ML18086A425

NUREG/CR7135 Draft for Public Comments - Resolution of Comments

ML18086A425
Person / Time
Issue date:	03/26/2018
From:	Felix Gonzalez NRC/RES/DRA/FRB
To:
References
NUREG/CR7135
Download: ML18086A425 (27)

Text

BNL PROPOSED RESOLUTION TO NRC PEER REVIWER COMMENTS ON NUREG/CR7135 ( DRAFT INITERNAL REVIEW, REV.2, OCTOBER 2012)

COMMENTS RECEIVED NOVEMBER 13, 2013 A B C D E F G No. Technical Topic Pg. Sect Comment RES Proposed Resolution BNL Concur?

and Comment 1 Type EJB16 ED 2 1.1 Exelon recommends that Item #2 be revised to read Accepted Y as follows: "Quickly detecting and extinguishing fires that may start and limiting their damage."

2 EJB17 ED 3 1.3 There appears to be a formatting issue on this page. Accepted Y Exelon suggests adding a space between the fourth 3 and fifth bullets.

EJB18 ED 7 2.2 Exelon suggests revising the third sentence in the Accepted Y first paragraph to read as follows: "In a July 2009 Memo (Ref. Klein, 2009) the Chief of the Fire Protection Branch of NRR identified Task 7 to consolidate regulatory documentation...." The word "identifies" was replaced with the word "identified."

4 EJB19 REG 7 2.2 This section states: Added at the end of section 2.2 the following statement "The views expressed in this report are Yes HOWEVER - Revised RES suggesterd text to improve clarity of document intent with respect to NRC regulations:

"RES envisioned that this NUREG report would be those of the authors and it is the responsibility of the reader to verify the language of applicable As discussed in Section 4 below, the NRCs licensing basis for fire protection is site specific. This document consolidates used by agency staff (inspectors and reviewers) who regulations and NRR positions. " information from many sources, including regulatory requirements. Since all the fire protection regulations promulgated by the NRC are not applicable to all plants, the information contained within this document should not be characterized evaluates the acceptability of alternative as requirements for any individual plant. It is the responsibility of the reader to verify the language of applicable compensatory measures after impaired conditions regulations and NRR positions .

are identified in fire protection features at nuclear power plants. Therefore, the report's overall objective is to serve as a consolidated source of regulatory and technical information for the NRC staff responsible for assessing the appropriateness of fire-safety compensatory measures at commercial NPPs."

Based on this statement, Exelon has some concern that the NUREG/CR will be used in a regulatory capacity, and licensees could potentially be cited when they do not meet the guidance specified in the NUREG/CR. Since the contents of the report seem to disagree with licensees NRC-approved Fire Protection Programs, Exelon is requesting further clarification concerning this interpretation and whether possible rulemaking was considered.

5 EJB20 GEN 7 2.2 The first paragraph of this section references Reject. Y document "SRM-M080717." This reference does not appear to be a valid document reference number. In Checked and the SECY is on NRC's website. (http://www.nrc.gov/reading-rm/doc-addition, a "July 2009 memo" is also referenced, collections/commission/secys/2008/secy2008-0171/2008-0171scy.pdf). The document does without including a reference citation. not appear if you do a google search but, will appear on the SECY page or if a search is done in NRC webpage.

6 1 of 27 03/26/2018

BNL PROPOSED RESOLUTION TO NRC PEER REVIWER COMMENTS ON NUREG/CR7135 ( DRAFT INITERNAL REVIEW, REV.2, OCTOBER 2012)

COMMENTS RECEIVED NOVEMBER 13, 2013 A B C D E F G No. Technical Topic Pg. Sect Comment RES Proposed Resolution BNL Concur?

and Comment 1 Type EJB21 GEN 8 2.3 Exelon believes that the following statement related The word "guidance" was changed to "information source" to clarify that NUREGs are for Y to the set of critiera and guidance to approve information purposes. As stated thru the Draft NUREG: "in certain unique cases, an appropriate impairments will be difficult to manage in some compensatory measure may not be specified in the FPP. NRC Information Notice (IN) 97-48, unique circumstances, and some consideration Inadequate or Inappropriate Interim Fire Protection Compensatory Measures, (Ref. US NRC, IN should be provided to make allowance for use of an 97-48) notes that when unique cases are identified, appropriate compensatory measures should evaluation (e.g., 86-10, as needed). be determined by the licensee and tailored to the particular circumstances on a case-by-case basis."

"This report provides guidance to assist the NRC staff in determining whether a compensatory measure is appropriate for a given impairment. It discusses the criteria and guidance upon which the approved fire protection program is based, and, to the extent practical, describes unique aspects of compensatory measures, such as the potential for advanced technologies to be implemented as an alternative to 7 the 'traditional" compensatory measures specified in EJB22 REG 3 Section 3 interchanges/mixes regulatory Order of the subsections in Chapter 3 has been changed to reflect this comment. A paragraph AGREE BUT REVISED RES SUGGESTED PARAGRAPH TO IMPROVE CLARITY WITH RESPECT TO requirements with other documents that are was also added at the introductory paragraphs of Chapter 3 to address this concern. The COMMENTERS CONCERN REGARDING TS AND LCOs BEING PART OF CLB: The set of NRC requirements guidance, but not necessarily binding on a licensee. Paragraph added is the following: applicable to a specific plant and a licensee's written commitments for ensuring compliance with and operation within Exelon believes that this may create confusion in The fire protection regulatory requirements were originally contained in the Licensees Plant applicable NRC requirements and the plant-specific design basis (including all modifications and additions to such application of this document. For example, the License Conditions for Operation (LCO) and Technical Specifications (TS). After GL 86-10 and GL commitments over the life of the license) that are docketed and in effect is called the Current Licensing Basis (CLB). As defined in 10 CFR 54.3, the CLB includes the NRC regulations contained in 10 CFR Parts 2, 19, 20, 21, 26, 30, 40, 50, 51, inclusion of an Information Notice, or Regulatory 88-12 was published, Plant Licensees started to move the Fire Protection requirements (other 54, 55, 70, 72, 73, 100 and appendices thereto; orders; license conditions; exemptions; and technical specifications. It Guide 1.189 in this section does not make it than SSD requirements) from the TS to Licensee Controlled Fire Protection Program in the FSAR. also includes the plant-specific design-basis information defined in 10 CFR 50.2 as documented in the most recent final retroactively binding on a licensee. The sections below provide a Historical Overview of Fire Protection Tech Specs, the Fire safety analysis report (FSAR) as required by 10 CFR 50.71 and the licensee's commitments remaining in effect that were Protection Program and guidance documents that are related to Fire Protection and Fire Safety made in docketed licensing correspondence such as licensee responses to NRC bulletins, generic letters, and enforcement Exelon suggests that it might be helpful to separate Compensatory Measures that were published after the Browns Ferry Fire. actions, as well as licensee commitments documented in NRC safety evaluations or licensee event reports.

the regulatory requirements from the guidance documents. This section should also recognize that the site's License Conditions, and TS (or items relocated from TS to a Licensee- Controlled document) are also regulatory requirements that contain FP requirements.

8 EJB23 ED 16 3.1 It appears that the last two sentences of the first Accepted. Corrected structure of the last two sentences. Y paragraph do not use a period in the correct place.

9 EJB24 ED 16 3.1 The second sentence in the last full paragraph reads: Accepted: Sentence revised to (change in red): Y Consequently, the operability requirements of most fire protection features that formally were

"... Consequently, the operability requirements of included in the plants TS currently are governed by licensee controlled procedures referenced in most fire protection features that formally were the NRC-approved fire protection program.

included the plant's TS currently are governed by licensee controlled procedures referenced in the NRC-approved fire protection program ...."

Exelon recommends that the sentence be clarified or reworded since it does not seem to be grammatically correct.

