Criteria, Review, and Approach Document for the Assessment of
Operational Readiness of Vital Safety Systems Response

Site: Y-12 Complex

Facility: 9212

System: Fire Suppression Wet Pipe Systems (WPS) 3, 6, 7, 8, 9, 11

> (Referred to in Surveillance Procedure as: 9212-000-WPS-003,
>
> 9212-000-WPS-006, 9212-000-WPS-007, 9212-000-WPS-008,
>
> 9212-000-WPS-009, 9212-000-WPS-011)

System Classification: Safety Significant

System Safety Function (list):

To minimize a fire in the area of coverage to reduce the chance of a
uranium release. To prevent fire from becoming a major wing/facility
fire and to reduce consequences of fires that do develop. \[Systems\]
are credited with minimizing fires in the areas protected by the
suppression systems.

(Document Y/MA-7254, Rev. 11, The Basis for Interim Operation for
Building 9212 Enriched Uranium Operation Complex, Table 6.1)

[OBJECTIVES:]{.underline}

VSS-1.1 VSS safety functions are defined and understood by responsible
line managers, and supporting information/documentation is available and
adequate. System testing is adequate to ensure operability. (Review
Approach Items 1,2,3 and 7)

Criterion VSS-1.1 was met. The safety function of Wet Pipe Systems (WPS)
3, 6, 7, 8, 9, and 11 are defined in Y/MA-7254, Rev. 11, *The Basis for
Interim Operations for Building 9212 Enriched Uranium Operations
Complex*. Review of the orientation given the line managers in Fire
Protection Operations who are responsible for overseeing the operation
of WPS 3, 6, 7, 8, 9, and 11 demonstrated that the safety functions of
this vital safety system are addressed. Interviews with these line
managers confirmed their understanding of the safety functions of the
Wet Pipe Systems (WPS) 3, 6, 7, 8, 9, and 11. Interviews with randomly
selected personnel within Fire Department Operations indicated a basic
understanding of the safety functions of the Wet Pipe Systems (WPS) 3,
6, 7, 8, 9, and 11 and where to obtain further information. Although
these reviews showed basic knowledge, a review of general Vital Safety
System information is warranted. The available drawings that document
the system configuration included system riser and flow diagrams and are
maintained at Y12 Facility Records. Comparison of the system testing
requirements, including the specified acceptance criteria and test
frequencies mandated by Y52-54-FDO-013, *Wet Pipe Sprinkler System
Monthly Surveillance for Building 9212 Complex* and Y52-54-FDO-045, *Wet
Pipe Sprinkler System Semi-Annual Surveillance for Building 9212
Complex* with the testing required to ensure operability defined in
Y/MA-7255, *The Operational Safety Requirements for Building 9212
Enriched Uranium Operations Complex,* verified that the testing of the
WPS 3, 6, 7, 8, 9, and 11 is adequate to ensure operability.

> No necessary documentation was unavailable or inadequate.
>
> Details of the assessment verifying compliance with this criterion
> follow.

1.1.1 (Approach Item 1): Using the DOE-approved facility safety analysis
(i.e., SAR, BIO, etc.) identify: a) the system safety function(s); b)
the normal, abnormal, and accident conditions under which the system is
intended to perform its safety function(s); and c) relevant system
functional requirements and performance criteria.

1.1.1.a Identify the system safety functions:

To minimize a fire in the area of coverage to reduce the chance of a
uranium release. To prevent fire from becoming a major wing/facility
fire and to reduce consequences of fires that do develop. \[Systems\]
are credited with minimizing fires in the areas protected by the
suppression systems.

> (Document Y/MA-7254, Rev. 11, *The Basis for Interim Operation for
> Building 9212 Enriched Uranium Operation Complex*, Table 6.1)

1.1.1.b The normal, abnormal, and accident conditions under which the
system is intended to perform its safety function(s):

> [Normal Conditions]{.underline}. Fire suppression systems must be
> operable during facility operating and warm standby modes. (Y/MA-7255,
> Rev. 11, Section 3.5.1)
>
> [Abnormal/Accident Conditions.]{.underline} The following are the
> dominant accident conditions for the relevant suppression systems:
>
> Wet Pipe Sprinkler Systems 3,6,7,8,9,11:
>
> Document Y/MA-7254, Rev. 11, Section 5.6.1.1.3 -- Fires involving safe
> storage bottles of organics
>
> Document Y/MA-7254, Rev. 11, Section 5.6.1.5 -- Transient combustible
> fires
>
> Document Y/MA-7254, Rev. 11, Section 5.6.1.8 -- Fire in B-1 Wing.

