ML17298B827

QA Program for Fire Protection.

ML17298B827
Person / Time
Site:	Palo Verde
Issue date:	01/09/1985
From:	ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR
To:
Shared Package
ML17298B825	List: IR 05000528/1984025 ML17298B822 ML17298B827
References
NUDOCS 8501230073
Download: ML17298B827 (66)

Text

QA PROGRAM FOR FIRE PROTECTION Page 1 of 42 INTRODUCTION FSAR Table 9B.3-1,"Comparison of Palo Verde Nuclear Generation Station to Appendix A of NRC Branch Technical Position," APCSB 9.5.1, Part C,"Quality Assurance Program," provides the NRC requirements for a Quality Assurance program for Fire Protection along with the ANPP position and basis for compliance to the NRC requirement.

The attached evaluation will describe how ANPP has complied with the commitments established in the above-mentioned table.The format used for this evaluation is as follows for each required element of the program as listed in Table 9B.3-1: I.Requirement stated in the NRC Branch Technical Position II.ANPP Position III.ANPP Compliance While retaining responsibility for the overall Fire Protection Quality Assurance Program, the ANPP has delegated some authority for implementation to Bechtel and its subcontractors.

Bechtel,'as the Architect/Engineer/Constructor, is responsible to'ANPP for the design, procurement, and construction of the Fire Protection System for the PVNGS Units 1, 2, and 3.Bechtel performed the Fire Hazards Analysis, established the Design Criteria, and constructed the Fire Protection System, subcontracting portions thereof to qualified contractors.

Viking Fire Protection Company is responsible to Bechtel for designing, furnishing, installing, flushing, and testing of the complete deluge,~ster spray, and sprinkler systems for fire protection.

Ora B.Hopper&Son, Inc.is responsible to Bechtel for furnishing and applying structural spray-on fireproofing.

ISI/ICMS or BISCO is responsible to Bechtel for furnishing and installing fire barrier penetration seal systems.Insulation Services, Inc.is responsible to Bechtel for furnishing snd installing fireproofing systems for electrical raceways.8501230073 850109"==A PDR*DOCK 05000528 PDR V I QA PROGRAM FOR FIRE PROTECTION Page 2 of 42'.DESIGN CONTROL AND PROCUREMENT DOCUMENT CONTROL I.Requirement stated in the NRC Branch Technical Position"Measures should be established to assure that all design-related guidelines of the Branch Technical Position are included in design and procurement documents and that deviations therefrom are controlled." II.ANPP Position"PVNGS complies.The measures to be established are delineated in Items (2)through (10)below." III.ANPP Compliance A.Design Control PVNGS FSAR A endix 9B-Fire Protection Evaluation Report The PVNGS FSAR Appendix 9B presents an evaluation of the Fire Protection Systems st PVNGS.The evaluation has been performed by comparing the PVNGS Fire Protection features to the guidelines contained in Appendix A of the Branch Technical Position APCSB 9.5-1 and to 10CFR50 Appendix R, Part III, Sections G, J, and O.The Plant Design has been reviewed and design provisions have been included for the preservation of at least one success path which can accomplish the safe shutdown functions.

In the event nf control room evacuation, alternate shutdown capability is also provided.The Fire Protection System has been examined from the following three viewpoints:

1.To provide a fire hazard's analysis.2.To identify the compliance with Appendix A of BTP APCSB 9.5-1.t 3.To identify compliance with 10CFR50, Appendix R, Part III, Sections G, J, and O.The result of the evaluation program determined that PVNGS can reach and maintain cold shutdown conditions fo13owing a postulated fire, even though several deviations from 10CFR50, f l QA PROGRAM FOR FIRE PROTECTION Page 3 of 42 Appendix R, NFPA Standards and Branch Technical Position APCSB9.5-1 have been identified in the PVNGS FSAR Appendix 9B, Amendment 13 and letter ANPP-31378-EEVB/WFQ, dated December 7, 1984.The Project General Design Criteria Manual governs the design of PVNGS Systems, Structures and Components.

During the Design Phase of the PVNGS Fire Protection System, fire prevention and separation were both used to ensure against the loss of a safety function due to a fire.Fire Prevention covers the design of automatic fire fighting equipment in accordance with recognized industry standards, and the design/selection of flame retardant materials so that the probability of a fire is very low.Separation criteria uses fire isolation techniques to prevent endangering redundant safe shutdown equipment.

The two subjects, while related, are separate and distinct.In plant areas~here fire is postulated to occur, the following separation requirements have been applied: Plant Arrangement Redundant safe shutdown equipment must not share an area in which there is a common source of flammable material like fuel oil or lube oil.Walls affecting a separation between such areas meet the requirements of ANSI N18.10, National Fire Code, ANI (NELPIA), and/or the Uniform Building Code.Where a flow path capable of communicating combustible gases or liquids from one safety area to another exists, instrumentation capable of detecting the transfer of the hazard (e.g., smoke, gas, or liquid detectors) is employed.The automatic trip of any flow moving equipment (e.g., fans, pumps)is accepted as sufficient isolation of any communicating pathway, if it can be shown that natural forces (gravity, dispersion, draft)will not continue flow from offending source.

QA PROGRAM FOR FIRE PROTECTION Page 4 of 42 Barriers Separation by barriers is considered as an extension of separation by the use of different fire areas.As such, all requirements expressed above apply equally well to the use of barriers.The Plant area barriers meet the design requirements (unless specific deviations have been addressed in FSAR Amendment 13, Section 98, Fire Protection).

Openings for cables in racewaysp trays, and distribution frames shall be closed using fire barriers that meet the design requirements.

Voids created where fire barriers)oin floors, walls, or ceilings, as well as piping that penetrates floors, walls, or ceillings are sealed to prevent communication of flammable liquids and gases.Materials used do not have a rating greater than 25 with respect to flame spread, fuel contribution, or smoke development as determined by ASTM-E84, Method of Test of Surface Burning Characteristics of Building Materials.