10 2 of 27 03/26/2018

BNL PROPOSED RESOLUTION TO NRC PEER REVIWER COMMENTS ON NUREG/CR7135 ( DRAFT INITERNAL REVIEW, REV.2, OCTOBER 2012)

COMMENTS RECEIVED NOVEMBER 13, 2013 A B C D E F G No. Technical Topic Pg. Sect Comment RES Proposed Resolution BNL Concur?

and Comment 1 Type EJB26 GEN 21 4.1 The following statement is misleading. The text was revised to reflect the references being cited which were Appendix A to the BTP Yes - However, RES suggested worrding for second part of comment was changed to to read : AAlthough APCSB 9.5-1 dated 5/1/76, section 6.b; also is cited in IN97-48 on second paragraph of page 3; FPP features are well designed and highly reliable, the functional performance of certain features may

'Although FPP features are well designed and highly and RG 1.189 Rev 2 page 44 section 2. degrade over the plants lifetime (i.e., become impaired) due to various operational- and environmental-reliable, it is expected that the performance of stressors, such as corrosion and aging.

certain features will degrade over the life of the The sentence was revised to:

plant." Although FPP features are well designed and highly reliable, it is expected that the performance of certain features will degrade over the life of the plant due to anticipated operations such as Exelon believes that this gives the impression that modifications and refueling activities.

Fire Protection SSCs are expected to degrade over the life of the plant and that nothing will be done about it. Fire Protection SSCs receive routine testing and maintenance, to provide a highdegree of reliability. In addition, many Fire Protection SSCs include integral monitoring/supervisory features, to continuously monitor their state of readiness, in-between periodic tests. Therefore, Exelon believes that this is worthy of further clarification.

11 EJB27 ED 21 4.1 There appears to be an extra space between the Accepted. Y words "can not" and an extra period at the end of the following sentence in this paragraph:

"When one element of the FPP can not perform its intended function, the overall level of defense-in-depth is reduced and, therefore, the potential for loss from fire is increased.."

12 EJB31 TS 23 4.2 The following statement provides outdated or Accepted in part: Y inaccurate information: GL 86 10 cites:

"The licensee may make changes to the approved fire protection program without prior approval of the "Under the guidance of GL 86-10 and GL 88-12, Commission only if those changes would not adversely affect the ability to achieve and maintain safe technical specifications of fire protection program shutdown in the event of a fire."

"The licensee may alter specific features of the approved program provided (a) such changes do not elements other than those related to the capability otherwise involve a change in a license condition or technical specification or result in an unreviewed safety for safe shutdown following a fire, were relocated question (see 10 CFR 50.59), and (b) such changes do not result in failure to complete the fire protection from the TS to documents referenced in the program as approved by the Commission. As with other changes implemented under 10 CFR 50.59, the approved FPP (e.g., UFSAR, FHA, and Technical licensee shall maintain, in auditable form, a current record of all such changes, including an analysis of the Requirements Manual)." effects of the change on the fire protection program, and shall make such records available to NRC Inspectors upon request. All changes to the approved program shall be reported annually to the Director of Initially, the NRC did not universally require that safe the Office of Nuclear Reactor Regulation, along with the FSAR revisions required by 10 CFR 50.71(e)."

shutdown equipment be captured in the TS. In "Temporary changes to specific fire protection features which may be necessary to accomplish maintenance or modifications are acceptable provided interim compensatory measures are implemented. At the same addition, the Improved TS programs in some cases time the licensee may request an amendment to delete the technical specifications that will now be have approved the removal of safe shutdown unnecessary."

equipment from TS. The current Standard TS do not GL88 12 cites:

include safe shutdown equipment. The NRC's "Fourth, the standard fire protection license condition in Generic Letter 86-10 must be included in the license.

Improved TS policy decisions have limited the Any other current fire protection license conditions shall be removed. This license condition precludes material that is required to be in TS to that which is changes to the approved Fire Protection Program without prior Commission approval if those changes would of the utmost importance to safety, and items which adversely affect the ability to achieve and maintain safe shutdown conditions in the event of a fire. The meet very specific criteria. Fire Protection and Post- shutdown requirement that applies because of a failure to establish a backup water supply within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 13 Fire Safe Shutdown equipment are not currently after a loss of the fire suppression water system is an example of a Fire Protection Program requirement that ld b b h l d d ld b h d d h h d dl 3 of 27 03/26/2018

BNL PROPOSED RESOLUTION TO NRC PEER REVIWER COMMENTS ON NUREG/CR7135 ( DRAFT INITERNAL REVIEW, REV.2, OCTOBER 2012)

COMMENTS RECEIVED NOVEMBER 13, 2013 A B C D E F G No. Technical Topic Pg. Sect Comment RES Proposed Resolution BNL Concur?

and Comment 1 Type EJB32 LT 23 4.2 The following statement is made as if it is a formal Accepted, the paragraph was modified to: Y NRC staff position. More recently, in a March 30, 2012 letter report (ML120900777 and ML120900789)), for the purposes of a data collection effort, the NRC/RES and EPRI (NEI and Industry) defineds a long "More recently, in a March 30, 2012, letter report term compensatory measure as one that has been in place for longer than 18 months. This (ML120900777), the NRC defines a "long term means that the functionality of impaired fire protection feature(s) is expected to be restored no compensatory measure" as one that has been in later than 18 months from the date of discovery. The NRC staff expects that the correction place for longer than 18 months. This means that the action(s) will be completed, and reliance on the compensatory measure eliminated, at the first functionality of impaired fire protection feature(s) is available opportunity, typically the first refueling outage. Any compensatory measure that is in expected to be restored no later than 18 months place beyond the next refueling outage (typically 18 - 24 months) is considered to be a long-from the date of discovery. Thus, a "long-term term compensatory measure.

14 compensatory measure" is considered as one that is EJB33 LT 23 4.2 Exelon believes that the following statement is Agree. Text has been revised and is citing the reference directly to avoid confusion with Modified RES Suggested text to include the RIS 2005-20 statement about 10CFR50 Appendix B .

inaccurate. paraphrasing. Revised text: Specifically the quoted text from the RIS was changed to read: Licensees should address any degraded or In determining whether the licensee is making reasonable efforts to complete corrective actions nonconforming condition in a time frame commensurate with the safety significance of the condition, As discussed in RIS 2005-20, the NRC staff may promptly, the NRC will consider safety significance, the effects on operability, the significance of even though 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, applies only to activities that approve the use of compensatory measures for the degradation, and what is necessary to implement the corrective action. The NRC may also affect the safety-related functions of SSCs. In determining whether the licensee is making reasonable longer periods if appropriately justified. In making its consider the time needed for design, review, approval, or procurement of the repair or efforts to complete corrective actions promptly, the NRC will consider safety significance, the effects on determination, the NRC staff considers safety modification; the availability of specialized equipment to perform the repair or modification; and operability, the significance of the degradation, and what is necessary to implement the corrective action.

significance, the effects on operability, the whether the plant must be in hot or cold shutdown to implement the actions. If the licensee The NRC may also consider the time needed for design, review, approval, or procurement of the repair or significance of the degradation, and what is does not resolve the degraded or nonconforming condition at the first available opportunity or modification; the availability of specialized equipment to perform the repair or modification; and whether necessary to implement the corrective action. They does not appropriately justify a longer completion schedule, the staff would conclude that the plant must be in hot or cold shutdown to implement the actions. If the licensee does not resolve the also may consider the time needed for designing, corrective action has not been timely and would consider taking enforcement action. Factors degraded or nonconforming condition at the first available opportunity or does not appropriately justify a reviewing, approving, or procuring the repair or that should be considered are (1) the identified cause, including contributing factors and longer completion schedule, the staff would conclude that corrective action has not been timely and would modification; the availability of specialized proposed corrective actions, (2) existing conditions and compensatory measures, including the consider taking enforcement action. Factors that should be considered are (1) the identified cause, equipment for the repair or modification; and, acceptability of the schedule for repair and replacement activities, (3) the basis for why the including contributing factors and proposed corrective actions, (2) existing conditions and compensatory whether the plant must be in hot or cold shutdown repair or replacement activities will not be accomplished prior to restart after a planned outage measures, including the acceptability of the schedule for repair and replacement activities, (3) the basis for to implement the actions. (e.g., additional time is needed to prepare a design/modification package or to procure why the repair or replacement activities will not be accomplished prior to restart after a planned outage necessary components), and (4) review and approval of the schedule by appropriate site (e.g., additional time is needed to prepare a design/modification package or to procure necessary Licensees are not required to consult the "NRC staff" management and/or oversight organizations. components), and (4) review and approval of the schedule by appropriate site management and/or if they have long-term compensatory measures. oversight organizations.

