 50-438/83-10-01, 50-439/83-10-01. The NRC staff has taken the position with TVA on other nuclear plants that preaction sprinkler system control valves should be electrically supervised. TVA maintains that NFPA 13 does not require this type of supervision. TVA has elected to request a formal code interpretation from NFPA. We expect to receive the results by November 1,1983 The NRC will be appraised of these findings at that time and, if as a result it becomes necessary, TVA will modify its deviation response appropriately.
If you have any questions concerning this matter, please get in touch with R. H. Shell at FTS 858-2688.
l To the best of my knowledge, I declare the statements contained herein are complete and true.
l Very truly yours, l
TENNESSEE VALLEY AUTHORITY L. M. Mills, nager Nuclear Licensing Enclosure oc: Mr. Richard C. DeYoung, Director (Enclosure)
Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission l
Washington, D.C.
20555 8308090384 830728 983-TVA SOTH ANNIVERSARY
{DRADOCK05000 An Equal Opportunity Employer
ENCLOSURE BELLEFONTE NUCLEAR PLANT UNITS 1 AND 2 RESPONSE TO DEVIATION 50-438/83-10-01, 50-439/83-10-01 PORTIONS OF IEE FIRE PROIECTION SYSTEMS DO NOT CONFORM TO THE DESIGN CRITERIA 0F THE APPLICABLE NFPA CODE Description of Deficiency FSAR Section 9.5.1.1 states that the codes and standards of the National Fire Protection Association (NFPA) will be used in the design of the fire protection system.
Contrary to the above, the following NFPA code deficiencies were identified:
1.
Fire Pumps (a) The fire pump starting circuits are not of the normally closed type and arranged such that breakage, disconnection, shorting of wires, or loss of power to the starting circuits would cause automatic continuous operation of the fire pump which is not in accordance with NFPA-20, Centrifugal Fire Pump, Sections 9-5.2.and 9-5.2.5.
(b) The fire pump relief valves are not provided with a means of detecting flow of water through the relief valves as required NFPA-20 Section 2-12.6.
2.
Automatic Sprinkler Systems (Fire Pump and Diesel Generator Buildings)
(a) The electrical circuits f rom the fire detection control panels to the sprinkler system actuation panels for the preaction control valves are not electrically supervised as required by NFPA-13, Sprinkler Systems, Section 5-3.5.4.
(b) The sprinkler piping systems are not supervised as required by NFPA-13 Section 5-3.5.4.
l TVA Response 1( a).
Admission or Denial of Deviation TVA denies the deviation occurred as stated.
l
] Lessons fer D nia.1 The fire pump actuation circuits are routed f rom two fire detection control-
. panels in the auxiliary instrument rooms through the Solid-State Control System (SSCS) cabinets to the fire pump controllers. The starting circuits from the SSCS cabinets to the pump controllers are wired to nomaally closed contacts and are arranged such that breakage, disconnection, or loss of
-power to the starting circuits will cause automatic continuous operation of the fire pumps. Circuits f rom the fire detection panels to the SSCS cabinets are wired to normally open contact and f ailure of these circuits will not cause automatic start of the fire pumps. However, if an input signal to the detection panels requiring fire pump start f ails to generate a corresponding output to the SSCS, the control room operator is notified that an alarm condition exists on that panel. This is tranmaitted over a-common alarm circuit from the detection panels to the Data Acquisition and Control, Operation Recording, Annunciation, Data Logging, Access Control, and Fire Detection System (DA00ADA). Appropriate manual actions will then be taken to start the fire pumps. All input signals to the detection panels are supervised.
In addition, the fire pumps can be started f rom the main control room through the SSCS.
If the SSCS should f ail, the fire pumps can also be started by-an emergency bypass switch located in the immediate vicinity of the SSCS cabinets. This switch is a normally closed contact and the circuit is arranged such that any breakage, disconnection, or loss of power will cause automatic continuous operation of the fire pumps. The fire pump controller is also wired so that a loss of power to the controller will cause autanatic continuous operation of the fire pumps.
TVA believes that the unique arrangement of the Bellefonte Nuclear Plant's SSCS in conj unction with the level of supervision of fire detection input circuitry to the detection panels and plant operating procedures provide a level of protection that meets the intent of NFPA 20-1976 (FSAR Code of Record).
TVA Response 1(b) i i
Admission or Denial of Allemed Devision TVA denies the deviation occurred as stated.
Reasons for Denial The present configuration allows the relief valves to discharge into a short run of 6-inch piping that connects to an overhead 12-inch header which carries the discharge to yard drainage. A 1/2-inch open-ended line taps into the 6-inch line and releases a portion of the relief valve discharge into an open funnel that also discharges to the yard drainage system.
Since this arrangement permits a visual detection of relief valve operation, it is TVA's opinion that the intent of NFPA 20-1976 has been t
met.
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TVA Ra scons, 2(a)
Admission or Denial of Allened Devision TVA denies the deviation occurred as stated.
