ML20080P700

RO 83-023 Responding to NRC Re Fire Damper Discrepancies.Fire Protection Sys Designed Per 10CFR50 App R Mods to Protect Safe Shutdown Sys.Audit Verifying Fire Protection Criteria Implemented Performed in Early Sept

ML20080P700
Person / Time
Site:	Crystal River
Issue date:	10/03/1983
From:	Westafer G FLORIDA POWER CORP.
To:	Robert Lewis NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
3F-1083-01, 3F-1083-1, RO-83-023, RO-83-23, NUDOCS 8310070307
Download: ML20080P700 (8)

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October 3, 1983 3F-1083-01 Regional Administrator, Region II Attention: R. C. Lewis, Director Division of Project and Resident Programs U.S. Nuclear Regulatory Commission 101 Marietta Street, N.W., Suite 2900 Atlanta, GA 30303

Subject:

Crystal River Unit 3 Docket No. 50-302 Operating License No. DPR-72 Licensee Event Report No.83-023 Gentlemen:

Florida Power Corporation (FPC) offers the following responses to your letter of August 17, 1983, concerning fire damper discrepancies at Crystal River Unit 3 (CR-3).

Item 1: Provision of sufficient justification to assure that no additional design and construction deviations exist on the fire protection systems and features provided for the safety-related areas of the plant.

Response 1: Since January 1,1971, thirty-seven (37) separate audits /

inspections of the CR-3 fire protection systems and features have been performed. Sixteen (16) of these inspections were performed by the Nuclear Energy Property Insurance Association (NEPIA); nine (9) inspections were performed by the NRC; five (5) inspections by an outside fire protection consultant, Professional Loss Control l (PLC); and seven (7) inspections by American Nuclear Insurers (ANI). These inspections / audits did not reveal any generic design deviations in the CR-3 fire protection l systems and features. A chronology of CR-3 fire inspec-tions/ audits is provided in Attachment 1. Summaries of the NRC and PLC inspection / audit reports are provided in Attachment 2. ,

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General Office 3201 Thirty-lourth Street South e P.O. Box 14o42, St. Petersburo. Florda 33733 e 813-866- g/

l R. C. Lewis October 3, 1983 J Page 2 During construction, Gilbert Associates drawings were sent to NEPIA for review and approval. No generic deviations in the CR-3 fire protection systems and features were identi-fied by this design review. In addition NUS Corporation performed two reviews of the CR-3 fire protection systems and features (1976 and 1977) and identified no generic deviations in the CR-3 fire protection systems- and features.

As a result of the discrepancy identified on June 13, 1983, FPC personnel have conducted an investigation and walkdown which resulted in the additional discrepancies described in LER No.83-023.

New fire protection systems and features are being designed by qualified fire protection engineers as a result of 10 CFR Part 50 Appendix R modifications to protect safe shut down systems. The new fire protection systems and features will add to or completely replace existing systems, thus lessening the probability that any generic design devia-tions exist at CR-3.

Proposals are being reviewed in-house to commission a new Fire Protection Program Review by a consultant independent of the one who performed the original review to assure FPC that no generic design or installation deviations exist in the CR-3 fire protection systems and features and to comply with the applicable provisions of Appendix R.

Item 2: Performance of sufficient quality assurance audits of your architectural and engineering organizations to assure that adequate design control is provided in the area of fire protection.

Response ~2: Gilbert Associates was the original plant design agent and has been the primary engineering firm used for the design of backfit modifications, including any related to fire protection. The only design work related to fire protec-tion not performed by GAI are as follows:

a) NUS: During preparation of FPC's response to the July 27, 1979 Fire Safety Evaluation Report (SER), NUS designed some fi re stops. This basically took approved methods and applied them to plant specific areas. NUS also designed the Lube Oil Collection System for Reactor Coolant Pump- Motors completed during Refuel IV.

R. C. Lewis October 3, 1983 Page 3 b) Professional Loss Control (PLC): During SER response preparation PLC provided locations for fire detec-tors. GAI performed engineering to implement PLC recommendation.

c) Stone & Webster: Presently working on several Appendix R tests.

FPC internal engineering organizations have not performed design changes to fire protection systems without the assistance of Gilbert Associates. A recent fire protection audit by FPC Quality Programs has identified a weakness in the FPC overall Design Control Program with respect to design changes not classified as safety-related. Interim corrective actions have been taken to assure these design changes consider fire protection adequately. There is no indication that this item has caused any condition that could be a concern from a fire protection perspective. The Fire Protection Program Review identi fied in response 1 above will assure no adverse conditions exist.

The Florida Power Corporation Quality Programs includes requirements for a yearly vendor evaluation to assure their overall corporate quality program meets the requirements of 10CFR50 Appendix B and other FPC regulatory commitments on design. In addition, an annual audit is performed of the CR-3 specific design control program to assure that an effective design control process is in place. This audit is essentially based on ANSI-N45.2.11-1974. Although these audits have not specifically addressed fire protection, fire protection is a design criteria identified to be con-sidered. The process is designed to assure the require-ments for design control are established. The audit assesses the effectiveness of the process. Fire protection criteria are part of the design process just as seismic, environmental, etc. No major findings which could have significantly degraded the program have been made.

In addition, an audit was performed in early September to verify the consideration of fire protection criteria in designs and to evaluate the design process as applied to the design and modifications of fire systems. Fire systems are classified non-safety related and are not subject to a full 10CFR50 Appendix B program. A design control process does exist however that ensures appropriate review of these design drawings.

R. C. Lewis October 3, 1983 Page 4 Based on the above work already performed, FPC believes that the Fire Protection Program at CR-3 is adequate. Continued design verification will be ensured by the new Fire Protection Program Review and quality assuranca audits.