Licensees follow their procedures, which are based on their approved Fire Protection Programs. This paragraph appears to be a paraphrase from RIS 2005-020, Revision 1, (Attachment paragraph 7.2). Exelon believes that due to the paraphrasing, a change in meaning may have been introduced. Therefore, 15 Exelon recommends that the exact language from EJB34 GEN 23 4.2 Typically, a licensee would evaluate if a fire system is Not accepted. As referenced, RIS 2005-20 and its attachment :NRC Inspector Manual, Part 9900: Y operable (functional) as part of the corrective action Technical Guidance: Operability Determinations & Functionality Assessment for Resolution of process, but it is not a formal assessment. Exelon is Degraded or Nonconforming Conditions Adverse to Quality or Safety" (Issue Date: 4/16/08), has requesting further clarification with regard to the specific guidance on the term functionality assessment and guidance on what it conveys.

term "functionality assessment."

16 4 of 27 03/26/2018

BNL PROPOSED RESOLUTION TO NRC PEER REVIWER COMMENTS ON NUREG/CR7135 ( DRAFT INITERNAL REVIEW, REV.2, OCTOBER 2012)

COMMENTS RECEIVED NOVEMBER 13, 2013 A B C D E F G No. Technical Topic Pg. Sect Comment RES Proposed Resolution BNL Concur?

and Comment 1 Type EJB35 GEN 23 4.2 The second paragraph indicates that compensatory Not accepted 96TIA008, first paragraph of section 2.1 has exact same wording. Y measures should be implemented to restore reduction in defense-indepth created by the degraded, inoperable, or non-conforming condition.

Exelon does not believe that a degraded condition necessarily warrants a compensatory measure.

Therefore, Exelon suggests deleting the word "degraded" from the statement.

17 EJB62 FW 33 4.3 This section states: Referenced sentence in section 4.3 was revised to: Revised RES suggested text to read: Most compensatory measures specified in approved FPPs remain virtually "For example, the compensatory measure typically specified for a degraded fire barrier is an unchanged from those put in place over 30 years ago following the Browns Ferry fire. Since these traditional measures "For example, the compensatory measure typically hourly fire watch. If, due to the specific hazards in the area (e.g. after implementation of the principally were established for common types of impairments, such as blocked sprinkler heads or damaged hardware on specified for a degraded fire barrier is an hourly fire compensatory measure, another echelon of defense-in-depth degrades), it is could be a fire door they may not provide an appropriate level of compensation in all cases. For example, issues such as the post-watch. If, due to the specific hazards in the area, it is determined that sole reliance on a fire watch would not be sufficient to assure the ability to fire safe shutdown deficiencies described in IN 97-48 and the multiple spurious operation concerns described in EGM 09-002, were not considered when the traditional compensatory measures were developed. In other instances, a licensee determined that sole reliance on a fire watch would achieve and maintain safe shutdown conditions in the event of fire, a licensee would be may prefer to implement a compensatory measure that differs from the one specified in its approved FPP. For example, not be sufficient to assure the ability to achieve and expected to implement an alternate measure or combination of measures." to minimize radiation exposure, a licensee may prefer to install a video imaging detection system in lieu of an hourly fire maintain safe shutdown conditions in the event of watch. Depending on the plant-specific circumstances, recent advances in fire technology, such as those illustrated in fire, a licensee would be expected to implement an Also, Subsection titled "Timing of Corrective Actions" in section 4.1 "Fire Protection Appendix B, may offer an appropriate resolution for each of the two scenarios described above. RIS 2005-07 gives alternate measure or combination of measures." Impairments" and subsection titled "Untimely Corrective Actions" and "Use of Long Term specific guidance for implementing these types of compensatory measures.

Compensatory Measures in complex fire protection regulatory issues" in section 4.2.2.1 This statement seems to be contrary to the guidance "Examples of Issues and Findings Related to Compensatory Measures" were added to address provided in Directors Decision DD-96-03. It appears comments related to the Directors Decision 96-03 and 07-03.

to convolute the deterministic compliance-based thought process associated with achieving safe shutdown and with the defense-indepth philosophy that recognizes that one echelon may be strengthened to account for imperfections in another echelon.

18 EJB63 35 5 Exelon believes that the following statement from Sentence was revised to: Y - However, RES Recommendation was revised to read as follows to improve clarity and cite appropriate reference:

this section might be incomplete: "The multiple layers of protection that are established by the defense-in-depth concept, offer No single element can be perfect or complete by itself. It is the combination of all three that provide defense-in-depth reasonable assurance that deficiencies in one layer are balanced by strengthening another layer protection of the public health and safety. As stated in NUREG 0050, "Recommendations Related to the Browns Ferry Fire." the goal is to provide a suitable balance between all three elements. Increased strength, redundancy, "The multiple layers of protection that are and will not present an undue risk to public health and safety. "

performance, or reliability of one echelon can compensate in some measure for deficiencies in the others.

established by the defense-in-depth concept, offer reasonable assurance that deficiencies in one layer will not present an undue risk to public health and safety."

BTP CMEB 9.5.1, provides the following additional words, that are fundamental to the concept of compensatory measures:

"No one of these echelons can be perfect or complete by itself. Each echelon should meet certain minimum requirements; however, strengthening any one can compensate in some measure for weaknesses, known or unknown, in the others."

Therefore, Exelon suggests adding the appropriate clarification.

19 5 of 27 03/26/2018

BNL PROPOSED RESOLUTION TO NRC PEER REVIWER COMMENTS ON NUREG/CR7135 ( DRAFT INITERNAL REVIEW, REV.2, OCTOBER 2012)

COMMENTS RECEIVED NOVEMBER 13, 2013 A B C D E F G No. Technical Topic Pg. Sect Comment RES Proposed Resolution BNL Concur?

and Comment 1 Type EJB64 GEN 35 5 Exelon recommends that the NRC consider including The cited section was signficantly revised to improve clarity. However, for reasons discussed in the example, BNL more examples in this section. Scenario 5.1 seems strongly disagrees with the commenter's suggestion that because suppression is availble there would be no cable fault.

too specific and does not address other plausible It should be noted that the purpose of the example scenario is to illustrate how CMs specified in the FPP may not provide a suitable level of compensation under unique circumstances.

scenarios. In addition, Exelon believes that this is a poor example for multiple reasons. Detection is available and there is suppression above the cable trays. Since suppression is available, there would be no cable induced fault. Additionally, the NRC has accepted site practices that determine what the applicable compensatory measure would be. If procedures are followed correctly to determine the appropriate compensatory measure, then there would be no justification as to why it is not adequate.

If Scenario 5.1 is the only one presented, Exelon suggests that it should be run in two fashions. First, as is currently described, with the cracked fire wrap over the MCCs. A second scenario should have the crack in the sprinkler protected area with the other trays and assume the cables are thermo-set, which Exelon considers to be of particular interest since a significant number of plants have this configuration.

This would set up a different risk driver and perhaps result in a different outcome.

20 EJB65 ED 35 5.1 The sixth sentence in this section appears to be Accepted: Added "is" and "to" words to the sentence as follows: Y missing the word "is" between the words "However, consistent with the plants fire protection licensing basis, sprinkler coverage is limited "coverage"a nd "limited." to a portion of the fire area that contains a high concentration of stacked cable trays. "

21 EJB67 ED 57 7 The term "Standards (Code) of Record" refers to (see Definition of Code of Record from the RG 1.189 R2 has been added to the glossary: Y Code of Record), but there appears to be no code of "Code of Record: Code edition in force at the time of the design or at the time the commitment record in the glossary. Exelon is requesting further is made to the NRC for a fire protection feature. (RG 1.189 R2)"

clarification.

22 EJB66 LT 7 Exelon believes the glossary should include definition Even though BNL and RES agrees with the comment to add and define "long term compensatory Y of a "long-term compensatory measure." measure" in the glossary, the glossary has been kept to definitions that have already been defined and accepted by both NRR and Industry thru prior references. It was not the scope of this report to define new terms and words.

