ML20211G624
| ML20211G624 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 01/31/1987 |
| From: | ABB IMPELL CORP. (FORMERLY IMPELL CORP.) |
| To: | |
| Shared Package | |
| ML20211G570 | List: |
| References | |
| 01-0210-063, 1-210-63, NUDOCS 8702250455 | |
| Download: ML20211G624 (26) | |
Text
L E
TEXAS UTILITIES GENERATING CO.
h COMANCHE PEAK STEAM ELECTRIC STATION
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!I SUPPLEMENT B lI FIRE PROTECTION
!I CORRECTIVE ACTION PLAN
!il MECHANICAL
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GENERIC ISSUES
{l REPORT 1
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IMPELL CORPORATION I
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APPENDIX H TEXAS UTILITIES GENERATING COMPANY COMANCHE PEAK STEAM ELECTRIC STATION UNIT 1 AND COMMON EVALUATION AND RESOLUTION OF TERA B
FIRE PROTECTION ISSUE RESOLUTION REPORT DAP-E-EIC-505 l
CORRECTIVE ACTION PLAN I
PREPARED FOR:
TEXAS UTILITIES GENERATING COMPANY GLEN ROSE. TEXAS I
I eReeAeED eY:
IMPELL CORPORATION I
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IMPELL REPORT NO.
01-0210-063 REV. O JANUARY 1987 I
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January 16. 1987 Table of Contents Page Title Page Table of Contents i
1.0 INTRODUCTION
1 2.0 SCOPE 1
3.0 ISSUE RESOLUTION PROCESS 2
4.0 REPORT ORGANIZATION 4
TABLE 1 Fire Protection Corrective Action Plans 5
TABLE 2 Fire Protection Program Work Scope Sumrcary 6
I, APPENDIX 1 Fire Exit Routes APPENDIX 2 Flame Spread Rating of Interior Finishes APPENDIX 3 Fire Damper Testing APPENDIX 4 Fire Detection System APPENDIX 5 Eight-Hour Emergency Lighting Units APPENDIX 6 Fire Protection Systems Interaction APPENDIX 7 Fire Safe Shutdown / Alternate Shutdown I
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I January 16. 1987 TEXAS UTILITIES GENERATING COMPANY COMANCHE PEAK STEAM ELECTRIC STATION UNIT 1 AND COMMON MECHANICAL CORRECTIVE ACTION PLAN FIRE PROTECTION
1.0 INTRODUCTION
This Mechanical Corrective Action Plan-Fire Protection for the Comanche Peak Steam Electric Station (CPSES) Fire i
Protection Program describes the method, scope and responsibilities for resolving the Comanche Peak Response Team (CPRT) design adequacy issues for fire protection.
The objective is to demonstrate that a complete Fire Protection Program is in place in accordance with FSAR and other licensing commitments, fully supported by adequate documentation.
2.0 SCOPE I
The Issue Resolution Report (IRR) DAP-E-EIC-505 issued by TERA and the individual Discrepancy Issue Reports identified several specific design issues that require closure and I
which, in turn, lead to generic technical issues.
The DAP identified issues associated with the Fire Protection Systems Interaction. Safe Shutdown / Alternate Shutdown and Fire Protection Program.
The issues associated with Safe i
Shutdown / Alternate Shutdown will be addressed by Engineering Planning Management Inc. (EPM), who has Lead Contractor responsibility for the Fire Safe Shutdown Analysis.
I Although not specifically identified in a DIR. work-in-progress will be considered as a separate iss' Work-in-progress includes fire protection activities that have not I
yet been completed or are currently undergoing significant revision.
8 This document addresses each of the generic issues and describes the program that will resolve these issues.
This program is designed to be comprehensive not only to respond to each issue previously identified but also to preclude future occurrence of similar issues.
New issues will be resolved by Impell, EPM, or other interfacing contractor as appropriate, whether they are TERA issues, new issues I
arising from completing the work-in-progress, or any other issues.
This will be accomplished by establishing the necessary interfaces and procedures to delineate the responsibility and methodologies which will constitute the
!I Fire Protection Group's function at CPSES.
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I 3.0 ISSUE RESOLUTION PROCESS In order to evaluate each of the concerns identified in I
DAP-E-EIC-505 and to ensure that each issue is adequately addressed within the current fire protection program, a thorough review of the IRR was completed.
Following this JI review, the most recent fire protection program procedures, project instructions and interfaces were reviewed to determine if the issues have already been resolved or incorporated in the fire protection program.
Additional I
revisions to the Impell Fire Protection Task Description (TNE-TD-IM-022) and Project Instructions have already been undertaken and/or identified to include changes resulting I
from the generic issues.
Specific technical or program issues identified in the individual DIRs, which have not already been incorporated into the Fire Protection Program I
are being isolated to ensure that their resolution is appropriately considered.
The proposed resolutions are determined by review of calculation / design input; design criteria and design values; design change implementations I
and interface control; specifications, vendor drawing and documents.
