ML20211J362
| ML20211J362 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 12/30/1985 |
| From: | Russell W Office of Nuclear Reactor Regulation |
| To: | Vollmer R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| Shared Package | |
| ML20209D558 | List:
|
| References | |
| FOIA-86-274 NUDOCS 8606260326 | |
| Download: ML20211J362 (6) | |
Text
,Q
./
.Q-f - ft: Nk3
(
f7*#
UNITED STATES
\\
E i
t#
NUCLEAR REGULATORY COMMISSION gj(
7 WASHINGTON, D. C. 20555
/
/('lp ' '
- ...e l
,jW i
December 30, 1985 j.7 -
f~
f,o.,f MEMORANDUM FOR:
Richard H. Vollmer, Deputy Director Office of Inspection and Enforcement FROM:
William T. Russell, Director Division of Human Factors Technology Office of Nuclear Reactor Regulation
SUBJECT:
GENERIC LETTER ON FIRE PROTECTION
/
The Technical Specifications Coordination Branch has reviewed the latest draft of the Generic Letter on Fire Protection and recommends the changes noted in Enclosure 1.
These changes are being proposed to make the Generic Letter more consistent with the approach being taken for the Perry operating license as shown in Enclosure 2.
Requirements which have in the past been implemented through Technical Specifications are instead at Perry being implemented through Surveillance and Administration Procedures.
The FSAR changes proposed for Perry did not incorporate the Technical Specifications requirements, but rather provided a general reference to the existence of procedures'that address those matters and incorporate the Fire Protection Evaluation Report by reference.
By these references, 10 CFR 50.59 becomes applicable to the fire protection-2 program at Perry.
The administrative controls included in the Perry Technical Specifications were also modified as noted in Enclosure 3.
These changes included the addition of the fire protection program under the administrative responsibi.ities of the PORC, similar to the existing requirements of the Emergency and 5ecurity plans, as well as under the Procedures / Instructions and Program requirements of the Technical Specifications.
The Audit requirements of the Technical Specifications retained those requirements that are applicable to the : fire protection programmatic controls, protection equipment and program implementation.
The Perry Technical Specifications will retain the requirements related to Remote Shutdown (3/4.3.7.4) without change.
However, the remaining fire protection sections, exclusive of the above changes to administrative controls, will be removed.from the Technical Specifications. While the remote shutdown features ~are applicable to control room habitability as well as certain fire scenarios, the retention of their Technical Specification requirements eliminate the use of 50.59 as a means to alter this aspect ofsfire protection considerations.
Thus, there may be a valid case to be made that alternate or dedicated shutdowns features, where provided in response to the requirements of Appendix R, should also be i 3,d 8606260326 860619 PDR FOIA I
GARDEB6-274 pop fcip Mr> ~M
/7 - Tr4
l Richard H. Vollmer December 30, 1985 addressed by Technical Specificatior.r requirements, notwithstanding the proposed eliminations of specific existing fire protection ~ Technical Specifications.
In summary, it is concluded that it would be more appropriate for the generic letter on fire protection to note that the modification of fire protection Technical Specifications is a matter which is under staff review and that guidelines for such actions will be forthcoming. has been marked up accordingly.
The Technical Specification Coordination Branch is currently developing an NRR proposal for changes to fire protection system Technical Specifications for operating reactors as a part of the overall NRR Technical Specification improvement effort.
At this time there are a number of considerations, some of which are noted above, which must be addressed and.this matter need not be resolved prior to the issuance of the proposed generic letter, hh =t&
William T. Russell, Director Division of Human Factors Technology Office of Nuclear Reactor Regulation
Enclosures:
As Stated cc w/encls:
g H. Dentoa, NRR D. Eisenhut, NRR V. Stello, ED0
+
u m
. t' amendment to the operating license which [ deletes] amends (thepresent]any current license conditions regarding [the] fire protection [ program] and
[ completed fire protection features.
Inclusion of the fire protection program in the FSAR will be a prerequisite for licensing for all applications now.under review. No license condition would then be required.]
substitutes the following standard condition:
1.
The licensee shall implement and maintain in effect all provisions of the approved fire protection program as described in the Final Safety Analysis Report for the facility (or as described in submittals dated
) and as approved in the SER dated
(and Supplements dated ---------) subject to the following provision.
2.
The licensee may not make changes to the approved fire protection program which would adversely affect the ability to achieve and maintain safe shutdown in the event of a fire without prior approval of the Commission.
The licensee may alter specific features of the approved program provided (a) such changes do not otherwise involve a change in a license condition or techr.ical specification or result in an unreviewed safety question (see 10 CFR 50.59), and (b) such changes do not result in failure to complete the fire. protection program as approved by the Commission. As with other changes implemented under 10 CFR 50.59, the licensee shall maintain, in auditable form, a current record of all such changes, including an analysis of the effects of the change on the fire protection program and shall make y
such records available to NRC inspectors upon request. All changes to the approved program shall be reported annually to the Director of the Office of Nuclear Reactor Regulation, along with the FSAR revisions required by 10 CFR 50.71(e).