Where it can be shown that a partial harrier can insulate equipment from the heat of a fire hazard, it is not required that the barrier be able to completely contain smoke or nonflammable noxious fumes.S atial Se aration The primary emphasis for fire hazards isolation is placed on the more definable methods of plant arrangement and barriers.Demonstrating adequate separation between redundant safe shutdown trains to satisfy Regulatory Guide 1.75 is not sufficient to satisfy the design requirements of 10CFR50, Appendix R.However, where detailed evaluation to show compliance with Regulatory Guide 1.75 (which also considers separation between lE and non-1E components and cables)is required, an arbitrarily selected separation distance unsupported by Regulatory Guide 1.75, or analysis or testing is not acceptable.

Spatial separation analysis sho~s that PVNGS complies with 10CFR50, Appendix R, Section IIIG, unless specific deviatons have been approved by a Safety Evaluation Report.

,1 1 M QA PROGRAM FOR FIRE PROTECTION Page 5 of 42 I Bechtel Power Cor oration (BPC)Design bases for power plant projects undertaken by the Bechtel Engineering Department is provided in Design Criteria Documents.

These Design Criteria Documents include applicable standards, codes, regulations and/or other information including ANPP requirements.

Design Criteria Documents prepared by a discipline group were reviewed by the following personnel in accordance with EDP-4.1,"Design Criteria":

-Group Supervisors

-Chief Engineer of the Discipline

-Chief Nuclear Engineer-Project Engineer Included in the Fire Protection System Design Reviews were the ANPP Fire Protection Engineer, the insurance broker, ANI (American Nuclear Insurer), ANPP Nuclear Engineering in addition to those involed in the normal Bechtel review cycle.In addition, the Project Quality Engineer monitored the Design Criteria reviews.The external design interfaces between the project engineering team and non-Bechtel organizations such as ANPP and consultants were established in accordance with EDP-4.25,"Design Interface Control." Uiking Fire Protection Com any (Specification No.13-MM-650)

Uiking designed the complete PUNGS deluge, water spray and sprinkler systems for fire protection.

All the design documentation (calculations, Specs., drawings, etc.)were submitted to Bechtel for review snd concurrence in accordance with their specification.

These design documents received similar reviews and concurrences to Bechtel's design documents.

QA PROGRAM FOR FIRE PROTECTION Page 6 of 42 N B.Procurement Document Control Bechtel Power Com oration (BPC)PVNGS specifications were prepared, reviewed, approved, and controlled in accordance with EDP-4.49,"Project Specification." During the specification preparation, the following were considered:

Project design criteria, system or structure functional requirements, and SAR (where applicable).

Applicable codes, standards, and regulatory requirements.

Appropriate quality standards and acceptance criteria.The need for design analyses such as physics, stress, materials, thermal, hydraulic, radiation or accident as a basis for the specification requirements.

Design or operational test requirements necessary to ensure that the item will perform satisfactori3y in service.Requirements for packaging, handling, shipping, storage, cleaning and protective coatings.Engineering required hold points, including drawing approvals.

Required documentation in accordance with the EDP on specifying Engineering and Quality Verification Documentation, including Form G-321-E&V or D which shall be appendices to the appropriate specification..Quality Program Requirements.

Data'sheets which are utilized to convey any technical specification requirements from Bechtel to the supplier and data sheets that are to be completed by the supplier for the purpose of reporting engineering information from the Supp1ier to Bechtel.

QA PROGRAM FOR FIRE PROTECTION Page 7 of 42 The Engineering specifications were checked, by a qualified engineer other than the originator of the Specification.

Additionally, the Discipline Group Supervisor, Chief Engineer, and the Project Engineer reviewed and approved the Specification, and revisions thereto.After preparation and approval of Engineering Specifications by Bechtel, a Purchase Order is prepared and submitted to ANPP for review, evaluation, and acceptance.

The ANPP Responsible Engineer reviews the Purchase Order to assure that it incorporates the resolution of the Bid Evaluation comments and routes it for concurrence to: l)the Supervising Engineer, 2)the Nuclear Quality Assurance Manager, or his designee, 3)if applicable, to the Nuclear Construction Manager and Legal Counsel, and 4)the Nuclear Engineering Manager, in accordance with NS-4,"Procurement Document Control." Upon receipt of signatures indicating acceptance, the Purchase Order is routed to the Vice President, Nuclear Production, for signature on the Purchase Order Acceptance Form.Viking Fire Protection Coro any (Purchase Order Number 10407-23-MM-650)

The following major design requirements were incorporated:

a.Codes and Standards l.(NFPA 13, 15, 72D, etc.2.NEMA, UL, OSHA in general 3.ANSI B16.l, 16.5, etc.i 4.ASTM A53, A320, etc.5.IEEE-383 b.System Cleanliness per ANSI 45.2.1 c.Testing per NFPA 13, 15, 72D, etc.

h f 4 QA PROGRAM FOR FIRE PROTECTION Page 8 of 42 ORA B.Hop er 6 Son Inc.(Purchase Order Number 1040?-13-AM-126)

The following standards and codes were incorporated:

l.Underwriters Labortories, Inc.(UL)2.Fire Restistive Directory ISI/ICMS (Purchase Order Number 10407-13-AM-208)

The following ma)or codes and standards were incorporated:

l.ASTM E84, E119, D149, D257 2.Regulatory Guide 1.36 3.IREE 634 (subject to the exception of NRC Task RS809-5)Insulation Services Inc.(Purchase Order 10407-13-MM-301)

The following ma]or codes 6 standards were incorporated 1.Regulatory Guides 1.36 and 1.38 2.ASTM A36, A478, B209, C167, C335, etc.3~AWWA/WPCF 4

QA PROGRAM FOR FIRE PROTECTION Page 9 of 42 2~INSTRUCTION, PROCEDURES AND DRAWINGS I.Requirement Stated in the NRC Branch Technical Position"Instructions, tests, administrative controls, fire drills and training that govern the fire protection program shou3d be prescribed by documented instructions, procedures or drawings and should be accomplished in accordance with these documents." II.ANPP Position"PVNGS complies." III.ANPP Com liance A.Instructions and Administrative Controls Instructions (procedures and/or drawings)were utilized by Bechtel, ANPP, and the Subcontractors in the design, installation, testing, training and inspections of the PVNGS Fire Protection System.Bechtel Power Corporation (BPC)Refer to Attachment A for s sample of procedures used.Vikin Fire Protection Com any Instructions, procedures, quality and acceptance criteria are a part of the system installation drawings as prepared by Viking's Design Department.