23 EJB25 GEN 18 3.2.1 Exelon suggests modifying the spacing between the Accepted. NFPA bullet was modified to: Y first bullet and the end of the first paragraph in this "* Various National Fire Protection Association Codes, such as NFPA 13 - "Standard for the section. In addition, Exelon recommends listing more Installation of Sprinkler Systems", NFPA 14 - Standard for the Installation of Standpipe and Hose applicable NFPA codes to the second bullet. Listing Systems, NFPA 72 - National Fire Alarm and Signaling Code, NFPA 51 - Standard for the only one code does not seem sufficient. At a Design and Installation of Oxygen-Fuel Gas Systems for Welding, Cutting, and Allied Processes, minimum, NFPA codes should be listed for the NFPA 251 - Standard Methods of Test of Fire Endurance of Building Construction and systems described in Section 3.2.1. Materials, and NFPA 600 - Standard on Industrial Fire Brigades. "

24 6 of 27 03/26/2018

BNL PROPOSED RESOLUTION TO NRC PEER REVIWER COMMENTS ON NUREG/CR7135 ( DRAFT INITERNAL REVIEW, REV.2, OCTOBER 2012)

COMMENTS RECEIVED NOVEMBER 13, 2013 A B C D E F G No. Technical Topic Pg. Sect Comment RES Proposed Resolution BNL Concur?

and Comment 1 Type EJB28 ED 21 4.1 Exelon recommends that the first sentence in the Accepted. Y (Footnot footnote be revised as follows since the word "in" e) seems to be missing between the words "identified" and 'NRC" in the current wording):

"As used in this document, phrases such as 'fire protection impairment," 'fire protection element" or

'fire protection feature" are intended to include any component or feature identified [in] NRC approved fire protection program documents (e.g., FSAR, FHA, SSA, TRM etc.) ....."

25 EJB40 ED 24 4.2.1 Exelon suggests rewording the statement "For typical Accepted. Y fire protection system impairments (e.g., inoperable fire detection or suppression systems) the appropriate compensatory measure(s) to be implemented are specified the plant procedures or other documents referenced in the approved FPP...,"

to read as follows in order to correct grammatical issues:

"For typical fire protection system impairments (e.g.,

inoperable fire detection or suppression systems) the appropriate compensatory measure(s) to be implemented are specified in the plant procedures or other documents referenced in the approved FPP."

26 EJB41 FW 25 4.2.1 Concerning the discussion around fire watch training Accept in part. Y and qualifications, Exelon does not consider it In section 4.2.1, the "Fire Watch" subsection, the description says: "Personnel required to necessary to train all fire watches on extinguisher perform fire watch duties for degraded FPP features TYPICALLY receive training in the following use. It appears that multiple types of fire watches are topics:

discussed in one place in the draft ....

NUREG/CR, and the discussion is intermingled to the - Selection and use of portable fire extinguishers point that it is unclear what training and ...."

qualifications apply and are appropriate for the different types of fire watches. Exelon does not The word typically agrees with the commenter that not all fire watches are trained to use fire expect an hourly fire watch patrol to be trained in extinguisher.

the use of a fire extinguisher. The purpose of a fire watch The only instance in the Draft NUREG/CR that implies that all fire watches do need training in fire in the Exelon model is to look for hazards (pre-fire extinguisher use is in the Glossary. This fire watch definition is a direct citation from Reg Guide conditions) and fires and report those conditions or 1.189. Though, throughout the body RG 1.189 it mentions that fire watch receive training in fire fires immediately. They are not intended to fight the extinguisher if applicable. The Draft NUREG/CR glossary definition from RG 1.189 will be revised fire. This approach insures that to say:

the control room is notified first and not after the Individuals responsible for providing additional (e.g., during hot work) or compensatory (e.g., for fire watch made an unsuccessful attempt to system impairments) coverage of plant activities or areas for the purposes of detecting fires or extinguish the fire. NGET covers hazard identification for identifying activities and conditions that present a potential fire hazard. The individuals in the plant, types of fires and how to report a fire. should be trained in identifying conditions or activities that present potential fire hazards, as well Obviously a hot work fire watch is trained as the use of fire extinguishers (if applicable) and the proper fire notification procedures.

in extinguisher use. If it becomes the NRC expectation that all fire watches must be fire extinguisher trained, this will create a training and logistic challenge. Exelon is requesting further clarification concerning the training for fire watches.

27 7 of 27 03/26/2018

BNL PROPOSED RESOLUTION TO NRC PEER REVIWER COMMENTS ON NUREG/CR7135 ( DRAFT INITERNAL REVIEW, REV.2, OCTOBER 2012)

COMMENTS RECEIVED NOVEMBER 13, 2013 A B C D E F G No. Technical Topic Pg. Sect Comment RES Proposed Resolution BNL Concur?

and Comment 1 Type EJB42 FW 26 4.2.1 The second to last paragraph begins by stating "a Accepted. Y roving fire watch patrol ....." Exelon believes that this should state "hourly" fire watch," and not "roving,"

as currently stated. These two words should not be interchangeable. Roving should only refer to certain specific circumstances where an area can only be patrolled once every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> or something similar to this as defined in Table 4-2.

28 EJB43 FW 26 4.2.1 The fifth sentence in the second to last paragraph Accepted Y should be revised to delete the word "to" (as noted) in the following sentence:

"...In some cases, however, the licensee may need to strategically to post several fire watches to assure the tours will be successfully completed in the allotted time-frame ......"

29 EJB44 FW 26 4.2.1 The second sentence in last paragraph appears to be Accepted. Y a fragment and should be revised accordingly. Exelon believes that sentence could be revised as follows (if appropriate):

"... Task Interface Agreement (TIA) (Ref. NRR 96TIA0008,1998) [states that a] procedure that does not require the fire watch to remain within the specified area at all times is not acceptable...."

30 EJB45 ED 27 4.2.1 The fourth line in the third paragraph seems to be Accepted Y missing the word "of" in the following statement:

"...compensatory measure for its removal [of] major shutdown cable....."

31 EJB46 FW 27 4.2.1 Exelon suggests that the sentence: "A Fire watch Accepted. Y enhances the level of protection afforded by degraded fire barriers; it was never intended to serve as a replacement for a fire barrier," be reworded as follows to correct a typographical issue:

"A fire watch enhances the level of protection afforded by degraded fire barriers; it was never intended to serve as a replacement for a fire barrier...."

32 8 of 27 03/26/2018

BNL PROPOSED RESOLUTION TO NRC PEER REVIWER COMMENTS ON NUREG/CR7135 ( DRAFT INITERNAL REVIEW, REV.2, OCTOBER 2012)

COMMENTS RECEIVED NOVEMBER 13, 2013 A B C D E F G No. Technical Topic Pg. Sect Comment RES Proposed Resolution BNL Concur?

and Comment 1 Type EJB47 FW 27 4.2.1 Exelon suggests that the NRC consider deleting the Accepted. SEE EJB62 Revised RES suggested text to eliminate any reference to an NRC Inspection Report .. The revised text now paragraph containing the following information: reads: Although an hourly fire watch is the most common compensatory measures, in certain unique instances cases it Subsection titled "Timing of Corrective Actions" in section 4.1 "Fire Protection Impairments" and may not be sufficiently effective. As discussed in Information Notice 97-48 (Ref. US NRC, IN 97-48) the sole use of a fire "Although a fire watch is the most common, in subsection titled "Untimely Corrective Actions" and "Use of Long Term Compensatory Measures watch for a safe shutdown function which is not adequately protected against fire damage is an inappropriate certain cases it may not provide a sufficiently in complex fire protection regulatory issues" in section 4.2.2.1 "Examples of Issues and Findings application of a compensatory measure. For example, in instances where impaired fire protection features could increase the likelihood for undesired or intolerable operations of equipment (such as those that may be caused by fire-effective type of compensatory measure. For Related to Compensatory Measures" were added to address comments related to the Directors induced circuit failures), the use of CMs not specified in the approved FPP, such as feasible and reliable operator example, NRC inspectors conducting a fire protection Decision 96-03 and 07-03. manual actions, may provide a more effective compensatory measure inspection in the mid- 1990s, (Ref. IR50-458/97-201) identified a licensee that had established an hourly The paragraph referenced in this comment was revised to:

