ML20096F301
| ML20096F301 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 05/14/1992 |
| From: | Joshua Wilson TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9205210012 | |
| Download: ML20096F301 (9) | |
Text
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nvre J L Whoo Yee Pu:wkot Snxpn ! Acty P rt May 14, 1992 U.S. Nuclear-Regulatory Commission ATIN!
Document Control Desk Washington, D.C. 20555 Gentlement In the Matter of
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Docket Nos. 50-327 Tennessee Valley Authority
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50-328 SEQUOYAH NUCLEAR'PIANT (SQN) - FIRE P!t0TECTION IMPROV-? ENT PIAN QUARTERLY STATUS REPORT A working meeting between TVA and NRC was held at SQN on August 19, 1991, to discuss _the self-identified problems in SQN's fire protection program and the improvement plan efforts initiated by TVA.
The improvement plan consisted of a multi-phase approach to address short-and longer-term
- actions, t.
A status report was generated, following the targeted completion date for Phase 1, to identify progress achieved and evaluate areas needing further action. This quarterly status report is included as Enclosure 1.
Changes to the improvement plan are identified in Enclosure 2.
A detailed evaluation of implementation of a number of specific Phase I actions is being conducted by the Site Quality organization. Results of this ongoing evaluation will also be incorporated into the continuing.
plan implementation, as appropriate.
Revisions to a number of fire protection procedures included in Phase I have not yet been completed as a result of competing priorities. Ongoing procedure revision activities will continue into Phaue II.
F
m U.S. Nuclear Regulatory Commiss?nn Page 2 May 14, 1992 No further actions are being tracked under Phase 1.
Phase 11 efforts have begun and are scheduled for completion by October 1, 1992, with the exception of Act1 n 2-10.
This action, which involves performance of the 9
plant walkdown procedure to update the fire hazards analysis, is being performed in conjunction with Action 4-2, to evaluate penetration seals, i
in an effort to improve the overall schedule.
e current schedule j
includes completion of Action 3-2, to issue the fire hazards analysis, f
and Action 4-2 during Phase III. Any changes to this achedule will be reflected in the quarterly status reports.
If you have any questions concerning this submittal, please telephone
-11. A. Cooper-at (615) 843-8422.
Sincerely,
-5 5/X-L. Wilson Enclosures cc (Enclosures):
Mr. D. E. LaBarge, Project Manager U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852 l
' NRC Resident Inspector Sequoyah Nuclear Plant 2600 Igou Ferry Road Soddy-Daisy, Tennessee 37379 Mr. B. A. Wilson, Project Chief U.S. Nucicar Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 a
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_ FIRE PROTECTION - 1MPROVEMENT. PLAN. - STATU
'PS 'ERIOD ENDINO APRIL 1, 1992 1-1 Special Maintenance-Instruction SMI-0-26-7, " Fire Hazaeds Analysis Walkdown Procedure," was issued on April 1,' 1992. This procedute g
provides instructions to quantify in situ and transient combustibles. A, vendor has been selected to perform _this walkdown and the ensuing calculation update.
The necessity of routine field verification of the fire hazards analysis-(THA) will be evaluated and methods established as appropriate before issuance of the FHA. This action is being added to a'hase III.
1-2 An act!, n e's has been.ieveloped to 'Aentify required actions and completiae Ortes to close NRC Informaston Notice No. 88-04,
" Inadequate Qvalification and Documentation of Fire Barrier Penetration Seals." A vendor has been selected to perform the required actions in order to improve the '-itial schedule provided in the improvement plan.
1-3 A review of corrective action documents (i.e., condition adverse *.o quality reports, significant corre tive action reports, problem evaluation reports, incident investigations, finding identification reports) was conducted. Two documents were identified with compensatory fire watch patrols in place that did not have breaching permits. Required permits have been tenerated and will
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remain open until corrective actions for the specific deficiencies are implemented.