Jemocrary chances.to weeific #4 r ^-^tM ti-2 #a2+"rts.shictL mayJte _mecessary to. Accognplich maantananea orJDodifiCatdotts are. acceptable provided inter 4a comoenSat_orY mea 5ur_tts are J "'l-aantaC *MDbite"itdD By O*Mf'
.m.
.__m_,
33 11.s
.u.,, - -, _ _ -,
- e - _;;,;;;72 3, 2_,
,mm,,#,,,u--,
J-....,.
If licensees fail to request I
amendments to their licenses to add this condition, the Commission will considet
~~
i I
whether such changes should be required by order or by rule.
1---Inclusion of the fire protection program in the FSAR will be a prerequisite for licensing for all applications now under review.
The standard license conditioi will be included in new licenses.
L.-
ldSc:Si2 ~(
f4r 6
1 l
_ - ~. ~,
Egn.m gs- $
~
/
4-i Two points shoul'd be noted in regard to these conditions: (1) they did not explicitly cover required fire protection features where modifications to the existing plant configuration or procedures were not required, and (2) some of the provisions in these conditions maa2 have been superseded by Sections III.G. J. O, and L of Appendix R.
License conditions for plants licensed after January 1,1979 vary widely in scope and content. Some only list open items that must be resolved by a specified date or event, such as exceeding five percent power or the first refueling outage. Some reference a commitment to meet Appendix R; some reference the FSAR and/or the NRC staff's SER. These variations have created l
problems for licensees and for NRC inspectors in identifying the operative and enforceable fire protection requirements at each facility.
These license conditions also create difficulties because they do not specify when a licensee may make changes to the approved program without requesting a license amendment.
If the fire protection program committed to by the licensee is required by a specific license condition or is not part of the FSAR for the facility, the provisions of 10 CFR 50.59 may not be applied to make changes without prior NRC approval. Thus licensees may be required to submit amendment requests even for relatively minor changes to the fire pro on program.
The aforementioned problems, in general, exist beca e of the many submittals that constitute the fire protection program for ch plant. The Comission believes that the best way to resolve these pro ems is to incorporate the fire protection program, including the fire h ards analysis p en + - + " - T;dcAJ h f-;ct' =, into t Final Safety Analysis Report (FSAR) for the facility.
In thijL=aae.._e qe protection program, including the systems, the administratf 6 = d
"""A controls, the organization, and other plant features associaQwith fireptection would be on a consistent status with other plant features oescribed in the FSAR. Also, the provisions of 10 CFR 50.59 would then apply directly for changes the licensee desires to make in the fire protection program.
In this context,' the detemination of the involvement of an unreviewed safety question defined in 150.59(a)(2) would be made based on the " accident....previously evaluated" being the postulated fire in the fire hazards analysis for the fire area affected by the change. The Comission also believes that a standard license condition, requiring licensees to comply with the provisions of the fire protection program as described in the FSAR, should be used to ensure ur.iform enforcement of fire protection requirement Therefore, each licensee should include, in the FSAR update required by 10 CFR 50.71(e) that will fall due more than 6 months after the date of this letter, the incorporation of the fire protection program that has been approved by the NRC, including the fire hazards analysis that forms the basis for the fire protection program., :-d th--% ;;=t5=hab b:"h This incorporation may be by reference to specific previous submittals and the NRC approvals where appropriate.
Upon completion of this effort, including the certification required by 10 CFR 50.71(e)(2), the licensee may apply for an
i current license' conditions regarding [the[j fire protection, program] and[thepre amendment to the operating license which deletes] amends Lcompleted fire protection featu es.
Inclusion of the fire protection program in the FSAR will be a prerequisite for licensing for all applications now ynder review. No license condition would then be required.]
substitutes the following standard condition:
1.
The licensee shall implement and maintain in effect all provisions of the approved fire protection program as described in the Final Safety Analysis Report for the facility (or as described in submittals dated
) and as approved in the SER dated ---------(and Supplements dated ---------) subject to the following provision.
2.
The licensee may not make changes to the approved fire protection program which would adversely affect the ability to achieve and maintain safe shutdown in the event of a fire without prior approval of the Commission.
The licensee may alter specific features of the approved program provided (a) such changes do not otherwise involve a change in a license condition er techr.ical specification or result in an unreviewed safety question (see 10 CFR 50.59), and (b) such changes do not result in failure to complete the fire protection program as approved by the Commission. As with other changes implemented under 10 CFR 50.59, the licensee shall maintain, in auditable form, a current record of all such changes, including an analysis of the effects of the change on the fire protection program, and shall make c
y such records available to NRC inspectors upon request. All changes to the approved program shall be reported annually to the Director of the Office of Nuclear Reactor Regulation, along with the FSAR revisions required by 10 CFR 50.71(e).
' Jemocrary channes. to snecifir. f 4--- mtet4-f=2tures<.shictL mayJe _mecesswy to. Accomplish maanrananca mJoodifications. art acceptable provided intef4m comoen5atory measures Are_i=1 - ntail *[ADbm6D By A'/2/2.rW~
a m
- m. m -,__--
,i i
'r'"ifi'=*i^-'
~--;-....J,....,.