roving fire watch as the only compensatory measure "Although a fire watch is the most common compensatory measures, in certain cases it may not for its removal major sections of electrical raceway provide a sufficiently effective type of compensatory measure. For example, NRC inspectors fire barrier systems (ERFBS) used to separate conducting a fire protection inspection in the mid-1990s, (Ref. IR50-458/97-201) identified a redundant trains of shutdown cables. Because the licensee that had established an hourly roving fire watch as the only compensatory measure for licensee considered the complete removal of the its removal of major sections of electrical raceway fire barrier systems (ERFBS) used to separate ERFBS as being equivalent to a degraded barrier, an redundant trains of shutdown cables. Because the licensee considered the complete removal of hourly fire watch was deemed an acceptable the ERFBS as being equivalent to a degraded barrier, an hourly fire watch was deemed an compensatory measure. However, as noted by the acceptable compensatory measure. However, as noted by the inspection team, the complete inspection team, the complete removal of ERFBS is removal of ERFBS is not the same as a degraded ERFBS that might have cracks or does not meet not the same as a degraded ERFBS that might have its specified fire-resistance rating. Had degraded ERFBS remained in place, the fire damage cracks or does not meet its specified fire-resistance would have likely been delayed long enough to permit the fire brigade to respond and extinguish rating... "(paragraph continues) the fire. 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. In the The paragraph attempts to create a distinction follow-up inspection (Ref. IR 50-458/98-16), even though the Licensee understood the between minor degradation and significant inspection team concern and that additional fire protection enhancement may have been degradation. The NRCapproved Fire Protection warranted, the licensees position was that the fire protection program requirements were not Program contains compensatory measures that were violated. The inspection team concluded that the use of the hourly fire watch patrol was also approved by the NRC, by virtue of them being consistent with the regulatory requirements and no violation occurred."

taken verbatim from the TS. The TS do not make a distinction as to the level of degradation. An SSC is either OPERABLE, or it is not. An inoperable SSC is assumed to provide no benefit regardless of how minor or major the degradation is. The TS do not 33 give partial credit, nor does the Fire Protection TRM.

9 of 27 03/26/2018

BNL PROPOSED RESOLUTION TO NRC PEER REVIWER COMMENTS ON NUREG/CR7135 ( DRAFT INITERNAL REVIEW, REV.2, OCTOBER 2012)

COMMENTS RECEIVED NOVEMBER 13, 2013 A B C D E F G No. Technical Topic Pg. Sect Comment RES Proposed Resolution BNL Concur?

and Comment 1 Type EJB48 FW 27 4.2.1 Discussion of Continuous Fire Watch states: Accepted. Paragraph was revised to: Y "Personnel assigned to a continuous fire watch should have no additional assigned duties that "Personnel assigned to a continuous fire watch would require their leaving the post. In addition, under normal plant conditions, a continuous should have no additional assigned duties that would fire watch should not leave the assigned post unless it is terminated by operations (typically the require their leaving the post. In addition, a shift supervisor) or relieved by his turnover."

continuous fire watch should not leave the assigned post unless it is terminated by operations (typically the shift supervisor); this includes drills and emergencies, unless plant conditions are too hazardous to remain."

This discussion appears to indicate that personnel safety is less important than accomplishing the continuous fire watch. Under normal circumstances, a continuous fire watch would remain in place, unless terminated by a licensed operator, or relieved by his turnover. However, this does not prohibit the fire watch from using common sense to ensure his/her personal safety. Changing radiological conditions, local evacuation alarms/announcements, or other safety issues, may require the individual to temporarily suspend their duties. These cases are unusual, but when they occur, Exelon believes that the fire watch should immediately notify Operations.

Operations should then address the suspension of the fire watch in the appropriate priority, also considering the priorities of whatever plant event required the continuous fire watch to leave his/her post. Therefore, Exelon suggests that the NRC consider clarifying this statement.

34 EJB49 ED 28 4.2.2 There appears to be an extra period after the Accepted. Y sentence that ends with: "qualified fire protection 35 engineer."

EJB50 GEN 28 4.2.2 First paragraph in this section states that the See response to comment EJB35. Y compensatory measure should offset the degradation in defense-in-depth created by the degraded, inoperable, or non-conforming condition.

Exelon does not believe that a degraded condition necessarily warrants a compensatory measure.

Therefore, Exelon suggests deleting the word "degraded" from the statement.

36 EJB51 ED 29 4.2.2.1 There appears to be an extra period after the first Accepted. Y 37 sentence of the first paragraph.

10 of 27 03/26/2018

BNL PROPOSED RESOLUTION TO NRC PEER REVIWER COMMENTS ON NUREG/CR7135 ( DRAFT INITERNAL REVIEW, REV.2, OCTOBER 2012)

COMMENTS RECEIVED NOVEMBER 13, 2013 A B C D E F G No. Technical Topic Pg. Sect Comment RES Proposed Resolution BNL Concur?

and Comment 1 Type EJB52 TS 29 4.2.2.1 The discussion regarding Palisades Inspection Report REVISED SUGGESTED TEXT for 4.2.2.1 sub-section Use of Long term Compensatory Measures During the 50-255/96-004 appears to be contrary to the Subsection titled "Timing of Corrective Actions" in section 4.1 "Fire Protection Impairments" and Resolution of Complex Fire Protection Regulatory IssuesTO READ AS FOLLOWS: The resolution of certain information contained in Directors Decision DD subsection titled "Untimely Corrective Actions" and "Use of Long Term Compensatory Measures fire protection impairments may require compensatory measures to remain in place for an extended period of time. For

03. Licensee TS would specifically allow the situation in complex fire protection regulatory issues" in section 4.2.2.1 "Examples of Issues and Findings example, in the early 1990s the staffs accepted the use of fire watches until comprehensive actions needed to correct discussed in the violation. Related to Compensatory Measures" were added to address comments related to the Directors Thermo Lag 330-1 fire barrier performance deficiencies were completed. As documented in GL 92-08, corrective actions for this issue were extensive, requiring each affected plant to implement resource intensive activities such as base lining Decision 96-03 and 07-03.

all fire barrier configurations, designing test assemblies and developing acceptance criteria for requalifying electrical If the discussion is to be retained, Exelon raceway fire barriers (ERFBs), and implementing any needed design changes and plant modifications. Thus, when recommends that the NRC consider providing determining the acceptability of long-term compensatory measures, the staff needed to consider both the extended clarification regarding the role of the Corrective period of time that would be needed to complete corrective actions and the significance of the Thermo-Lag barrier Action Program (10 CFR 50, Appendix B) to further degradations on plant safety.

explain why additional compensatory measures were warranted. In June 1991, NRR established a Special Review Team to investigate the safety significance and generic applicability of technical issues regarding Thermo-Lag fire barriers. With regard to safety significance, the Special Review Team determined that the degraded barriers will provide some level of fire protection. When considered in conjunction with other fire safety defense-in-depth measures already in place, the Special Review Team judged the relative safety significance of the degraded Thermo-Lag fire barriers to be low (Ref.: IN 92-46) .

As documented in Federal Register Notice All Licensees of Reactors with Installed Thermo-Lag Fire Barrier Material; Issuance of Directors Decision under 10 CFR 2.206, 61FR 70 (April 10, 1996), pages 16005 - 16016, the staff determined that compensatory measures using fire watches were adequate and acceptable for degraded Thermo-Lag fire barrier impairments. Specifically, the Directors Decision states:

The goal of the NRC staffs Thermo-Lag Action Plan is directed towards restoring the functional capability of fire barriers as soon as practicable. There is not a time limit associated with the use of fire watches as a compensatory measure.

Given the margin of safety a fire watch brings to a fire protection program the NRC staff has determined that continuing the use of fire watches while barriers are inoperable is acceptable. However, the NRC believes that notwithstanding interim reliance on compensatory measures, appropriate actions must be taken by licensees to restore operability of Thermo-Lag barriers.

38 EJB53 FW 29 4.2.2.1 Exelon considers the discussion of NRC TIA Accepted in part. Though the96TIA008 is reapeated in most cases it is for different purposes. Y 96TIA0008 to be repetitive and perhaps unnecessary. Mention of 96TIA008 in Chapter 3 discusses available guidance documents, mention in 4.2.1 is Instead of repeating this information again, Exelon for discussing general fire watches, the example in 4.2.2.1 discusses the actual event prior to the believes that it might be more constructive to 96TIA008 more in detail. The following sentences where added to the last part of Subsection provide discussion of the D.C. Cook TS amendment "Improper Definition of a Continuous Fire Watch":

that was approved by the NRC, allowing a continuous fire watch to observe multiple locations "In this case the licensee informed the Region IV inspector that it had based its new criteria for a within the same fire area. For the discussion to be continuous fire watch on a letter from the NRC to the Licensee of Donald C. Cook NPP (Ref. NRC more helpful, it the NRC might consider including a Letter 1986). As stated in the letter, the continuous fire watch definition was revised to:

discussion of the specific limitations that were agreed to. A continuous fire watch requires that a trained individual be in the specified area at all times and that each fire zone within the specified area be patrolled at least once every fifteen minutes with a margin of five minutes.

