Information Notice 1997-48, Inadequate or Inappropriate Interim Fire Protection Compensatory Measures
9.
'5
UN.TED STATES
NUCLEAR REGULATORY COMMISSION
OFFICE OF NUCLEAR REACTOR REGULATION
WASHINGTON, D.C. 20555-0001
July 9, 1997
INADEQUATE OR INAPPROPRIATE INTERIM FIRE
PROTECTION COMPENSATORY MEASURES
All holders of operating licenses or construction permits for nuclear power reactors.
Purpose
The U.S. Nuclear Regulatory Commission (NRC) Is Issuing this Information notice to alert
addressees to potential problems associated with the Implementation of interim compensatory
measures for degraded or Inoperable plant fire protection features or degraded or Inoperable
conditions associated with post-fire safe-shutdown capability. It is expected that recipients
will review the informatioit for applicability to their facilities and consider actions, as
appropriate, to avoid similar problems. However, suggestions contained In this information
notice are not NRC requiremnents; therefore, no specific action or wdtten response is
required.
Description of Circumstances
The NRC foresaw cases in which fire protection features would be inoperable and allowed
licensees, through plant technical specifications (TS) or approved fire protection plans
controlled by license conditions, to implement alternative actions to compensate for the
inoperable condition or component until permanent corrective actions are implemented. In
general, the combination of appropriate compensatory measures and the defense-in-depth
fire protection features provides an adequate level of fire protection until the licensees
complete the corrective actions, For common types of deficiencies (e.g., an Inoperable fire
suppression system), the specific compensatory measures are generally noted in either the
TS or in the NRC-approved fire protection program. For unique plant-specific situations (e.g.,
Inadequate cable separation), the appropriate compensatory measures are determined by the
licensee on a case-by-case basis. (This is discussed further later in the information notice.)
NRC reviews of licensees' corrective actions to address degraded or Inoperable conditions
associated with a plant's abilities to achieve and maintain post-fire safe shutdown have noted
some weaknesses in the interim compensatory measures. For example, some licensees
have relied exclusivoly on the 1-hour roving fire watch as an interim compensatory measure
for deficiencies that affect their abilities to achieve and maintain post-fire safe shutdown and
have not considered or Implemented other appropriate interim compensatory measures, such
as briefing operators on degraded post-fire, safe-shutdown-system conditions; temporary
repair procedures; temporary fire barriers; or detection or suppression systems. In addition,
____
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IN 07.48 July 9, 197o MC kIspectlons of fire protection programs have found weaknesses In kliensees' fle watch
t'Org programs and In the conduct of fire watch dutiee. Specific examples documented In
NRC Inspection reports Include the following:
ODutig a November 1996 Inspection at Waterford Generating Station (Inspection Report
W0-382/95-020, Accession No. 9603260040), NRC Inspectors found that the licensee's
procedures redefined the
Intent
of a continuous fire watch. The licensees' procedure
required a 15-minute roving fire watch, with a margin of 5 minutes, In lieu of a continuous
fir watch. In addition, required fire watches were not performed in areas In which fire
detection equipment was out of service and In areas In which fire barriers were degraded.
This Issue Is currently under review by the NRC for disposition.
During an April 1996 Inspection at Palisades Nuclear Plant (Inspection Report 60-255/
96-004, Accession No. 9805290105). the NRC Inspector noted that the licensee relied on
fire watches as compensatory measures for a number of post-fire, safe-shutdown-design
deficiencies Identified by the licensee pursuant to Appendix R to Part 50 of T ", 10 of the
Code f Federal Regulations (10 CFR Part 50) while long-term corrective actlukns were
being evaluated. The licensee did not alert the operators to these deficient conditions nor
did It provide interim shutdown strategies to operators on how to ouccossfully deal with
potential fire damage to required safe-shutdown components. The potential conse- quences could have been extensive since placing and maintaining the plant in post-fire
hot standby could only have bean achieved by significant operator actions, trouble- shooting, and repair activities to compensate for the post-fire, safe-shutdown-design
deficiencies. The sole use of a fire watch for a safe shutdown function which Is not
adequately protected against fire damage is an Inappropriate application of a
compensatory measure. This problem resulted in a Severity Level III Violation.
- On October 17, 1998, Arkansas Nuclear One had an event involving a fire in a reactor
coolant pump (RCP) and inadequacies associated with the RCP oil collection system.
The licensee's initial compensatory measures placed the lift olK pumps in the "stop"
condition. This action enhanced the fire protection annunciator procedures by giving
additional guidance to the operators when responding to the RCP smoke detector alarm.
However, the licensee did not propose Interim plant operational measures which would
help operators identify and mitigate the consequence of potential oil leakage from the
RCP oil system sites not protected by the RCP oil collection system. This problem
resulted in a Severity Level III Violation.