If licensees fail to request
^
I
' amendments to their licenses to add this condition, the Commission will considet whether such changes should be required by order or by rule.
inclusion of the fire protection program in the FSAR will be a prerequisite for licensing for all applications now under review.
The standard license condition will be included in new licenses.
i l
g g
1 (INSERT)
With t e addition of the fire protection program to the FSAR, as noted above, the Staff finds that a significant reduction in the content of fire protection technical specifications is appropriate. As a consequence, additional g~ idance will be provided to licensees and applicants in the u
near future on the content of plant specific proposals to request such action.
i
. - ~..
--.-.y
UN C6 OW6" L:s 4
THE CLEVELAND ELECTRIC ILLUMIN ATING COMP ANY CLEVELAsso. oH10 44101 - TeLaPMoret (tit) s234000. aiutensATpeo sLDo. -- se PusLICsouARE P.o. Dox 0000 Serwng The Bestlocation in the Nation j
l M.mRAY R. EDELMAN vict PatslotNT peuCLEAR November 15, 1985 FY-CR1/NER-0393 L L
l Mr. B. J. Youngblood, Chief Licensing Branch No. 1 Division of 1.icensing U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Ferry Wuclear Power Flant Docket Nos. 50-440; 50-441 lI Fire Protection Progran FSAR and Technical Specification Changes _
Dear Mr. Youngblood During recent discussions with your staff, we were requested to evaluate the L
concept of concurrently amending the FSAR, by incorporating our Fire Protection Evaluation Report (TFER) into FSAR Chapter 9, and removing the fire protection i
elements from the Ferry Technical Specifications. In addition to adding the FFER into the FSAR, this will entail a shifting of fire protection testing j
p requirements from surveillance instructions (SVI's) to periodic test
. instructions (FTI's). This will, in effect, transfer fire protection prograa commitments,- reporting requirements and taendments from the jurisdiction of 10CF150.73 and 10CF150.90 to 10CFR50.59 and 10CFR50.71(e). The FNFF Fire Protection Program will be completely described and controlled through the FSAR rather than through the combination of FFER, FSAR and Technical Specifications.
This will be consistent with the recommendations of the Committee to Review p
Generic Requirements (CRGR).
The fire protection program in place at FNFF meets the requirements of existing Technical Specifications. With reistively straightforward changes, incor-7 poration of the total fire protection program into the FSAR as recommended by CRGR can be accomplished by fuel load. We endorse this spyroach and believe Based on this is a significant improvement in the fire protection program.
further discussions with the staff, we have begun implementing this change.
The attscheents to this letter provide a detailed discussion of the asisting and modified fire protection programs, a revised FSAR discussion of the inspection and administrative programs, and a tabulation of the existing Feriodic Test and Surveillance Instructions.
p F
FDR pp f
e I i
I e
.~~~.
s e
I
~
-2 November 15, 1985 Mr. B. J. Youngblood FY-CE1/Nta-0393 L l
with these revisions, the FNFF Firts Protection Program commitaants will be totally defined within the revised FSAE Section 9.5-1 and the new FSit I
' Appendix 9A (i.e., the current FFER). Previously defined Technical Specification requirements will be embodied within the implementing procedures and tastructions of the Operations Manual. Thus, this effort will result in an effective FNFF Fire Protection Program which is acceptable to the staff, and will enable PNFF Technical Specifications to be issued excluding fire protection elements prior to certification. If you should have any
}
questions, please feel free to call.
Very truly re,
[
d
. h rray E. Edel
.Vice President Nuclear Group' MEE:nje I
Attachments cc: Jay Silberg, Esq.
John Stefano (2)
J. Grobe I
b L
L I
f f
i t
e
.-..-_--g..__
Atteclunent
-l FY-Q 1/NRA-0393 L We pro se that the Remote Shutdown (3/4.3.7.4) feature of the Technical Specifications be retained without any changes. The remaining fire protection associated sections listed above will be removed free the Technical Specifications. The existing Ferry Surveillance lastructions taple5 nting sections 3/4.7.6, 3/4.7.7 and 3/4.3.7.8 will be retained by converting them to Periodic Test Instructions. The limiting conditions and remedial action portions of these same sections will be re-established by espanding an existing Plant Administrative Procedure, PAP-1921 " Fire Barrier Removal" and writing a new Plant Administrative Procedure, PAP-1923, " Actions on Isoperable Fire Protection Systems." An equivalent level of limiting conditions, and actions to be tskan will be established within these procedures to provide an equivalent level of protection as described la the existing Technical Specifications.
The Administrative portion of Technical Specifications 6.2.2(a) and 6.5.2.8,(e)(f)) are invoked by PAP-1911 and the Operations Quality Assurance Plan, Appendix C.
No change is required to these documents, other than removing the references to Technical Specificationa. In addition, the entire series of Perry Administrative Procedures (PAP-1910 through PAP-1922) will be retained, as they implement our overall plant Pire Protection Program in addition to our commitments presently discussed in the FPER.
