4.0 Summary of Major DCISC Review Topics, 17th Annual Report - July 1, 2006 thru June 30, 2007
4.21 Fire Protection
4.21.1 Overview and Previous Activities
Fire protection requirements are contained in NRC’s regulations in 10CFR50 Appendix R. Appendix R specifies the minimum requirements for safe shutdown systems and equipment, fire hazards analysis, prevention, detection and mitigation, fire brigades and training, emergency lighting, fire barrier and penetration qualifications, and fire doors. PG&E has committed to implementing these requirements, utilizing interpretations and deviations approved by NRC. The NRC periodically performs inspections of the DCPP fire protection program implementation.
The DCISC has looked into the following aspects of DCPP fire protection in the previous reporting period:
- Corrosion in Fire Protection Piping
- 2005 Triennial Fire Protection
- Fire Protection Review with System Engineer
- Appendix R (NRC Fire Protection Requirements) Program
The DCISC concluded in the last period that DCPP’s 2005 annual fire protection audit found the Fire Protection Program and System to be satisfactory and effective but highlighted concerns regarding the Fire Protection System Health due to long-standing unresolved problems such as piping corrosion. Engineering responded with a long-term plan intended to return the system to excellent system health (Green) status in 2011. Although the system remains fully operable, the DCISC is concerned about the timeliness of corrective actions and will closely follow the project implementation.
The DCISC had the following fire protection recommendation in the last period:
- Recommendation R06-4:
- DCPP should place additional emphasis and resources at the management and project level to improve the health of its Fire Protection System from Yellow status (unsatisfactory) to at least White status (satisfactory) in a timelier manner than is currently planned.
- Basis for Recommendation:
- As stated in the conclusion in the July 20-21, 2005 DCISC Fact-finding Meeting “[t]he Fire Protection System has had long term equipment and piping problems. DCPP has been working on these problems since 1990 and has corrected some of them but has not solved the longest-lasting ones. They have an action plan and long term plans which, if funded, should resolve these issues. It appears that it is taking a very long time to approve, fund, and implement the resolution of these issues.” The corrective action schedule has slipped since the July 2005 Fact-finding Meeting, and the DCISC believes more emphasis and resources should be placed on regaining system health to at least the White (satisfactory) status.
- PG&E Response:
- DCPP continues to focus on the health of all systems that are rated unsatisfactory. The Fire Protection System is in yellow health status; therefore, management has taken aggressive action by forming a High Impact Team to more effectively address the corrective maintenance in the firewater suppression system. The team will also evaluate strategies to remedy long standing firewater pipe corrosion issues. Actions to change Fire Protection System health status from unsatisfactory to satisfactory have been identified and are being aggressively pursued with continued senior station leadership oversight.
The DCISC found this response acceptable at its January 31 – February 1, 2007 Public Meeting (Volume II, Exhibit B.6).
4.21.2 Current Period Activities
The DCISC reviewed the following fire protection item during the reporting period.
- 2006 Annual Fire Protection Audit
- Fire Protection System Review
2006 Annual Fire Protection Audit
DCPP Quality Verification performed its 2006 Annual Fire Protection Audit to fulfill the audit requirements in NRC’s Generic Letter 82-21, “Technical Specifications for Fire Protection Audits.” The scope of the audit was to verify that:
- Installed Fire Protection (FP) systems and barriers are appropriate for the objects protected.
- The fire loading in each fire area has not increased above that specified in the FSAR Update.
- Regularly scheduled maintenance is performed on plant FP systems.
- Identified deficiencies have been promptly and adequately corrected.
- Special permit procedures (e.g., hot work) are followed.
- Plant personnel are receiving appropriate training in fire prevention and fire fighting procedures and the training program is consistent with approved standards.
- Plant response to fire emergencies is adequate.
- Administrative controls are limiting transient combustibles in safety-related areas.
- Problem areas identified in previous audits have been corrected.
- The audit also reviewed the progress of DCPP actions to implement NFPA 805, “Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants.”