The corrective action effort will be performed in accordance with the Impell QA Program and the Impell Project Instructions for corrective action implementation.
The planned review of generic issues is as follows.
3.1 Review and Establish Design Criteria Bases In order to establish design criteria, pertinent fire protection design information will be reviewed.
This includes:
I FSAR Section 9.5-1, SER and related supplements (SSERs),
Reg. Guides, NRC IE Bulletins and Notices, BTP 9.5-1 Appendix A, 10 CFR 50 Appendix R.
CPSES NRC Correspondence related to design criteria TERA Design Criteria List Design Basis Documents Drawings Specifications ANI Requirements - Basic Fire Protection for Nuclear Power I
Plants I
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I These documents establish the design basis for each system and component design.
Any inconsistencies in the design commitments are resolved so that uniform licensing / design I
criteria can be used for the remainder of the corrective action efforts.
3.2 Review Design Calculations Calculations will be reviewed to ensure that design inputs I
are correct and current, that the assumptions, methodology and criteria used in the calculation are consistent with the design bases established for the CPSES design, and that the installed and tested conditions have been verified against I
the calculation results.
The review will ensure that sufficient calculations have been prepared to fully document the CPSES design.
Inconsistencies between the calculations and any design documents are identified and resolved in accordance with I
applicable design bases.
Results from the calculation review are provided to the appropriate engineering organization for activities not within Impell scope.
New calculations are prepared and existing calculations supplemented, as necessary, to provide complete, documented CPSES calculation bases.
Impell Project Instructions are I..
developed for review, preparation, revision and control of calculations.
3.3 Review Design Documents and Specifications The CPSES design documents and specifications, which provide g
detailed engineering requirements for the design, 5
fabrication ana installation of systems ana components, wi11 be reviewed for consistency with the established licensing and design bases and the calculation bases.
This planned I
review includes design documents, such as flow diagrams and specifications, which define the conceptual engineering requirements.
The review will proceed to detailed I
production documents, as necessary, since the implementation of design criteria must be verified.
All of these documents are subject to change for various reasons during the design process.
The review verifies that the basic design I
commitments have been maintained consiatently throughout these documents.
3.4 Review of As-Built and Test Data Throughout the planned review process, as-built and actual I
test results are used to verify that the installed conditions meet the design bases verified in calculations and design documents.
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3.5 Implementation of Review Results The activity to resolve discrepancies, revise affected documentation, and initiate design change packages if necessary, is ongoing during all review phases.
The following guidelines will be used:
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Project Instructions are established to ensure a f
consistent review of design documents.
Resolution of discrepancies are evaluated for l
conformance to existing design and licensing commitments.
The Design Basis Documents (DBDs) prepared by Impell are I
issued as a part of the review effort to provide a final I
documentation of design bases.
Listed below are the DBDs which are Impell's responsibility.
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DBD-ME-001 CPSES Fire Hazards Analysis g
DBD-ME-002 Penetration Seals DBD-ME-063 Fire Barriers l
DBD-ME-104 Fire Detection Systems i
DBD-ME-225 Fire Protection Systems l
Design document revisions occurring from this corrective I
action and prepared by Impell are sent to TUGCO for review.
Impell has final responsibility for l
incorporating revisions to these documents.
Impell will interface with other organizations to exchange l
information on the issues, to gather information for the planned corrective actions and to provide results when needed by other organizations.
The organizations with which Impell interfaces include TUGCO, Stone & Webster, EPM, EBASCO, and TERA.
Others will be included as required.
4.0 REPORT ORGANIZATION The body of this report describes the general approach taken to evaluate and resolve each of the Generic Technical Issues identified.
A description of the specific resolution of each Generic Technical Issue is contained within the appendices to this report.
A separate appendix has been developed for each Generic Issue.
Each appendix includes a summary of the issue background, Impell's understanding of the issue, the action plan to resolve the issue, a complete list of relevant documents reviewed by TERA and Impell's implementation of the resolution.
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TABLE 1 FIRE PROTECTION CORRECTIVE ACTION PLANS 1.
Fire Exit Routes (TERA DIR No. D-0879) 2.
Flame Spread Rating of Interior Finishes (TERA DIR No.
D-0880) 3.
Fire Damper Testing (TERA DIR No. D-0881) 4.
Fire Detection System (TERA DIR No. D-0893) 5.
Eight-Hour Emergency Lighting Units (TERA DIR No. D-0894)
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Fire Protection Systems Interaction (TERA DIR Nos.
D-0970, D-0971, D-0972) 7.
Safe Shutdown / Alternate Shutdown I
(TERA DIR Nos. D-1949, D-1950, D-1951, D-1952, D-1953, D-1954, D-2165 D-2166, D-2167, D-2168) 8.
