ML20046C555
| ML20046C555 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 08/02/1993 |
| From: | Cosgrove D PACIFIC GAS & ELECTRIC CO. |
| To: | |
| Shared Package | |
| ML20046C542 | List: |
| References | |
| OLA-2, NUDOCS 9308110138 | |
| Download: ML20046C555 (41) | |
Text
t RELKnED CORRESPONDENCE r i. :
.; L Y 2 UNIT 2D STATES OF AMERICA '
3 NUCLEA*A REGULATORY COMMISSION -
D-93 E -4 P 3 :43 4 DEFORE THE ATOMIC SAFETY AND LICENSING BOARD
- o a .,
, d t',: I4h - '
5 ti AM "
6 In the Matter of: ) Docket Nos. 50-275-OLA !
)- 7 ) 50-323-OLA I 8 Pacific Gas and Electric Company )
9 ) (Construction Period l 10 (Diablo Canyon Nuclear Power ) Recovery) l 11 Plant, Units 1 and 2) ) !
12 ) ,
i 13 TESTIMONY OF PACIFIC GAS AND ELECTRIC COMPANY ;
14 ADDRESSING CONTENTION V: THERMO-LAG COMPENSATORY MEASURES i
) 15 Introduction 16 Q1 Please state your name, affiliation, qualifications and 17 current job responsibilities. !
D 18 A1 (Cosgrove) My name is David K. Cosgrove. I am the i 19 Supervisor of the Safety and Fire Protection group at Diablo 20 Canyon Power Plant ("DCPP"). This group is one of the 21 organizations that comprise the Safety, Health and Emergency ,
22 Services ("SH&ES") Section within the Technical and Support '
23 Services Department at DCPP. The other groups that work 24 within this department include the Emergency Planning group 25 and the Fitness for Duty group. j J 26 As Fire and Safety Supervisor, I am responsible for:
27
- the plant Safety Program, 28
- the activities of the Industrial Hygienist,
)
29
- the Medical Facility and the Medical Testing I 30 Specialists, ;
9308110138 930002
I l
l O
l' a the Fire Marshal and the staff of Industrial Fire l 2 Officers, and O 3
- the Fire Protection Engineer and the Fire Protection 4 Specialists.
5 I have more than 20 years of experience in the nuclear l
() 6 industry and have been working at DCPP for almost ten years.
7 A summary of my qualifications and experience is provided in 8 Exhibit 1.
- g. 9 (Powers) My name is Robert P. Powers. I am the Manager 10 of the Nuclear Quality Services Department within the 11 Nuclear Power Generation ("NPG") Business Unit. This !
O 12 Department reports directly to the Senior Vice President and ,
13 General Manager of NPG and is comprised of four sections 14 that independently review DCPP performance. Until May 1, O 15 1993, I was the Manager of the Support Services Department .
16 of DCPP. The Support Services Department was comprised of 17 the Safety, Health and Emergency Services section, the NPG O 18 Training Section, the Security Section and the General 19 Services section. As the Support Services Department 20 Manager, I was responsible for management and direction of !
O 21 all program activities within Support Services, including I
22 those pertaining to fire protection.
23 I have more than sixteen years of experience in the ;
I O 24 nuclear industry and have been working at DCPP for over 25 eleven years. A summary of my qualifications and experience !
26 is provided in Exhibit 2.
O 27 Q2 What contention will you address:
O I I
l 1 A2 We will address San Luis Obispo Mothers for Peace I 2 ("MFP") Contention V as admitted in this proceeding, which 3 alleges that PG&E is not adequately implementing and 3
4 adhering to the interim compensatory measures required by 5 the NRC in connection with the use of Thermo-Lag at the i
L 6 Diablo Canyon Power Plant.
3 7 Q3 What is the purpose of your testimony?
q 8 A3 The purpose of our testimony is to provide a response t 9 to the above contention. We have adequately implemented the I
10 Thermo-Lag interim compensatory measures required by the NRC (3
l l 11 in Bulletin 92-01 and its Supplement 1 in all plant areas in 12 which Thermo-Lag is used as a 1-hour or 3-hour fire barrier.
13 Our implementation of these measures has adhered to all NRC 3
14 requirements for such measures in Thermo-Lag areas, and the 15 NRC has noted no deviations or violations from requirements.
16 There is no basis for the contention that our implementation 3
17 of these measures has been inadequate.
18 Backcround 3
19 Q4 Describe generally the approach taken to fire 20 protection in the program implemented at DCPP.
3 .
21 A4 The fire protection program at DCPP utilizes a 22 " defense-in-depth" approach that includes a three-part g 23 philosophy:
24
- Prevention: Prevent fires from starting; O
i s
I 1
[I 1 1
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- Detection / Suppression: Detect fires quickly, suppress 2 those that occur, put them out quickly and limit their j 3 range; and 4 e Mitigation: Design plant safety systems so that, 5 should a fire start, essential plant safety functions l 6 will not be prevented from being performed.
[)
7 Thermo-Lag fire barriers, in certain applications here '
) 8 at issue, are part of the mitigation echelon of fire 9 protection. Specifically, these barriers are designed to 10 limit the range of postulated fires by providing barriers :
[) 11 rated for either one or three hours. The rating of the 12 barrier depends upon the requirements for the specific l 13 application. Firewatches also serve as part of the
[) 14 detection / suppression component of defense-in-depth.
15 QS How have Thermo-Lag concerns affected DCPP's I) 16 defense-in-depth program for fire protection?
l f
17 AS Testing of Thermo-Lag material has raised questions as l
b 18 to its ability to satisfactorily perform as a fire barrier 19 for the rated duration in certain applications. While 20 Thermo-Lag barriers can be expected to perform their
[] 21 intended function for some length of time, they are I
- 22 nevertheless being treated by PG&E as inoperable in those i
23 very limited locations at DCPP where Thermo-Lag is used to
? 24 meet cable separation criteria. Accordingly, interin 25 compensatory measures, accepted by the NRC throughout the 4_
D-
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1 nuclear industry, are in place at DCPP. These measures !
2 principally include firewatches similar to firewatches used l Q. 3 as compensatory measures as allowed by Technical 4 Specifications and the DCPP fire protection program when 5 fire barrier penetrations or other fire protection systems O- 6 are inoperable.
I l
7 Q6 How is the firewatch program utilized in the fire O 8 protection program at DCPP generally?
9 A6 PG&E's Equipment Control Guidelines (" ECGS") govern the Q 10 fire detection instrumentation system, the spray and/or 11 sprinkler systems, the CO2 system, the Halon system, and the 12 fire barrier penetrations. All these ECGS provide for the O 13 use of firewatch personnel as a compensatory measure when 14 any of the systems is not operational. In some cases, these 15 firewatches are stationed continuously at a specific O 16 location. In other situations, a roving firewatch is used 17 to inspect an area or location once each hour. The use of l 18 roving verses continuous usually depends upon whether fire 0 19 detection devices are available in the area. The use of 20 these types of firewatches to compensate for degraded or 21 inoperable fire protection systems is an accepted industry O 22 practice that is routinely implemented at other nuclear i
! 23 stations and is accepted by the NRC.
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l 1 DCPP Firewatch Procram '
2 Q7 How is the firewatch program organized at DCPP? f l
0 l 3 A7 There are two principal types of firewatches used at i 4 DCPP: I g 5
- Craft firewatches: Whenever welding or open flame work l
)
6 is performed, a second person must be in the immediate i
7 area to act as a firewatch. These are usually short v l
g 8 duration tasks. These individuals receive specific 9 firewatch training and this task is often fulfilled by 10 the working craftsmen. These craft firewatches are not C) 11 typically used to implement compensatory measures when 12 fire protection systems are inoperable. As a result, 13 these "hotwork" firewatches are not affiliated with 14 tais contention.
9 15
- Roving and continuous firewatches: These personnel are 16 employed exclusively to perform firewatch tasks as 17 ccmpensatory measures (either roving or continuous) 0 18 when a fire protection system is inoperable. Examples 19 include nonfunctional fire detectors or impaired fire
.O 20 barrier penetrations.
21 Infrequently, other plant employees (such as 22 radiographers) may fulfill the role of firewatch during the O 23 conduct of special tests or examinations (such as 24 radiography) that preclude access to plant areas.