As previously indicated, El presently has in-place all of the documents /
procedures to implement Technical Specification requirements for fire protection. By fuel load, CEI will have in-place the new procedure, PAP-1923, which replaces existing Technical Specification requirements for active systems and will have prepared changes to our procedures as required to effect all the other aspects of rearrangement.
I l
l e
.e s.e se.
E I
l g.-
'l Attrehment FY-CE1/NRR-0393 L l
l Description of the Existina and Prooosed FNFP Fire Protection Programs
~.
I f
Existing The existing Fire Protection Progras is complete and has all of the implementing features of the controlling documents in place. This progran consiste ofa i
(1) FSAR Section 9.5.1 J
(2) Fire Protection Evaluation Report (FFER) 1 i
(3) Technical Specification Sections o
3/4.3.7.8 Fire Detection o
3/4.7.6 Fire Suppression Systems o
3/4.7.7 Fire Rated Assemblies o
6.2.2(e)
Fire Brigade.
o 6.5.2.8(e) and (f)
Administrative QA for Fire Protection i
(4) Surveillance Instructions (List Attached)
(5) Periodic Test Instructions (List Attached)
(6) Administrative Procedures (List Attached)
I (7) Plant Operating Procedure P0P-0210 (8) OQA Plan, Appendix G Perry Operations Procedure, 70P-0210, establishes the Fire Protection Program and Plant Administrative Procedures PAP-1910 through 1922 taplement the various features of fire protection according to WEB BTP 9.5-1 and 10CFR50 Appendix 1.
L FSAR section 9.5-1 provides a general discussion of fire protection / detection /
suppression features and invokes the FPER.
The FPER includes a fire hasards analysis. safe shutdown summary, deviations, and comparison tables to 10CFR50 Appendix R and BTP APCSS 9.5-1 Appendix A.
At Perry, the FPER has been handled as an antension of the FSAR siellar to i
the Emergency Plan. Surveillance Instructions implement the Technical Specifiestion Sections for surveillance. Periodic Test lastructions cover the I
surveillances in areas of the program not in Technical Specifications and include the requirements of the ANI. These are listed on the attached pages.
h Proposed Restrangement I
The FFER in its entirety will be placed into the FSAR se Appendix 9A, and r
become Volume 14A. The only substantive changes to the FPER contents will be the incorporation of asterial that was scheduled for FPER sevision 5.
FSAR Section 9.5.1.4 will be amended by incorporating a discussion of fire protection operations, testing and surveillances. As shown in the attachment,
,'~
~
information provided addresses plant administrative procedures, periodic testing and remedial actions for inoperability.
l l
l
\\
l y
..-_v
Attcciment FY-CE1/NRR-0393 L i
i TDM 1 FIRE PROTECTION i
PRESENT FLANT ADMINISTRATIVE PROCEDURES i
F FAP-1910 FIRE PROTECTION FROGRAM PAP-1911 F1kE IMERGENCY l
BURN FERMITS FOR IGNITION SOURCES FAP-1912 I
CONTROL OF TRANSIENT COMBUSTIBLES PAP-1913 IMPAIRMENT OF FIE FROTECTION SYSTEMS FAF-1914
[
FAP-1915 FIRE REPORT PAP-1916 DUTIES OF FIRE WATCH FIRE PROTECTION TRAINING FROGRAMS FAP-1917 L
FAP-1918 FIRE DRILLS FIRE BRIGADE RQU1FMENT, INVENTORY. INSFECTION AND FAP-1919 NAINTENANCE FAP-1920 PERIODIC FIRE INSFECTIONS FAP-1921 FIRE BARRIER REMOVAL H
-FRE-FIRE FLANS FAF-1922 ACTIONS ON IMOFERAstE FIRE FROTECTION SY N FAP-1923 l
E i
I i
i I
..n __ _.
y - -....... _.