DCPP Quality Verification (QV) performed its annual audit of the Fire Protection Program in September and October 2006. Their overall conclusion was as follows:
- The audit team concluded that implementation of the FP program at DCPP is satisfactory. As used here, Satisfactory is meant to convey the following: overall performance meets and in some areas exceeds minimum standards. Some strengths were identified; however, some repetitive or long-standing problems exist. Deficiencies are generally considered minor, but some may be considered significant. The overall program is considered to be effective.
The audit contained the following remarks regarding FP system health and problem resolution:
Good progress towards improving the material conditions of FP equipment during 2006
- Funding was approved to recoat the interior of the FWST and replace connected suction, discharge and recirculation piping
- Replacement of the obsolete CO2 tank refrigeration compressor was on track to be completed in 2006
- Replacement of Fire Pumps 0-1, 0-2, and associated base plates should also be completed in 2006.
- Most of the work to replace degraded transformer deluge piping had been completed.
Two discrepancies (since corrected) were noted:
- The FP System Health Report had not been updated since May 4, 2006 (versus a requirement to review and/or update monthly)
- Several actions required to restore the FPS to Green either did not have an associated long-term AR and Plant Health Issue Plan or were associated with cancelled PHIPs.
Comments on Maintenance Rule Monitoring
- Based upon an absence of flow switch functional failures during the current monitoring period, the team concluded that the corrective actions were sufficient to resolve the flow switch performance problems; however, there were several programmatic/administrative items remaining open.
- Goal-setting actions implemented for the FPS deluge valves were acceptable, PM had been correctly performed for all Unit 1 & 2 deluge valves, and there have been no subsequent deluge valve functional failures.
- Goal-setting actions completed to date for the Unit 1 fire water to Containment isolation valve are adequate.
QV’s summary of the effectiveness evaluation stated:
- Good progress was made during 2006 towards improving the material condition of the FP System. However, restoration of system health to a green status is not projected until 2011. Long-term conditions that remain include providing alternate Fire Water capability to the Unit 1 and Unit 2 containments.
- Overall resolution of previously documented concerns was satisfactory. However, repeat concerns were identified [in] this audit for untimely closure of FP System recurring task work orders, and for vehicles being parked in the vicinity of Unit 2 transformers between the delay fence and the administration building.
- Similarly, DCPP’s overall administration of TCPs was satisfactory; however, strengthened controls are warranted to preclude the types of process errors identified in this audit.
- Finally, DCPP’s progress on the transition to NFPA 805 is acceptable. A tremendous amount of work has been completed, and still remains to be completed. DCPP is losing resources that are currently assigned to the project, with the lead engineer having just taken a job with Westinghouse.
The audit found 17 Quality Problems documented with Action Requests. The problems were not considered significant.
Review of Fire Protection System with System Engineer
The DCISC Fact-finding Team met with Dan Hromyak, Fire Protection System Engineer, at the May 30-31, 2007 Fact-finding Meeting (Volume II, Exhibit D.9, Section 3.1) to review the status of the DCPP Fire Protection System (FPS). Mr. Hromyak had been System Engineer for about one year.
The purpose of this Fact-finding Meeting was to review DCPP’s actions and progress in bringing FPS to satisfactory system health, i.e., from Yellow to White status. The FPS is governed not by plant Technical Specifications (TS) but by DCPP Equipment Control Guidelines (ECGs), the National Fire Protection Association standards, and by DCPP’s Fire Insurance Company.
The System Engineer considers FPS a “high maintenance” system. His major effort is improving system health from Yellow (unsatisfactory) to White (satisfactory), and his main focus is on the Firewater Suppression System in which there is much corroded piping. The most significant challenge to margin with the Fire Protection System continues to be the corrosion and occlusion of firewater piping and components. There are also equipment aging and obsolesce issues for a variety of components as described below.
The following health report reflects the completion of fire pump replacements and motor work and return of the fire water flow switches to MR(a)(2) status.