Work-in-progress I
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TABLE 2 FIRE PROTECTION PROGRAM I
WORK SCOPE
SUMMARY
The work listed below is provided as an overview of Impell's I
plan to execute the work described in Impell Task Description TNE-TD-IM-022.
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Implementation of the overall Fire Protection Engineering Program which includes:
-Develop Project Instructions I
-Update and maintain the Fire Hazards Analysis Design Basis Document (DBD-ME-001)
-Update Final Safety Analysis Report I
-Perform licensing commitment review
-Perform code and standard compliance review
-Close open items from the NRC Appendix R audit I
-Update and maintain Fire Protection Tracking System, or equivalent
-Establish design basis of emergency lighting and communications with regard to Fire Protection commitments I
-Update Ventilation and Smoke Removal System Analysis
-Review Reactor Coolant Pump and Oil Collection System for regulatory compliance I
-Update and design verify Penetration Seal Design Basis Document (DBD-ME-002)
-Compile SSER 12 compliance documentation I
-Resolve fire damper deficiencies
-Review TUGCO Q-List for fire protection items
-Gather / Create and file documentation to support NRC and ANI g
audits 5
-Review Technical Specifications and update as necessary
-Prepare Fire Detection System Design Basis Document (DBD-ME-104)
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-Prepare Fire Barrier Design Basis Document (DBD-ME-063)
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Support of all fire protection construction and production projects, including:
- Plant suppression system design and installation approval I
- Support sprinkler system upgrade and pipe replacement project
- Water supply project support to TUGCO Operations for i
Outlying Building construction activities
- ANI and TUGCO interface
- Specification and drawing maintenance I
- Incorporate the SWEC designed fire pumps and storage
- Penetration seal construction support activities tanks for the fire protection system into overall fire protection system design, construction, and start-up.
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-Thermolag review including fire tests, derating factor evaluations and vendor document review and design control I
-TUGCO Operations plant support activities
-Fire Protection procurement support
-NFPA Code compliance documentation 1
-Disposition of NCR's and TDDR's regarding Fire Protection
-Support for Systems Interaction Group activities regarding suppression systems
-Maintenance of flow diagrams (0225 series) and fire I
protection related BRP drawings
-Prepare Fire Suppression System Design Basis Document (DBD-ME-125)
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-Maintenance of the following specifications:
MS-22 MS-38E MS-38A MS-38F I
MS-38B MS-38H MS-38C MS-73A MS-38D MS-98
-Support to TUGCO Start-Up for review of test procedures and resolution of TDCR's The scope of work does not include:
-Fire Protection Maintenance I
-Fire Protection Operations (i.e.
fire brigade training, pre-fire planning, Fire Protection system operations)
-Direct interface with the NRC concerning Fire Protection commitments I
-Training (General employee, off-site fire department, fire watch, safe shutdown)
-Quality Assurance audits I
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I APPENDIX 1 Issue 1 - Fire Exit Routes I
(TERA DIR No. D-0879 Rev. 0)
1.0 Background
This DIR identifies the TERA concern that the current plant exit route signs do not provide plant personnel with a clearly marked means of escape from all fire areas.
2.0 Impell Understanding of the Issue CPSES is committed to clearly marking fire exit routes.
In order to implement an effective corrective action plan to resolve the above concern, the plan must ensure that the fire exit route commitments are met.
The implementation of these commitments must be reviewed, clearly documented and easily auditable.
3.0 Impell Action Plan to Resolve the Issue Impell is performing a walkdown of primary plant egress paths in order to ensure that exit sign locations are clearly marked.
The egress paths were determined based on the I.
shortest travel distance to an outside exit, taking into consideration the doors that will be maintained in a locked position during operation of the plant.
The posted I
emergency evacuation routes were used as an additional criterion for determining these paths.
Areas which have iradequate exit route markings will be I
identified to SWEC-Electrical, who has responsibility for completion of the final installation of fire exit signs.
The issue identified in TERA DIR D-0879 will be addressed under this project.
4.0 Relevant Documents Reviewed by TERA Site Walkdown of exit routes.
5.0 Implementation of the Resolution The development of the following Project Instruction and I
Field Verification Method is planned to implement the action.
I TE-FVM-FP-XXX " Field Verification to Determine Fire Exit Routes" IMT-FP-10 " Documentation and Verification of Fire Protection I
Licensing Commitments" Al-1
I APPENDIX 2 Flame Spread Rating of Interior Finish Issue 2 I
(TERA DIR No. D-0880 Rev. 0)
1.0 Background
DIR No. D-0880 identifies specification inadequacies for several specifications regarding the flame spread ratings of I
interior finishes.
TERA's EIC Criteria E11 (FP)-26 requires a flame spread rating of 25 or less.
Specs 2323-AS-1, 2323-AS-12, 2323-AS-15, 2323-AS-16, 2323-AS-56 do not specify this limit.
The DIR also states that the extent to I
which these types of materials have been used in the plant is unknown.