Atttchment FY-CEI/NER-0393 L TASLE 2 FIRE FROTECTION I
SURVEILL&NCE INSTRUCTIONS SVI-F54-70351 UNIT 1 CONTROL ROON FIRE DETECTION INSTRON1NTATION CHANNEL FUNCTIONAL TEST FOR BONETWELL 938 FANELS SVI-F54-T1277 ELECTRIC MOTOR DRIVEN FIRE FUNF OPERABILITY TEST SVI-F54-71278 FIRE SUPPRESSION SYSITM VALVE POSITION VERIFICATION i
SVI -F54-T1280 FIRE SUFFRESSION VALVE CYCLE TEST SVI-F54-T1281 FIR'E SUFFRESSION WATER SYSTEM SIMULATED AUTOMATIC ACTUATION TEST SVI-F54-T1282 FIRE SUFFRESSION TARD MAIN WATER FLOW TEST l
SVI-F54-T1283 DIESEL FIRE FUMP RUN & START SVI-F54-T1284 EYDRANT EOSE BOUSE MONTHLY INSFECTION SVI-F54-T12Q5 FIRE EYDRANT SEMIANNUAL INSFECTION 3
SVI-F54-T1286 ANNUAL HTDRANT MOSE BOUSE INSFECTION & EYDRANT FLOW VERIFICATION SVI-F54-T1287 DIESEL FIRE FUMP WEEKLT SATTERY CEECKOUT I
SVI-F54-T1288 DIESEL FIRE FUMP BATTERY SPECIFIC CRAVITY CHECK SVI-F54-T1289 DIESEL DRIVEN FIRE FUNF BATTERY INSFECTION J
SVI-F54-71290 SPRINKLER READER AND WOZZLE SFRAY AREA INSFECTION SVI-F54-T1291 UATER SPRAY, FRE-ACTION SFRINKLER, AND AUTOMATIC l
SPRINKER SYSTEMS FUNCTIONAL 11ST SVI-F54-T1293 CHARCOAL FILTER BED SFRAY N0ZZLE VISUAL INSFECTION Is SVI-F54-T1294 CO SYSTEM VALVE POSITION VERIFICATION 2
SVI-F54-71295 CO STORAGE TANK FRESSURE AND CAPACITY VERIFICATION g
2 SVI-F54-T1296-A C0 SYSTEM OPERABILITY TEST FOR UNIT 1 DIESEL CEkERATORROOMS i
I I
I ede a __;--
\\
?
Att:ctment FT-CEI/NRR-0393 L SVI-F54-71296-R CO SYSTEM OPERARILITY TEST FOR UNIT 1 CONTROL ROOM 2
l h
SVI-F54-T1298 UNIT 1 FIRE DETECTION FUNCT FOR DELDGE CONTROL FANELS (1552-F209, 1551-F210) EEAT DETECTORS SVI-F54-71299 UNIT 1 FIRE DETECTION INSTRUMENTATION CMANNEL.
FUNCTIONAL TEST FOR DET-RONICS FANELS SVI-F54-T1300 UNIT 1 FIEI, DETECTION INSTEDNENTATION CMANNEL FUNCTIONAL FOR MONEYWELL W939 SINGLE E0hE FANELS i
SVI-F54-T1301 UNIT 1 FIRE DETECTION INSTRUMENTATION MANNEL FUNCTIONAL TEST FOR FYROTRONICS FANELS SVI-F54-T1302 UNIT 1 FIRE DETECTION INSTRUMENTATION MANNEL FUNCTIONAL TEST FOR FIRETEK 240 FANELS SVI-F54-71303 UNIT 1 FIRE DETECTION INSTRUMENTATION CNANNEL I
FUNCTIONAL TEST FOR EONETWELL 938 FANELS I
UNIT 1 FIRE DETECTION INSTRUMENTATION CMANNEL SVI-F54-T1304 TUNCTION TEST FOR CNEMETRON FANELS i
SVI-F54-71305 FIRE ROSE STATION NONTELY INSFECTION c
SVI-F54-T1306 FIRE NOSE STATION EIGHTEEN (18) NONTH INSFECTION SVI-F55-T1307 FIRE MOSE OPERAR1LITT TEST I
SVI-F54-T1310 FENETRATION SEAL VISUAL INSFECTION SVI-F54-T1311 FIRE DANFER FISUAL INSFECTION L
SVI-F54-T1312 FIRE RARRIER VISUAL INSFECTION SVI-F54-71313 FIRE DOOR SUPERVISORY SYSTEM FUNCTIONAL TEST SVI-F54-T1314 LOCKED FIRE D0OR WEEELT VERIFICATION SVI-F54-71315 UNLOCEED AND UNSUPERVISED FIRE DOOR DAILY VERIFICATION
[
SENIANNUAL FIRE DOOR LATCM INSFECTION SVI-F54-T1316 f
SVI-F54-T1317 NAGNETICALLY EELD'0 FEN FIRE D0OR OPERABILITY TEST l
SVI-F54-T2002 RX RECIRC FUNF FIRE SERVIG CO2 TLV OPERABILITY TEST l
i j
i.