25 In keeping with the DCPP overall fire protection O 26 defense-in-depth philosophy, a roving firewatch program has 27 been in place essentially since Units 1 and 2 have been in O --
t 1 operation. This roving firewatch program was not mandated 2 by regulation, but was implemented solely at PG&E's f
() 3 discretion. At a minimum, every hour a roving watch 4 transits through a majority of the fire areas where safe 5 shutdown equipment is located. This watch is conducted 24 O 6 hours a day, 365 days a year, even when all the fire systems 7 are fully functional.
O 8 Q8 How are roving and continuous firewatches supervised 9 and managed?
O 10 A8 The roving and continuous firewatch personnel are 11 contracted through Bechtel Construction Corporation and the 12 DCPP Fire Protection Specialist is responsible for the
- 13 day-to-day administration of this contract. The Fire 14 Protection Specialist is also responsible for maintaining 15 the list of protection systems impairments and for the 9 16 performance of the routine inspections of the plant fire 17 barriers.
18 Firewatch foremen are on shift 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day to 9 19 supervise the individual firewatch personnel. The foremen 20 are available to provide additional technical guidance and 21 to coordinate the establishment of compensatory measures
- 22 with Operations personnel.
! 23 In addition to the core firewatch personnel routinely l 24 employed at DCPP, an ancillary group of trained firewatch 6 25 personnel (or "watchstanders") is available in the local 26 area and can be called in if areas or locations are
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O 1 identified that require the use of additional watchstanders.
2 These ancillary firewatches are also available to fill in g 3 for the core watchstanders during vacations and illnesses.
4 Q9 What training does a firewatch receive?
J 5 A9 Firewatches receive in excess of 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of training 6 specifically for the job functions they perform. They g 7 initially attend the same general employee fire protection 8 training that is provided to all DCPP personnel. They also 9 complete specific firewatch training, including training on 3 10 identification of fire protection deficiencies, such as 11 combustibles and impaired fire barriers, and " hands-on" 12 training on use of portable fire extinguishers. Attendance 13 at these classes is documented in the Plant Information 3
14 Management System ("PIMS").
15 Firewatches also receive instruction on the 3 16 identification and control of transient combustibles (i.e.,
17 those combustible materials not permanently installed in the 18 plant such as wood, paint, solvents, oils and compressed 3 19 gasses). Before assignment to perform firewatch patrols, 20 each new watchstander receives several shifts of "on-the-21 job" training with the firewatch foreman.
3 22 The firewatch foremen receive additional training in 23 fire fighting equipment and techniques as well as a 5-week 24 DCPP systems class that includes training in the Final e 25 Safety Analysis Report Update ("FSAR") and all fire 26 protection systems. Firewatch foremen also receive
)
9 1 instruction in fire barrier inspections and perform the 2 monthly fire barrier inspection surveillance when not gp 3 engaged in actual roving or continuous firewatches.
4 Q10 What are the duties and responsibilities of the g 5 firewatches?
6 A10 Firewatches are required to be knowledgeable of the gp 7 specific hazards involved in their assignment and to be 8 aware of the consequences or potential consequences of any 9 fire in the area. Firewatch personnel (roving and craft) g, 10 have no other duties while performing firewatch dutics.
11 DCPP procedures NPAP A-13, " Plant Organization for Fire Loss 12 Prevention," and NPAP B-13, " Qualification and Training 13 Requirements of Plant Personnel Specifically Concerned with 7) 14 Fire Loss Prevention," describe the responsibilities of the 15 roving and continuous firewatches. These responsibilities 16 include:
17
- Notifying the shift foreman of all fires and sounding ;
1 18 the fire alarm if necessary.
3 19
- Extinguishing fires when obviously within the 20 capability of the equipment available and his/her i
21 training. l I
] 22
- Satisfying requirements for continuous and hourly i
l 23 roving firewatches when fire protection systems / fire i 1
l 24 barriers are impaired.
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- Satisfying compensatory requirements when combustible 3
26 loading exceeds commitment levels. l D
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1 e Maintaining knowledge of the " ignition source area" 2 (i.e., safety-related equipment location, special heat
) 3' sensitive equipment in the area).
4 Q11 Describe how the roving firewatch is typically
) 5 implemented.
6 All DCPP is comprised of many unique fire areas (or
) 7 compartments), divided by fire-rated walls, floors and fire 8 barriers. An hourly rovi..g firewatch usually begins his or 9 her round at the top of the hour. The watchstander walks a 3 10 standard route through aach fire area within Unit 1, Unit 2, 11 and the common fire areas each hour. The fire areas in 12 which interim compensatory measures for Thermo-Lag are in
) 13 place are included on these routes. Each tour takes about 14 45 minutes. At the end of each tour, the watchstander 15 usually trades places with another watchstander, and then
) 16 that watchstander begins the next round at the top of the 17 hour. The length of the tour route and the hourly frequency 18 make it impractical for one individual to perform all the
) 19 hourly rounds in each 12-hour shift. (When a continuous 20 watch has been established in an area of the plant as a ,
21 compensatory measure, the roving watchstander trades places ,
) 22 with the continuous watchstander every hour.) When 23 necessary, the standard tour route is modified or augmented 24 to include other fire areas or locations if a degraded or
) 25 impaired fire protection system or barrier has been f
26 identified.
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1 Q12 How are these firewatch activities documented?
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30 2 A12 The roving watch carries a portable electronic "bar i 3 code" reader wand (similar to those in use at retail 4 markets) which scans bar codes installed in the fire areas I i
O 5 along the tour route. At the end of the shift, the hand
- 6 wand (about the size of a personal calculator) is down- ,
7 loaded to a personal computer and a printout of the watch i O 8 activities is generated that documents the watchstander's 9 name, badge number, the location of each area and the time 10 the watch was in the area. The program also utilizes a o 11 results code, so that any special conditions identified ,
12 during the hourly inspection can also be documented. The 13 log of the watch activities is maintained on a computer disk ,
O 14 and in hardcopy form for one year by the Fire Protection 15 Specialist. ,
16 The continuous firewatch records are maintained by hand -
O 17 and consist of a logsheet that describes the location of the 18 continuous watch and a place to record the watchstander's i
19 name and the time once each hour.
O 20 Q13 What measures have been established in the event that a ,
21 firewatch cannot complete his or her patrol during the hour? .
O 22 A13 If a problem occurs during the performance of an hourly 23 firewatch round that causes a delay, the firewatch has been i O 24 instructed to call or page the firewatch foreman, the 25 Industrial Fire Officer or ultimately the operations Shift 1
0 !
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1 Supervisor, if necessary, to arrange for assistance in 2 completion of the hourly patrol. During the performance of
)
3 non-destructive radiographic examinations, when exclusion 4 perimeters are established for personnel radiation safety 5 considerations, the radiography examiners are utilized to ]
) 6 perform the firewatch activities in the specific plant l 7 areas. This requirement occurs infrequently. s
) 8 Q14 What do the firewatches look for? l 9 A14 In addition to the obvious conditions that are
) 10 addressed in general fire protection training, such as i 11 smoke, fire and open fire doors, the firewatches are also ;
12 triefed each shift on the location of all newly identified i
I
) 13 impaired or degraded fire systems or barriers. They carry a 14 copy of the list of fire system impairments vita them on !
15 their rounds, as well as a copy of the relevant fire 16 protection administrative procedures. They monitor fire i 17 areas for excessive combustible materials to ensure that ,
i 18 permissible quantities are not exceeded. '!
) 19 The firewatches also document minor discrepant :
t 20 conditions that they may observe during their rounds, such l i
21 as burned-out licht bulbs and door closers that need to be i t
) 22 adjusted. These discrepancies are reviewed and evaluated by [
23 the firewatch foreman and the plant fire protection 24 specialist to ensure that adequate corrective actions are ,
t
) 25 implemented. [
4 1 Thermo-Lac Firevatches 2 Q15 Did PG&E establish interim compensatory measures in
[) 3 response to NRC Bulletin 92-01 and Supplement 1?
4 A15 Yes. On June 29, 1992, DCPP verified that interim f) 5 compensatory measures were in place in the plant areas where 6 Thermo-Lag was credited as a fire barrier for conduits and 7 cable trays, consistent with the scope and guidance in NRC
) 8 Bulletin 92-01. The Bulletin requested all nuclear plants 9 to implement interim compensatory measures similar to those 10 that would La required for impaired barriers associated with
- ) 11 safe shutdown equipment or circuits.