In the case of 96TIA008, the NRC staff did not agree with the adopted definition because the fire area would not be continuously manned and new definition would have allowed the continuous fire watch to leave the fire area. "

39 EJB54 ED 29 4.2.2.1 There appears to be an extra period after the Accepted Y sentence:"The majority of these reviews have found compensatory measures to be appropriate for the given impairment.."

40 11 of 27 03/26/2018

BNL PROPOSED RESOLUTION TO NRC PEER REVIWER COMMENTS ON NUREG/CR7135 ( DRAFT INITERNAL REVIEW, REV.2, OCTOBER 2012)

COMMENTS RECEIVED NOVEMBER 13, 2013 A B C D E F G No. Technical Topic Pg. Sect Comment RES Proposed Resolution BNL Concur?

and Comment 1 Type EJB55 ED 29 4.2.2.1 There appears to be an extra period after the Accepted Y statement: "sensitivity to implementing immediate corrective actions commensurate with the safety significance of the deficiencies.."

41 EJB56 FW 29 4.2.2.1 Under the section titled Improper Definition of a Not accepted. This is a direct citation to 96TIA008 Section 2.1 paragraph 6. See response to Y Continuous Fire Watch, there is a sentence stating: comment NIE12 and the definition of a Fire Area. It is possible that if a fire area has several "Depending on the size of the fire area and the rooms that might not be easily accessible the fire marshall or responsible dessignee for assigning specific hazards involved, it may be necessary to fire watches should select appropriate quantity of fire watches.

strategically post several continuous fire watches in single fire area to effectively maintain confidence that potential fire conditions will be promptly detected and reported." For some licensees, the site Fire Marshall or designees, selects the number of fire watches needed. If it becomes the NRC's expectation to correlate fire area size with number of fire watches needed, Exelon recommends that the NRC provide additional guidance in this matter.

42 EJB57 FW 30 4.2.2.1 Exelon recommends that the NRC consider deleting Not accepted. The 96TIA008 is an example of a situation where the licensee tried to Y the discussion of a Region IV concern with a plant's redefine/reinterpret the continuous fire watch definition which was not accepted by the NRC.

redefinition of hot work. The topic of hot work fire watches does not appear to be related to the intended purpose of this draft NUREG/CR.

43 12 of 27 03/26/2018

BNL PROPOSED RESOLUTION TO NRC PEER REVIWER COMMENTS ON NUREG/CR7135 ( DRAFT INITERNAL REVIEW, REV.2, OCTOBER 2012)

COMMENTS RECEIVED NOVEMBER 13, 2013 A B C D E F G No. Technical Topic Pg. Sect Comment RES Proposed Resolution BNL Concur?

and Comment 1 Type EJB58 REG 30 4.2.2.1 Exelon believes that the discussion of a Browns Ferry Not Accepted. Y violation (Inspection Report 2003-007) highlights a As discussed in the Example in the Draft NUREG/CR and in more detail in the Inspection Report, distinction that needs to be further clarified in the the licensee did not comply with Defense-in-depth strategy which holds that a weakness in one draft report. When viewed from a purely of the above elements can be offset by enhancing the other elements. As stated, the inspectors deterministic perspective, any change to a concluded that the licensee inappropriately used the fire protection program change process to compensatory measure could be judged by an revise the FPP to permit removing fire suppression systems and/or fire rated barrier assemblies inspector to be a decrease in the effectiveness of the from service without enhancing the other defense-in-depth elements as a compensatory Fire Protection Program, which could pose concerns measure.

on the part of licensees. All compensatory measures (TS, TRM, etc.) are inherently based on a qualitative probabilistic foundation, or some other justification as to how a compensatory measure compensates for the inoperable function. The TS allows a SSC to be inoperable for a specific period of time, or if specific compensating actions are taken, because the risk of that condition is judged to be acceptably low, based on some qualitative or quantitative criteria.

In the Browns Ferry example provided, the inspector found that the risk significance was Green, and that when the overall capability of the Fire Protection Program was considered, the safe shutdown capability remained adequate. This essentially means that the inspector agreed with the licensee that based on the qualitative evaluation of the situation, the safe shutdown capability was not adversely affected; however, the inspector disagreed that the change was permissible under the Fire Protection License Condition based on a purely deterministic thought process.

This disparity seems to highlight the problem with 44 trying to use purely deterministic thinking when 13 of 27 03/26/2018

BNL PROPOSED RESOLUTION TO NRC PEER REVIWER COMMENTS ON NUREG/CR7135 ( DRAFT INITERNAL REVIEW, REV.2, OCTOBER 2012)

COMMENTS RECEIVED NOVEMBER 13, 2013 A B C D E F G No. Technical Topic Pg. Sect Comment RES Proposed Resolution BNL Concur?

and Comment 1 Type EJB60 MSO 32 4.2.2.1 This section includes a statement that: Not accepted, with change. The reports referenced are examples where the NRC found use of Enhanced REVISED RES suggested text regarding Inspection findings to read as follows: A review of NRC Operator Rounds but the reason that they were closed where not related to the use of Enhanced Operator inspection reports may infer that the NRC has generically accepted the use of once-per-shift operator "In a subsequent, June 9, 2010, meeting summary Rounds. In one case there was found no non-compliance and in the other the licensee had taken additional rounds as a suitable compensatory measure for potential MSOs. However, in the absence of other plant-steps. It is unclear if in the second example if there would have been an issue has the licensee not taken the (Ref. NRC Public Meeting Summary, ML101590181), specific mitigating factors, their use is not viewed as providing an acceptable level of compensation for additional steps. The last paragraph was modified to:

the staff stated that sole reliance existing operator MSOs that may be caused by fire. As illustrated in the following two examples, plant-specific mitigating plant rounds that take place once per shift (i.e., every "During a subsequent meeting between the NRC Fire Protection Steering Committee and industry factors can vary widely.

8 or 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> depending on the shift's duration) is stakeholders on August 23, 2010 (Ref. NRC Public Meeting Summary, ML102460061), the staff again not an appropriate compensatory measure ....." discussed the industrys use of enhanced operator rounds as a compensatory measure for MSO issues, and During a Triennial Fire Protection inspection conducted at the Vogtle Electric Generating Plant (VEGP) in reiterated its position that using this approach is considered a noncompliance and licensees should 2010(Ref. IR 2010006), the NRC questioned if potential MSOs identified by the licensee were non-The discussion then continues as follows: implement compensatory measures consistent with the approved fire protection program. NEI staff indicated compliances with its current licensing basis (CLB)and if the compensatory measures implemented (i.e., once they would look into the use of enhanced operator rounds."

per shift operator rounds) constituted sufficient compensation. The licensee countered that the MSO

"...the staff again discussed the industry's use of scenarios did not represent any non-compliances, as consideration of the multiple circuit faults was outside These three paragraphs where added to the last part of this subsection:

enhanced operator rounds as a compensatory of the fire protection licensing/design basis for VEGP. The inspection team referred this licensing basis measure for MSO issues, and reiterated its position "In some instances, it was found that NRC noted use of enhanced operator rounds as compensatory issue to the Office of Nuclear Reactor Regulation for review via Unresolved Item (URI) 05000424; that using this approach is considered a measures for MSOs. In these two examples the NRC closed the items because they found no non-compliance 425/2010006-02, Licensing Basis for Multiple Spurious Operations and Adequacy of Related noncompliance and licensees should implement or the licensee had taken additional steps other than the use of enhanced operator rounds. Compensatory Measures. The NRC staffs review of this URI is documented in NRC Inspection Report compensatory measures consistent with the Vogtle Electric Generating Plant - NRC Triennial Fire Protection Inspection Report Nos. 05000424/2012007 approved fire protection program." In 2010, the Vogtles Electric Generating Plant (VEGP) Triennial Inspection (Ref. IR 2010005) generated the and 05000425/2012007 (ML12237A175), which concludes that compensatory measures are not required Unresolved Item (URI) 2010005-02. The NRC questioned if the identified MSOs were non-compliances and if because the concern identified by the inspection team (potential MSOs) does not constitute a non-the compensatory measure (e.g. operator rounds constituted sufficient compensation. In its inspection NRC It is important to note that statements made by the compliance with the Vogtle design and license basis.