1-4 The document control change management system was reviewed to determine if azogrammatic deficiencies exist. This review
-concluded that the system is functioning'as intended, and changes are not required.
1-5 The Appendix R coordinator is;now notified of design review l
meetings.
Based on the' complexity of the design, the coordinator
-determines the level of involvement required, i.e., if attendance L
at the 10 percent, 50 percent, or 80 percent meetings is
-appropriate.- The coordinator must attend the 80 percent meetings for design changes tnat may impact Appendix R.
1-6 Hydraulic performance evaluations have been completed for the high-pressure-fire _ protection system. Pressures and flows for sprinkler-- systems servicing safety-related areas have been
. evaluated using the projected 40-year pipe degradation, where applicable. Areas specifically calculated were plotted to provide flow curves in order to trend systen performance. As a result of these calculations, incorporating alert values into procedures will
-be addressed in Action 2-12.
Results of these criculations
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-indicate acceptable flows except' for the diesel generator building roof hose stations. As demonstrated by December 1991 testing, this y
area currently exceeds required flow by approximately 20 percent; j
therefore, these results are not of immediate connern.
Long-term w rrective action is being evaluated.
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e LThe minimum flow demands back to the pump have been evaluated for
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safety-related_ areas utilizing the most hydraulically limiting impairment. -Results indicate that sufficient flow is available for each valve.
The system has also been_ evaluated to ensure that overpressure conditions have not.resulted in unacceptable operatice. The replacement of the fire pumps will also implement long-term correction for this conce n.
Calculations performed to implement this commitment were reviewed by a member of the Society of "~re Protection Engineers,iho is a registered professional engine:r
- 1 the state of Tennessee.
1-7 The new fire detection central azarm system has been installed and tested.
Human factors, lucluding volume control, have been incorporaied.
The system is operating very well.
1-8 The_ review process for fire protection requirements in design change packages has been enhanced. Training has been conducted f or design change package preparers to ensure that Appendix R is considered in the design and to provide an overall familiariantion with fire protection as a whole.
If preliminary review indicates that fire protection is affected, the-fire protection coordinator reviews the package.
The discipline load engineers are responsible for ensuring that compliance is maintained and proper reviews are received.
- u. Funct'ional responsibilities have been identified for the fire protection coordinator, the Ntmlear Engineering (NE) fire protection system engineer, electrical design engineers, civil design engineera, and mechanical design engineers, relative to fire protection.
1-10 NE has developed a fire protection training program for individuals involved in the day-to-cay activities associated with. fire protection.
This training consists of six modules (each presented twice annually)
-as follows:-
Module 1 - Technical Support / Licensing basis Module 2 - Fire suppression systems Module 3 - Fire containment / compartmentation Module 4 - Fire detection Module 5 - Flammable / combustible materials and FHA
-Module 6 - Miscellaneous Additionally, training was conducted for NE personnel preparing design changea as_ discussed in Action 1-8 above.
1 Calculations SQN-APPR-1 and SQN-APPR-2 have been revised.
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1-12
'A training plan has been developed for Fire _ Operations personnat and fire brigade members, which includes six days of instruction in fire protection systems. Detection, high pressure fire protection.. carbon dioxide, and fog and sprinkler systems are included in this training. This training is being conducted on a recurrent basis.
1-13 The primary and alternate system engineers for Fire Protection-Systems 13, 26, and 39 will be added to the training files maintained by the Fire Protection instructor to annually provide and document training. Additionally, a training memo will be sent to all-Technical Support engineers describing the latest revision to SSP-12.15.
Training de.' eloped f or NE personnel is discussed in Action 1-10.
14 Site general employee training now adequately covers fire-protection-related areas. Precautions associated with carbon dioxide use, compartmentation, and control of combustible materials are covered in sufficient detail to convey personnel responsibilitier in these areas.
1-15 The permit process has been revised and is covered by SSP-12.15.
Requirements for both active and passive impairments are delineated in the SSP. Based on outage implementation lessons learned, additional enhancements will be incorporated.