ORA B.Ho er&Son, Inc.Manufacturer's published procedures and recommendations for storage, handling, surface preparation, application, touch-up and repair, curing and inspection were required for use in their specification.

P f I QA PROGRAM FOR FIRE PROTECTION Page 10 of 42 ISI/ICMS The various procedures/instructions utilized by this subcontractor are contained in the following three manuals: Production Work Instruction Manual Quality Assurance Procedure Manual Quality Control Procedure Manual Insulation Services, Inc.The various procedures/instructions utilized by this Subcontractor are contained in the Quality Assurance Manual and the Quality Control Procedure and Production Work Instructions for Installing Thermal Lag 330-1 Subliming Compound Manual.B.Test Refer to the"Test and Test Control" section of this report for compliance.

C.Fire Dri13s&Trainin During the construction phase of PVNGS, Bechtel implemented the"Fire Protection and Prevention Manual." It has as its basic minimum the requirements of OSHA as detailed in Federal Register, Volume 37, No.243, dated December 17, 1972.The Site Construction Manager/Project Superintendent instituted a Fire Brigade with a qualified Fire Brigade Chief.The Fire Brigade Chief plans, supervises, and conducts regularly scheduled training meetings and practice drills as necessary to insure complete understanding of Fire Fighting Plans and of the equipment provided.For the operations phase, Administrative procedures, Fire Protection Controls and the fire brigade are discussed in Section B of FSAR Table 9B.3-1.

1 QA PROGRAM FOR FIRE PROTECTION Page ll of 42 The PVNGS fire protection program is governed by the documents listed below.Fire Protection Documents 1.Fire Protection Policy-2P426.00.00 2.Fire Protection Program No.14PR-OZZOl 3.Technical Specifications 4.Fire Protection Equipment Testing and Maintenance Procedures No.14MT-9FP01 5.Control of Combustible Materials No.14AC-OZZ04 6.Fire Protection Systems Surveillance Test Procedures No.14ST-3ZZ02 thru 34ST-9ZZ26 7.Fire Team Training No.83TR-OZZ07 8.Fire Watch Duties No.14AC-OZZ05 9.Fire System Impairment No.14AC-OZZ01 10.Pre-Fire Strategies Book ll.Hot Work Authorization No.14AC-OZZ03 12.Plant Change Package and Design Change Package Review for Fire Protection No.14AC-OZZ06 QA PROGRAM FOR FIRE PROTECTION Page 32 of 42 3.CONTROL OF PURCHASED MATERIAL EQUIPMENT AND SERVICES I.Requirement Stated in the NRC Branch Technical Position"Measures should be established to assure that purchased material, equipment and services conform to the procurement documents." II.ANPP Position PVNGS complies by requiring each supplier/subcontractor to furnish the fol3owing documents for their respective fire protection equipment or services: Code Compliance documents which are prepared by the manufacturer or installer and certified by the Authorised Code Inspector.

Performance Test Verification Reports (where applicable).

Pressure Test Verification Reports (hydro, air, leak, or vacuum as applicable).

Certificates of Compliance for Shipment.Material Certificates of Compliance (where required by code).Subcontractors and Suppliers submit the'documentation required by their specifications as noted below: Viking Fire Protection Com any (13-MM-601)

Performance Test Report of System Pressure Test Hydro Installation Inspection and Verification Report Ora B.Ho er (l3-AM-126)

Prototype Test Reports Material Specifications and Data Manufacturer's Material and Application Certificates QA PROGRAM FOR FIRE PROTECTION Page 13 of 42 ISI/ICMS&BISCO (13-MM-301 6 33-AM-208)

Fire Endurance Test Reports Installation Certificate of Compliance Honeywell, Inc.(13-MM-651)

Code Compliance Inspection and Verification Report CHEMETRON, Inc.(13-MM-652)

Performance Tests and Verification Report Air Bubble Test Report Code Data Sheets Over and above the aforementioned commitments, PVNGS has utilized audits, monitoring, inspections and testing as methods to provide'dditional assurance that purchased materials and equipment perform their intended functions.

Verification of implementation of the measures established in the procurement documents is documented by the following'.

Audits/Surveillance (refer to"Audit" section of this report)Inspection/Malkdowns (refer to"Inspection" section of this report)Test (refer to"Test and Test Control" section of this report)Review cycle for Procurement Document (refer to"Design and Procurement Control" section of this report)

QA PROGRAM FOR FIRE PROTECTION Page 14 of 42 4.INSPECTION I.Requirement Stated in NRC Branch Technical Position"A program for independent inspection of activities affecting fire protection should be established and executed by, or for, the organization performing the activity to verify conformance with documented installation drawings and test procedures for accomplishing the activities." II.ANPP Position PVNGS complies by utilizing the American Nuclear Insurers (ANI)as the independent inspection organization, ANI is included in the review cycle for a11 installation drawings and witness of system acceptance tests.In addition to the ANI review of installation drawings and witness of s'stem acceptance tests, the ANI representative has conducted inspections to verify the systems have been designed/installed in accordance with the applicable codes and standards..

ANI acceptance of Fire Protection Systems is documented by official correspondence.

Over and above the aforementioned commitment, PVNGS has utilized additional inspection activities to provide an additional 3evel of confidence that installation requirements have been met.Bechtel Power Co oraton Prior to subsystem transfer from Bechtel to Startup and to Operations, a walkdown of the subsystem is performed in accordance with WPP/QCI 31.0, Subsystem Transfer Acceptance.

This procedure also applies to the transfer/acceptance of components within a subsystem.

IP-5.26,"Configuration Verification Walkdowns," provides specific walkdown verifications of existing plant conditions in support of the project configuration control program.Attachment 5.26-04,"Fire QA PROGRAM FOR FIRE PROTECTION Page 3.5 of 42 Protection Design Documentation Walkdown Program," provides the guidelines for performing a walkdown of the station fire protection features to verify that the systems have been.installed in accordance with the design requirements.