1.1.1.c Relevant system functional requirements and performance criteria

Functional requirements for the sprinkler systems are identified in LCO
3.5.1 of Y/MA-7255 Revision 17, *Operational Safety Requirements for
Building 9212 Enriched Uranium Operations Complex*. Water Pressures for
the credited sprinkler systems are as follows:

  ----------------------------- -----------------------------------------
  Sprinkler System Number       Required Water Supply Pressure (psig) per
                                LCO 3.5.1

  9212-000-WPS-003              35.0

  9212-000-WPS-006              37.5

  9212-000-WPS-007              27.5

  9212-000-WPS-008              32.5

  9212-000-WPS-009              32.5

  9212-000-WPS-011              20.0
  ----------------------------- -----------------------------------------

During the review it was noted that the water supply pressures specified
in the OSR met or exceed the requirements specified in the associated
Fire Hazard Analysis.

Relevant system performance criteria are identified in LCO 3.5.1 of
Y/MA-7255 Revision 17, *Operational Safety Requirements for Building
9212 Enriched Uranium Operations Complex*.

Acceptance criteria include the following:

-   2-in. main drain test results are less than or equal to 10 psig for
    each wet pipe sprinkler system

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-   main control valves or post-indicating valves, if provided, for each
    wet pipe sprinkler system are open.

-   water flow indication when an inspector's test valve (ITV) for an
    associated sprinkler system is opened.

    2.  (Approach Item 2) Identify the acceptance criteria from the
        surveillance tests used to verify that the system is capable of
        accomplishing its safety function(s). Review the acceptance
        criteria against the function(s), conditions, requirements and
        performance criteria identified in section 1.1.1 above.

+----------------------------------+-----------------------------------+
| **Requirement**                  | # Implementation                  |
+----------------------------------+-----------------------------------+
| LCO 3.5.1                        |                                   |
+----------------------------------+-----------------------------------+
| WPS-003                          |                                   |
+----------------------------------+-----------------------------------+
| system water pressure 35.0 psig  | Y52-54-FDO-013 Rev. 3.0 Step 5.1  |
|                                  | \[5\]                             |
+----------------------------------+-----------------------------------+
| 2-in main drain test results 10  | Y52-54-FDO-045 Rev. 0.2 Step 5.4  |
| psig                             | \[8\]                             |
+----------------------------------+-----------------------------------+
| Main control valve or PIV is     | Y52-54-FDO-013 Rev. 3.0 Step 5.1  |
| open                             | \[3\]                             |
+----------------------------------+-----------------------------------+
| ITV test indicates water flow    | Y52-54-FDO-045 Rev. 0.2 Step      |
|                                  | 5.2.1\[9\]                        |
+----------------------------------+-----------------------------------+
| WPS-006                          |                                   |
+----------------------------------+-----------------------------------+
| system water pressure 37.5 psig  | Y52-54-FDO-013 Rev. 3.0 Step 5.1  |
|                                  | \[5\]                             |
+----------------------------------+-----------------------------------+
| 2-in main drain test results 10  | Y52-54-FDO-045 Rev. 0.2 Step 5.4  |
| psig                             | \[8\]                             |
+----------------------------------+-----------------------------------+
| Main control valve or PIV is     | Y52-54-FDO-013 Rev. 3.0 Step 5.1  |
| open                             | \[3\]                             |
+----------------------------------+-----------------------------------+
| ITV test indicates water flow    | Y52-54-FDO-045 Rev. 0.2 Step      |
|                                  | 5.2.1\[9\]                        |
+----------------------------------+-----------------------------------+