found that VEGP had revised its FPP to allow enhanced operator rounds in place of the hourly fire watch in NRC staff in a meeting do not represent formal NRC fire areas where fire barriers are degraded. This requirement is applicable to licensees list of potential non-staff positions. The citations provided are actually compliances related to MSOs because if the cables where protected by a 3-hour ERFB, a 1-hour ERFB with Similarly, a 2010 inspection at Millstone Power Station Unit 2 and Unit 3 (Ref. NRC IR Millstone Power part of a much longer on-going dialogue between detection and suppression, or a 20 feet separation with detection and suppression, the MSO scenario would Station,- NRC Triennial Fire Protection Inspection Report 05000336/2010008 and 05000423/2010008 )

the industry and the NRC on the topic of alternative be precluded from happening. However the licensee modified its FPP to allow for the use of operator rounds concluded that operator roundsaugmented byadditional monitoring of fire detection system operability compensatory measures for MSOs. Exelon believes in place of the hourly fire watch. This URI was referred to NRR for review which was subsequently closed in provided an adequate level of compensation for potential MSOs.

that taking these two fragments out of context might in the VEGP IR 2012007. NRC found that there was no non-compliance and no compensatory measure was misrepresent the resolution of the topic and suggests required.

that NRC consider further clarification.

In a similar instance, in 2010 Millstone Inspection (Ref. NRC IR 2010008) the NRC reviewed and evaluated the adequacy of the licensees method for determining if redundant trains of safe shutdown equipment are made This topic continues to be discussed at workshops, inoperable or nonfunctional due to single or multiple spurious actuations. The NRC noted that the Licensee and other forums. NEI developed APC 10-11, had enhanced the operator rounds and had additional monitoring of fire detection system operability has "Industry Position Paper on Use of Compensatory been implemented. The team concluded that the licensee had an adequate method for evaluating the 45 Measures for Addressing Multiple Spurious operability and functionality of components subject to spurious operations "

EJB59 GEN 31-32 4.2.2.1 The discussion of enhanced operator rounds makes Accepted. The correct ML# of the second Meeting is ML102460061. Y reference to two different meeting summaries, yet provides the same ADAMS number ML101590181 for both meeting summaries. Exelon is requesting that the NRC provide appropriate reference citations to both meeting summaries.

46 14 of 27 03/26/2018

BNL PROPOSED RESOLUTION TO NRC PEER REVIWER COMMENTS ON NUREG/CR7135 ( DRAFT INITERNAL REVIEW, REV.2, OCTOBER 2012)

COMMENTS RECEIVED NOVEMBER 13, 2013 A B C D E F G No. Technical Topic Pg. Sect Comment RES Proposed Resolution BNL Concur?

and Comment 1 Type EJB61 32-33 4.2.3 This section states: Accepted. The statement was revised to: Y "In certain instances, a licensee may prefer to implement a method of compensation different "In certain instances, an approach different from the from that specified in its approved FPP. "

one specified in the approved FPP may be needed to provide an effective method of compensation."

This statement seems to be in conflict with the accepted understanding of TS and TRM compensatory measures, RIS 2005-07, and Directors Decision DD-96-03. RIS 2005-07 clearly indicates that alternative compensatory measures are an option a licensee may choose to use, if they prefer. The application of alternative compensatory measures is not a requirement.

Licensees that have chosen to implement RIS 2005-07 have typically done so by immediately implementing the existing compensatory measures that are prescribed by their TRM procedures. This is considered a conservative action, and is typically the only action that is needed. If at some later time, it becomes desirable to do so, the licensee may perform a formal evaluation to justify an alternative compensatory measure, and put that measure in place.

Therefore, Exelon recommends that the NRC consider further clarification concerning this discussion.

47 EJB14 LT iii, xii, Abstract, The following statement is made on page iii of the Accepted. The part of the paragraph has been modified to: Y and Executiv NUREG/CR: More recently, in a March 30, 2012 letter report (ML120900777 and ML120900789), for the 23 e purposes of a data collection effort, the NRC/RES and EPRI (NEI and Industry) defineds a long Summar "Thus, a compensatory measure that is in place term compensatory measure as one that has been in place for longer than 18 months. This y, and Section beyond the next refueling outage (typically 18 - 24 means that the functionality of impaired fire protection feature(s) is expected to be restored no 4.2 months) is considered to be a 'long-term later than 18 months from the date of discovery. The NRC staff expects that the correction compensatory measure."' On page xii the draft action(s) will be completed, and reliance on the compensatory measure eliminated, at the first NUREG/CR states: "NRC defines a 'long term available opportunity, typically the first refueling outage. Any compensatory measure that is in compensatory measure' as one that has been in place beyond the next refueling outage (typically 18 - 24 months) is considered to be a long-place for longer than 18 months. This means that the term compensatory measure.

functionality of impaired fire protection feature(s) is expected to be restored no later than 18 months from the date of discovery."

A similar definition is also found on page 23. Exelon believes that these definitions provided on pages iii, xii, and 23 contain contradicting information related to a long-term compensatory measure. Therefore, Exelon recommends revising or clarifying the definitions to be consistent.

48 15 of 27 03/26/2018

BNL PROPOSED RESOLUTION TO NRC PEER REVIWER COMMENTS ON NUREG/CR7135 ( DRAFT INITERNAL REVIEW, REV.2, OCTOBER 2012)

COMMENTS RECEIVED NOVEMBER 13, 2013 A B C D E F G No. Technical Topic Pg. Sect Comment RES Proposed Resolution BNL Concur?

and Comment 1 Type EJB68 FW B-6 B.1.3 This section addresses Video Image Detection (VID) Accepted. The paragraph below was added to section B.1.3 as an example that the NRC has Y - However, Recommended text was relocated from Appendix B to Section 4.2.3 (Alternate Comensatory Measures).

and its coverage in NFPA-72. The benefits and found on a Licensee that uses the system to keep radiation doses low. Still,It is responsibility for limitations do not cover any possibility of using VID the Licensee to evaluate their non-conforming conditions and assess the need for using alternate technology to supplement roving fire watches in compensatory measures.

existing plants. Exelon is requesting further clarification regarding the use of this technology as a Paragraph added:

supplement to roving fire watches and whether "In the NRC-RES review of alternate compensatory measures, the RES staff found examples of a there is any potential benefit. Licensees that uses cameras and detection system to keep radiation doses low.

• In one example cameras where installed in high radiation areas with a TV monitor in a lower radiation area where a fire watch could verify for fires.

• In similar instances, a system was designed to detect fires and send an alarm signal to the Control Room thru the phone lines. In this last example an fire watch would verify that the phone line was functioning."

49 EJB69 ALT B-12 B.2.1 This section discusses Solid Propellant Gas Accepted. Both were added on potential limitations as added below: Y Generators. Exelon contacted one manufacturer for

• Mounting within and enclosures could increase costs the Stat X system and found out that one limitation is

• Canisters would need to be placed close to the source which could be challenging that the canisters have to be placed close enough to the source so that they actuate. Another problem is that tight enclosures have to be built, which could result in increased costs.

50 EJB70 ALT B-12 B.2.1.1 This section discusses Condensed Aerosol Accept with no change. It is not expected that every system will work in all situations and non- Y Generators, and as stated, are only effective in conforming conditions. It is the responsibility of the Licensee to evaluate their non-conforming enclosed spaces. Unfortunately, these closed spaces conditions and evaluate and assess the system (or combination of systems) that would work best do not already exist in most existing nuclear in their situation.

applications and the costs of building enclosures do not seem necessarily justified over traditional suppression methods.

51 EJB71 ALT B-14 B.2.1.2 This section discusses Nitrogen Gas Generators. A Accepted. Added to possible limitations as added below: Y limitation is that the use of inert N2 gas would likely

• Could require oxygen monitoring on installed enclosures to ensure habitable conditions call for monitoring the building or enclosure every time personnel enter to ensure that oxygen concentrations are within habitable limits. Further, additional cost would be incurred to build enclosures to contain the nitrogen at pressure for most applications at existing plants.