Walkdowns were required of a31 buildings and outside areas as listed below: Control Bui3.ding Diesel Generator Bui1ding Fuel Building Auxiliary Building Radwsste Building Main Stam Support Structure Fire Water Pump House Main Transformer ESF Transformer Auxiliary Transformer Normal Service Transformer Startup Transformer tube Oil Storage Tanks Turbine Building Auxiliary Boilers Guard House WPP/QCI 205.0, Fire Protection Sprinkler Piping Installation, establishes requirements for the inspection of Quality Class"R" Fire Protection Sprinkler Piping and associated pipe supports installed in accordance with engineering drawings which implement the requirements of Specification 13-MM-650 and applicable codes and standards.

Special Construction Inspection Plan (CIP)544.0, Fire Protection Sprinkler Piping, was used by Field Engineering for the inspection of a representative sample (10%)of Unit 1 Quality Class:"R" Fire Protection Sprinkler Piping and associated pipe supports installed in accordance with 13-MM-650.

On November 19, 1984, Bechtel Engineering initiated a sampling program to perform an independent assessment of the MONOKOTE Fire Retardant application thickness adequacy.The unit of sampling inspection was defined as an individual beam or column.A total of 19 inspection units were sampled within Unit 3, and 9 inspection units within Unit 1.

QA PROGRAM FOR FIRE PROTECTION Page 16 of 42 Selection of inspection units was performed by partitioning the sampled areas into cells representing all elevations and plan locations.

Of the approximately 280 individual thickness measurements made during sampling, zero were more than 1/8 inch below the required average thickness.

Thus, no"low point" exceeding the UL Fire Resistance Directory minimum acceptance thicknesses were discovered.

73AC-OZZ04, Subsystem/System Acceptance by PVNGS Nuclear Operations, delineated the methods and responsibilities for the process of jurisdictional"Acceptance" of a system/subsystem from Stsrtup or Construction Groups hy PVNGS Nuclear Operations.

This procedure applies for Units 1, 2, 3, and common.The System Completion Group (SCG)conducted an acceptance walkdown of the Fire Protection Systems.

i 4 P QA PROGRAM FOR FIRE PROTECTION Page 17 of 42 5.TEST AND TEST CONTROL I.Requirement Stated in the NRC Branch Technical Position"A test program should be established and implemented to assure that testing is performed and verified by inspection and audit to demonstrate conformance with design and system readiness requirements.

The tests should be performed in accordance with written test procedures; test results should be properly eva3.uated and acted on." II.ANPP Position PVNGS complies.III.ANPP Com liance PVNGS FSAR Chapter 14,"Initial Test Program," defines the requirements beginning with the transfer of the system from construction through Power Ascension Testing of PVNGS Units l, 2, and 3.The testing phase has been broken into the fo33owing phases: Prerequisite Testing consists of tests and inspections required to assure construction is complete and that systems are ready for Phase I Testing.Phase I Testing (Preoperational Testing)demonstrates that structures, systems and components operate in accordance with design operating modes, throughout the full design operating range.The ANPP Startup Organization, is responsible for implementing the requirements of the Test Program described above.Administrative Control procedures are utilized to control snd implement the requirements of Prerequisite and Preoperational Testing (Phase I Testing).Attachment"B" provides a sample of Administrative/Imple-menting Test Procedures used by the Startup organization to verify proper design snd instal3.ation of the Fire Protection System.The personnel performing these tests are independent of the construction/

installation organization.

II QA PROGRAM FOR FIRE PROTECTION Page]8 of 42 As part of the normal procedure review cycle of the Phase I Test procedures, ANPP Quality Assurance Department provides an independent review of these procedures and changes thereto to verify that regulatory and quality requirements have been properly addressed.

Additiona3.1y, the Fire Protection test procedures and results have been found acceptable for insurance purposes by ANI.Test results are reviewed and evaluated by qualified individuals and/or groups in accordance with 90AC-OZZ18,"Test Results Review." Implementation of the testing program was verified by the conduct of Audits and Surveillances.

Refer to the"Audit" section of the report.For the Operational Phase Testing Activities (Phase II to IV), the Technical Specification requirements are implemented by 73AC-9ZZ04,"Surveil3.ance Testing." Bechtel Power Cor oration WPP/QCI 203.0, Piping System Pressure Testing, establishes a procedure for the performance and documentation of piping systems pressure testing.These tests are witnessed by teh AFE/PTE.WPP/QCI 202.4, Ho3.iday Testing, establishes a proceduree for the performance and documentation of Ho3iday Testing of underground piping.These tests are witnessed by the AFE.Vikin Fire Protection Com any The following tests were conducted in accordance with NFPA 15 and are usual3y witnessed by ANI, ANPP Nuclear Construction and Bechtel: Hydrostatic Testing Sprinkler Flow Testing Sprinkler Perfromance Testing

gA PROGRAM FOR FIRE PROTECTION Page 19 of 42 6.INSPECTION, TEST AND OPERATING STATUS I.Requirement Stated in the NRC Branch Technical Position"Measures should be established to provide for the identification of items that have satisfactorily passed required tests and inspections.

II.ANPP Position PVNGS complies III.ANPP Coro liance Inspection, Test, and Operating Status is verified prior to transfer of systems from Construction to Stsrtup and prior to acceptance of a system by Nuclear Operations.

Transfer of components or subsystems and supporting documentation from Construction to PVNGS Startup is performed in accordance with 90GA-OZZ04,"Startup System Turnover." Open items that potentially impact the comp3etion of the Project are tracked on the Master Tracking System (MTS)in accordance with 90GA-OZZ05, Startup Master Tracking System beginning at Construction Transfer and continuing through Acceptance by PVNGS Nuclear Operations.