+----------------------------------+-----------------------------------+
| **Requirement**                  | # Implementation                  |
+----------------------------------+-----------------------------------+
| WPS-007                          |                                   |
+----------------------------------+-----------------------------------+
| system water pressure 27.5 psig  | Y52-54-FDO-013 Rev. 3.0 Step 5.1  |
|                                  | \[5\]                             |
+----------------------------------+-----------------------------------+
| 2-in main drain test results 10  | Y52-54-FDO-045 Rev. 0.2 Step 5.4  |
| psig                             | \[8\]                             |
+----------------------------------+-----------------------------------+
| Main control valve or PIV is     | Y52-54-FDO-013 Rev. 3.0 Step 5.1  |
| open                             | \[3\]                             |
+----------------------------------+-----------------------------------+
| ITV test indicates water flow    | Y52-54-FDO-045 Rev. 0.2 Step      |
|                                  | 5.2.1\[9\]                        |
+----------------------------------+-----------------------------------+
| WPS-008                          |                                   |
+----------------------------------+-----------------------------------+
| system water pressure 32.5 psig  | Y52-54-FDO-013 Rev. 3.0 Step 5.1  |
|                                  | \[5\]                             |
+----------------------------------+-----------------------------------+
| 2-in main drain test results 10  | Y52-54-FDO-045 Rev. 0.2 Step 5.4  |
| psig                             | \[8\]                             |
+----------------------------------+-----------------------------------+
| Main control valve or PIV is     | Y52-54-FDO-013 Rev. 3.0 Step 5.1  |
| open                             | \[3\]                             |
+----------------------------------+-----------------------------------+
| ITV test indicates water flow    | Y52-54-FDO-045 Rev. 0.2 Step      |
|                                  | 5.2.1\[9\]                        |
+----------------------------------+-----------------------------------+
| WPS-009                          |                                   |
+----------------------------------+-----------------------------------+
| system water pressure 32.5 psig  | Y52-54-FDO-013 Rev. 3.0 Step 5.1  |
|                                  | \[5\]                             |
+----------------------------------+-----------------------------------+
| 2-in main drain test results 10  | Y52-54-FDO-045 Rev. 0.2 Step 5.4  |
| psig                             | \[8\]                             |
+----------------------------------+-----------------------------------+
| Main control valve or PIV is     | Y52-54-FDO-013 Rev. 3.0 Step 5.1  |
| open                             | \[3\]                             |
+----------------------------------+-----------------------------------+
| ITV test indicates water flow    | Y52-54-FDO-045 Rev. 0.2 Step      |
|                                  | 5.2.1\[9\]                        |
+----------------------------------+-----------------------------------+
| WPS-011                          |                                   |
+----------------------------------+-----------------------------------+
| system water pressure 20.0 psig  | Y52-54-FDO-013 Rev. 3.0 Step 5.1  |
|                                  | \[5\]                             |
+----------------------------------+-----------------------------------+
| 2-in main drain test results 10  | Y52-54-FDO-045 Rev. 0.2 Step 5.4  |
| psig                             | \[8\]                             |
+----------------------------------+-----------------------------------+
| Main control valve or PIV is     | Y52-54-FDO-013 Rev. 3.0 Step 5.1  |
| open                             | \[3\]                             |
+----------------------------------+-----------------------------------+
| ITV test indicates water flow    | Y52-54-FDO-045 Rev. 0.2 Step      |
|                                  | 5.2.1\[9\]                        |
+----------------------------------+-----------------------------------+

3.  (Approach Item 3) At what frequency are the tests identified in
    Question 1.1.2 above performed? Determine whether these tests and
    inspections are required by Technical Safety Requirements,
    Operational Safety Requirements (OSRs), or other Authorization Basis
    or Authorization Agreement requirements.