6
-- _ -_.. - -r --.-, _, _ _ c
.n
Attcchment FT-CEI/NR1-0393 L SVI-F54-T3014 DIESEL FIRE FUNF FUEL ANALYSIS
$VI-F54-T5035 DIESEL INSFECTION TYPE C LOCAL LEAK RATE TEST OF F54 PENETRATION F210 EVI-F54-I9210 l
TYPE C LOCAL LEAK EATE TEST OF F54 PENETRATION F406 SVI-F54-T9406 NOTE: To Re Rewritten as Periodic Test Instructions I
P l
b 1
i W
'e b
l i
e f
1 i
l
o
\\
Attxhment FY-CE1/NRR-0393 L
[
r TABLE 3 FIRE PROTECTION FRESENT PERIODIC TEST INSTRUCTIONS l
I FTI-P54-P0001 FIRE MOSE STATION INSFECTION l
I FTI-P54-P0002 FIRE MOSE STATION 18 MONTH INSFECTION FIl-F54-P0003 FIRE MAIN FLOW TEST j
i PT1-F54-F0004 FIRE EYDRANT OPERABILITY TEST FTI-F54-F0005 FIRE MOSE EYDR0 STATIC TEST FTI-P54-F0006 PORTABLE FIRE EXTINGUISEERS MONTHLY INSFECTION FTI-P54-P0007 PORTABLE FIRE EXTINGUISHERS MAINTENANCE INSFECTION FTI-F54-F0008 FIRE SUFFRESSION SYSTEM (WATER) VALVE LINEUF &
INTEGRITY INSFECTION FT1-F54-F0009 WATER SPRAY SYSTEM MONTHLY OPERABILITY TEST FTI-F54-P0010 NET FIFE SPRINKLER SYSTEMS MONTMLY OPERABILITY TEST E
PTI-F54-F0011 FREACTION SPRINKLER SYSTEMS OPERABILITY TEST I
7II-P54-P0013-A WATER SFRAY SYSTEM FIAW TEST FOR UNIT 1 & 2 STARTUP TRANSFORMERS, AND UNIT 1 AND 2 INTERBUS TRANSFORMERS FTI-P54-P0013-B WATER SFRAY SYSTEM FLOW TEST FOR MAIN TRANSFORMERS, I
AUXILIARY TRANSFORMER AND ISO-PEASE SUS DUCT (UNIT 3) r FTI-P54-P0014 FREACTION SF11NELER SYSTEMS ANNUAL TRIP TEST FTI-F54-P0015 FIRE DETECTION FUNCTIONAL TEST FIl-F54-P0016 CARBON D1011DE SYSTEMS WEEKLY STORAGE TANK CAPACITY VERIFICATION j
FTI-F54-P0017 CARRON DIOKIDE FIRE FROTECTION SYSTf.M VALVE LTNEUF r
INSTRUCTION FT1-P54-P0018 CARBON D10EIDE FIRE EXTINGUISRING SYSTEM PUFF TEST r
e 6
.u.,n.
-.. - ~ ~ - - - - - - - - - - -
p--
I
Ctt=hment FY-CE1/NER-0393 L FTI-F54-F0020 BALON STORAGE TANK LEVEL VERIFICATION FTI-F54-F0022 FIRE DAMPER OPERABILITY TEST I
FTI-754-F0023 TARD VALVES, ETDRANTS, 30$E & SOSE 300$E EQUIPMENT MONTHLY INSFECTION VERITICATION I
WATER SFRAY SYSTEM FLOW TEST FOR UNIT 1, WTDROGEN FTI-F54-F0025 I
SEAL OIL UNIT l
PTI-F54-F0029 FIRE EYDRANT SEM1 ANNUAL INSFECTION f
I FTI-F54-F0030 CO SYSTEM 18 MONTH OPERABILITY TEST 2
)
FTI-754-F0031 18 MONTH RALON SYSTEM TEST l
t L
i I.
t i
I t
h L
i i
t f
l me
.m_.-
i 4
Drawings E-023-001 through E-203-034, provided in the FPER, show fire l
barr'iers, fire detection equipment, fire suppression equipment, and locations
{
of equipment, instruments and cable associated with safe shutdown operations.
)
Figures 9.5-1 through 9.5-6 show the following-l
\\
l a.
Fire pasps and pressure maintenance components.
b.
Underground distribution piping arrangeesnts.
c.
Internal distribution piping arrangement.
b d.
Mose stations.
a.
Fire suppression systems.
Section 4.0 of the FPER provides the following information for each area /sonet i
A listing of all mechanical and electrical equipment that af fects the safe a.
5 shutdown operation.
- b. ~ A list of both permanent and reasonably espected transient combustibles.
I c.
Type of fire detection systes provided.
d.
Types of fire suppression equipment (primary and backup).
The effect of the postulated fire on the capabiltiy to safety shut down e.
the reactor and on the potential release of radioactive material.
9.5.1.4 Inspection and Testina tenuiremente l
Administrative controle are provided through existing Flent Administrative Procedures, Ferry Operating Procedures and the Operations Quality Assursace Program to ensure that the Fire Protection Progree and equipment is properly maintained. This includes QA audits of the program implementation, senduct of periodic test inspections, and remedial actions for systems and barriers out of l
i f
service. This progree emphasises those elessats of fire protection that are i
l associated with safe shutdown as described in Appendia 9A and their significance when evaluating progree and equipment deficiences.
j l
All fire protection equipment and systems are subject to a complete inspection L
and acceptance test in accordance with the National Fire Codes af ter installation is completed. After the plant is in operation, periodic i
i' 9.5-19 I
l l
O og> e me s es. m W n.-
- --n,
,-,,,.,,.-,e--,m-,--_m,----.--
,_,,-v--
-am-----.,,-nan _-. -, --
,-.--n.-,m
.,.ema-e--
i inspections and tests will be conducted as defined by the Fire Protection Progra's and National Fire Codes.
The following fire protection features will be subjected to periodic tests and I
inspections:
Fire alars and detection systems s.
b.