Acceptance of a system/subsystem from Startup to PVNGS Nuclear Operations is performed in accordance with 73AC-OZZ04,"Subsystem/System Acceptance by PVNGS Nuclear Operations." Open items that potentially impact the completion of the Project are tracked on the Operation Master Tracking System in accordance with?3AC-OZZ3l, Operations Master Tracking System beginning at Subsystem Acceptance by PVNGS Nuclear Operations.

4 QA PROGRAM FOR FIRE PROTECTION Page 20 of 42 ANPP Corporate Quality Assurance reviews a sampling of documentation records on Quality C3ass Q and"R" systems, and the subsystem/aress that are considered"Important to Safety" as defined in 73AC-OZZ03..

These reviews verify compliance with the following, as a minimum: Document is identifiable to the Item/Test for which it applies.Installation records are consistent with the installation.

Document entries are completed in accordance with applicable procedural requirements.

Document has required stamps, signatures, initial, dates, etc., per applicable procedural requirements.

Installation, Test and/or Inspection Records indicate acceptability.

Deficiencies and exceptions are properly identified and documented.

The above activity is performed in accordance with QADP 6.6, Subsystem/Area Document Review.After the operations acceptance package reviews are performed and determined to be acceptable, the package is routed to the PVNGS Plant Manager for fina3.acceptance.

Startup Testing (Prerequisite and Preoperational) is monitored by the Discipline Test Schedule (DTS)in accordance with 90GA-OZZ22, Startup Discipline Test Schedule.

QA PROGRAM FOR FIRE PROTECTION Page 21 of 42 7.NONCONFORMING ITEMS I.Requirement stated in the NRC Branch Technical Position"Measures should be established to control items that do not conform to specified requirements to prevent inadvertent use of installation." II.ANPP Position PVNGS complies.III.ANPP Corn liance Bechtel Power Cor oration (BPC)During the construction phase, the identification, documentation, segregation, review, disposition and notification to affected organizations of materials, parts, components or services which are found to nonconforming to specific requirements for all quality classes are documented in accordance with WPP/QCI 5.0,"Nonconforming Material, Parts and Components." EDP-4.61, Nonconformance Reports, defines a method for review, evaluation, disposition and control of NCRs received by Pro)ect Engineering.

Field Change Requests received by Product Engineering are reviewed, evaluated, dispositioned and controlled via EDP-4.62, Field Change Request.Supplier/Subcontractor deviations from procurement documents are documented on a Supplier Deviation Disposition Request (SDDR)in accordance with their respective specifications.

Bechtel reviews and dispositions the SDDR in accordance with EDP 4.63,"Supplier Deviation Disposition Request." During the PVNGS Startup phase, the identification, documentation, segregation, review, disposition and notification to affected organizations of materials, parts, components, or services which are found to be nonconforming to specified requirements are documented, reviewed and dispositioned in scccordance with 90GA-OZZ19,"Startup Field Report."

QA PROGRAM FOR FIRE PROTECTION Page 22 of 42-8.CORRECTIVE ACTION I.Requirement Stated in the NRC Branch Technical Position"Measures should be established to assure that conditions adverse to fire protection such as failures, malfunctions, deficiencies, deviations, defective componentsp uncontrolled combustible material and nonconformance are promptly identified, reported and corrected." II.ANPP Position PVNGS companies.

III.ANPP Com liance Bechtel Power Cor oration (BPC)Control of design deficiencies is achieved by the use of various documents which are used after discovery of the deficiency.

Attachment"C" shows a matrix which summarizes the various documents used to identify and initiate correction of deficiencies, for which Engineering has responsibility for resolution of deficiency in design.It also references the document defining each method and the normal point of discovery.

The matrix includes a summary of the self-closing documents as well as other methods used to identify design deficiencies (refer to EDP 4.65,"Design Deficiency Processing").Design deficiencies indicated by the document types listed in the matrix shall be assessed for possible additional reporting under either of the following:

10CFR50.55(e)

-Significant Deficiency Reporting 10CFR Part 21-Substantial Safety Hazard Defects and Noncompliance Reporting Corrective Action Request, Nonconformance Report, Field Change Request, Supplier Deviation Disposition Request, etc.are reviewed for reportability in accordance with the EDPs governing these items.If a reviewer of any of these believe that he/she has noted a Potentially Reportable Condition, a Deficiency Evaluation Report (DER)is initiated in accordance with EDP 4.66,"Substantial Safety QA PROQRAH FOR FIRE PROTECTION Page 23 of 42 Hazard and Significant Deficiency Reporting (Deficiency Evaluation Report)" and reviewed by ANPP in accordance with NS-17, Processing Deficiency Evaluation Reports.Corrective Action Requests (CAR)provide objective evidence for the identification and resolution of deficiencies in the implementation of the Quality Program.PQPH No.16.0, Corrective Action governs the use of Bechtel CARs.A"subsequent system jurisdictional transfer/release" form is generated in accordance with WPP/QCI 31.0, Subsystem Transfer Acceptance which states that"all construction to be performed by subcontractor is complete, including final inspection documentation verifying that subcontractors portion of the subsystem is in accordance with applicable specifications and drawings and is ready for functional testing, calibration and/or operations." This form also allows for exceptions to be attached on an IIL/PL.ANPP Quality Assurance Department Procedures 16.0 controlled the use of Corrective Action Requests for ANPP during the construction and startup phases.Appropriate methods to identfy snd correct deficiencies during the transfer of Fire Protection Systems/Subsystems from Construction to Startup and subsequent acceptance by Operations have been established.

The details of these methods are discussed in"Inspection" and"Inspection, Test and Operating Status".

QA PROGRAM FOR FIRE PROTECTION.Page 24 of 42 9.RECORD I.Requirement Stated in the NRC Technical Branch Position"Records should be prepared and maintained to furnish evidence that criteria enumerated above are being met for activities affecting the Fire Protection Program." II.ANPP Position PVNGS complies.III.ANPP Com liance Bechtel Power Cor oration Bechtel controls construction documentation through the following programmatic and implementation documents:

PQPM 17.0,"Quality Assurance Records" PQPM 17.1,"Supplier Quality Assurance Records-House Office Procurement" EDP 4.37,"Design Calculations" EDP 5.32,"Nuclear Project Records Management (Design Office)EDP 5.15,"Design Drawing Control" EDP 5.16,"Supplier Document Control" IP 5.32,"Project Records Retention (Design Office)" IP 4.25,"Transmittal of Drawings 6 Data" IP 4.33,"As-Built Records" Bechtel retains these records on behalf of ANPP pending review and acceptance by ANPP based on contractual stipulations.