+-----------------------------------+---------+-----------------------+
| **Surveillance Requirement**      | ### Fr  | **Implementation**    |
|                                   | equency |                       |
+-----------------------------------+---------+-----------------------+
| Y/MA-7255 SR 4.5.1.1 -- Verify    | Monthly | Y52-54-FDO-013 Rev.   |
| the water supply pressure for     |         | 3.0 Wet Pipe          |
| each sprinkler system meets the   |         | Sprinkler System      |
| minimum supply pressure           |         | Monthly Surveillance  |
| requirements specified in Table   |         | for the Building 9212 |
| 3.5.1-1 (Y/MA-7255)               |         | Complex - Step 5.1    |
|                                   |         | \[5\]                 |
+-----------------------------------+---------+-----------------------+
| Y/MA-7255 SR 4.5.1.2 -- Verify    | Monthly | Y52-54-FDO-013 Rev.   |
| the main control and post         |         | 3.0 Wet Pipe          |
| indicator valve, if provided, for |         | Sprinkler System      |
| each sprinkler system in Table    |         | Monthly Surveillance  |
| 3.5.1-1(Y/MA-7255) is open.       |         | for the Building 9212 |
|                                   |         | Complex - Step 5.1    |
|                                   |         | \[3\]                 |
+-----------------------------------+---------+-----------------------+
| Y/MA-7255 SR 4.5.1.3 -- Perform a | Semi    | Y52-54-FDO-045 Rev.   |
| 2-in. main drain test for each    | -Annual | 0.2 Wet Pipe          |
| wet pipe sprinkler system in      |         | Sprinkler System      |
| Table 3.5.1 to verify the water   |         | Semi-Annual           |
| supply pressure reduction is less |         | Surveillance for the  |
| than or equal to 10 psig from a   |         | Building 9212 Complex |
| static condition.                 |         | -Step 5.4 \[8\]       |
+-----------------------------------+---------+-----------------------+
| Y/MA-7255 SR 4.5.1.4 -- Open an   | Semi    | Y52-54-FDO-045 Rev.   |
| ITV in each wet pipe sprinkler    | -Annual | 0.2 Wet Pipe          |
| system in Table 3.5.1 and verify  |         | Sprinkler System      |
| water flow through the associated |         | Semi-Annual           |
| system.                           |         | Surveillance for the  |
|                                   |         | Building 9212 Complex |
|                                   |         | -Step 5.2.1 \[9\]     |
+-----------------------------------+---------+-----------------------+

4.  (Approach Item 7). Are drawings that document the system
    configuration available? If so, identify the types of drawings
    (e.g., piping and instrumentation diagrams, electrical one-line,
    wiring, or schematic diagrams, installation drawings).

> Response: System riser and flow diagrams (piping) are available for
> the WPS 3, 6, 7, 8, 9, 11 and are maintained at Y12 Facility Records.

VSS-1.2 The backlog for surveillances, tests, inspections, maintenance,
repair, upgrades, or other work on the system is managed and kept to an
appropriate minimum. (See Review Approach item 6.)

Criterion VSS-1.2 was met. The processes for assigning priorities to
surveillances, tests, inspections, maintenance, repair, upgrades, and
other work on WPS 3, 6, 7, 8, 9, and 11 are not formally documented. The
process for prioritizing test, maintenance and inspection was
promulgated as a part of Fire Protection Operations RFA 166. The process
is installed in the FireBase scheduler and provides a ranking number for
each system dependent of system grade, Authorization Basis assignment,
building importance and system type. Review of these processes showed
that the WPS 3, 6, 7, 8, 9, and 11 have been assigned a priority for
surveillances, tests and inspections that is commensurate with their
importance to safety. WPS 3, 6, 7, 8, 9, and 11 are subject to the
requirements of Y/MA-7255 Revision 17, *Operational Safety Requirements
for Building 9212 Enriched Uranium Operations Complex* which requires
that surveillances, tests, and inspections be conducted on a specific
schedule. The backlog for surveillances, tests, and inspections on WPS
3, 6, 7, 8, 9, and 11 is managed to keep it at an appropriate minimum. A
review of the FireBase database records for the last three years showed
that there is some discontinuity between hard copy and electronic
maintenance records. Had these maintenance items been actually missed
the facility would have initiated an occurrence report. Due to the fact
that there are no supporting occurrence reports, it is probable that all
of the required surveillances, tests, and inspections have been
conducted on schedule and that a documentation problem exists. All
surveillances are currently up to date.