12 The list of fire areas subject to interim compensatory 13 measures and PG&E's interim compensatory measures were
] 14 subsequently revised in response to Bulletin 92-01, 15 Supplement 1. PG&E identified 11 fire areas at DCPP using 16 Thermo-Lag fire barrier systems to separate equipment or 3 17 circuits associated with safe shutdown of the plant and 18 subject to c mpensatory measures. The specific location of 19 these instal 1r e m.- ,3 described in PG&E's response to D 20 Supplement 1 to onu Bul. tin 92-01 (DCL-92-208, September 21 28, 1992), which is included as Exhibit 3. These 22 compensatory measures were accepted by the NRC (NRC Letter D 23 dated October 27, 1992, H. Rood to G. M. Rueger, " Review of 24 Response to NRC Bulletin 92-01, Supplement 1").
) 25 Q16 What modifications, if any, were made to the firewatch 26 program to comply with the NRC Bulletin 92-01, Supplement I?
D
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O 1 A16 DCPP does not make extensive use of Thermo-Lag fire l 2 barriers. The firewatches were briefed on the specific ;
i g 3 locations where Thermo-Lag is installed and the tour route 4 was slightly modified to encompass the additional fire 5 areas. These areas are inspected once every hour where fire O 6 detection systems are installed, using the existing roving I 7 firewatch program described earlier. In those areas of the i 8 plant where a detection system is not installed, a Portable r
O 9 Detection System has been installed in conjunction with the 10 hourly roving firewatch patrol, in lieu of posting a ;
11 continuous firewatch. This Portable Detection System ,
O 12 utilizes smoke detectors and a dedicated plant phone system ,
13 to immediately alert plant personnel in the event of a fire 14 in the area and has been approved for use at DCPP by the !
O .15 NRC. The Thermo-Lag installations in the Containment j 16 Buildings are radiant energy heat shields and are not 1-hour 17 or 3-hour fire barriers subject to firewatch compensatory [
i 0 la measures.
e i
19 Q17 Since the firewatch program was modified in June 1992,
() 20 how many missed or late firewatches have occurred in areas 21 where Thermo-Lag compensatory measures are in place?
l 0 22 A17 Since the establishment of these compensatory measures 23 in June 1992, the hourly patrol of the Thermo-Lag barriers 24 has been successfully performed on all but one occasion by O 25 the assigned firewatch personnel. On this one occasion, on 26 February 25, 1993, during a 6-hour period a portion of the O
O 1 total tour route was not completed and one Thermo-Lag fire 2 area (area 3CC, the Unit 2 containment penetration area on O 3 85' elevation and the loor elevation) was not accessible to 4 the firewatch. This partially completed tour occurred when 5 radiographic (X-ray) examinations were being performed on O 6 P l ant welds and all plant personnel except those involved 7 with the radiography were excluded from this area of the 8 plant for personnel radiation safety reasons. In the O 9 unlikely event of a fire during these periods, the persor.nel 10 performing the radiography would have identified and 11 reported any potential fire.
O 12 The overall completion success rate of the hourly 11 firewatch in Thermo-Lag fire areas has been greater than 14 99.9 percent since the initiation of the interim O 15 compensatory measures.
16 17 Q18 Have the interim compensatcry measures been
() 18 successfully implemented in all other respects?
19 A18 Yes. The firewatch program at DCPP is more proactive O 20 than that at many nuclear stations in that a full-time 21 hourly roving watch is maintained at all times, regardless l
l 22 of the status of the individual fire protection systems.
() 23 When the NRC issued Bulletin 92-01, DCPP was not required to 24 develop a new program to provide the required interin 25 conpensatory measures. Instead, an established program,
@ 26 with training and procedures, was adopted and employed 27 successfully to address Thermo-Lag areas. The DCPP O
[) _ !
1 firewatches are dedicated, competent personnel who i 2 understand the significance of the job they perform. On the i
9 3 backshifts and weekends, these firewatches are literally the 4 eyes and ears (and nose) of the plant. At no time since the l l
5 operation of the plant has there ever been a fire in an area 9 6 where safe shutdown equipment is located that impacted the ;
7 operation of the plant or the capability to safely shut down j i
8 the plant. ;
s O ;
9 Incidents cited by MFP i
10 Q19 MFP, in the original basis statement for this {
3 _11 Contention, claim that a number of specific deficiencies ,
i 12 show that the Thermo-Lag compensatory measures have not been !
13 implemented effectively. Others were listed in discovery.
D 14 Please respond. t 15 A19 MFP listed five incidents in their basis statement for i g 16 the contention and listed 35 documents in their 17 June 21, 1993 discovery response (Appendix B). These are f 18 alleged by the MFP to be indicative of inadequacies in the
$ 19 DCPP firewatch program. However, only two of these ;
20 incidents represent an actual missed firewatch that occurred i
.i 21 because the firewatch was either physically restricted from l 9 22 or detained in the performance of the firewatch rounds..
23 These two instances occurred prior to June 1992, before the {
- 24. Thermo-Lag compensatory firewatches were established. ,
i S 25 In one case, on September 17, 1991, the hourly roving i 26 firewatch tour was not fully completed because the roving
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e ;
1 0
1 watch was not able to promptly exit from the radiologically l l
2 controlled area of the plant and exchange duties with the ca 3 firewatch in the turbine building. The firewatch was 4 delayed by radiation protection personnel, while they 5 evaluated some indications of radioactive contamination. !
l g 6 The contamination was eventually traced to the presence of 7 naturally occurring Radon (a radioactive material) on the 8 firewatches' clothes. The roving watch tour was not g 9 performed for two hours. This event is documented in LER 10 1-91-015-00, dated October 16, 1991.
11 The second event occurred on June 20, 1992, when the g 12 turbine building was evacuated as a prudent personnel safety 13 measure due to an acid and caustic chemical spill. The 14 roving firewatch was not performed for eight hours in areas g 15 of the plant affected by the spill. This event is addressed 16 in LER 1-92-007-00, dated July 20, 1992.
17 In the overall context of the DCPP fire protection 18 program, these two isolated instances are not significant 3
19 because the associated fire detection and suppression 20 systems remained fully functional during these periods.
3 21 Moreover, since 1985, the roving firewatches at DCPP have 22 successfully comp]eted in excess of 99.99 percent of the 23 scheduled rounds.
3 24 A majority of the remaining items listed by MFP have 25 little or no relevance to the adequacy of the firewatch 26 program. For the most part, these documents address fire g 27 protection equipment deficiencies (impairments) such as 28 breached fire barriers or inoperable fire detectors.
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1 Breached barriers and inoperable barriers.are not 2 deficiencies in firewatches. When discovered, these O 3 equipment impairments require the establishment of either 4 continuous or roving firewatches until they are repaired.
5 When documented in LERs, these deficiencies by convention
.O 6 are classified as " missed firewatches," not as " breached 7 fire barrier" or " inoperable detector," because the 8 compensatory measures were not in place while the component O 9 was impaired. However, the firewatches in fact were not 10 " missed," but were not yet instituted only because the 11 impairment was not yet identified.
O 12 Furthermore, none of the items cited are associated 13 with Thermo-Lag fire barrier material or firewatches in the 14 11 Thermo-Lag areas subject to interim compensatory O 15 measures. Thus, they cannot support a theory that we have 16 not adequately implemented the specific set of firewatches 17 that constitute the Thermo-Lag interim compensatory o la measures. >
l t
O 19 020 Did any of the incidents cited by the MFP significantly f 20 impact the fire protection capabilities at DCPP?
.i O 21 A20 No. The individual incidents cited generally address t
22 specific equipment malfunctions or individual design 23 discrepancies, and when viewed in the overall DCPP fire f CF 24 protection context represent a minimal reduction in the ;
25 total " defense-in-depth" program. j t
O l
.O i
-1 The fire protection program is multifaceted and 2 includes a central alarming fire detection system that is l
() 3 regularly inspected and tested. Also, many areas of the l t
4 plant are equipped with automatic fire suppression systems j i
5 such as water sprinklers, carbon dioxide or Halon gas. In l i
O 6 addition, the design of the plant includes extensive use of j 7 redundant equipment, circuits, and fire barriers other than ;
8 Thermo-Lag, such that a fire in one area would not impact i
O 9 the ability of the plant to safely shutdown. Major fire 10 areas containing switchgear and power distribution equipment 11 are separated at DCPP by fire area boundaries from other O 12 redundant trains, thereby eliminating the need fer extensive 13 use of Thermo-Lag to achieve cable separation requirements.