Subcontractors/Su liers Subcontractors/Suppliers submit both engineering documents and quality verification documents to Bechtel in accordance with the requirements of their purchase specification.

Section 3 of this report identifies types of documents submitted.

gA PROGRAM FOR FIRE PROTECTION Page 25 of 42 ANPP Drawing and Document Control (DDC)retains all transferred records from Bechtel DDCC and other ANPP generated records, eg., Start-up Test Results, for established retention periods in accordance with the Records Management Procedures Manual.

QA PROGRAM FOR FIRE PROTECTION Page 26 of 42 10.AUDI10 I.Requirement Stated in the NRC Branch Technical Position"Audits should be conducted and documented to verify copliance with the fire protection program including design and procurement" documents; instruction; procedures and drawings;and inspection and test activities." II.ANPP Position PVNGS complies III.ANPP Com liance Bechtel Power Cor oration (BPC)Bechtel Quality Assurance Department conducted and documented numerous fire protection subcontractor audits and survei13ances in accordance with"the Pro)ect Quality Program Manual, sections 18.0, (audits), 18.3", (Subcontractor Audits-Jobsite)and 18.6.(Project QA Surveillance)".'ttachments D and E to this section provide a list of these audits and surveillances.

ANPP Quality Assurance Department conducted and documented numerous fire protection audits and surveillances in accordance with the Quality Assurance Manual, section 18.0, (audits).Attachments D and E to this section provide a 3ist of these audits and surveillances.

In addition, the ANPP Quality Assurance Program establishes annual, biennial, and triennial audits of the PVNGS Fire Protection Program as required by Technical Specifications.

PVNGS audits'have been conducted as required by the commitment to verify the implementation of the QA Program.In those cases, where Fire Protection Systems were not specifically the subject of an audit, the generic controls which are applied to a function have been audited.For example, the design and procurement programs used by QA PROGRAM FOR FIRE PROTECTION Page 27 of 42 Bechtel are the same whether the systems are Quality Class"Q","R", or"S".Therefore, these audits provide an adequate level of confidence that the controls are sufficient to assure proper implementation of programs.

fl II QA PROGRAM FOR FIRE PROTECTION Page 28 of 42 CONCLUSION As previously noted, a Quality Assurance Program was in place to meet the requirements of Appendix A of the NRC Branch Technical Position APCSB 9.5-1.The following is a brief synopsis of the three major Branch Technical Position Criteria: Design Control and Procurement Document Control, Inspection, and Test and Teat Control.The Design activities were accomplished in accordance with approved procedures, instructions or drawings and were reviewed'and approved by competent individuals.

Included in the Fire Protection System Design reviews were the ANPP Fire Protection Engineer, The Insurance Broker, ANI, ANPP Nuclear Engineering and those involved in the normal Bechtel revie~cycle (Chief Engineer, Discipline Group Supervisor, etc.).The result of the evaluation program defined in the PVNGS FSAR Appendix determined that PVNGS can reach and maintain co1d shutdown conditions following a postulated fire, even though several deviations from 10CFR50, Appendix R, NFPA Standards and Branch Technical position APCSB 9.5-1 have been identified in the PVNGS FSAR Appendix 9B, Amendment 13 and letter ANPP-31378-EEVB/llFQ dated December 7, 1984.In addition, as a result of the NRC Inspection dated July 9-13, 1984, s full-scale seismic computer analysis of"worst case" sprinkler piping conditions was performed by Viking.Also, an independent verification of the entire Category IX sprinkler piping installation was conducted by Bechtel to verify design adequacy (Reference B/ANPP-E-123389).

Similarly, ANPP Nuclear Engineering has reviewed the following material regarding Fire Protection System Category IX Design and concludes that the design meets the applicable Category IX requirements (Reference ANPP-21406 ACR/GJV and ANPP-21516 MFH/GJV): Bechtel Seismic Category IX Evaluation Calculations, 13,MC-ZZ-004 Viking Hanger details and calculations, M650-200-4 Viking Seismic Analysis Verification, M-650-824-1 Bechtel Cable Tray Supports Calculation, 13-CC-ZS-005 NRC Item 50-528/84-25 0

'QA PROGRAM FOR FIRE PROTECTION page 29 of 42 In addition to the Design Documents receiving ANPP review, Procurement Documents also were reviewed by ANPP personnel which included Nuclear Engineering, Site Construction, Quality Assurance, Legal Counsel and the Vice President of Construction Projects'.

Even though the personnel conducting the verification walkdowns for"R" and"S" installations did not necessarily meet the qualification requirements.

of ANSI N45.2.6, independent verification of the Fire Protection installations was achieved as follows: ANI inspection of Fire Protection Installation t Bechtel Engineering Wa2kdowns prior to system acceptance in accordance with WPP/QCI 31.0 Bechtel Engineering configuration, verification walkdowns in accordance with IP-5.26.Bechtel Engineering walkdowns for verification of Subcontractor rework in accordance with WPP/QCI 205.0 Bechtel 10%walkdowns of seven (7)Fire Protection subsystems/systems in accordance with Special CIP 544.0 ANPP Engineering subsystem/system acceptance walkdowns performed in accordance with 73AC-OZZ04 Bechtel Engineering sample verification of structural steel fire retardant coating application.

Finally, as delineated'above', not only were the tests required by the various specifications performed, but also, ANPP conducted extensive testing of the Fire Protection System in accordance with the requirements described in the FSAR, Chapter 14, PVNGS Technical Specifications and also the PVNGS Station Manual.These tests have assured compliance of the Fire Protection System'to meet the Design Criteria and perform its intended function.Additionally, ANI has accepted the PVNGS Fire Protection System for insurance purposes.