Reasons for Denial NFPA 13-1976 (FSAR Code of Record) section 5-3.5.2 only requires fire detection devices to be supervised. It is TVA's position that this section does not require electrical supervision of the circuits from the fire detection control panels to the sprinkler system preaction control valves. At Bellef onte, the fire detectors, pressure switches, and fire pump start switches associated with the preaction and deluge systems are monitored by class A supervised circuits in accordance with NFPA 71D-197 and NFPA 72E-1974. IVA f eels that this level of supervision meets the requirements of NFPA 13-1976, section 5-3.5.2.
In addition, the contacts of the breakers which supply power to the solenoids that actuate the preaction and deluge valves, the circuits providing power to the fire protection panels, and the circuits from the panels to the pressure switches downstream of the valves are all electrically supervised. The pressure critches provide control room i
indication of valve status'.
Therefore, failure of any suppression valve to open in a fire alarm condition will be indicated in the main control room.
Appropriate actions would then be taken by the fire brigade to manus 11y actuate the valve at the local control valve station.
TVA Response 2(b)
Admission or Denial of Allened Deviation IVA denies the deviation occurred as stated.
Jessons for Denial All preaction sprinkler systems at Bellefonte, including those in the j
diesel generator and fire pump buildings, are supervised by pressure rritc'nes downstream of the system control valves. The pritches provide annunciation in the Main Control Room anytime a control valve opens and water is admitted into the sprinkict sy s t em s.
The preaction sprinkler systems covering areas of the plant containing l
Class 1E motor control centers and auxiliary control panels are also provided with low pressure air supervision. The systems have pressure i
switches that provide main control room annunciation indicating when the integrity of the piping systems have been lost.
Both types of supervision were provided in the sprinkler system design out of concern for release of water in saf ety-related areas of the plant.
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I Proccuro switth sypsrvicica corpled with norac11y dry hsedars downstroca cf the control valves, closed sprinkler heads,. seismically designed components, and control valve actuation by cross-zoned fire detector i
provides a high degree of assurance that water damage to safety-related equipment cannot occur due to spurious sprinkler system operation. Air supervision was provided as an added degree of assursace around critical electrical equipment that is very susceptible to water ammage. This philosophy was part of the original fire hazard analysis and was based on defense in-depth approach instead of a rigorous analysis.
Therefore, it is ~1YA's position that adequate supervision of all sprinkler system piping is provided in accordance with NFPA 13-1976, Section 5-2 and 5.3 (FSAR Code of Record).
NOTE: NRC's ref erence to NFPA-13 Section 5-3.5.4 is based on a more recent issue of the code and '1VA believes that our ref erence to NFPA-13 Section 5-3.5.2 is identical.
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Bal,EFONTE NUCLEAR PLANT UNITS 1 AND 2 RESPONSE 10 DEVIATION 50-438/83-10-03, 50-439/83-10-03 EXTERIOR FIRE PROTECIION WATER SYSIEM WAS NOT INSTALLED UNDER A QA/QC PROGRAk Description of Deficiency FSAR Appendix 9.5 A, Section C, identifies the quality assurance program to be applied to the design and construction of the fire protection systems at Bellefonte to ensure a reliable and quality product. IVA drawing 7YWO400-RS-01 is marked to indicate that the exterior fire protection water rystem is to be installed under a quality assurance program.
Contrary to the above, the exterior fire protection water system was not installed under a quality assurance program.
TVA Response
_ Admission or Denial of Alleged Deviation TVA admits the deviation occurred as stated.
Corrective Steps Which Have Been Taken and Results Achieved TVA acknowledges that construction activities for all the exterior fire protection piping systems shown on TVA drawing No. 7YWO400-RS-01 have not been installed in accordance with a fire protection quality assurance program.
It is our position that the program applies only to those f eatures which may aff ect fire protectica for saf ety-related areas of the plant. Thus, only those f eatures required f or the perf ormance of the fire protection system in the saf ety-related structures or adj acent non-saf ety-related structures where an uncontrolled fire could af f ect safety-related structures should f all under the quality assurance program.
1.
TVA has initiated the designation of Q* (which denotes a limited j
quality assurance for systems not requiring complete compliance with 10 CFR 50 Appendix B) on all applicable fire protection system drawings in l
accordance with TVA's Division of Engineering Design Engineering Procedures (EN DES-EP) 4.25, revision 3 (issued March 24, 1980) and EN
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DES-EP 3.09, revision 2 (issued October 28, 1980), and defined the Q*
l boundaries on the applicable design criteria diagrams under engineering change notice (ECN) 1357 on September 14, 1981. In addition, IVA has issued General Construction Specification G-73 (G-73), ' Inspection, l
Testing, and Documentation Requirements for Fire Protection Systems and Features,' dated March 16, 1982.
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2.
EN DES uill issco EN DES-EP 1.55, Limited Firo Protootion Quality Assurance Program, which will define what organizations are responsible for defining fire protection quality assurance boundaries on design drawings and will state the general criteria f or establishing these bounda ries. Subsequently, a review of all Bellef onte dra< wings that f all under the fire protection quality assurance program for conformance to the procedure will be made. Amy deficiencies will be
- corrected through drawing revisions.