14 Also, administrative controls limit the amount of temporary O 15 combustible materials permitted in the plant. Finally, all 16 DCPP plant employees receive initial and yearly 17 requalification training which includes fire protection 0 18 safety. The success of the DCPP fire protection program is 19 not dependent solely on the performance of one portion of 20 the program, but rather on the consolidation of many O 21 individual attributes that comprise the " defense-in-depth" 22 philosophy.
O 23 021 Does this. conclude your testimony?
24 A21 Yes.
O O
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D LIST OF EXHIBITS D 1. Professional qualifications of David K. Cosgrove
- 2. Professional qualifications of Robert P. Powers
- 3. PG&E Response to NRC Bulletin 92-01, Supplement 1, DCL-92-208, dated September 28, 1992 O
D D
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O l 1
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PROFESSIO!JAL QUALIFICATIO!JS O OF 1 DAVID K. COSGROVE O
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[] RESUME MANAGER, NUCLEAR QUALITY SERVICES David K. Cosgrove D 1. Birthdate - October 22, 1951
- 2. Citizenship - USA
- 3. Education & Qualifications O a. Five senesters toward a B.S. in Mechanical Engineering
- b. U.S. Navy Nuclear Power School (Qualified in Submarines)
- c. PG&E Technical Staff Training Progran
- 4. Employment History '
) a. January 1971 to December 1977 - U.S. Navy Submarine Service
- b. September 1980 to February 1984 - Quality Assurance Engineer for Bechtel Power Corporation for engineering & design activities in the San Francisco General Office and later for field construction activities at Washington Nuclear Project
_J #2 in Richland, WA.
- c. February 1984 to November 1985 - Quality Assurance Supervisor for Bechtel Power Corporation at Diablo Canyon Power Plant for the On-Site Engineering Group and later for Field Construction Activities for the Bechtel Site Services
'O group as the construction completion contractor.
- d. November 1985 to August 1991 - Quality Control Specialist for Pacific Gas and Electric Co. in Nuclear Plant Operations at Diablo Canyon Power Plant with responsibility for the
, oversight of the Quality Evaluation problen resolution J progran and a Quality Control representative at Nonconforrance Technical Review Groups.
l
- e. August 1991 - Supervisor of the Safety and Fire Protection l
group:
O
- Responsible for the administration of the plant safety progran through the Plant Safety group and the Industrial Hygienist.
f Supervision of the Fire Protection program, including j)
(
the fire suppression and fire barrier systens through the Fire Protection specialists and systen engineer including the plant firewatches, and the Fire /Energency Response progran through the Plant Fire Marshal, including the Fire Brigade and the Industrial Fire Officers.
S
- Administration of the site Medical Facility for routine and erergency redical treatment as well as the Medical Testing specialists that administer required medical exans.
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4 4h c d4 #-e -- .46., _a a se,4 i
EXHIBIT 2 PROFESSIONAL QUALIFICATIONS OF l
ROBERT P. POWERS s
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RESUME :
MANAGER, NUCLEAR QUALITY SERVICES Robert P. Powers
) 1. Birthdate - February 20, 1954
- 2. Citizenship - USA
- 3. Education
) a. B.S., Biology, Tufts University, Medford Massachusetts, 1975.
- b. M.S., Radiological Physics, University of North Carolina, Chapel Hill, North Carolina, 1976.
- 4. Employment History - Joined PG&E in July 1982.
- a. December 1976 - July 1982 - Health Physicist -
Tennessee Valley Authority.
- b. July 1982 - Employed by PG&E - Assigned to General Office,
) Nuclear Operations Support as a Health Physicist and Senior
)
Nuclear Generation Engineer. I
- c. September 1984 - Assigned to Chemistry and Radiation Protection Department at DCPP as a Senior Chemistry and Radiation Protection Engineer.
- d. January 1987 - March 1987 - Rotational Assignment to Acting Manager Quality Control,
- e. July 1988 - Promoted to Manager of the Radiation Protection Department.
- f. February 1990- Assigned to Senior Reactor Operator License Class.
- g. May 1991 - Certified as Senior Reactor Operator - DCPP.
) h. June 1991 - Assigned as Director, Mechanical Maintenance.
- i. July 1992 - Promoted to Manager, Support Services.
- j. May 1993 - Promoted to Manager, Nuclear Quality Services. !
) 5. Nuclear Experience
- a. Health Physicist in the Tennessee Valley Authority's Nuclear Program with assignments in environmental monitoring, radiation dosimetry, operational health physics, emergency planning, and uranium mining and milling.
)
- b. Certified as a Health Physicist by the American Board of 1 Health Physics, 1982.
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3 Y-1
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- c. Health Physicist and Senior Nuclear Generation Engineer in PG&E's Nuclear Power Program. Assigned to the General Office with responsibilities in dosimetry, operational plant support, and emergency planning.
O
- d. Senior Cheristry and Radiation Protection Engineer, DCPP.
Responsible for all aspects of applied health physics program for DCPP Units 1 and 2.
- c. Acting Manager of DCPP Quality Control Department. Managed
() all aspects of the plant Quality Control Programs.
- f. Manager, Radiation Protection Department, DCPP.
- g. Received Senior Reactor Operator's Certification, DCPP Units 1 and 2, 5/92 O h. Director of Mechanical Maintenance - Responsible for all aspects of turbine, purp, valve, HVAC, reactor and steam generator maintenance for DCPP Units 1 and 2.
- i. Manager Support Services - Responsible for Training,
() Security, Building and Land Services, Energency Planning, Fire Protection and Industrial Safety.
- 6. Formal Training
- a. Senior Reactor Operator Class /1990 - 1991/DCPP -
participated and corpleted 15 nonths of classroom,
) simulator, and on-the-job assignrents leading to certification as a Senior Reactor Operator.
- b. Internal Dosinetry Class - 1989 - one week class by Dr. V. Serable, University of Lowell, covering detailed analysis of dose calculation of internally disposited radionuclides.
- c. Uraniur Mining and Milling - 1982 - one week class by Eberline Co. on radiological inpact and assessment of mining and tilling operations.
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'l PG&E RESPONSE TO NRC BULLETIN 92-01, SUPPLEMENT 1 l 1
O DCL-92-208, DATED SEPTEMBER 28, 1992 i i
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Pacific Gas and Electric Com;:any 77 Eire 5:*ee: G's;: y u Rue;er O, sr r r::s:c ::. s::cs saw.v.e preseem 3e 415 F3 :M: Sr: s.tr3;r
.::r Mr.r G air.:n September 2E, 1992 O PGLE Letter tos. DCL-92-208 HSL-92-050 U.S. fluclear Regulatory Com :ission ATT!4: Document Control Desk g Washincton, D.C. 20555
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Re: Docket tio. 50-275, OL-DPR-80 Docket tio. 50-323, OL-DPR-82 Diabic Canyen Units 1 and 2 Docket rio. 50-133, OL-DPR-7 Humboldt Bay Poser Plant, Unit 3 O Response to supplement 1 of fiRC Bulletin 92-01 Gentlemen:
PGLE's response to Supplement 1 of fiRC Eulletin 92-01, " Failure of Thermo-Lag 330 Fire Barrier System to Perform its Specified Fire O Endurance function, dated August 28, 1992, is provided in the enclosure. PGLE is following the efforts coordinated by fiUMARC regarding the industry fire barrier operability assurance and restoration efforts. The fiUMARC program includes establishment of a database of Thermo-Lag 330 tests, development of guidance for test applicability to as-built configurations, development of more detailed O generic installation guidance, and consideration and coordination of additional Thermo-Lag 330 testing as appropriate. Results of the fiUMARC program will be reviewed for applicability to DCPP when available.
Sincerely,
/$0$v :.u m fl m UI.akay.w f Gregory M. Rueger i cc: Biff Bradley
- g Ann P. Hodgdon John B. Martin Philip J. Morrill Harry Rood CPUC .
Diablo Distribution g HEPP Distribution Enclosure SS455/85K/Atti/2242
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1 PG&E Letter Nos. DCL-92-208
- . HSL-92-060 l
l ENCLOSURE RESPONSE TO SUPPLEFENT 1 0F NRC BULLETIN 92-01
,9 Supplerent I to NRC Eulletin 92-01, " Failure of Thermo-Lag 330 Fire Barrier System to Perform its Specified Fire Endurance Function,' requested licensees to: (1) identify areas of the plant that use either 1- or 3-hour pre-formed Thermo-Lag 330 panels and conduit shapes for the protection and separation of g the safe shutdown capability; (2) in those plant areas in which Therco-Lag fire barriers are used in raceways, walls, ceilings, equipnent enclosures, or other areas to protect cable trays, conduits, or separate redundant safe shutdosn functions, it;1ement in accordance with plant procedures the appropriate corpensatory measures consistent with those which would be irplemented by either the plant Technical Specifications or the operating g license for an incperable fire barrier; and (3) provide a written notification stating whether the licensee has or has not taken the above actions, and where the licensee has declared fire barriers inoperable, describe the measures being taken to ensure or restore fire barrier operability.