Discussion]
In accordance with 10 CFR 50.48, "Fire protection," each operating nuclear power plant must
have a fire protection plan that satisfies Criterion 3 of Appendix A to 10 CFR Part 50.
Licensees of plants licensed to operate before January 1, 1979, are required to satisfy the
provisions of Appendix R to 10 CFR Part 50, Section Ill.G, "Fire protection of safe shutdown
I'
.
IN 97-48 July 9, 1997 capability;" Section Ill.J, "Emergency lighting;" and Section 111.0, "Oil collection system for
reactor coolant pump;" and the provisions of Appendix A to the Branch Technical Position of
the Auxiliary Power Conversion Systems Branch (BTP APCSB) 9.5-1, "Guidelines for Fire
Protection for Nuclear Power Plants Docketed Prior to July 1, 1978." Licensees of plants
licensed to operate after January 1, 1979, are required to satisfy the fire protection provisions
of their operating licenses. Generally, these plants have fire protection programs that satisfy
the provisions of NUREG-0800, "Standard Review Plan (SRP)," Section 9.5.1; "Fire
Protection Program," July 1981.
Appendix A to BTP APCSB 9.5-1 specifies that licensees should establish administrative
controls for normal and abnormal conditions or such other anticipated operations as
modifications (e.g., breaking fire stops/penetration seals, Impairment of fire dete,'tion and
suppression systems) and refueling activities. The controls should be reviewed by
appropriate levels of licensee management, and appropriate special actions and procedures, such as fire watches or temporary fire barriers, should be implemented to ensure adequate
fire protection and reactor safety.
On November 7, 1991, the NRC issued Generic Letter 91-18, "Information to Licensees
Regarding Two NRC Inspection Manual Sections on Resolution of Degraded and
Nonconforming Conditions and on Operability" (Accession No. 9111040293). This generic
letter contained two sections, "Resolution of Degraded and Nonconforming Conditions" and
"Operable/Operability: Ensuring the Functional Capability of a System or Component," to be
included in Part 9900, "Technical Guidance," of the NRC Inspection Manual. These additions
are based upon previously issued guidance.
With respect to fire protection and post-fire, safe-shutdown capability, the licensee may
discover a previously unanalyzed condition. Under these conditions, Part 9900, "Technical
Guidance: Resolution of Degraded and Nonconforming Conditions," Section 4.4, "Discovery
of an Existing But Previously Unanalyzed Condition or Accident," notes that the licensee, upon discovering an existing but previously unanalyzed condition that significantly
compromises plant safety, shall report that condition in accordance with 10 CFR 50.72 and
shall place the plant in a safe condition. Once a degraded or nonconforming condition of
specific structures, systems, or components (SSCs) is Identified, an operability determination
should be made as soon as possible, consistent with the safety Importance of the SSC
affected. For SSCs that are outside plant TS, engineering judgment must be used to
determine safety significance.
Part 9900, "Technical Guidance: Resolution of Degraded and Nonconforming Conditions,"
Section 4.8, "Reasonable Assurance of Safety," states that for SSCs which are not expressly
subject to TS and which are determined to be Inoperable, the licensee should assess the
reasonable assurance of safety. If the assessment assures safety, then the facility may
continue to operate while prompt corrective action is taken. As stated in Part 9900, the
following items are to be considered for such assessments: the availability of redundant or
backup equipment, compensatory measures (including limited administrative controls), and
the conservatism and margins.
U
IN 97-48 July 9, 1997 This Information notice requires no specific action or written response. If you have any
questions about the Information In this notice, please contact one of the technical contacts
listed below or the appropriate Office of Nuclear Reactor Regulation (NRR) project manager.
"Mi ee M. solosson, Acting Director
Division of Reactor Program Management
Office of Nuclear Reactor Regulation
Technical contacts:
Darrell Schrum, Rill
(630) 828-9741 E-mail: dls3@nrc.gov
Rogello Mendez, Rill
(630) 829-9745 E-mail: rxm@nrc.gov
Patrick Madden, NRR
301-415-2854 E-mail: pmmMnrc.gov
Attachment: List of Recently Issued NRC Information Notices
Attachment
July 9, 1997 LIST OF RECENTLY ISSUED
NRC INFORMATION NOTICES
Information
Notice No.