2.0 Impell Understanding of the Issue CPSES is committed to using interior finish materials with I
a flame spread rating of 25 of less.
Specifications pertaining to interior finish material should specify acceptable flame spread ratings and the materials actually used should correspond to these ratings.
3.0 Impell Action Plan to Resolve the Issue I
The resolution of this issue will be undertaken through the completion of the Interior Finish Compliance Review.
Impell is reviewing specifications pertaining to the use of I
interior finish materials in order to ensure that they specify acceptable flame spread ratings.
Impell is also performing an as-built walkdown which I
identifies locations where interior finish material are used and through document search and contact with the supplier to verify that the flame spread ratings are acceptable.
Flame spread ratings which are not acceptable will be identified by Impell and appropriate corrective action taken.
SWEC-Civil has the responsibility for final installation.
4.0 List of Relevant Documents Reviewed by TERA Specifications, including 2323-AS-1, 2323-AS-12, 2323-AS-15 I
2323-AS-16, and 2323-AS-56.
5.0 Implementation of the Resolution I
The development of the following Project Instruction and Field Verification Method is planned to implement the action plan.
TE-FVM-FP-XXX " Determination of As-Built Interior Finish Characteristics" IMT-FP-10 " Documentation and Verification of Fire Protection Licensing Commitments" I
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I APPENDIX 3 Issue 3 - Fire Damper Testing (TERA DIR No. D-0881 Rev. 0)
1.0 Background
DIR No. D-0881 identifies a concern over a lack of functional testing of fire dampers.
The DIR states that the I
fire dampers installed at CPSES will not be periodically tested under full air flow conditions as recommended by NFPA 90A and as recently discussed in the 10 CFR Part 21 letter issued by Ruskin Mfg. Co.
2.0 Impell Understanding of the Issue I
DIR No. D-0881 identifien that fire dampers at CPSES will not be periodically tested under full air flow conditions as recommended by NFPA 90A " Standard for the Installation of Air Conditioning and Ventilating Systems".
Section 7 of I
Appendix B to NFPA 90A provides information for the*
maintenance of Fire Door Assemblies, Fire Dampers, Smoke Dampers, and Ceiling Dampers.
It is Impell's understanding that it is the intent of Appendix B-7 that fire de.mpers be periodically tested with I
the system in its normal operating mode even when the ventilating, air conditioning and exhaust systems are shut down, manually or automatically, on confirmation of a fire.
3.0 Impell Action Plan to Resolve the Issue The resolution of this issue is being undertaken by Impell i
through its Fire Damper Operability Review.
Fire dampers installed at CPSES will be periodically functionally tested under normal air flow conditions.
Impell is interfacing with EBASCO IIVAC to develop an acceptable test procedure.
A program is also being i
developed by Impell and EBASCO, coordinating with TUGCO Start-Up, to do pre-operational testing of the fire dampers to verify that they operate reliably under normal air flow.
EBASCO HVAC will be responsible for reworking the fire I
dampers as necessary to ensure operation under air flow.
Technical input will be provided by Impell.
TUGCO Operations will have final responsibility for revising the test procedures to reflect the testing under air flow.
I The issue identified by TERA DIR D-0881 will be addressed through this project.
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I 4.0 Relevant Documents Reviewed by TERA NFPA-90A DCA 20,222 - DCA 20,861 Drawing #2323-MI-0768 5.0 Implementation of the Resolution The development of the following Project Instruction is planned to implement the action plan.
IMT-FP-XXX " Fire Damper Operability Review" 5
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I APPENDIX 4 Issue 4 - Fire Detection System (TERA DIR No. D-0893 Rev. 0)
1.0 Background
TERA DIR No. D-0893 identifies a concern over improperly designed primary and secondary power supplies for the plant fire detection system.
Specifically, the DIR states that I
the primary and secondary power supplies for the detection system local control panels are routed through a common power feed, thus circumventing the single failure criteria of NFPA 72D.
2.0 I.npell Understanding of the Issue The local fire alarm control panels are connected to one common AC power circuit for the primary and secondary power sources.
NFPA 72D, 1975 Edition, Paragraph 2231 states that I
when power supplies are required for remotely located control panels, "They shall comprise a primary (main),
secondary (standby) and a trouble power supply which shall I
meet the same requirements as for the central supervising station power supplies."
paragraph 2224 of NFPA 72D, states that a power supply for the central supervising station I
shall provide, "A separate power supply, independent of the main power supply, shall be provided for the operation of trouble signals.
The secondary power supply may be used for this purpose."
Since these panels are not connected to separated power circuits, they do not comply with this code.
3.0 Impell Action Plan to Resolve the Issue I
CPSES is committed to meeting the requirements of NFPA-72D.
Impell is performing a code compliance review of NFPA-72D.
the purpose of which is to ensure that the plant as-built configuration is in compliance with the requirements of I
NFPA-72D.
Compliance will be clearly documented and easily auditable.