1-16 SSP-12.15 Revision 0, was issued February. 13, 1992, to replace Physical Security Instruction 13. " Fire Protection Program."
Administrative Instruction 15, " Torch Cutting, Welding, Open Flame, Grinding, and Spark Producing Work Permit " was incorporated into this procedure.
However, SQN determined that changing the responsibility for permit authorization to Fire Operations was not warranted; thia responsibilicy will be maintained.by the responsible general foreman.
Specific requirements-to be evaluated for impairments are i
delineated in the procedure.. Combining the permits for impairments was evaluated and determined to not be an effective method of control, based on human factors considerations. The procedure also contains lists of areas containing Appendix R wraps, special Appendix R areas, 'and sai'ety-related areas to aid in appropriate evaluation of impairments.
1-17 Procedure. revisions are ongoing.
Procedures-receive a review by the system' engineer and/or. Fire Protection engineer following each-performance ~for technical accuracy and noted procedural deficiencies. A r.ask team made up of the ' ire protection systems engineers is performing a technical review to ensure that the procedures are reviewed for technical inadequacies and that revisions are initiated. A total of 152 procedures have been
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4 identified as affecting fire protection.- Of these, 28 have been-revised to date.
Revisions are in process on 75, and 49 remain to be reviewed.
1-18 Prefire plans were revised in February 1991 to reflect the current organization, capabilities, and tactics.
The prefire plans are currently in revision to incorporate.the procedures into a "Prefire Plan Manual" and to add and clarify information.
This will be accomplished as part of Phase II.
1 As delineated in SSP-6.21. " Maintenance Management System Initiation of Work Requests," the Fire Protection engineer is notified of work requests involving fire Protection for review of priority and accuracy. Workplans are reviewed by the Fire Protection engineer before approval to ensure that Fire Protection aspects are appropriately addressed.
1-20 surveillance Instructions (sis) 167 and 654 have been revised to include valves required by technicel specifications (TS) in 0-SI-FPU-026-167.M, " Fire Header Valve Lineup Inspection," which replaced SI-167, " Fire Header Valve Lineup Inspection"; and non-TS valves in 0-PT-FPO-026-654.M. " Fire Header Valve Seal Inspection,"
which replaced SI-654, " Fire Header Valve Seals Inspection."
During the review of the implementation of this action, an administrative inadequacy was identified in the procedurea that will require further revision.
'1 hic action will be included as part of the procedure revision effort discussed in Action 1-17.
' l-21 System.0perating Instruction (SOI) 0-S0-26-1, Revision 5, "High
' Pressure Fire Protection," was issued on April 1, 1992, to include steps to promptly drain the fire protection system following an inadvertent actuation.. Additional human performance enhancements are also being1 incorporated.
L 1-22 As discussed in the previous quarterly status report,'because of the favorable results obtained during the system porformance test, further mechanicci cleaning of the high-pressure fire protection system is not warranted at this time. Data from the performance-test will be trended to ensure that performance is acceptable and to' recommend further cleaning, if required.
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- 23 A test was. performed by Telecommunications to determine the extent of-the condition of " dead spots" at SQN.- It was determined that the new Motorola Sabre radios would work properly with no dead spots identified, it' the batteries for the. radios were charged and discharged. fully. Operations has ordered the discharge equipment and.is in the process of instructing plant > personnel on their proper use to ensure adequate radio coverage.
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-S-In parallel, TVA is in the process of finalizing the design for a new repeater system at SQN, which will add a fourth frequency.
The schedule for implementation has not been finalized, but initial projections are for implementation during fiscal year 1993. Additional'information will be tracked and prioritized by site personnel to ensure the communications system at SQN meets the requirements.
1-24. Training for fire brigade members has been developed.
Implementation of the training was started in January 1992 and will continue throughout the calendar year. SQN determined that immediate training for fire brigade members was not necessary. A modular format to convey required information will be utilized and will be adjusted on a yearly basis as needs evolve.