QA PROGRAM FOR FIRE PROTECTION Page 30 of 42 ATTACHMENT A s.Design EDP-4.1,"Design Criteria" EDP-4.25,"Design Interface Control" EDP-4.37,"Design Calculations" EDP-4.46,"Project Drawings" IP-4.1,"Design Criteria" IP-4.2,"Design Calculations" IP-4.30,"Product Engineering Drawings" b.Procurement EDP-6.5,"Bid Evaluation" EDP-5.10, Supplier Quality Assurance Program Selection and Evaluation" IP-1.24.0,"Evaluation and Selection of Potential Suppliers" IP-3.24.5,"Preparation, Processing and Content of Purchase Orders" IP-1,.24.8,"Purchase Order Revision" c~Installation and Inspection WPP/QCI 101.0, WPP/QCI 151.0, WPP/QCI 202.0, WPP/QCI 203.0, WPP/QCI 258.0, WPP/QCI 302.0,"Welding Control""Mechanical Equipment Installation""Piping System Insta3lation""Piping Systems Pressure Testing""E3.ectrical Equipment Insta3.3ation""Instrumentation Installation" QA PROGRAM FOR FIRE PROTECTION Page 31 of 42 ATTACHMENT B FIRE PROTECTION

-STARTUP PHASE TEST PROCEDURES 90AC-OZZ02 90AC-OZZ18 91PE-1CL01 91PE-1FP01 91PE-1FP02 91PE-1FP03 9IGT-OZZ20 92PE-1QK01 92GU-OZZ54 92GS-OZZ23 92GS-OZZ25 92GU-OZZ41 92GU-OZZ49 Startup Test Conduct Test Results Review Local Leak Rate Test Fire Protection System Pre-Operational Test of the Halon 1301 Fire Suppression System Carbon Dioxide Flooding Test Fire Damper Initial Operation Fire Detection and Alarm System Cardox for Battery and Switchgear Rooms ACI Model A888-134 Control Unit ACI Model A888-M135 Control Unit with Aci Battery Backup Control Unit Smoke Detectors Ansul Model PID-9 Ionization Smoke Detector 92GU-OZZ50 Protectowire Control Panel ACR1615 (5 systems)ACR1638 (6 systems)

QA PROGRAM FOR FIRE PROTECTION Page 32 of 42 92GU-OZZ51 92GU-OZZ53 92GU-OZZ55 92GU-OZZ56 92GU-OZZ91 92GU-OZZ92 Protectowire Control Panel ACR1603 Pyrotronics Fire Protection Control Panel System 3 Battery Pack Alison Model A888-M135A Control Panel with ACI Battery Backup ACI Panel A888-M136 Alison Model A12000 and N12000 Combustion Defectors Pyrotronics Ionization Detector Model No.DI-2 92GU-OZZ98 92GU-OZZ36 MF-323.1 MF-323.2 MF-323.3 MF-323.4 Honeywell W940A Panel Checkout ANSUL Autopulse Dual Zone Panel Model 1060-Halon 1301 Flushing Hone Stations Turbine Building Flushing Radwaste, Control 6 Corp.Bldg.Fire Hose Statopms Velocity Flush for F.B.Fire Hose Stations Flushing Containment Fire Hose Stations MF-323.5 F3ushing Deluge/Presction Va3.ves QA PROGRAM FOR FIRE PROTECTION Page 33 of 42 MF-323.6 MF-323.7 Flushing Auxiliary Building Fire Hose Stations Fire Protection Systees C02 Flush NOTE: These test procedures are available upon request.

QA PROGRAM FOR FIRE PROTECTION Page 34 of 42 ATTACHMENT C DESIGN DEFICIENCY PROCESSING MATRIX Document Type Origin Authority Reference Document Point Of Discovery Nonconformance Report (NCR)Field Field Inspection Manual Engineering Depart-ment Procedures Field Field Change Request (FCR)Field Engineering Depart-Field ment Procedures Supplier Devia-tion Disposition Request (SDDR)Suppliers Engineering Depart-Supplier ment Procedures Shop Audit Finding Report (AFR)Quality Assurance Nuclear Quality Assurance Manual/Quality Assurance Program Engineering Construc-tion Sup-plier Quality Engineering Reports Project Quality Engineer Project Procedures Engineering Shop Inspection Reports Procurement Procurement Inspec-tion Department Manual Supplier Procurement Audit Reports Procurement Procurement Inspec-tion Department Manual Supplier Shop QA PROGRAM FOR FIRE PROTECTION Page 35 of 42 Document Type Origin Authority Reference Document Point Of Discovery Corrective Action Report (CAR)Startup Fie3d Report (SFR)Quality Assurance Startup Nuclear Quality Assurance Manual/Quality Assurance Program Startup Field Report Index Engineering Construc-tion Sup-plier Startup

QA PROGRAM FOR FIRE PROTECTION Page 36 of 42 ATTACHMENT D AUDITS PERFORMED ON FIRE PROTECTION SYSTEM AUDIT NO.ORGANIZATION PURPOSE 80-VFP-S-27 BPC To verify the implementation of the Viking Quality Assurance Manual and Subcontract 13-MM-650.

81-VFP-S-lo BPC To verify the implementation of the Viking Quality Assurance Manual and Subcontract 13-MM-650.

81-VFP-S-27 BPC To verify the implementation of the Viking Quality Assurance Manual and Subcontract 13-MM-650.

82-VFP-S-9 BPC To verify the implementation of the Viking Quality Assurance Manual and Subcontract 13-MM-650.

82-VFP-S-27 83-VFP-S-ll BPC BPC To verify the implementation of the Viking Quality Assurance Manual and Subcontract 13-MM-650.

To verify the implementation of the Viking Quality Assurance Manual and Subcontract 13-MM-650.

83-VFP-S-21 BPC To verify the implementation of the Viking Quality Assurance Manual and Subcontract 33-MM-650.

f QA PROGRAM FOR FIRE PROTECTION Page 37 of 42 AUDIT NO.ORGANIZATION PURPOSE 84-VFP-S-9 BPC To verify the implementation of the Viking Quality Assurance Manual and Subcontract 13-MM-650.