Areas which are not in compliance will be identified to SWEC-I&C who has final responsibility for the fire detection system.
The issue identified by TERA-DIR D-0893 will be addressed in this code compliance review.
4.0 List of Relevant Documents Reviewed by TERA NFPA-72D I
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5.0 Implementation of the Resolution The development of the following Project Instructions and Field Verification Method are planned to implement the action plan.
IMT-FP-04
" Conducting and Documenting NFPA Code Compliance Reviews" IMT-FP-10
" Documentation and Verification of Fire I
Protection Licensing Commitments" TE-FVM-FP-044
" Instructions for Code Compliance Review of Fire Detection and Alarm Systems" I
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I APPENDIX 5 Issue 5 - Eight Hour Emergency Lighting Units (TERA DIR No. D-0894 Rev. 0)
1.0 Background
TERA DIR No. D-0894 identifies a failure to provide 8-hour battery powered emergency lighting units in areas required for operator actions for post fire shutdown.
Specifically, I
these 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> battery packs are needed to comply with Section III.J of Appendix R to 10 CFR 50.
These lights are to be designed based on operator actions on post fire shutdown equipment according to prescribed procedure.
2.0 Impell Understanding of the Issue Section III.J of Appendix R to 10 CFR 50 requires that emergency lighting with at least an 8-hour battery power supply be provided in all areas needed for operation of safe I
shutdown equipment and in access and egress routes thereto.
In order to implement an effective corrective action pl.i to I
resolve the above concerns, the plan must ensure that emergency lighting regulatory requirements and CPSES commitments are met.
The implementation of these I
requirements must be reviewed, clearly documented and easily auditable.
3.0 Impell Action Plan to Resolve the Issue EPM is currently revising the Fire Safe Shutdown Analysis (FSSA).
The revision will require approximately 15 to 20 I
additional manual actions to be performed by plant operators.
Impell is performing an Emergency Lighting Analysis in order to ensure that regulatory requirements are I
met and adequately documented under this project.
Impell is coordinating with EPM, TUGCO-Operations and SWEC-Electrical to review the existing plant configuration against the revised FSSA.
Locations where the requirements are not met I
will be identified to SWEC-Electrical who has final responsibility for installation of emergency lighting.
Impell has the responsibility to insure that lights are I
properly aimed upon installation.
TUGCO-Operations has the responsibility to maintain lights as installed.
!E The issue raised in the above DIR will be addressed in this
!E analysis.
4.0 List of delevant Documents Reviewed by TERA Appendix R Reassessment Program TIM-840869 AS-1 i
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5.0 Implementation of the Resolution i
I The development of the following Pro.j ec t Instructions are planned to implement the action plan.
I IMT-FP-22 " Emergency Lighting Requirement! Evaluation" IMT-FP-10 " Documentation and Verification of Fire Protection Licenaing Commitments" I
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APPENDIX 6 Issue 6 - Fire protection Systems Interaction (TERA DIR. Nos. D-0970 D-0971 and D-0972)
1.0 Background
DAp reviews associated with Fire protection Systems Interaction have identified concerns that a failure or inadvertent operation of suppression system could I
significantly impair or dieable safety-related systems.
Specific concerns include the failure to seismically qualify diesel generator room suppression system deluge I
valves to remain closed during a seismic event and demonstrating that suppression system piping in the diesel generator rooms is seismically supported.
A third concern I
is the lack of protection of diesel generator mechanical and electrical equipment, including local control panels and motor control centers from the damaging effects of water spray due to failure or inadvertent operation of these I
suppression systems.
2.0 Impell Understanding of the Issues As required by Appendix A to BTp-9-5.1, General Design Criteria 3 and Appendix R to 10CFR50, fire protection system I
interactions with safety-related equipment must be evaluated for all plant areas to ensure that a failure or inadvertent operation of suppression systems does not significantly impair the safety-capability of structures, systems, and I
components important to safety.
Additionall;s che CpSES FSAR states that essentiel equipment I
that could be damaged by a sprinkler system discharge is protected, and that safety-related equipment that does not itself require sprinkler water protection but is susceptible I
to unacceptable damage if wetted by sprinkler water discharge, is protected by water shields or baffles.
I In order to implement an effective corrective action plan to resolve the above concerns, the plan must ensure that regulatory requirements and CpSES commitments are met.
The implementation of these requirements and commitments I
must be reviewed, clearly documented and easily auditable.
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3.0 Impell Action Plan to Resolve the Issues I
Impell is undertaking a comprehensive analysis which includes a review of seismic qualification of suppression system piping and supports and a review of flooding level and moderate I
energy line break calculations in order to ensure that, for all plant areas, adequate protection is provided such that safety related equipment will not be disabled by falling suppression piping or an inadvertent operation.The protection provided must I
be clearly documented and auditable to regulatory requirements and CPSES licensing commitments.
This analysis is based on the guidelines presented in Generic Letter 83-41.