1-25 SOI 0-S0-26-1; SI-122, "High Pressure Fire Protection System Yard
' Hydraulic Performance Verification"; and the former SI-180, " Fire Pump Start Test," ( ttain the required steps to ensure that plant personnel are aware of the requirement to have two of the three pressure contro1' valves in service while operating the fire SI 0-SI-SFT-026-002.0, " Auxiliary Building Fire Protection pumps.
System Hydraulic Perf ormance 5'erification," and the SI-73 series will.be revised to include this requirement before the'next performance.- These. actions will be included as part of ti.e procedure upgrade effort discussed in Action 1-17.
1-26 SS?-12.15 provides instructions for evaluating-impairments and
. determining compensatory measures.
In addition to the table listing areas containing Appendix R wraps that provide one-hour separation.tur discussed in Action 1-16 above, tables have been provided.for special Appendix R' areas and safety-related areas to aid it. impairment evaluation.
1-27
'II-S-91-029:
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. A walkdown of the fire-suppressior, sprinkler system was performed.
and discrepancies between plant configuration and drawings were-reconciled by drawing deviations. Enhancements to the SI-241 series will be incorporated as a result of these walkdowns.- These actions willite-included'as part of the procedure upgrade effort discussed in Action 1-17.
II-S-91-041:
Walkdowns of the control and auxiliary building nonpoured masonry walls have been completed, and it was concluded that the fire barriers inspected demonstrate the requirements of functional barriers.
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II-S-91-049:
Training regarding the control of transient fire loads is included in general. employee training. The procedure for controlling transient fire loads-is now included in SSP-12.15.
II-S-91-055:
--The_ procedures for fire br-rier inspections have been revised. A prerequisite to ensura' thaw inspectors have been trained on fire
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barrier requirements is included.in the revised' procedure.
1-28 Qualified personnel performing maintenance activities for fire protection attributes can be mobilized to ensure compliance with TS requirements.
For this reason, the capability to perform maintenance on fire protection features is adequate.
1-29 SMI-0-317-18 Revision 3, " Appendix R - Casualty Procedures," was issued March 30,-1992, and identifies the location and tagging of material. required for performance of the instruction.
It also states that this material will be inventoried on an annual basis.
A preventive maintenance instruction has been issued to perform this' inventory.
1-30 The study for Project Control No. 607 to upgrade the fire suppression system has been completed. The current schedule reflects initiation'and issuance of the design package in fiscal year 1993. An action is being added in Phase III to track the design-issuance.
1-31 'American Nuclear Insurers Fire /All Risk recommendations have been
. evaluated and prioritized.
-A recommended implementation sequence has-been developed. SQN is'now insured by Nuclear Mutual Limited; their. recommendations are being evaluated.
1-32 Audits and assessments of improvement plan action implementation L
and effectiveness are being established throughout plan implementation. -Long-term audits of the fire protection program will'be accomplished in accordance with TS requirements and as
-deemed _ appropriate.by the Fire Protection manager, site management, and Site Quality.
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-ENCLOSURE 2 ACTION ADDITIONS OR CHANGES TO UPCOMING PHASEi
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. Phase II 2-13 Revise prefire plans into Prefire Plan Manual to add and clarify
.information.
2-17 Complete remaining procedure teviews.
2-18 Evaluate flows at-diesel generator building hose stations and determine corrective action.
Phase III 3-5 Perform the plant walkdown procedure to update the fire hazards analysis (FHA) (replaces Action 2-10).
3-6 Evaluate'the necessity of field verification of the FHA and establish methods as appropriate before issuance of the FHA.
.3-7 Issue a design package for Project Control No. 607, Fire Suppression System Upgrade.
3-8 Complete evaluation of the mechanical and electrical' fire barrier penetration seals in accordance with the guidelines in Information Notice No. 88-04 (replaces Action 4-2).
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