The process for prioritizing corrective maintenance is documented on the
Test, Maintenance and Inspection web site. It is used by TM&I schedulers
to prioritize work. In general, TM&I support personnel have been able to
care only for those items that directly affect operability of the VSS.
Remaining maintenance is backlogged. Of note, the inability of Fire
Department Operations to conduct all test, maintenance and inspection
throughout the Y12 plant has been the focus of several recent
inspections both internal and external. The deficiencies have been
targeted at the balance of plant systems. A review of the current
backlog of maintenance, repair, upgrades, and other work in the EIS
deficiency database was reviewed. A backlog of 27 maintenance job
requests affect WPS 3, 6, 7, 8, 9, or 11. None affect the operability of
WPS 3, 6, 7, 8, 9, and 11.

The corrective actions necessary to remedy the problems identified in
the TM&I program are identified as a part of ESAMS action items I 31820
and I 39665 when funding is authorized to support these issues.

Details of the assessment verifying compliance with this criterion
follow:

1.  (Approach Item 6) Identify the current backlog for the system for
    items such as preventive maintenance, corrective maintenance,
    modifications, surveillances, tests, inspections, and corrective
    actions.

Response: There is a backlog of 27 maintenance job requests affecting
WPS 3, 6, 7, 8, 9, or 11. None affect the operability of WPS 3, 6, 7, 8,
9, and 11. Although the plant-wide backlog of over 600 items has been
identified by internal assessments and commented on by various outside
agencies, VSS have priority in this regard per the prioritization scheme
used by TM&I. Recent reviews and audits conducted internally (March
2000) and externally (DOE HQ Integrated Safety Management Verification,
Phase II, FP 2.3 August 2000 and DNFSB Review of the Y-12 Fire Program
July 2000) identified the large backlog of general maintenance items for
fire systems as a program weakness. The corrective actions necessary to
remedy these problems are identified as a part of ESAMS action items I
31820 and I 39665 when funding is authorized to support these issues.

VSS-1.3 Configuration Management and Maintenance programs effectively
ensure operational availability of the system. (See Review Approach
Items 5, 8, and 9)

Criterion VSS-1.3 was met. The Configuration Management and Maintenance
programs covering WPS 3, 6, 7, 8, 9, and 11 were reviewed. Modifications
and changes are evaluated and controlled in accordance with Y15-187,
*Integrated Safety and Change Control Process*. Modifications important
to safety are reviewed by appropriate technical personnel and presented
to the facility Operational Safety Board (OSB) for concurrence prior to
implementation. The process also requires USQ screening. As part of the
change control process, impacted procedures and drawings are required to
be identified and updated.

Maintenance activities on WPS 3, 6, 7, 8, 9, and 11 are performed in
accordance with formal work packages developed in accordance with
Y10-35-008, *Planners Guide*, Y15-204, *Work Instruction Process and
Development*, and work instructions are provided by system engineers as
part of the work package development. As part of the Y‑12 Complex
Integrated Safety Management Program, reviews by the Operational Safety
Boards, including representatives of the facility to ensure appropriate
requirements are captured. Post maintenance testing of the system for
proper service and closure of the work package prior to
return-to-service authorization is required. Maintenance personnel, work
planners, and supervisors have been trained in the applicable
authorization basis and NFPA requirements. Thus, the Configuration
Management and Maintenance Programs effectively ensure operational fire
suppression systems.

The responsibility for maintenance and operation of these VSS and all
fire systems is assigned to Y-12 Fire Protection Operations as described
in Y79-001INS, *Y-12 Fire Protection Program Manual* and Y14-001INS,
*Conduct of Operations Manual*. Fire Protection line management receive
awareness training for the various AB (VSS) systems for which they of
responsible. The training is in the form of Web training and Required
Reading.

Details of the assessment verifying compliance with this criterion
follow.

1.  (Approach Item 5) Identify formally scheduled activities, in
    addition to those addressed in section 1.1.2 above that are intended
    to help ensure reliable performance of the system. Include
    preventive maintenance, walkdowns, inspections, and assessments as
    appropriate.