Wet pipe automatic sprinkler systema c.
Water spray systems d.
Freaction water spray systems e.
Freaction sprinkler systems f.
Carbon dioxide total flooding systems Local application carbon dioxide systems g.
I h.
Foaa application system 1.
Fire pumps Fire barriers (walls, fire doors, penetration seals, fire dampers) j.
k.
Manual suppression (fire hoses, hydrants, extinguishers) j Equipment out of service including fire suppression, detection, and barriers will be controlled through the adminstrative program and appropriate remedial actions taken. The program requires all impairments.to fire protection system to be identified and appropriate motification given to the Fire Protection Engineer for' avaluation.. Based on the condition, engineering analysis may be L
- required to determine"the extent of the fire hasard to safe plant operations.
~ ~ ~
As conditions warrant remedial actions would include compensatory measures to L
ensure equivalent level of fire protection in additions to timely efforts to 1
effect repairs and restore equipment to service.
p
'9.5.1.5 Fersonnel Qualification and Training I
The responsibility for the design, system equipment selection and development J
of test specifications for the completed physical aspects of the fire 3
protection system is delegated to the fire protection consultant, Gilbert Associates Inc., Reading, pennsylvania. These responsibilities will be conducted by or under the direct supervision of an engineer who is qualified l
for Member grade in the Society of Fire Protection Engineers.
I 9.5-20
_,n
.,n-n,.
..-e n,
.,a.
L The development of the plant fire protection program is the responsibility of the Fire Protection Staff. This staff te composed of personnel prepared by l
training and experience in fire protection and personnel trataed and asperienced in nuclear plant safety to provide a balanced approach ta directing l
l Additional references to fire training can be found la Section 13.2.5. Specific 1
administrative procedures, emergency plane, maintenance and teettag procedures t
and drills will be described in the PNPP Operations Manual.
i i
i l
I I
t I
l L
f i
I l
l l
l l
9.5-20e y-- ----
1
Ef4 % S M E.b,
[!
fpgQ 6.0 ADMINISTRATIVE CONTROLS T
I
.I m
(.
6.1 RESPONSIBILITY f
6.1.1 The Manager, Perry Plant Operations Department, shall be responsible for overall unit operation and shall delegate in writing the succession to this responsibility during his absence.
6.1.2 The Shift Supervisor or, during his absence from the control room, a designated individual shall be responsible for the control room command function.
A management directive to this effect, signed by the Vice President - Nuclear Group shall be reissued to all station personnel on an annual basis.
6.2 ORGANIZATION CORPORATE 6.2.1 The corporate organization for unit management and technical support shall be as shown on Figure 6.2.1-2.
UNIT STAFF 6.2.2 The unit organization shall be as shown on Figure 6.2.2-1 and:
Each on duty shift
- shall be composed of at least the minimum shift a.
crew composition shown in Table 6.2.2-1; b.
At least one licensed Operator shall be in the control room when fuel is in the reactor.
In addition, while the unit is in OPERATIONAL CONDITION 1, 2 or 3, at least one licensed Senior Operator shall be in the control room; A Health Physics Technician
- shall be on site when fuel is in the c.
reactor; d.
ALL CORE ALTERATIONS shall be observed and directly supervised by either a licensed Senior Operator or licensed Senior Operator Limited to Fuel Handling who has no other concurrent responsibilities during this operation; e.
As e fire gade of at 1 st f members shal e aintained on The re briga shall no nelude he Shift si e at all pervisor the Sh tT nical Advis nor e two othe embers i
! shutdown of the it j
of the mi mum shift necessary for and any ersonnel r uire r other e nt' % nctions during g
(
fire ergency; a
- The Health Physics Technician W '5 M;;d c~---'ith may be less than the minimum requirements for a period of t'me not to exceed 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, in order to accommodate unexpected absence, provided immediate action is taken to fill
(
the required positions, PERRY - UNIT 1 6-1 i
NOV 121965
ikY i
t a
ADMINISTRATIVE CONTROLS RESPONSIULITIES 6.5.1.6 The PORC shall be responsible for:
a.
Review cf all Administrative Procedures; b.
Raview of the safety evaluations for (1) proposed procedures /
instructions, (2) changes to procedures / instructions, equipment, systems or facilities, and (3) tests or experiments performed under the provisions of 10 CFR 50.59 to verify that such actions do not constitute an unreviewed safety quaition; Review of proposed procedures / instructions and changes to procedures /
c.
instructions, equipment, systems or facilities which involve an unreviewed safety question as defined in 10 CFR 50.59; d.
Review of proposed tests or experiments which involve an unreviewed safety question as defined in 10 CFR 50.59; Review of proposed changes to Technical Specifications or the e.
Operating License; f.
In.estigation of all violations of the Technical Specifications including the preparation and forwarding of reports covering evalua-tion and recommendations to prevent recurrence to the Vice President -
Nuclear Group and to the Nuclear Safety Review Committee; g.
Review of all REPORTABLE EVENTS; i
h.
Review of the plant Security Plan and Security Contingency Instruc-tions and submittal of recommended changes to the Nuclear Safety Review Committee; i.