Discussion of System Health Color
Yellow status is due to major performance/health issues which include one MR(a)(1) item and the following six equipment problem areas:
- The single train of fire water supply to Containment is a Single Point Vulnerability (SPV). There is no way to route additional hose stations into Containment to fight fires during Modes 1 through 4. At-power work on the Auxiliary Building Firewater Header is not permissible. Corrective action is to provide a redundant fire water supply into Containment. The SE plans to re-present this item to the Plant Health Committee (PHC) soon for approval and to complete the project in Outage 1R15.
- The CO2 System Control Valve and Solenoid Valve have experienced degradation and failures. There have been nine solenoid failures over an 18-month period, and the master control valve has been replaced twice due to damage. Valve changes have begun, and completing change-outs and establishing valve maintenance will take until May 2009.
- The Fire Water Storage Tank requires interior cleaning and recoating and replacement of the connected suction, discharge and recirculation piping. Estimated completion is December 2009.
- The Fire Water Hose Reel Cross-Connecting Header Piping between Units 1 and 2 Turbine, Auxiliary and Containment headers is severely corroded and occluded. Corrective action is to monitor corrosion rates and eventually replace header piping which would be completed in December 2011.
- There are 268 active system Action Requests (ARs). Of those, resolution of 47 firewater suppression ARs is key to achieving White status. An assigned High Impact Team comprised of Maintenance, Operations and Scheduling is expected to complete corrective maintenance by November 2008.
- There is corrosion of the fire suppression system piping upstream of Auxiliary Transformer 2-1 and of the deluge system for Start-Up Transformer 2-2 for which requires piping redesign and replacement. This work is planned for Outages 1R15 and 2R15.
Currently, the SE expects achievement of White status by June 2009.
Items in Maintenance Rule (MR)(a)(1) Status & Critical Equipment Failures
Deluge valves for main turbine bearings, Main Feedwater Pumps, and H2 Seal Oil skids have been placed in (a)(1) status for failure of four valves to actuate. Return to MR(a)(2) status requires completion of revised preventive maintenance (PM) and satisfactory test results. Completion is expected January 30, 2008.
Scheduled Major Maintenance or Modifications
Near-term:
- Cross-tie valves are being replaced to remove an operator workaround.
- Work to address the 47 system ARs.
Overall, the DCISC Fact-finding Team notes some tangible progress toward achieving White status since its review of Fire Protection in April 2006 and notes substantial favorable progress in the approach and resources being applied to problem resolution as follows:
- A High Impact Team, which meets weekly with the SE, has been assigned to work down the 47 corrective maintenance ARs and other work needing resolution for advancement to White.
- The new SE has shed himself of many non-engineer tasks, such as periodic testing and administrative items, to concentrate on identifying the scope of problems and prioritizing them.
- The SE has improved and streamlined PMs and testing procedures.
- The SE appears to be taking a strong, effective role in obtaining Plant Health Committee approvals to improve the system health.
- The SE reports seeing measurable progress towards White status.
DCPP is finally beginning to make measurable progress toward resolving the many issues and problems affecting the Fire Water Systems. Although the schedule for achieving satisfactory (White) status is long with completion in June 2009, it is recognized that the system remains functional and that the corrective actions have scheduling constraints and are long-term in nature. It is important that DCPP keep or increase its efforts to resolve Fire Water system problem resolutions. The DCISC will continue to follow progress on the Fire protection System.
4.21.3 Conclusions and Recommendations
- Conclusion:
- DCPP’s 2006 annual fire protection audit found the Fire Protection Program and System to be satisfactory and effective but highlighted concerns regarding the Fire Protection System Health due to long-standing unresolved problems. Engineering is making measurable progress in improving system health and expects White (satisfactory) health by 2009. Although the system remains fully operable, the DCISC is concerned about the long time frame projected to achieve satisfactory health for the Fire Protection System: White in 2009 and Green in 2010 or 2011.
- Recommendations: None