Response: All testing, inspection and maintenance of VSS systems are
specified by the National Fire Protection Association consensus codes as
modified by a DOE authorized equivalency, including those items
specified in the Authorization Basis. Additional testing of WPS 3, 6, 7,
8, 9, and 11 beyond the Authorization Basis are specified in Y-FPO-017*,
Wet Pipe Sprinkler System Technical Basis*. Many of these items
(inspections and preventative maintenance items) are written into the
various procedures supporting Wet Pipe Sprinkler test, maintenance and
inspection and are scheduled for conduct in the FireBase scheduler.
Those that are not yet included in procedures are scheduled to be
included in the future. Additional activities that are conducted to
support health of fire systems include periodic building inspections
conducted with operations that assess the fire prevention activities of
the building and monthly trending reviews of suppression parametric
values for untoward trends or out of specification readings.

Maintenance is performed using formalized work packages developed per
Y10-35-008, *Planners Guide*, Y15-204, *Work Instruction Process and
Development*, and work instructions provided by system engineers as part
of the work package development. OSB review, including fire and facility
representatives, is required to ensure all fire watch and restoration
requirements are captured. Post maintenance testing of the system for
proper service and closure of the work package prior to
return-to-service authorization is required as part of the maintenance
package development.

2.  (Approach Item 8) Review the processes used to ensure that work on
    the system and changes to the system are properly controlled (i.e.,
    formally reviewed, approved, implemented, tested, USQ review
    performed if required, documents updated, and work/change accepted).

> Response: Modifications/changes are evaluated and controlled per
> Y15-187, *Integrated Safety and Change Control Process*. Modifications
> important to safety are reviewed by appropriate technical personnel
> and presented to the facility Operational Safety Board for
> concurrence. The process requires evaluation by the USQ process. As
> part of the change control process, impacted procedures and drawings
> are identified and updated. The August 2000 management assessment of
> the FPO configuration control process indicated a maturing process
> with few deficiencies.

3.  (Approach Item 9) Determine whether the procedures identified in
    Items 1.1.2 and 1.3.1 above, and the drawings identified in Item
    1.1.4 above, are controlled under formal document control
    process(es), and indicate whether the process requires that
    documents be updated as necessary to maintain their accuracy.

> Response: Modifications/changes are evaluated and controlled per
> Y15-187, *Integrated Safety and Change Control Process*. Modifications
> important to safety are reviewed by appropriate technical personnel
> and presented to the facility Operational Safety Board (OSB) for
> concurrence. The process requires evaluation by the USQ process. As
> part of the change control process, impacted procedures and drawings
> identified and updated. The August 2000 management assessment of the
> FPO configuration control process indicated a maturing process with
> few deficiencies.
>
> Modifications made to Authorization Basis documents are controlled by
> Y74-802, *Authorization Basis Documents for Nuclear, PSM/RMP, and
> Specified Chemically Hazardous Facilities* and Y74-804, *Preparation
> and Performance of Implementation Plans for Authorization Basis
> Documents*. Changes created by modifications to Fire Hazard Analysis
> are reviewed by the affected facility and the USQD process is executed
> as necessary and then implemented into the Authorization Basis. All of
> these documents are controlled within the Y-12 Document Control
> System. If the change to the Authorization Basis affects roll-down
> procedures, the requirement is captured in the implementation plan and
> procedure are modified per Y15-202, *Technical Procedure Control*
> which requires USQD and OSB interaction.

VSS-1.4 The system is operable and available to fulfill its safety
function when required. (See approach Items 4 and 10)

Criterion VSS-1.4 was met. Surveillance and testing records developed in
accordance with Y52-54-FDO-013, *Wet Pipe Sprinkler System Monthly
Surveillance for Building 9212 Complex* and Y52-54-FDO-045, *Wet Pipe
Sprinkler System Semi-Annual Surveillance for Building 9212*, covering
the last three years were reviewed. This review demonstrated that WPS 3,
6, 7, 8, 9, and 11 had never failed to meet test and surveillance
acceptance criteria or experienced demand failures in operation. The
only periods of system non-availability were identified to be at times
of system maintenance or at times where human error was involved. These
time frames were excluded from this calculation. Therefore, the best
estimate is that these fire suppression systems have always been
operable during this period. Thus, the operating history of WPS 3, 6, 7,
8, 9, and 11 provides evidence that it is operable and available to
fulfill its safety function when required.

Details of the assessment verifying compliance with this criterion
follow.