PG1E reviewed the ap;1icability of Supplement I to Bulletin 92-01 for Humboldt
, Eay Power Plant (HEFP) and determined that HEPP does not use Thermo-Lag fire barriers. PGSE also reviewed Supplement I for Diablo Canyon Power Plant (DCPP). As a result of the expansion of scope in Supplement 1, PG&E has added three additional fire area (Nos. 9,10, and 11 of Table 1) to the fire areas previously identified in PGLE's original respcnse to Bulletin 92-01. The fire areas in which Thermo-Lag is used as a 1- or 3-hour fire barrier are itemized in Table 1.
3 DCPP Technical Specification (TS) 3.7.10, " Fire Barrier Penetrations,"
requires for non-functional fire barrier penetrations either that an hourly fire watch be established in combination with operable fire detectors or that a continuous fire watch be established. As a result of the uncertainties associated with qualification of Thermo-Lag fire barrier systems, PGLE has 3 taken action consistent with TS 3.7.10 for the Thermo-Lag fire barriers in the fire areas described in Table 1, until such tire that information is available to verify the adequacy of these Thermo-Lag systems or to verify the level of protection provided by such systems.
As a conservative measure to augrent the approved Appendix R Fire Protection
), Program, DCPP has maintained hourly fire watches in effect since the beginning of commercial operation in all safe shutdown fire areas (except in the Units 1 and 2 containments and intake structure) where DCPP credits Appendix R safe shutdown circuits. Also, in general, the combustible loadings for the DCPP fire areas with Thermo-Lag are relatively low. As interim compensatory measures in response to the original Bulletin and to Supplement 1, PG&E 3 expanded the scope of the hourly fire watches to include the intake structure and verified that the fire areas with operable fire detection equipment where DCPP credits the use of Thermo-Lag to protect Appendix R safe shutdown circuits have been covered by the hourly roving fire watches. In addition, P0&E posted continuous fire watches for Fire Areas 22-C and 13-E. Fire Area 22-C has cperable suppression (autcmatic wet pipe) capability, but does not 9 have cperable fire detection equiprent. Fire Area 13-E has neither detection er suppressicr. ca;Ebility.
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In PG&E's original response to Bulletin 92-01 (PG&E letter DCL-92-173, dated July 29, 1992), PG&E had conservatively included the two containment Fire Areas 1 and 9, which each have one 1.5 inch o conduit and boxes made from pre-formed Thermo-Lag panels for fire junction boxes. These Thermo-Lag systems in O the containment buildings are located in the annular areas, which are relatively free of combustibles. The major fire hazards in the containment buildings are the reactor coolant pump (RCP) motor oil and grease, but each RCP is provided with an automatic wet-pipe sprinkler system. In addition, the containment buildings are provided with both smoke and flame detection l systems. However, PG&E considers these Thermo-Lag installations in the :
O containments to be radiant energy heat shields, and not I- or 3-hour fire !
barriers. The basis for considering the e installations to be heat shields is ,
presented in Attachment 1. As discussed with the NRC,-PG&E is of the >
understanding that Thermo-Lag installations considered to be heat shields i rather than barriers do not fall under the requirements of Bulletin 92-01 or i Supplement 1, and therefore PG&E has not included Fire Areas 1 and 9 in this ;
O response to supplement 1. ;
Also, in PGLE's original response to Bulletin 92-01, PG&E had included Fire -
Area 19-A, which has two 2-inch ce conduits and boxes made from pre-formed ,
Thermo-Lag panels for two junction boxes. Fire Area 19-A has operable fire l suppression capability and is included in the scope of the hourly fire watches ~
O that PG&E has maintained since the beginning of commercial operation. PG&E .
has determined that this Fire Area need not have been included in the scope of Bulletin 92-01 and Supplement 1. This determination is based on the l consideration that the Thermo-Lag was installed as a prudent measure to protect the circuits for auxiliary saltwater solenoid valves FCV-602 and >
FCV-603, only one of which needs to be operable to achieve Mode 3 (Hot g Standby). In the event of a fire in this area, the circuits for these valves could be disabled by hot shorts. If both valves are postulated to be made ,
inoperable through the hot shorts, then as described in Emergency Operating Procedure (EP) M-10, the valves may be made operable by venting. Fire Area :
19-A therefore has not been included in the scope of Supplement 1. ,
Vith respect to Fire Area 3-L, inis Area has partial smoke detection, but PG&E l O has determined that the detectors are not in close enough proximity to the i Thermo-Lag enclosure to credit as a compensatory measure. The Thermo-Lag i enclosure is used to protect emergency lighting circuits, and not safe ;
shutdown functions per se, to ensure that lighting is available for operator :
access to valves 8505A and 8805B. In conjunction with the hourly fire watch, !
PG&E has installed 8-hour battery-operated lights to ensure that a lighted O access path for operators is available. In addition, the room in which the Thermo-Lag enclosure is installed is designated as a "No Storage Area".
While PG&E has stationed continuous fire watches in the two remaining areas where Thermo-lag is credited and that do not have fire detection equipment,
- PGLE proposes to use a portable detection system (PDS) for these areas, in O conjunction with an hourly fire watch in place of the continuous fire watch. '
An evaluation performed in accordance with the guidance of 10 CFR 50.59 is provided as Attachment 2 for the use of the PDS. PG&E proposes to implement use of the PDS following concurrence from the NRC.
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I Thermo-Lag Compensatory Fire C) Fire Area (FA) Installation Detection Suppression Actions Duration (minutes)
! 1. FA 3-BB One 3 c conduit; box Smoke Sprinklers Hourly Fire 17 l l (Unit I made from pre-formed Watch Containment panels for one l' 4 ,
b! i Penetration conduit; boxes made from pre-formed panels Area) ;
a for 5 junction boxes ;
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Two 3' & conduits;
! 2. FA 3-CC Smoke Sprinklers Hourly Fire 11 I
(Unit 2 boxes made from pre- Watch O .
Contahanent formed panels for 6 j ,
Penetration Area) jun: tion boxes .
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- 3. FA 3-L One 4 e conduit; box None None Continuous Fire 15 '
(85 Foot Elevation made from pre-formed Watch, or Hourly Auxiliary panels for 1 jun: tion Fire Watch with O Building) box Temporary S-hour Lights to ensure a.
lighted prh in case of Thermo-Lag failure causing loss ,
of vitallights 4 FA 4-B One 4* 4 conduit Smoke Sprirliers Hourly Fire Watch 32 ;
(Access Control)
- 5. FA 5-A-4 One 2" d conduit Smoke None Hourly Fire Watch 34 ,
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O Switchgear Room) .
- 6. FA 5-B-4 One 2' 4 conduit Smoke None Hourly Fire Watch 34 (Unit 2 480 V .
Switchgear Room)
- 7. FA 22-C h (Unit 2 Diesel Two 2* 4 conduits None Sprinklers Continuous Fire Watch, or Portable 9
Generator Detection System Corr; dor) with Hourly Fire Watch ' *
- 8. FA 30-A-5 Individual boxes made Smoke High pressure Hourly Fire Watch 19 e j
(Units 1 and 2 from pre-formed panels CO2 for j ,
l Intake Structure) for two 1* 4 conduits, circulating l two 2* p conduits, and water pump L four 3* 4 conduits; motors '
1 boxes made from pre- !
formed panels for 2 Jun: ten boxes SS46S/E5K O
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Table 1 4 -
Thermo-Lag Installations (cont'd) r 9 Thermo-Lag Compensatory Fire !
Fire Area (FA) Insta!!ation De:ettion Suppression Actions Duration !
(minutes)
- 9. FA 10 Tnermo-Lag / Pyro: rete Smoke None Hourly Fire 23 ;
(Unit 1 - 17 kV Brrier Watch l O Switch; car Room) i I
J0. FA 20 Thermo-Lag / Pyro: rete Smoke None Hourly Fire 23 !
(Unit 2 - 12 kV Burier Watch I Switch;er Room) l C
l 11. FA 13-E/11-B-2 Prtia! Wil constructed None/Nor.c None/None Continuous Fire 2 min!