EBASCO Systems Interaction Group is responsible for performing the calculations and providing them to Impell.
I The Fire Protection Group is interfacing with Impell Equipment Qualification in order to ensure all safety-related equipment is identified.
Work-in-process affecting this analysis is the rework of various fire suppression system to upgrade them to the requirements of NFPA-13 and the replacement of small bore piping affected by microbiological 1y induced corrosion.
Impell Fire Protection is responsible for the review and approval of the system plans and is providing the approved I
hydraulic calculations to EBASCO Systems Interaction Group for recalculation of the flooding and moderate energy line break calculations.
Upon completion of the comprehensive analysis, areas where inadvertent operation could impair safety-related systems will be identified by Impell to the appropriate responsible I
organization for initiation of corrective actions.
Design modifications to suppression systems, such as spray shields i
or baffles, will be the responsibility of Impell and design I
modifications to mechanical or electrical equipment will be the responsibility of SWEC-Mechanical or SWEC-Electrical, j
respectively.
4.0 List of Relevant Documents Reviewed by TERA Elec/I&C Criteria E11-97, 98 and 99 Rev. O dated 12/18/85 I
Spec. MS-98 Rev. 1 and DCAs per memo CPP-14,892 dated j
1-17-84.
5.0 Implementation of the Resolution The development of the following Project Instruction is planned to implement the action plan.
IMT-FP-XXX " Inadvertent Operations Analysis" I
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APPENDIX 7 Issue 7 - Fire Safe Shutdown / Alternate Shutdown
1.0 Background
I The DAP review associated with Fire Safe Shutdown / Alternate Shutdown identified 10 (ten) issues related to the capability of safety shutting down the plant following a fire in any given plant area.
The specific concerns identified I
are as follows:
DIR No.
Subject D-1949 Diagnostic Instrumentation Not Addressed in the Fire Protection Program Review (FPPR)
I D-1950 Alternative Shutdown Capability Has Not Been Demonstrated D-1951 Minimum Shutdown Margin Analysis Not Adequately Identified I
D-1952 Shutdown Without Pressurizer Heater Analysis Not Available D-2165 Safe Shutdown Components Not Adequately Identified D-1954 6.9kV Feeder Beaker Circuits Not Evaluated j
for Fire Damage i
D-1953 Post-Fire Shutdown Procedures Not Developed D-2166 Associated Circuits Review Inadequate in FPPR D-2168 Fire Area Analysis Lacks Substantiation g
D-2167 Safe Shutdown Circuits Not Consistent with 5
FPPR 1
2.0 EPM Understanding of the Issue
, I Section III.G of Appendix R requires fire protection features to be provided for structures, systems and components important to safe shutdown such that one train of j
systems necessary to achieve and maintain hot shutdown conditions from either the control room or emergency control i
g stations is free of fire damage.
l 5 In order to implement an effective corrective action plan to resolve the above concerns, the plan must ensure that the I
fire safe shutdown / alternate shutdown regulatory requirements and CPSES commitments are met.
The implementation of these requirements and commitments must be reviewed, clearly documented and easily auditable.
3.0 EPM Action Plan to Resolve the Issues l
The resolution of these issues will be undertaken through the completion of the following tasks:
In the Fire Safe Shutdown Analysis (FSSA), the diagnostic instrumentation identified as required for safe shutdown will be included in the separation analysis.
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- The Fire Safe Shutdown Analysis is being reviewed to ensure that it includes an alternate shutdown analysis I
which adequately demonstrates alternate shutdown capability.
- The Fire Safe Shutdown Analysis is being reviewed to ensure that all required safe shutdown equipment is adequately identified.
- The separation analysis included in the Fire Safe Shutdown Analysis is being reviewed to ensure that the 6.9kV breakers are evaluated for fire damage.
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- The alternate shutdown analysis is the basis for post fire shutdown procedure development.
TUGCO Operations will use the FSSA to review and update appropriate operations I
procedures.
The FSSA analysis is further enhanced by the development and I
iss0ance of the CPSES Fire Safe Shutdown Analysis Design Basis Document, DBD-ME-020.
EPM is performing a review of the conclusions of I
Westinghouse's WCAP 11331 (CPSES Thermal-Hydraulic Analysis of Fire Safe Shutdown Scenario, dated October 30, 1986) to confirm the FSSA and DBD-ME-020 system design basis.
The coordination of the safe shutdown power supplies will be reviewed by EPM to verify that it adequately supports the Fire Safe Shutdown Analysis.
The issues raised in the above DIR's will be addressed through these tasks.
4.0 List of Relevant Documents Reviewed by TERA FPPR Rev. 3 l
5.0 Implementation of the Resolution l
l W The development of the following Project Procedures is planned to implement the action plan.