1.  (Approach Item 4) For each of the past three years: a) identify the
    number of times that the system has failed to meet its test
    acceptance criteria; b) identify the number of times that the system
    has failed in response to facility operating conditions (i.e.,
    failed on demand); and c) estimate the percentage of time that the
    system was not capable of accomplishing its safety function(s) when
    required to be operable.

> Response: Based upon review of surveillance results documented in the
> FireBase scheduler for the last three years the only instance where
> the system failed to meet its acceptance criteria was in early 1998
> where the recorded water pressure for WPS 003 was less then that
> specified in the procedure. It was determined that the procedure was
> in error and the systems continued in operation. Similarly, a review
> of occurrence reports have identified no instances where the system
> failed in response to facility operating conditions. Therefore, the
> system has been available 100 per cent of the time while operating to
> accomplish its safety functions.

2.  (Approach Item 10) Identify any systems and equipment (e.g.,
    electric power, instrument or control air, diesel fuel transfer,
    vacuum, heat tracing, etc.) that directly support the operation of
    the vital safety system being assessed (i.e., where the support
    systems/equipment are essential for the safety system to perform its
    safety functions) that are not included within the defined system
    boundary).

> Response: The following systems, which support the operation of the
> 9212 VSS, were also examined: electric power system, steam supply
> system, and water supply system. As discussed below, this examination
> demonstrated that the short-term loss of electric power, steam supply,
> or off-site water supply would not prevent these systems from
> performing their safety function. This examination also demonstrated
> that 9212 has LCO compensatory measures to ensure that the VSS would
> be able to perform their safety function in the event of a longer-term
> loss of electric power, steam supply, or off-site water supply or that
> operations in the facility would be curtailed.

-   **Electrical:**

> The electrical system provides power to the excess pressure pumps
> located on some WPS and power to the heating systems in valve houses
> throughout the plant. In general the short-term loss of electrical
> power is not limiting to the ability of any of these systems to
> suppress a fire. The purpose of the excess pressure pump is to reduce
> the effect of plant water surges on the fire suppression systems and
> the failure of the pump to operate will at most result in some
> additional fire alarm activity. The function of the excess pressure
> pump is not taken credit for in any Authorization Basis document.
>
> Valve house heat ensures that no portion of the suppression system
> riser assembly freezes during cold weather. Frozen pipes could
> adversely affect the operation of a suppression system either by pipe
> breakage or plugging. Temperatures in valve houses are monitored by
> fire system low temperature devices, which alert the Fire Department
> to a loss of heat in the valve house. Loss of heat to a valve house in
> excess of 2 hours generally results in either the installation of
> portable heat or frequent checks by Fire Department Operations or as
> determined by Fire Protection Engineering. The function of valve house
> heat is not taken credit for in any Authorization Basis document.

-   **Steam:**

> Steam provides heat to many facilities at Y12. The function of steam
> heat is not taken credit for in any Authorization Basis document.
> Facility steam heat ensures that no portion of the suppression system
> piping freezes during cold weather. Frozen pipes will adversely affect
> the operation of a suppression system either by breakage of piping or
> plugging of piping. Loss of heat to a facility in excess of 2 hours
> generally results in frequent checks by either facility operations or
> Fire Department Operations or as determined by Fire Protection
> Engineering.