3.
EN DES is reviewing the construction procedures and instructions in effect during the period f rom December 1,1977, to March 16,1982,. for compliance with the intent of G-73.
All nonconforming items will be documented and appropriately dispositioned.
4.
The Division of Construction (CONST) will review all Bellef onte drawings under Fire Prot ection Quality Assurance Program and will i
verify that adequate gnklity assurance records exist in compliance with G-73 for installations after March 16, 1982, and in compliance with the intent of G-73 for installations between December 1,1977, and i
March 16,1982. All nonconforming items will be documented and appropriately dispositioned.
Corrective Steos Taken to Avoid Further Deviations Full implementation of the proposed engineering procedure and the existing general construction specification should prevent further deviations at i
Bellefonte.
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TVA will evaluate the adequacy of the fire protection quality assurance boundaries and the required documentation-on.other active nuclear plants.
i If problems are identified, they will be corrected in a manner similar to the actions outlined above.
Action to be Taken or Planned to Imorove Manamement Control Effectiveness As previously stated in the TVA response above, TVA attempted t'o initiate the requirements of the fire protection quality assurance program through the issuance of TVA memorandums. At the time, this appeared to be the most expedient method to establish QA requirements consistent with our l
commitment in Helleronte b3AK Appendix 9.5A, section C.
TVA acknowledges that memorandums are not appropriate to establish a f ormal quality assurance program.
Consequently, TVA initiated action to correct this problem by establishing Fire Protection Quality Assurance-requirements in the Office of Engineering Design and Construction (OEDC) Program Requirements Manual (PRM) No. 2QAI-2 issued on June 29, 1982. Addi-l tionally, TVA is reviewing EN DES-EP 1.55 which will be issued by August 1, 1983. The issuance of these documents will formally establish a quality assurance program beginning with the upper tier OEDC level program j
requirement s.
EN DES-EP 1.55 will formally establish the requirements f or l
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d3 sign end prec"trensnt cativities within EN DES, and G-73 feraclly sstablishoa the rsquiremsnts fcr co trel cf thoso activition eithin CONST.
These actions are considered adequate to prevent recurrence and no additional action beyond those listed above and the corrective actions for this specific finding are planned.
Date When Full Compliance will be Achieved The corrective actions listed above will be completed by July 1,1984.
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l BELLEFONIE NUCLEAR PLANT UNIIS l' AND 2 RESPONSE 'IO DEVIATION 50-438/83-10-05o 50-439/83-10-05 IMPROPER FIRE DAMPER INSTALLATION Descriotion of Deficiency FSAR Appendix 9.5 A Section C.2 states that the design, installation, inspection, and tests associated with the fire protection systems are
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accomplished in accordance with written and approved instructions, procedures, and drawings. WA drawing 3AWO910-00-01 Note 29 states that the fire dampers and sleeve assemblies for
- ire barrier penetrations will be installed per.. vendor installations and 'SNAGA' standards.. The vendor's fire damper documents require the dampers to be attached to the damper sleeve by -welds, bol ts, scr ew s, or rivets spaced no more than 8-int.hes on center on all sides of the damper assembly.
Contrary to the above, the fire dampers are not installed in accordance with manuf acturer's specifications in that the dampers are attached to the sleeve by tack welds spaced 12 inches on conter and located only on one side of the damper assembly in lieu of. the required 8-inch spacing on all sides of the assesbly.
TVA Resnonse Admission or Denial of Deviation WA admits the deviation occurred as stated Corrective Steos Which Have Been Taken WA's Division of Construction (CONST) has halted installation of all types of fire dampers until this concern is resolved. CONST ha s reque st e d the t -
WA's Division of Engineering Design (EN DES) obtain vendor instructions for installation of all types of fire dampers used on site. Bellef onte Mechanical Engineering Unit generated nonconformance report (NCR) 2391 to document the as-built installation of the dampers to allow EN DES to determine if the present installation is adequate cto meet all requirements.
Q)NST wi11' rework all dampers as required by the disposition to NCR 2391.
Corrective Stoos Taken to Avoid Further Deviations Q)NST personne1' installe 1 fire dampers per 'SMACNA' standards which were referenced on TVA drawings.
IVA considered this adequate requirements for installation of fire dampers. This interpretation of the requirements for i
installation was ~not a f ailure to meet these requirements but rather an
- incorrect decision that 'SNAmA' would satisfy vendor installation r equir ement s.
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'1VA G-73 issued March 16,1982, includes requirements to ensure that CONST personnel use all applicable EN DES-approved design drawings and/or the EN DES-approved manuf acturer's instructions when installing fire danpers.
Date When Full Compliance will be Achieved A.
Investigation by EN DES on 'SMAGA' versus vendor's requirements will be cceplete by December 1,1983.
B.
Any rework required by the disposition of NCR 2391 should be corrected by December 3,1984.
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