P257-02
" Alternate and Fire Safe Shutdown Systems Analysis" P257-03
" Selection and Classification of Safe I
Shutdown Circuits and Cables" P257-04
" Analysis and Logic Development of the Emergency Power Distribution System" I
P257-07
" Alternate ard Fire Safe Shutdown Analysis (FSSA) by Fire Area" P257-08
" Fire Safe Shutdown Analysis (FSSA) Project INDMS Data Base Control" I
P257-09
" Raceway Route / Equipment Location Field i
Verification" P257-12
" Containment Walkdown Procedure" I
P257-13
" Twenty (20) Foot Walkdown Procedure" A7-2
I APPENDIX 8 Issue 8 - Work-In-Progress 1.0 Back stround I
Although not specifically identified in a DIR, the IRR raised concerns regarding activities not yet completed or undergoing significant revision.
These activities include:
a.
Completion the Fire Safe Shutdown Analysis b.
Fire Hazards Analysis Update c.
Fire Protection Deviation Report d.
SSER 12 Compliance Documentation e.
Emergency Lighting and Communications Compliance f.
Fire Damper Deficiency Resolution I
g.
Completion and Review of the Associated Circuit Analysis h.
New Fire Protection Water Supply i.
Sprinkler System Upgrade and Pipe Replacement I
J.
Breaker Coordination Studies 2.0 Impell Understanding of the Issues The objective of the CPSES Fire Protection Program is to achieve, demonstrate and maintain CPSES in compliance with l
regulatory requirements, CPSES licensing commitments and other applicable codes and standards.
The activities listed and their successful completion impact I
conclusions to be drawn relative to the adequacy of the CPSES Fire Protection Program.
3.0 Impell Action Plan to Resolve the Issue The completion of outstanding fire protection design, I
calculation and evaluation work activities are being performed by Impell or EPM, as appropriate, through the overall Fire Protection Engineering Program as described in Impell's Fire Protection Task Description, TNE-TD-IM-022 and I
EPM's Fire Safe Shutdown Task Description, TNE-TD-EPM-052.
Each Task Description describes the task assigned to the I
Lead Contractor in sufficient detail to plan and execute the l
task.
For each Task Description, a control program has been established and is being executed in accordance with I
approved procedures / project instructions.
Each Task Description defines the organizational structure to l
implement the task and delineates the authority and responsibility of the persons and organizations involved in i I performing the activities as detailed in the Task l
Description.
The responsibilities and interfaces among the l
contributing contractors, both internal and external, are l
l A8-1
I defined.
Provisions have been made within the program for periodic audits, review and evaluation of the effectiveness of the program in achieving objectives.
Resolution of issues will be accomplished by establishing the necessary interfaces and procedures to delineate the I
responsibilities and methodo.logies which will constitute the Fire Protection Group's function at CPSES.
4.0 List of Relevant Documents Reviewed by TERA 1.
CPSES SSER Number 12, Section 9.5.1, Fire Protection 2.
10 CFR 50, Appendix R, Fire Protection Program for Nuclear Power Facilities 3.
10 CFR 50, Appendix A, General Design Criterion 3, Fire Protection I
4.
DIR-XXXX: Primary Issue DIR on Fire Protection (Later) 5.
Regulatory Guide 1.29, Rev. 1 Seismic Design Classification 6.
Branch Technical Position CMEB 9.5-1 on Fire Protection I
7.
IEEE 387-1977, IEEE Criteria for Diesel Generator Units Applied as Standby Power Supplies for Nuclear Power Generating Stations 8.
CPSES FSAR Section 9.5 Fire Protection 9.
CPSES Fire Protection Program Review (FPPR), Rev. 3 10.
CPSES Fire Hazards Analysis (FHA), DBD-SY-1 I
11.
Technical Description 2323-TD-0225, Fire Protection System 12.
Specification 2323-ES-17B, Fire Detection System 13.
Specification 2323-MS-98, Fire Protection Equipment I
14.
Impell Fire Protection Engineering, Status Presentation (Handout), August 20, 1986 15.
TXX-4527 dated August 5, 1985 on Breaker Coordination I
Study 16.
Safety Deficiency Action Report, SDAR-CP-86-25, Breaker Fuse Coordination I
17.
Safety Deficiency Action Report, SDAR-CP-86-34 Defective Fire Stop Installations 18.
Safety Deficiency Action Report, SDAR-CP-86-47, Fire Penetration Seal Design I
I A8-2
5.0 Implementation of the Resolution The development of the following Project Instructions is planned to implement the action plan.
IMPELL PROJECT INSTRUCTION NO.