(107 Foot of pre-formed Thermo- Watch, or Portable 2 min Elevation Turbine La; panels Dete: tion System Building) with Hourly Fire l 0' W at:h I D
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1 Attachment 1 1 I
PGLE considers the Thermo-Lag configurations inside the Units 1 and 2 '
.O containments to be radiant energy heat shields. The basis for this consideration is provided in the following clarification.
i 10 CFR 50. Accendix R. Recuirements O The requirements of Appendix R for " Fire protection of safe shutdown !
capability" are outlined under Section III.G.2 of Appendix R. Specifically, !
Appendix R requires that one of the following fire protection means be i provided inside non-inerted containments:
III.G.2.d: " Separation of cables and equipment and associated nonsafety '
O circuits of redundant trains by a horizontal distance of more than i 20 feet with no intervening combustibles or fire hazards"; ;
III.G.2.e: " Installation of fire detectors and an automatic fire suppression i system in the fire area"; or O III.G.2.f: " Separation of cables and equipment and associated nonsafety ;
circuits of redundant trains by a noncombustible radiant energy l shield." '
i PG&E Submittals O
on September 23, 1983, PG&E provided supplemental information to the fiRC regarding PG&E's compliance with Section III.G, III.J, III.L, and 111.0 of !
Appendix R. In Item 1 of the Enclosure to that letter, PG&E committed to
" provide either a radiant energy s:.ield or 1-hour rated fire barriers for the j reactor coolant temperature instrumentation."
'O In Section 9.5.1.1 of Supplemental Safety Evaluation Report 23, the fiRC staff concluded that *With the installation of a 1-hour fire-rated barrier or radiant energy shield..." the technical requirements of Section III.G.2 of Appendix R in containment would be met and that a deviation from the j requirements of Appendix R was no longer necessary. Due to the fact that !
O there are no provisions for use of a 1-hour fire-rated barrier to comply with !
Section III.G.2 of Appendix R inside containment, it is concluded that the fiRC l staff considered the Thermo-Lag barrier as a radiant enorgy shield. !
.i Generic letter (GL) 85-10 O Further, Section 3.7.1 of GL 85-10.provides the fiRC's interpretation of
" noncombustible radiant energy shields." As outlined in GL 85-10, radiant.
energy shields are provided so that " radiant energy from a fire involving the cables from one division would not degrade or ignite cables of the other .
divisions. The shields also direct the convective energy from the fire away l from the surviving division." The example cited in GL 85-10 for a radiant j O energy shield is a 1/2-inch marinite board in a metal frame. The 1/2-inch thicknessprinite board provides a fire endurance of 1/2 hour, which q
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corresponds to the guidelines outlined in Section C.7.a(1)b of Branch i Technical Position (BTP) CMEB 9.5-1. Within the response provided in GL 85-10 is a position in which the NRC has previously accepted "nonfire-rated radiant energy shields that have been demonstrated by fire hazards analysis to provide
) an acceptable level of protection against the anticipated hazard of a localized fire within containment."
Thermo-Lag is classified as a " noncombustible" matirial based on tests, performed in accordance with ASTM E84 Standards by Underwriters Laboratories, with the following results:
Flame Spread 5 fuel Contributed 0 Smoke Developed 15 Section 5.4.1 of BTP APCSB 9.5-1 identifies noncombustible materials as those l whose propertics exhibit a flame spread, smoke, and fuel contribution of 25 or
) less when tested in accordance with ASTM E84 Standards.
1 Conclusion L In accordance with the above discussion, PG&E considers the Thermo-Lag J installations in the Units 1 and 2 containments to be radiant energy heat shields. As discussed with the NRC, PG&E is of the understanding that Thermo-Lag installations considered to be heat shields rather than barriers do not fall under the requirements of Bulletin 92-01 or Supplement 1; therefore, PGiE has not included Fire Areas 1 and 9 in this response to Supplement 1.
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L Attachment 2 10 CFR 50.59 Safety Evaluation D
DESCRIPTION OF CHANGE This safety evaluation evaluate's the acceptability of the design of the Portable Detection System (PDS) for use in DCPP Units I and 2. This safety ,
evaluation will evaluate procedures that will control operation of the PDS and i 3 evaluate the technical review of the design of the PDS. The following documents will be covered by this safety evaluation: -
S;rveillance Test Procedure (STP) 1-34J, " Portable Detection System Installation Testing and Operation Procedure" '
D STP I-34K, " Portable Detection System Weekly Test" Compliance Review with NFPA 72 (1990), "' Standard for the Installation, Maintenance, and Use of Protective Signaling Systems" i The PDS is a self-contained, portable fire detecting system that consist.s of a -
D panel, UL-listed, com ercial-grade fire detectors, cables, and end-of-line connectors. The PDS is powered by 120V AC power and has a 12V DC battery ,
backup. The panel is an enclosed metal case with a hinged lockable door. The "
panel contains switches for AC and battery power, buzzer, detector zones I and 2, and external bell / strobe lights (optional). The panel has indicator LEDs for alarm, trouble, and normal conditions for detector zones 1 and 2. The 9 panel also has LEDs for normal and trouble indication for AC power and a telephone line, and for battery power operation and low battery power. The PDS uses a voice-synthesized dialer to communicate / transmit supervisory and alarm signals via messages. The messages specify the location of the panel and the type of signal (trouble or alarm). '
3 The PDS will be used, in lieu of a permanently installed fire detection system, as an " operable fire detector" to assist the plant in detecting fires. ;
The limiting condition for operation for TS 3/4.7.10, " Fire Barrier Fe..etrations," requires that "all fire barrier penetrations (including cable t
pene ' ration barriers, fire doors, and fire dampers) in fire area boundaries ,
protecting ' safety-related areas shall be functional." Whenever the fire !
3 barrier penetration is non-functional or cannot perform its intended design function, TS 3/4.7.10 specifically requires that:
i With one or more of the above required fire barrier penetrations non-functional, within I hour, either establish a continuous fire watch on at least one side of the affected penetration, or verify the OPERABILITY of fire detectors on at least one side of O the non-functional fire barrier and establish an hourly fire watch patrol.
( There are two Thermo-Lag configurations (Fire Areas 22-C and 13-E) that do not have a detection system that fulfills the intent of TS 3.7.10, and therefore a continuous fire watch has been established. in order to provide a means of fire protection / prevention without reducing the effectiveness of the existing ;
fire protection capability, FGLE has proposed to use the PDS, in conjunction :
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with an hourly fire patrol and administrative controls, as an acceptable compensatory measure for the Thermo-Lag fire barriers.
The design of the PDS was reviewed against the requirements of the 1990
). edition of NFPA 72. Because IUPA 72 is written primarily for fire detection '
systems that are permanently installed, it is expected that the PDS will not comply fully with the requirements / recommendations provided in NFPA 72. The basis for acceptability of " deviations" or " complies with intent" to NFPA 72 has been evaluated with respect to using the PDS in lieu of a permanently ,
installed fire detection system. Because a fire patrol will be provided on an -
) hourly basis to check the PDS connections, power supply, operation, and phone line availability, and procedures for functional tests will be implemented, the use of the PDS was determined to be technically compatible with a permanently installed detection system. Acceptability of the implementing procedures, in conjunction with an hourly fire patrol, will ensure that the PDS will perform its intended function. Thus, the effectiveness of the Fire .
3 Protection Program is maintained.
SCREENING CRITERIA FOR DETERMINING THE NEED FOR A SAFETY EVALUATION
- 1. 10 CFR 50.59 Safetv Evaluation Screen a) Yes No X Does it involve a change to the Technical Specifications (Appendix A of the DCPP Operating License) or the license itself? (NOTE: if the !
answer to this question is "YES", skip b-e and !
proceed to part 2, the Environmental Protection l
) Plan screen.)
b) Yes No X Does it involve a change to the DCPP facility as described in the FSAR?
i c) Yes X No Does it involve a change to a procedure :
(including the Fire Protection Plan or
) procedures) as described in the FSAR (i.e., Does I
it change system operation or administrative control over plant activities as described in the FSAR)? .
3 d) Yes No Does it involve a test or experiment that could !
) X result in the operation of the facility in a manner not described in the FSAR or which could have an adverse effect on nuclear safety?
e) Yes No X Does it involve a change to DCPP facilities or r procedures that could affect nuclear safety in a
) way not previcusiv evaluated in the FSAR because it was not anticipated?