If you have any questions or would desire to meet with us, please contact this office.

Sincerely, y

G. R. Westafer Manager, Nuclear Operations Licensing and Fuel Management Westafer(W01)C5-1 Attachments

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ATTACHMENT 1 CHRONOLOGY OF CR-3 FIRE INSPECTIONS ANI NEPIA NRC PLC Feb. 18, 1971 Sept. 22, 1971 Dec. 10, 1971 Dec. 14-15, 1972 Apr. 30 - May 1, 1973 Aug. 16,27,28, 1973 Dec. 19-20, 1973 Apr. 3-5, 1974 Aug. 1-2, 1974

. Nov. 18-19, 1974 Mar. 25-26,1975 June 26, 1975 Sept. 29-30, 1975 Sept. 29 - Oct.1,1975 Dec. 1, 1975 Mar. 15, 17, 1976 June 23-24,1976 July 20-22 & Aug. 2-5,1977 Dec. 5-9,1977 & Jan.11-12,1978 Apr. 3-6, 1978 April 17-21,1978 Oct. 2-6, 1978 Nov. 28 - Dec.1,1978 Mar. 27-28, 1979 Apr. 9-13, 1979 May 24-26, 1979 Mar. 17-20, 1980 May 26-28, 1980 1

! Nov. 17-20, 1980 Dec. 2-5, 1980 l Mar. 2-4, 1981 May 4-7,1981 Nov. 16-20, 1981 Nov. 17-20, 1981 June 14-16, 1981 Aug. 9-12, 1982 May 3-5,1983 l

Thompson (Attl)ND117

.. . ATTACHMENT 2 PROFESSIONAL LOSS CONTROL (PLC) FIRE AUDIT SUMMARIES

1. " April 1978" - PLC - Annual Fire Protection Inspection Section 2.1 Inspection of Plant Facilities

... an inspection of plant safety related areas was conducted. The emphasis of this inspection was an assessment of the effectiveness of the plant's Fire Protection Program to control fire hazards and maintain fire protection equipment in these areas."

2. April 1979 - Annual Fire Audit The plant audit included general inspections of installed fire supression, fire detection and alarm systems.

3. May 1980 - Triennial Audit 1.0 Introduction "The inspection consisted of a review of the plant Safety Evalu-ation Report, review of procedures relating to fire protection, review of fire brigade organization and training, and an on-site inspection of all plant facilities."

4. March 1981 - Annual Fire Audit The inspection consisted of a review of the plant Fire Hazards Analysis and comparison to APCS BTP 9.5-1 Appendix A, review of procedures related to fire protection, revi ew of fire brigade organization and training, and on-site inspection of plant facili-ties.

5. " June 1982" - Fire Protection Audit Section 3.3 Fire Protection Systems and Equipment "The plant audit included general inspection of the installed water supply and distribution system, fire detection and alarm systems, and fire suppression system."

l Schmiedel(Inspect)DN6-2 Attachment 2 (Cont'd)

NRC FIRE INSPECTION REPORT / AUDIT SUMMARIES

1. September 29 - October 1,1975 (Report No. 75-14): This special inspection was made to inspect the fire prevention and fire protection type activities relating to construction, testing and start-up and early plans for these activities during operation of the plant.

During a walk-through inspection of the plant, attention was directed to the fire protection equipment.

No substantive deficiencies were identified in this inspection of the fire prevention and fire protection activities.

2. July 20-22 and August 2-5,1977 (Report - No. 77-13): The plant was toured to inspect rafety-related areas; examine portions of the fire system; and observe activities related to fire protection.

3. December 5-9, 1977 and January 11-12,1978 (Report No. 77-24): Inspection included a discussion with licensee personnel regarding the FPC response to the NRC BTP on Fire Protection.

4. April 3-6,1978 (Report No. 78-08): The inspector reviewed certain Admini-strative Procedures, Surveillance Procedures, Maintenance Procedures, held discussions with the licensee, and toured certain portions of the plant to determine the status of the fire prevention and protection system. No items of noncompliance or deviations were observed.

The inspector toured various areas of the plant to observe the following:

a. Plant cleanliness

-b. Fuel inspection in the Fuel Storage Building

c. Operating activities in the Reactor Building

d. Fire detection and fire protection systems in various portions of the plant which included the control room, cable spreading room and auxiliary building.

No items of noncompliance or deviations were found.

5. October 2-6, 1978 (Report No. 78-24): The inspectors conducted a preliminary fire protection survey of the plant in preparation for the NRC. Fire Team Site Visit in November 1978.

"The inspector reviewed the results of the latest fire insurance inspection which was conducted on April 17-21, 1978."

"The inspector toured various areas of the facility to observe. .. fire protection / prevention systems and conditions."

6.- November 28 - December 1, 1978: NRC Fire Team Site Visit to review the fire protection program. Revised their list of questions as a -result of their visit. Performed extensive review of site physical fire protection features.

o, Attachment 2 (Cont'd)

7. ' March 27-28,1979. (NRC Fire Team Site Visit): Reviewed some areas of the plant in detail and discussed the draft of the SER for CR-3.

8.- December 2-5, 1980 (Report No. 80-40): The plant was toured to:

A. Review the progress and action on the fire protection commitments made-to the NRC.

B. Assure that the fire protection systems required by Technical Specifica-tion were in service.

C. Evaluate the effectiveness of the implementation of the fire protection administrative control procedures.

9. November 17-20, 1981 (Report No. 81-25): A tour of the plant was made by the inspector to review the fire protection modifications of the detection _ system and reactor _ building standpipe and to review the general fire protection features provided for the plant.

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