Information Notice 1997-48, Inadequate or Inappropriate Interim Fire Protection Compensatory Measures

Inadequate or Inappropriate Interim Fire Protection Compensatory Measures

ML070180068
Person / Time
Site:	Beaver Valley, Millstone, Hatch, Monticello, Calvert Cliffs, Dresden, Davis Besse, Peach Bottom, Browns Ferry, Salem, Oconee, Mcguire, Nine Mile Point, Palisades, Palo Verde, Perry, Indian Point, Fermi, Kewaunee, Catawba, Harris, Wolf Creek, Saint Lucie, Point Beach, Oyster Creek, Watts Bar, Hope Creek, Grand Gulf, Cooper, Sequoyah, Byron, Pilgrim, Arkansas Nuclear, Three Mile Island, Braidwood, Susquehanna, Summer, Prairie Island, Columbia, Seabrook, Brunswick, Surry, Limerick, North Anna, Turkey Point, River Bend, Vermont Yankee, Crystal River, Haddam Neck, Ginna, Diablo Canyon, Callaway, Vogtle, Waterford, Duane Arnold, Farley, Robinson, Clinton, South Texas, San Onofre, Cook, Comanche Peak, Yankee Rowe, Maine Yankee, Quad Cities, Humboldt Bay, La Crosse, Big Rock Point, Rancho Seco, Zion, Midland, Bellefonte, Fort Calhoun, FitzPatrick, McGuire, LaSalle, Fort Saint Vrain, Shoreham, Satsop, Trojan, Atlantic Nuclear Power Plant
Issue date:	07/09/1997
From:	Slosson M Office of Nuclear Reactor Regulation
To:
References
IN-97-048, NUDOCS 9707020308
Download: ML070180068 (11)

9. '5 UN.TED STATES

NUCLEAR REGULATORY COMMISSION

OFFICE OF NUCLEAR REACTOR REGULATION

WASHINGTON, D.C. 20555-0001 July 9, 1997 NRC INFORMATION NOTICE 97-48: 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, A

____  ?DE q=TE 91-011 911o(

(9707020308 dQV

11111111111111111011

IN07.48 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. Ifthe 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. Ifyou 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

IN 97-48 July 9, 1997 LIST OF RECENTLY ISSUED

NRC INFORMATION NOTICES

Information Date of

Notice No. Subject Issuance Issued to

97-47 Inadequate Puncture 06/27/97 All "users and fabricators"

Tests for Type B of type B transportation

Packages Under 10 CFR packages [as defined In

71.73(c)(3) 10 CFR 171.11(60)(8)]

97-46 Unisolable Crack in 07/09/97 All holders of OLs or CPs

High-Pressure for nuclear power reactors

Injection Piping

96-44, Failure of Reactor 07/02/97 All holders of OL permits

Supp. 1 Trip Breaker from for nuclear power reactors

Cracking of Phenolic

Material In Secondary

Contact Assembly

97-45 Environmental 07/02/97 All holders of OLs or CPs

Qualification for nuclear power reactors

Deficiency for

Cables and Contain- ment Penetration

Pigtails

97-44 Failures of Gamma 07/01/97 All holders of OLs or CPs

Metrics Wide-Range for test and research

Linear Neutron Flux reactors

Channels

97-43 License Condition 07/01/97 All holders of OLs or CPs

Compliance for nuclear power reactors

97-42 Management Weaknesses 06/27/97 All fuel cycle conversion, Resulting In Failure enrichment, and fabrication

to Comply with Shipping facilities

Requirements for Special

Nuclear Material

OL - Operating License

CP - Construction Permit

IN 97-48 July 9, 1997 This information notice requires no specific action or written response. Ifyou 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

DOCUMENT NAME: 97-48.1N

To Ituveasm pof Agocufm k otsInbam born T, a Copy W~o

utischment/.ncioswe *I a Copy w/o IIchment/ancdoeure N" a No Copy

I

OFFICE

NAME

TECH CONTS

TGreen*

PMadden*

IC/PECB:DRPM

AChaffee*

AD:DRPM

MSIosson*

DTF 02/03/97 062397 0/ 97

02/04/97 ................. Z "II

UNI!LIAL KLLUXU LUPY

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

LOFC

NAME

DATE

T. Greene*

2/03/97 PECB:DRPM

P. Madden*

2/04/97 SPLB:DSSA

G. Holahan'

5/25/97 DIDSSA

Chaffee C4

"97 C/PECB:DRPM

I'll -

I,

-)(0/0?W

OFC D/DRPM

NAME M. Slosson

DATE 6/ 197

IN97- June ,1997 This Information notice requires no specific action or written response. Ifyou 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

OFC PECB:DRPM SPLB:DSSA DIDSSA C/PECB:DRPM

NAME T. Greene* P. Madden* G. Holahan* A. Chaffee

DATE 2/03/97 2/04/97 5/25/97 61 /97

01ý

OFC D/DRPM

NAME M. Slosson

DATE 8/ /97 (OFFICIAL RECORD COPY)

DOCUMENT NAME: G:\TAGYINFIRE.TAG

IN97- May ,1997 This Information notice requires no specific action or written response. Ifyou 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

OFC PECB:DRPM SPLB:DSSA D/DSSA C/PECB:DRPM

NAM T. Greene* P. Madden* G. Holahan* A. Chaffee

E

DATE 2/03/97 2/04/97 4125197 5/ /97

,n I

OFC D/DRPM

4q 4, //'3V,7 NAM M. Slosson

E

DATE 5/ 197

[OFFICIAL RECORD COPY)

DOCUMENT NAME: G:\TAG\INFIRE.TAG

IN 97- April .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.

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 Notlc as

• - See pervious concurrence

OFC PECB:DRPM SPLB:DSSA DqW ' ' C/PECB:DRPM

NAM T. Greene* P. Madden* lahan A. Chaffee

E -__-

DATE 2/03/97 2104/97 1 7 2/ /97 OFC D/DRPM

NAM -rh~n

E

DATE 2/ /97

[OFFICIAL RECORD COPY)

DOCUMENT NAME: G:ATAG\INFIRETAG

• ,4r*I.' IN97- 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

OFC PECB:DRPM SPLB:DSSA DIDSSA CIPECB:DRPM

NAT. Green@ P en . Holahan', A. Chaffee

E

DATE 12/3/97 F/1197 21 /97 j2/ /97 OFC D/DRPM

NAM T. Martin

E

7 DATE 12/ /97

[OFFICIAL RECORD COPY]

DOCUMENT NAME: G:\TAG\INFIRE.TAG