Review of the Emergency Plan and implementing instructions and sub-mittal of recommended changes to the Nuclear Safety Review Committee; j.
Review of changes to the PROCESS CONTROL PROGRAM, the 0FFSITE DOSE CALCULATION MANUAL, and Radwaste Treatment Systems;
' "k. ' Review of any accidental, unplanned or uncontrolled radioactive release including the preparation of reports covering evaluation, recommendations, and disposition of the corrective action to prevent recurrence and the forwarding of these reports to the Managers,?erry Plant Departments, the Nuclear Safety Review Committee and the
~
~
i Vice President - Nuclear Group; 1.
Review of Unit operations to detect potential hazards to nuclear safety; andr Investigations or analysis of special subjects as requested by the m.
Chairman of the Nuclear Safety Review Committee 4 4 4
l e
t% ub r9a
.J y.a g ;f, y
% 4 tL.
O M4
,ws.- ' JA
%QQxg i
(
(
L Ce~A,,
l PERRY - UNIT 1 6-9 N0Y 12 585
~
i FIN.N I
ADMINISTRATIVE CONTROLS AUDITS (Continued) p.
'The performance of activities required by the Operational Quality Assurance Program to meet the criteria of Appendix B, 10 CFR Part
- 50. at least once per 24 months; 3
~
3 l
e.
The fire protection programmatic controls including the implementing procedures at least once per 24 months by qualified licensee QA personnel; j
f.
The fire protection equipment and program implementation at least
- d once per 12 months utilizing either a qualified corporate licensee i
fire protection engineer (s) or an outside independent fire protection consultant. An outside independent fire protection consultant shall be utilized at least every third year; p.
The radiological environmental sonitoring program and the'results 1
thereof at least once per 12 months; 1
h.
The 0FFSITE DOSE CALCULATION MANUAL and implementing procedures at least once per 24 months; l
i '.
The PROCESS CONTROL PROGRAM and implementing procedures at least i
once per 24 months; 1
1 The performance of activities required by the Quality Assurance l
j.
Program for effluent and environmental sonitoring at least once per 12 months; and l
j k.
Any other area of unit operation considered appropriate by the NSRC j
or the Vice President - Nuclear Group.
RECORDSh 6.5.2.9 Records of NSRC activities shall be prepared, approved, and distributed as indicated below:
L 4.
Minutes of each NSRC meeting shall be prepared, approved, and i
~
i forwarded to the Vice President - Nuclear Group within 14 days i
following each meeting.
I b.
Reports of reviews encompassed by Specification 6.5.2.7 shall be prepared, approved, and forwarded to the Vice President - Nuclear j
Group within 14 days following completion of the review.
c.
Audit reports encompassed by Specification 6.5.2.8 shall be forwarded to the Vice President - Nuclear Group and to the management positions rdsponsible for the areas audited within 30 days sfter completion of the audit by the auditing organization.
(
PERRY - UNIT 1 6-13 gy 11Y
t i
FW O m'
~
ADMINISTRATIVE CONTROLS f
6.8 PROCEDURES / INSTRUCTIONS AND PROGRAMS 6.8.1 Written procedures / instructions shall be established, implemented, and maintained covering the activities referenced below:
The applicable procedures recommended in Appendix A of Regulatory a.
Guide.l.33. Revision 2. February 1978.
b.
The applicable procedures required to implement the requirements of NUREG-0737 and supplements thereto.
c.
Security Plan implementation.
d.
Emergency Plan implementation.
e.
PROCESS CONTROL PROGRAM implementation.
f.
0FFSITE 00$E CALCULATION MANUAL implementation.
Q.Mb L...i.;; "r:;;n: fer Offh;;t M] environmental sonitoring.
g.
$ Al fsu 9L;w c.w) flagsM & ' M'm V.
'6.8.2 ma6n aaministrau ve ri n 4. vi irecification 6.8.1, and changes thereto, shall be reviewed by the PORC and shall be approved by the Managers, Perry Plant Departments, prior to implementation.
All procedures / instructions shall be reviewed periodically as set forth in administrative procedures.
6.8.3 The following programs shall be established, implemented..and maintained:
a.
Primary Coolant Sources Outside Containment A program to reduce leakage from those portions of systems outside g
containment that could contain highly radioactive fluids during a serious transient or accident to as low as practical levels. The systems include the NPCS, CS, RHR, RCIC, LPC5, feedwater leakage control system, and post-accident sampling systems.
The program-shall include the following:
~1.
Preventive maintenance and periodic visual inspection requirements, and
[
2.
Integrated leak test requirements for each system at refueling cycle intervals or less.
~
?
b.
In-Plant Radiation Monitoring A program which will ensure the capability to accurately determine the airborne iodine concentration in vital areas under accident i
conditions. This program shall include the following:
1.
Training of personnel, 2.
Procedures for monitoring, and 3.
Provisions for maintenance of sampling and analysis equipment.
Il0V121985 PERRY - UNIT 1 6-16 f
- -