84-VFP-S-19 84-UA-S-20 BPC BPC To verify the implementation of the Viking Quality Control Manual and compliance with Subcontracts 13-MM-650.

In-cluded in this audit was an assessment of corrective ation taken to resolve previously identified deficiencies and verification of BCI Construc-tion implementation of WPP 205.0 ,"Fire Protection Sprinkler Piping Installation." Verify implementation of the Ora B.Hopper and Son Subcon-tract 13-AM-126.

84-ISI-S-15 83-ICMS/ISI-S-14 83-ICMS/ISI-S-26 83-ISI-S-30-UA BPC BPC BPC BPC To verify implementation of the Insulation Services Subcontract 13-MM-301 To verify implementation of'the ICMS/ISI Subcontract 13-AM-208.

To verify implementation of the ICMS/ISI Subcontract 13-AM-208.

To verify implementation of the ISI Subcontract 13-MM-301.

II ,r QA PROGRAM FOR FIRE PROTECTION Page38 of 42 AUDIT NO.ORGANIZATION PURPOSE 82-ICMS/ISI-S-20 82-ICMS/ISI-S-32 BPC BPC To verify implementation of the ICMS/ISI Subcontract 13-AM-208.

To verify implementation of the ICMS/ISI Subcontract 13-AM"208'83-10 ANPP To verify compliance by both Bechtel and Subcontractor to Project Specifications and applicable portions of NRC Technical Branch Position APCSB 9.5-1.Additionally, audit verify corrective action taken to resol.ve NRC Open Item.083-14 S-83-037 ANPP To verify the adequacy of the Fire Protection Program, Admin-istrative Contxol and Imple-menting Procedure.

To verify the Fire Protection Administrative Program during startup phase activities, is in compliance with Branch Techni-cal Position ASB 9.5-1, Appen-dix A, the FSAR and the Opera-tions Quality Assurance Criter-ia Manual.Trend Analyses CAR CA-84-Olll ANI Triennial Fire Protection Audit Problems identified with Sub-contractor control.Verification of compliance with different Fire Protection Criteria.84-024 ANPP Annual audit to verify the adequacy of the Fire Protection Program.

QA PROGRAM FOR FIRE PROTECTION Page 39 of 42 ATTACHMENT E FIRE PROTECTION SURVEILLANCE REPORTS NO/DATE 6/4/So 6/8/80 7/7/So 7/8/80 7/9/80 7/29/80 8/6/80 8/6/80 10l27l80 11/25/80 12/17/80 12/17/80 1/15/81 1/17/Sl 1/28/81 1/28/81 1/28/81 3/9/81 ORGANIZATION BPC BPC BPC BPC BPC BPC BPC BPC BPC BPC BPC BPC BPC BPC BPC BPC BPC BPC ITEM/OPERATION Storage Installation Receiving Inspection Installation Drawing Control Installation Fabrication/Installation Storage Fabrication/Installation Fabrication/Installation Record Installation Storage Installation Operations/Test Records Hydrostatic Testing Receiving Inspection

QA PROGRAM FOR FIRE PROTECTION Page 40 of 42 NO/DATE ORGANIZATION ITEM/OPERATION 4/2/81.4/21/81 5/29/81 6/21/82 6/21/82 6/21/82 9/29/82 9/29/82 3/2/83 3/22/83 8/5/83 10/6/83 10/21/83 11/2/83 ll/2/83 1/19/84 5/4/84 6/5/84 9/10/84 BPC BPC BPC BPC BPC BPC BPC BPC BPC BPC BPC BPC BPC BPC BPC BPC BPC BPC BPC Verification of QA Manual Storage/Housekeeping Storage/Housekeeping Document Control Acceptance Test Control of M&TE Drawing Submittals Handling, Storage&Shipment Control of M&TE Procurement Document Control Instruction, Procedures and Drawings Handling, Storage&Shipping Installation Work Control Handling, Storage&Shipping Review of Drawings Use of Fie3d Drawings Drawing Control Calibration of M&TE QA PROGRAM FOR FIRE PROTECTION Page 41 of 42 NO/DATE 7/30/84 7/30/84 9/13/84 32/9-27-76 46/10-8-76 120/3-4-77 176/6-6/77 330/10-26-77 535/3-2-79 579/8-1-79 696/5-21-80 717/6-27-81 787/1-27-81 805/3-11-81 807/3-14-81 835/7-29-81 863/11-18-81 864/11-19-81 ANPP CONDUCTED SURVEILLANCES BPC BPC BPC ANPP ANPP ANPP ANPP ANPP ANPP ITEM/OPERATION Control of Purchase Materials Equipment and Services Handling, Storage&Shipping Housekeeping Excavation and Firewater Storage Tank Rain, Flood&Fire Protection Flushing Handling, Storage&Shipping Storage Placement Storage Testing Storage Testing Walkdowns Testing Storage Work Completion Work Completion

QA PROGRAM FOR FIRE PROTECTION Page 4g of 42 NO/DATE 1003/5-9-82 10028/8-26-82 1113/10-26-82 1114/30-31-82 1179/10-15-82 1206/12-28-82 1260/2-4 to 7/83 1275/2-15-83 287/2-22-83 1315/2-14 to 28-83 1338/4-4-83 1339/4-4-83 1411/4-22 to 25-83 1437/5-26-83 1481/6-21-83 1499/6-30-83 R84-062/1-12-84 R84-0466/2-13-84 ANPP CONDUCTED SURVEILLANCES ANPP ANPP ANPP ANPP ANPP ANPP ANPP ANPP ANPP ITEM/OPERATION Corrosion Problems Control of Purchase Materials Installation

-Seismic IX Hangers Work Completion Seismic IX Hangers (Inspect)Installation Fire Protection Sprinkler Fab, Shop FP Alarm System Installation Verification of Viking Activ-ities Investigation of Underground Piping.Testing (Hydro)Vendor Surveillance (Viking)Alarm System Installation FP Sprinkler Fabrication Shop Testing (Hydro)Alarm System Installation Followup on Audit C83-10 Investigation 83-25 j