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- 2. Environrental Protection plan Screen Yes tio X Does it involve a change to DCPP procedures or design which could affect the environment, or a O change to the Environmental Protection Plan?
(Appendix B of the DCPP Operating License.)
- 3. Eeercencv plan Screen Yes fio X Does it involve a change to the DCPP Emergency g , Plan (EP) or emergency response equipment or procedures described in the EP?
- 4. Security Plan Screen Yes No X May it involve a change to the Security Plan or O--
Safeguards Contingency Plan or to equipment or procedures described in the Security Plan or Safeguards Contingency Plan? -
The PDS, in conjunction with an hourly fire patrol, may be used in lieu of a permanently installed detection system to fulfill the action statement for C TS 3/4.7.10. TS fire barriers are part of the Fire Protection Program. Use of the PDS is a change to system operation and administrative control of plant activities. Administrative controls are provided when using the PDS to ensure use of the 120V AC power supply and dedicated telephone line does not impact other DCPP commitments (i.e., Security Plan or Emergency Plan).
O ID CFR 50.59 SAFETY EVALUATID;i l As described in the Safety Evaluation Screen, the PDS, in conjunction with an I hourly fire patrol and administrative controls, will be used as a compensatory measure for Thermo-Lag barriers that do not have operable fire detectors.
O The design of the PDS was compared against the requirements / recommendations of NFPA 72 (1990), and where the design " deviated" or " complied with the intent" of NFPA 72, a basis for acceptability was provided. Based on the intended use of the system, in corjunction with an hourly fire patrol and administrative controls, which will verify PDS connections, power supply, operation, and i
phone line availability, and the completion of functional tests, the use of Q the PDS was determined to be technically compatible with a permanently installed detection system. A dedicated phone line will be used with the PDS to ens"re party lines and connections for existing phones and phone lines are
! not affected.
Operation of the PDS will require a 120V AC power supply source and an D operable telephone line. In addition, a backup battery is provided for the i PDS in the event of a loss of a power source. Detectors are installed in one or two independent zones (up to 25 detectors per zone) per PDS panel, and when activated (by smoke particles or heat), will transmit a signal to the PDS control panel. The detectors are connected to the panel via cables. The cable wires are soldered to nine pin connectors that are screwed to female 3 receptacles on the detectors and panel. This type of connector ensures there will be no inadvertent disconnects to cause false alarms or render the PDS SS ES/E5K D
O inoperable. The dialer will call eight (8) designated phone numbers to notify the recipient of a fire in the specified location. The phone numbers to be called are: Unit 1 Control Room, Unit 2 Control Room, Fire Watch Supervisor, Shift Supervisor, Central Alarm Station, Secondary Alarm Station, Industrial O Fire Office, and the Safety Manager. The PDS dialer will continue to call each of these stations until an individual answers the phone and takes action to investigate the location of the alarm and reset the panel. Investigation of the fire alarm in accordance with existing emergency procedures will be conducted, and followup actions will be taken accordingly.
- O Upon installation, the PDS will be tested in accordance with the installation testing and operation procedure (STP I-34J). This procedure also provides instructions for care and maintenance while the PDS is in storage status.
While the PDS is in use, thc PDS will undergo a weekly functional test (STP I-34K) and a 6-month functiond . test (STP I-34L). The performance of these tests ensures that the PDS is functional by testing the alarm and
'O trouble circuits for continu.ity, manually notifying the designated phone numbers on the dialer, and verifying that the proper messages are being l transmitted from the recorder. In addition, the 6-month functional test
- ensures the PDS panel cables and detectors are functional (i.e., detectors are
! checked for sensitivity and activated using test gas). If at any point the hourly fire patrol or the individual responsible for the test determines that O
the operability of the PDS is not acceptable, a continuous fire watch is posted within an hour in accordance with TS 3/4.7.10 and the PDS is removed.
L Yes No X May the probability of occurrence of an accident previously r evaluated in the FSAR be increased?
O Justification: The PDS may be used as a means of-fire detection in support of TS 3/4.7.10. The PDS will be placed in an area that currently does not have any detection. The PDS will utilize 120V AC and a telephone line for operation, and will not interact with i equipment important to safety or its support equipment. Therefore, the occurrence of design basis accidents previously evaluated in O the FSAR Update will not be affected.
Fire detectors will be connected to the PDS via cables, thereby introducing transient combustible materials to the area of concern. l The transient combustible loading introduced by the PDS will be reviewed prior to installation to ensure transient combustible !
O loading limits are not exceeded. In order to ensure the cables do !
not dangle and interact with equipment, they will be attached with
, wire ties in accordance with Administrative Procedure (AP) C-65, ,
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- Temporary Attachments." Each PDS could, at most, monitor 25 fire !
detectors per zone (the PDS can accommodate 2 zones), and each :
detector on each zone is connected with cable connections. t lO Placerent of the fire detectors is monitored by a fire protectien j i engineer to ensure compliance with NFPA 72E requirements. The PDS ;
i- panel is made of fire-resistive material and will not contribute to !
the combustible loading.
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In addition, the PDS is nct an ignition source and will not create lO.
a fire. Therefore, use of the PDS will not be a fire hazard, and >
j the probability of a fire occurring in the area remains the sate. )
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Failure of the PDS will not affect equipment important to safety.
In the. event the hourly fire patrol determines the PDS is non-fer.ctional or unable to perform its intended function, then the PDS is either replaced with another PDS or a continuous fire watch is
'D posted (as required by TS 3/4.7.10). The probability of occurrence if any accident previously evaluated in the FSAR Update will remain the same.
Yes ~ Mo I May the consequences of an accident previously evaluated in 3 the FSAR be increased?
hstification: As stated above, the PDS will not affect operation of equipment important to safety. Therefore, if an accident previously evaluated in the FSAR Update occurs, equipment expected to mitigate the consequences of the accident will be available. No o" new accidents will be created by the use of the PDS and an hourly fire patrol .
The hourly patrol verifies the PDS has adequate power and the phone line is adequately connected and operable. In addition, a weekly functional test and a 6-month functional test are performed. The fire patrol and functional tests ensure that the PDS will be O cperational to notify appropriate personnel immediately, in the Event a fire occurs Within the hour. If a fire occurs, operators and fire brigade members will mitigate the consequences of the fire in accordance with existing procedures. The consequences of a fire prcpagating across a TS barrier has not been evaluated in the Appendix R analysis (Section 9.5 of the FSAR Update). The Appendix 0 R analysis relies on the functional integrity of the TS fire tarrier to confine or ret ard fires from spreading to redundant safe shutdown equipment to ensure that at least one train of systems necessary to shut down the plant will be free from fire damage.
The use of the PDS will provide early detection of the fire and reduce the potential for circuit damage to redundant equipment O required for safe shutdown as occumented in the Appendix R analysis. Section 9.5 of the FSAR Update will be reviewed to ,
ensure Fire Protection Program commitments are not violated (i.e., i verify that intervening combustibles are not introduced between redundant components where separation is credited). The i Telecommunications group will also be notified upon installation of l C the PDS to ensure Co=unications commitments are not violated. '
The PDS, hourly fire patrol, and daily, weekly, and semiannual functional tests ensure that if a fire were to occur, it would be detected and suppressed during its incipient stage and would not '
propagate across the TS barrier. Therefore, the consequences of 2 O fire as evaluated in the FSAR Update will not be affected.
Yes No_ X May the probability of occurrence of a malfunction of equipment irportant-to-safety, previously evaluated in the FSAR, be increased?
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Justification: Use of the PDS will not interact with equipment 4 important to safety. The PDS will require a 120V AC and an operable telephone line. The power outlets used in the area do not provide power to vital equipment; therefore, plugging in the PDS O will not affect operation of safety-related equipment. In the .
event 120V AC power is lost, a battery back-up (12V DC source) is !
4 provided, and a trouble alarm is initiated locally. When the _
backup battery's voltage drops to 11.5V, a trouble signal is then initiated remotely (i.e., a " trouble" phone call is made to designated stations). .
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In addition, the telephone line is not used for operation of safety j equipment; therefore, plugging in the PDS to an existing telephone line will not affect equipment important to safety. The PDS will be installed on a dedicated phone line and coordinated with '
Telecommunications to ensure commitments are not violated. The use 10 of the PDS and administrative controls on phones on the same phone line will not affect the existing Communication Evaluation performed for the Appendix R analysis (Calculation No. E-134DC).
Therefore, the probability of occurrence of malfunction of equipment important to safety, previously evaluated in the FSAR Update, will not be affected.