TITLE IMT-AD-01 ORGANIZATION IMT-AD-02 ORGANIZATIONAL INTERFACE IMT-AD-03 PREPARATION OF PROJECT INSTRUCTIONS IMT-AD-04 PERSONNEL INDOCTRINATION AND TRAINING IMT-AD-05 CORRESPONDENCE CONTROL I
IMT-AD-08 CONTROL OF QUALITY ASSURANCE RECORDS IMT-AD-09 SITE EVALUATION PLANS I
IMT-AD-11 PREPARATION AND REVIEW OF SPECIFI-CATIONS IMT-AD-12 REVIEW AND PROCESSING OF INTERDISCIPLINARY DRAWINGS IMT-AD-13 PREPARATION AND REVIEW OF FIELD REVIEW CHANGES IMT-AD-13-01 PREPARATION AND REVIEW OF ENGINEERING CHANGE NOTICES (ECN'S)
IMT-AD-13-02 REVIEW AND PROCESSING OF FCR'S IMT-AD-14 REVIEW AND PROCESSING OF PPF'S AND g
DM'S I
m IMT-AD-15 PREPARATION AND REVIEW OF DESIGN ENGINEERING PACKAGES (DEP'S)
IMT-AD-15-01 PREPARATION AND REVIEW OF DESIGN I
BASIS DOCUMENTS (DBD'S)
I l
IMT-AD-16 DESIGN VERIFICATIGS OF ENGINEERING l
DOCUMENTS l
IMT-AD-18 PREPARATION AND REVIEW OF CALCULATIONS IMT-AD-20 DESIGN CONTROL GENERAL REQUIREMENTS I
IMT-AD-21 INSTRUCTIONS FOR WRITING FIELD l
REQUISITIONS IMT-AD-23 REVIEW AND TRANSMITTAL OF RFI'S
- g IMT-AD-24 FIELD VERIFICATION g
IMT-AD-25 REVIEW AND APPROVAL OF BRP DRAWINGS IMT-FP-01 G.F.P.S.
DOCUMENT REVIEW IMT-FP-02 G.F.P.S.
F.C.A.'S IMT-FP-03 G.F.P.S.
NCR DISPOSITION IMT-FP-04 CONDUCTING & DOCUMENTING NFPA CODE l
COMPLIANCE REVIEWS ll 11 11 ll Ae-3
b IMPELL PROJECT INSTRUCTION NO.
TITLE j
IMT-FP-05 PRODUCTION AND REVISION OF DRAWINGS IMT-FP-06 MAINTENANCE OF FIRE HAZARD ANALYSIS IMT-FP-07 REVIEW AND UPDATE OF FHA IMT-FP-08 PREPARATION OF CONSTRUCTION i
TRAVELERS IMT-FP-09 FIRE PROTECTION DEVIATION REVIEW AND ANALYSIS IMT-FP-10 DOCUMENTATION & VERIFICATION OF FIRE PROTECTION LICENSING COMMITMENTS IMT-FP-11 AS-BUILT VERIFICATION METHOD FOR MECHANICAL PIPING PENETRATIONS IMT-FP-12 FIRE TEST REVIEW IMT-FP-13 DETERMINATION OF PENETRATION SEALING REQUIREMENTS (PCN'S)
IMT-FP-14 PREPARATION OF PENETRATION CHANGE NOTIFICATIONS (PCN'S)
IMT-FP-15 CONTROL & MAINTENANCE OF
=
PEN-P1-0100 AND PEN-P2-0100 IMT-FP-16 CABLE / RACEWAY FIRE STOPS IMT-FP-17 REVIEW OF PENETRATION SEAL MAPS IMT-FP-18 PENETRATION SEAL CLEARANCE CALCULATIONS (ENLARGED 1
ANNULAR GAP) PREP AND REVIEW IMT-FP-19 VENDOR DOCUMENT REVIEW IMT-FP-20 DRAFTING STANDARDIZATION i
INSTRUCTION IMT-FP-21 AS-BUILT PACKAGE PREPARATION IMT-FP-22 EMERGENCY LIGHTING REQUIREMENT EVALUATION IMT-FP-23 COMMUNICATIONS REQUIREMENT EVALUATION IMT-FP-24 FIRE PROTECTION INTERFACES IMT-FP-25 REVIEW OF TUGCO DESIGN DEFICIENCY REPORTS (TDDR'S)
IMT-FP-25-01 INITIATION OF TUGCO DESIGN DEFICIENCY REPORTS (TDDR'S) 1 IMT-FP-26 PROCESSING NONCONFORMANCE REPORTS (NCR'S)
IMT-FP-26-01 INITIATION OF NONCONFORMANCE REPORTS (NCR'S)
IMT-FP-27 REVIEW OF TEST DEFICIENCY REPORTS (TDR'S)
=
IMT-FP-28 REVISION OF TUGCO ENGINEERING HELD FIRE PROTECTION RELATED DRAWINGS IMT-FP-29 REVIEW AND APPROVAL OF G.F.P.S.
AS-BUILT DESIGN DRAWINGS j
IMT-FP-30 INTERDISCIPLINARY REVIEW PERFORMED BY IMPELL FIRE PROTECTION IMT-FP-31 REVIEW AND UPDATE OF FSAR 1
IMT-FP-33 FIRE PROTECTION FILING SYSTEM IMT-FP-34 NON-RATED BARRIER ANALYSIS A8-4
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