-   **Water:**

> The source of water to the Y-12 fire suppression systems is the plant
> potable water system. The normal potable water supply to the entire
> Y-12 plant is provided from the Pine Ridge water plant, located North
> of the Y-12 plant. The normal potable water supply to Y-12 is a
> gravity fed system that consists of three main supply lines (two 16\"
> and one 24\" feed lines) that provide seven connections to the Y-12
> plant. They are capable of supplying approximately 7 million gallons
> per day through an underground common grid water supply system for the
> entire Y-12 plant. In addition to the normal potable water supply from
> the Pine Ridge water plant, Y-12 maintains a secondary supply of three
> 2-million gallon water tanks located on Chestnut Ridge that can supply
> water to the Y-12 plant in the event that the primary water supply is
> lost. [Two million gallons of this secondary water supply has been
> dedicated for firefighting activities.]{.underline} A third source of
> water is available to the Y-12 plant from two 1½-million gallon tanks
> just north of the plant. The water from these tanks is not always
> available on a full time basis and is therefore not considered
> available for fire protection purposes. Testing of the underground
> water system is accomplished periodically by Y-12 Plant Utilities.
> This testing includes monthly cycling of electrically operated valves
> and quarterly placement of the emergency water system on line.
>
> Due to the common grid supply, water is capable of reaching all fire
> suppression system via multiple paths. The vulnerability is a supply
> failure (rupture/blockage) at or near the fire system tap off from the
> underground supply. A situation such as this could result in a loss of
> water to the suppression system and since a supply of water is
> credited in the Authorization Basis entry into the LCO action steps is
> necessary. Back up water can be supplied using another source attached
> to the fire department connection.
>
> Recently control of the water filtration plant which supplies water to
> Y-12 was transferred to the city of Oak Ridge. Additionally, several
> isolation valves exist outside the confines of Y-12 which, if shut,
> could potentially affect water supplies/pressures in Y-12. The current
> controls on these valves are administrative only and base on
> interfaces between the city of Oak Ridge and Y-12.

**Conclusion**

This assessment demonstrates that WPS 3, 6, 7, 8, 9, and 11are
operational and that processes are in place to ensure its continued
operational readiness. The fire suppression safety functions and their
corresponding functional requirements are defined, implemented, and
maintained through mature programs and procedures that have resulted in
achieving on-time surveillances. The resultant monitoring through these
surveillances and operating procedures indicate that the vital safety
systems have been operable and available to fulfill their function as
required.

# Additional Information

On February 2, 2001, BWXT Y-12 submitted a Price Anderson Amendments Act
(PAAA) Noncompliance Tracking System (NTS) report identifying
deficiencies in the Y-12 fire protection program that were outside the
scope of the fire protection vital safety systems. To evaluate the
ability to continue operating, a team of Operations, Environment,
Safety, and Health, and Fire Protection representatives met to determine
what additional actions or compensatory measures were needed, and
concluded as follows:

-   There were no immediate actions needed beyond those compensatory
    measures already in effect. The deficiencies in the fire protection
    program do not represent any known imminent danger conditions.

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-   There were no Limiting Conditions for Operations action steps needed
    as a result of the deficiencies identified in the NTS report. Each
    nuclear facility is assessing the deficiencies with respect to the
    impact on their safety authorization basis.

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-   With respect to all Safety Class and Safety Significant fire systems
    (i.e., the fire protection vital safety systems) in the Y-12 Complex
    nuclear facilities, all test, maintenance, and inspection
    requirements for operability, as specified by the applicable
    authorization bases, are being met.

It was determined that no additional compensatory measures were needed
because as fire protection deficiencies have been identified, they have
been evaluated for compensatory measures and compensatory measures have
been implemented where needed. The fire protection program has
overlapping echelons of protection as part of protection-in-depth that
compensate for deficiencies, including a capable, trained, and equipped
emergency response force that is on-site 24 hours per day.

These deficiencies are being addressed as a part of the comprehensive
site-wide action plan for the improvement of Fire Protection at the Y-12
Complex \[Comprehensive Fire Protection Correction Action Plan (ESAMS
S4637/I39665)\]. A project task team is being established to address all
fire protection deficiencies (programmatic, hardware, infrastructure,
project, etc.) at the Y-12 Complex, and this team will develop a
comprehensive corrective action plan.

BWXT Y-12 Assessor:
\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_ \_\_\_\_\_

> Signature Date

BWXT Y-12 Reviewer:
\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_ \_\_\_\_\_

> Signature Date

BWXT Y-12 Reviewer:
\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_ \_\_\_\_\_

> Signature Date

[DOE employee who reviewed this assessment:]{.underline}

\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_
\_\_\_\_\_

Signature Date

Estimated Hours (BWXT Y-12 and DOE) for data gathering, assessment, and
documentation:

[DOE:]{.underline} \_\_\_\_\_\_

[BWXT:]{.underline} FSM [63]{.underline} ; Procedures [1.5]{.underline}
; FCM [3]{.underline} ; FDO [1]{.underline} ; TMI [14]{.underline} ; FPO
[3]{.underline} ;

Eng [116]{.underline} ; Management Review [15 .]{.underline}