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, The PDS will be used to provide early detection of a fire and
- reduce the potential for fire damage to redundant components and/or circuits. The effects of a fire on equipment important to safety has been evaluated in the Appendix R analysis. The actions or equipment used (e.g., telephones) to mitigate fire-induced O-malfunctions of equipment important to safety will be the same as l previously evaluated in Section 9.5 of the FSAR Update.
l Yes No X May the coasequences of a malfunction of equipment important to safety, previously evaluated in the FSAR, be increased?
Justification: As stated above, the use of the PDS does not affect the function of equipment important to safety. Therefore, the consequences of malfunction of equipment important to safety will remain the same. i The PDS will provide early detection of a fire in the area. The O hourly fire patrol will check on PDS operability by verifying power <
is supplied to the PDS, the telephone line is connected, and the fire detector zone (s) is connected. Other administrative controls -
(such .as weekly and 6-conth functional tests) are implemented to ;
verify operability of the PDS. This will ensure that the PDS will provide early indication in the event of a fire within the fire 1 O watch's hourly patrol.
Yes No X May the possibility of an accident of a different type than any already evaluated in thc FSAR, be created?
r O Justification: The PDS is not a fire hazard. Installation of the i i PDS will be evaluated to ensure transient combustible loading SE455/E5K O j
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limits are not exceeded and commitments in Section 9.S' of the FSAR Update (Fire Protection) are not. violated. In addition,- .
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installation of the PDS will be coordinated with Telecommunications to ensure communications commitments are not affected. The use of !
an existing telephone line will not affect plant operation. Where i k-_ necessary, dedicated phone lines will be installed for use by the l PDS. This will ensure the phone line is available for use by the PDS. If the phone line is connected to a phone required by other l'
- Diablo comitments (e.g., Security Plan or Emergency Plan), the PDS.
j- will not be used on that particular phone line, and a dedicated line will be utilized. '
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The PDS and detectors are not seismically qualified. Attention !
will be given to location of the detectors and connaction cables to .i ensure that in the event of an earthquake, the detectors and cables i will not affect Seismically Induced Systems Interaction (SISI) .,5 targets. The criteria for not affecting SISI targets as described
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! i in the SISI Hanual will be reviewed by qualified reviewers prior to l l installation of the PDS panel and its detectors to ensure SISI i concerns are not created. The existing fire detection system is j j not required to be seismically qualified; therefore, the PDS does j l not have to be seismically qualified. ;
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? Therefore, a new type of accident will not be created by use of the j l PDS.
l Yes No X May the possibility of a malfunction of equipment important ,
to safety of a different type than any previously evaluated
) in the FSAR, be created? .j ou;tification: Use of the 120V AC power source and existing telephone line will not impact the operation of equipment 'important ,
tc safety. Therefore, the possibility of a malfunction of 1; equipment of a different type will not be created. Where '
) necessary, dedicated phone lines are used to ensure that 1 commitments are not violated. '!
Phones that are required or committed for other reasons (e.g., +
Security Plan or Emergency Plan) will not be used by the PDS. J Prior to installing the PDS, a representative from - !
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t Telecomunications will approve placement of the PDS and ensure that commitments are not affected by the installation. InJ i
l addition, Section 9.5 of the FSAR Update will be reviewed to ensure i commitments made in the Fire Protection Program are not affected.
[ In addition, because the PDS and detectors are not seismically l y qualified, attention will be made to installation of detectors and -
connecting cables to ensure that in the event of an earthquake, the l
l detectors and cables will not affect operation of SISI targets. {
! The PDS will not be used in areas where SISI targets may be 1
( affected. SISI requirements will be coordinated with a qualified l individual. The criteria in the SISI Manual will be reviewed to ;
)~ ensure the potential for creating SISIs due to installation of the PDS will not be involved.
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Yes fio X Does the proposed change, test or experiment reduce the margin of safety as defined in the basis for any Technical Specification?
O Justification: The PDS, in conjunction with the hourly fire patrol '
and administrative controls, will be used as a compensatory measure for the Thermo-Lag fire barriers. Use of the PDS will maintain the margin of safety as described in the basis of TS 3/4.7.10. The PDS, in conjunction with the bourly fire patrol verifying operation of the PDS (i.e., check the power connection, telephone connection, O detector zone connection, etc.) provides an equivalent level of fire protection of a permanently installed fire detection system.
In addition, the PDS is checked weekly to ensure the dialer and battery backup works properly. A functional test is performed upon -
installation and every six months to ensure proper operation of the PDS. In the event the PDS is determined non-functional, a c ntinu us fire watch is posted in accordance with TS 3/4.7.10.
O fiFPA Code Comparison Review was conducted to evaluate the basis for acceptability of " deviations" and " complies with intent" of the code requirements. Because the system is not a permanent system, it was not expected to fully comply with the code. The temporary use f the system, in conjunction with the fire patrol and O additional administrative controls, provides an equivalent level of fire protection consistent with a permanently installed detection system that would have been used, if it was available, in ,
accordance with the action statements of TS 3/4.7.10.
TS 3/4.3.3.8, " Fire Detection Instrumentation," is not affected by O use of the PDS. The PDS is used to supplement the permanently installed detection systems required by TS 3/4.3.3.8. As stated in the basis of TS 3/4.3.3.8:
The operability of detection instrumentation !
ensures that adequate warning capability is ,
C available for prompt detection of fires. This capability is required in order to detect and locate fires in their early stages. Prompt ;
detection of fires will reduce the potential for damage to safety-related equipment and is an integral element in the overall facility Fire O Protection Program.
The intent of using the PDS to satisfy the TS 3/4.7.10 action
, statement for Thermo-Lag fire barriers is to provide early !
detection of a fire. The hourly fire patrol and additional administrative controls will provide assurance that the PDS is as O reliable as a permanently installed system.
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Yes fio X May this change result in a decrease of effectiveness of the j
Fire Protection Plan?
Indicate the Fire Protection Plan (FSAR Update, Section 9.5, Volume
? 11) sections reviewed?
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If the answer to the above question is "no", provide a statement '
justifying the conclusion. Include the following: l
- a. Cite and describe the sections of the Fire Protection Plan being changed.
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- b. Describe the proposed change and how it affects the effectiveness of the program.
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- c. Cite and describe the applicable NRC requirements (including the NRC basis of acceptance) or PG1E commitments and justify
.O that the proposed revision meets these requirements or commitments.
The Fire Protection Plan credits the functional integrity of !
fire barriers to ensure that fires will be confined or adequately retarded from spreading to adjacent portions of the O facility. TS 3/4.7.10 provides action statements to provide an equivalent level of fire protection in the event a fire barrier or its penetrations is non-functional. The design of the PDS
- was reviewed against the requirements of NFPA 72. which is-applicable to permanently installed detection systems. Because the PDS is a " portable system" and not a permanent .
O installation, several requirements of the code could not be i met. The basis for acceptability of the " deviations" and
" complies with intent' are documented in the Code Compliance Review. Because of the temporary use of the PDS, the hourly -
fire patrol, and additional administrative controls, the use of ;
the PDS is determined to be an equivalent level of fire O protection.
The PDS is not described in Section 9.5 of the FSAR Update.
The PDS supplements the permanently installed fire detection i
system, and therefore does not reduce the ability to detect :
fires as described in the FSAR Update. The PDS is a temporary o means of fire detection. Use of the PDS does not reduce the effectiveness of the Fire Protection Program or change the description of the fire detection system in Section E.1 of Table B-1 of Section 9.5B.
The use of the PDS was discussed with the NRC prior to ,
'O implementation. The NRC appeared to not have a technical concern with using the PDS and an hourly fire patrol, but requested a safety evaluation be performed to determine that an unreviewed safety question is not created.
In addition, Section 9.5 of the FSAR Update will be reviewed to
'g ensure that commitments made in the Fire Protection Program are '
not affected. Based on the above safety evaluation, use of the PDS will not reduce the effectiveness of the approved Fire Protection Program.
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Conclusion :
Based upon the above criteria and justification, PG&E has determined that an unreviewed safety question is not involved. Further, a change to the DCPP
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l Technical Specifications is not involved.
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- 2. - Environmental Protection Plan Evaluation i
Not applicable. '
)- 3. Emeroency Plan Evaluation - 10 CFR 50.54(o) '
Not applicable.
l 4. Security Plant Evaluation _10 CFR 50.54(o) l i j Not applicable. '
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