Date of
Issuance
Subject
Issued to
97-47
97-46
96-44, Supp. 1
97-45
97-44
97-43
97-42
Inadequate Puncture
Tests for Type B
Packages Under 10 CFR
71.73(c)(3)
Unisolable Crack in
High-Pressure
Injection Piping
Failure of Reactor
Trip Breaker from
Cracking of Phenolic
Material In Secondary
Contact Assembly
Environmental
Qualification
Deficiency for
Cables and Contain- ment Penetration
Pigtails
Failures of Gamma
Metrics Wide-Range
Linear Neutron Flux
Channels
License Condition
Compliance
Management Weaknesses
Resulting In Failure
to Comply with Shipping
Requirements for Special
Nuclear Material
06/27/97
07/09/97
07/02/97
07/02/97
07/01/97
07/01/97
06/27/97 All "users and fabricators"
of type B transportation
packages [as defined In
All holders of OLs or CPs
for nuclear power reactors
All holders of OL permits
for nuclear power reactors
All holders of OLs or CPs
for nuclear power reactors
All holders of OLs or CPs
for test and research
reactors
All holders of OLs or CPs
for nuclear power reactors
All fuel cycle conversion, enrichment, and fabrication
facilities
OL - Operating License
CP - Construction Permit
IN 97-48 July 9, 1997 This information notice requires no specific action or written response. If you have any
questions about the Information In this notice, please contact one of the technical contacts
listed below or the appropriate Office of Nuclear Reactor Regulation (NRR) project manager.
original signed by S.H. Weiss for
Marylee M. Slosson, Acting Director
Division of Reactor Program Management
Office of Nuclear Reactor Regulation
Technical contacts:
Darrell Schrum, RIIl
(630) 828-9741 E-mail: dis3@nrc.gov
Rogelio Mendez, RIIl
(630) 829-9745 E-mail: rxmonrc.gov
Patrick Madden, NRR
301-415-2854 E-mail: pmm@nrc.gov
Attachment: List of Recently Issued NRC Information Notices
Tech Editor has reviewed and concurred on 01/28/97
- - See pervious concurrence
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IN 97- June ,1997 This information notice requires no specific action or written response. If you have any
questions about the Information in this notice, please contact one of the technical contacts
listed below or the appropriate Office of Nuclear Reactor Regulation (NRR) project manager.
Marylee M. Slosson, Acting Director
Division of Reactor Program Management
Office of Nuclear Reactor Regulation
Technical contacts:
Darrell Schrum, Rill
(630) 828-9741 E-mail: dls3@nrc.gov
Rogello Mendez, Rill
(630) 829-9745 E-mail: rxm@nrc.gov
Patrick Madden, NRR
301-415-2854 E-mail: pmm@nrc.gov
Attachment: List of Recently Issued NRC Information Notices
'- See pervious concurrence
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IN 97- June ,1997 This Information notice requires no specific action or written response. If you have any
question about the Information In this notice, please contact one of the technical contacts
listed below or the appropriate Office of Nuclear Reactor Regulation (NRR) project manager.
Marylee M. Slosson, Director
Division of Reactor Program Management
Office of Nuclear Reactor Regulation
Technical contacts:
Darrell Schrum, Rill
(630) 828-9741 E-mail: dls3@nrc.gov
Rogello Mendez, Rill
(630) 829-9745 E-mail: rxmanrc.gov
Patrick Madden, NRR
(301) 415-2854 E-mail: pmm@nrc.gov
Attachment: List of Recently Issued NRC Information Notices
- See pervious concurrence
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IN 97- May
,1997 This Information notice requires no specific action or written response. If you have any
question about the Information In this notice, please contact one of the technical contacts
listed below or the appropriate Office of Nuclear Reactor Regulation (NRR) project manager.
Marylee M. Slosson, Director
Division of Reactor Program Management
Mece of Nuclear Reactor Regulation
Technical contacts: Darrell Schrum, Rill
(630) 828-9741 E-mail: dls3@nrc.gov
Rogelio Mendez, RIII
(630) 829-9745 E-mail: rxm@nrc.gov
Patrick Madden, NRR
(301) 415-2854 E-mail: pmm@nrc.gov
Attachment: List of Recently Issued NRC Information Notices
- See pervious concurrence
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IN 97- April
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question about the information In this notice, please contact one of the technical contacts
listed below or the appropriate Office of Nuclear Reactor Regulation (NRR) project manager.
Thomas T. Martin, Director
Division of Reactor Program Management
Office of Nuclear Reactor Regulation
Technical contacts: Darrell Schrum, Rill
(630) 828-9741 E-mail: dls3@nrc.gov
Rogello Mendez, Rill
(630) 829-9745 E-mail: rxm~nrc.gov
Patrick Madden, NRR
(301) 415-2854 E-mail: pmm@nrc.gov
Attachment: List of Recently Issued NRC Information Notlcas
- - See pervious concurrence
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IN 97- febre
, 1997 This Information notice requires no specific action or wdtten response. If you have any
question about the Information In this notice, please contact one of the technical contacts
listed below or the appropriate Office of Nuclear Reactor Regulation (NRR) project manager.
Thomas T. Martin, Director
Division of Reactor Program Management
Office of Nuclear Reactor Regulation
Technical contacts: Darrell Schrum, Rill
(630) 828-9741 E-mail: dls3@nrc.gov
Rogelio Mendez, Rill
(630) 829-9745 E-mail: rxm@nrc.gov
Patrick Madden, NRR
(301) 415-2854 E-mail: pmm@nrc.gov
Attachment: List of Recently Issued NRC Information Notices
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