52 EJB72 ALT B-16 B.2.3 Transportable systems consist of a dry chemical Accepted. Added a sentence on the last paragraphs as below: Y extinguisher with a small pressurized hose. They are "Depending on the situation multiple systems might need to be acquired to provide adequate only meant to put out the fire on one or several coverage and monitoring to make sure it has no actuated and that the system remains in the small components when the hose melts. There might required place."

be a need to purchase multiple systems to provide adequate coverage, which seems to be a drawback.

53 EJB73 ALT B-16 B.2.3 The Pre-packaged Portable Water Mist Systems need Accepted. Last three sentences were revised to: Y heat sensors and control panels that would likely "The skid is designed so it can be easily transported with a fork lift (which is a limitation on NPPs increase the cost. One drawback is that these enclosure accessibility and available space). According to one manufacturer, this system has systems have limitations on the enclosure sizes successfully demonstrated fire extinguishment in Factory Mutual fire tests for machinery spaces although they can be placed on larger enclosures. up to 9,175 ft3 (260 m3). Some system could need sensors or a control panel to actuate."

54 EJB15 ED xii Executiv There appears to be a typographical error in the first Not accepted. The sentence seems to be correct. Y e sentence in the last paragraph. The word 'be" should "This report consolidates a number of NRC communications and technical documents related to Summar be inserted after the word "to." the use of fire protection compensatory measures at commercial NPPs. "

55 y 16 of 27 03/26/2018

BNL PROPOSED RESOLUTION TO NRC PEER REVIWER COMMENTS ON NUREG/CR7135 ( DRAFT INITERNAL REVIEW, REV.2, OCTOBER 2012)

COMMENTS RECEIVED NOVEMBER 13, 2013 A B C D E F G No. Technical Topic Pg. Sect Comment RES Proposed Resolution BNL Concur?

and Comment 1 Type EJB1 REG General Exelon is concerned that the draft NUREG/CR Accepted in part with no change. The document objective is to discuss all historical NRC Y appears to reinterpret previous NRC communications related to Compensatory Measures and provide a discussion on available new communications, and seems to treat informal NRC technologies that could potentially be used as alternative Compensatory Measures. Currently communications as if they should be binding on NRC has very little information on Alternative Compensatory Measures and the few examples licensees. A licensee might not be able to make that we have have already been discussed in the Draft NRUEG/CR. In part it was the purpose of effective use of this document as guidance in helping this comment period, for industry to provide more examples of previously used alternative to develop a change to its compensatory measures. compensatory measures that NRC-RES would not be aware of. The comments received provided Exelon believes that it would be beneficial if the no new specific examples of alternative compensatory measures.

NUREG/CR included more helpful information concerning alternate compensatory measures, or making permanent changes to compensatory measures.

56 EJB10 ALT General The main body of the draft NUREG/CR speaks Accept with no change. These new technologies are available technologies that could be in Y exclusively to compensatory measures. However, theory used by a Licensee. In some cases, for example, cctv that could already have been Appendix B discusses advanced technologies; very installed for security purposes could also be paired with a detection software as a compensatory few of which have anything to do with compensatory measure, transportable suppresion system could be used in conjunction with Fire Watches, etc.

measures. The advanced detection technologies discussed are installed systems and provide little benefit to the compensatory actions subject of the NUREG/CR.

57 EJB11 ALT General Exelon recommends that where CO2 and Halon-1 Accepted. Y 301 are listed, clean agents should be added to the 58 list.

EJB12 GEN General Exelon recommends that the NUREG/CR should cite Accepted, No change? Performing a search on the EPRI Fire Event Database resulted in 198 fires Y examples of where compensatory measures that were there was a fire watches (continuous or roving) detecting the fire. All of this fires were have been successful or where the lack of extinguished either thru the fire brigade, manual suppression, manually actuated suppression appropriate compensatory measures have resulted system or other means. The database currently does not list compensatory measures that were in a fire with more damage. If there are no examples, in place in the event of a fire. They list the fire and who was the mechanism to suppress and that might be an important piece of information as extinguish the fire. The purpose in part of the comments was for industry to provide examples well. of alternate compensatory measures that they have successfully used that where not mentioned in the draft NUREG/CR.

59 EJB13 FW General Exelon believes that it would be beneficial to know Agree with this statement, but this is out of the scope of this NUREG/CR. Perhaps this would be Y the number of fires within the industry that have more in line with the Fire Protection Database efforts.

been extinguished by a suppression system or at least caused a suppression system to actuate. As an industry, licensees put in continuous fire watches when suppression systems are inoperable, but the number of times the systems have actuated might be helpful information.

60 17 of 27 03/26/2018

BNL PROPOSED RESOLUTION TO NRC PEER REVIWER COMMENTS ON NUREG/CR7135 ( DRAFT INITERNAL REVIEW, REV.2, OCTOBER 2012)

COMMENTS RECEIVED NOVEMBER 13, 2013 A B C D E F G No. Technical Topic Pg. Sect Comment RES Proposed Resolution BNL Concur?

and Comment 1 Type EJB2 LT General In several places, the draft NUREG/CR document Subsection titled "Timing of Corrective Actions" in section 4.1 "Fire Protection Impairments" and Y asserts that the NRC does not accept long-term subsection titled "Untimely Corrective Actions" and "Use of Long Term Compensatory Measures compensatory measures. References are cited that in complex fire protection regulatory issues" in section 4.2.2.1 "Examples of Issues and Findings appear to be internal NRC documents, or NRC staff Related to Compensatory Measures" were added to address comments related to the Directors positions that Exelon believes might not necessarily Decision 96-03 and 07-03.

be binding on licensees.

The NRC has previously addressed the issue of long-term compensatory measures in Director's Decisions DD-96-03 (all licensees with thermo-lag) and DD 03 (ML071500403). These Director's Decisions make it clear that there is no upper time limit for licensees to implement compensatory measures, and that compensatory measures are allowed by the licensee's operating license and approved fire protection program. If the NRC intends to administratively curtail the allowance for compensatory measures as the draft NUREG/CR seems to suggest, then Exelon believes that the NRC might be inadvertently modifying the licensee's approved fire protection program. As a result, any changes might need to be processed via a formal regulatory change process (not via the NUREG/CR guidance). This may result in a potential backf it consideration.

61 18 of 27 03/26/2018

BNL PROPOSED RESOLUTION TO NRC PEER REVIWER COMMENTS ON NUREG/CR7135 ( DRAFT INITERNAL REVIEW, REV.2, OCTOBER 2012)

COMMENTS RECEIVED NOVEMBER 13, 2013 A B C D E F G No. Technical Topic Pg. Sect Comment RES Proposed Resolution BNL Concur?

and Comment 1 Type EJB3 TS General The draft NUREG/CR does not seem to include any As discussed in Section 3.1 of the report, one of the first actions taken by the Commission in response to the Browns discussion or history of the NRC's technical basis for Ferry fire was to impose TSs for fire protection systems. During the 1976-1977 timeframe, each operating plant was the specific compensatory measures that were provided a sample of recommended standard TS for fire protection and was requested to compare TS for existing fire protection systems against that sample; and provide proposed fire protection TS for staff review. The incorporation fire contained in the original Fire Protection Technical protection systems including impairments and their associated compensatory measures into the TS, was deemed Specifications (TS). necessary to assure that prompt compensatory measures would be taken,and appropriate temporary protection features would be provided.

As stated in NUREG-0298, "Fire Protection Action Plan,"the NRC requested each site perform a comparison to Branch Technical Position (BTP)

APCSB 9.5-1, via letter dated September 30, 1976. In that letter, the NRC also requested sites propose "Technical Specifications for the fire protection systems of your facilities."

This was followed by an NRC letter, dated December 3, 1976, that transmitted sample Fire Protection TS.

Licensees were requested to populate the plant-specific listings of equipment and systems; however, the surveillance requirements and compensatory measures were dictated by the NRC staff, but no specific technical basis was provided in the letter.

The letter indicated the following:

"The essential part of this guidance is to indicate the scope of material to be included in the Technical Specifications for your facilities in the areas of equipment and administrative requirements, and the actions that we [NRC] would find appropriate if a limiting condition for operation could not be met."

Exelon believes that since there seems to be a lack of any written basis for the original NRC model Fire 62 Protection TS issued on December 3, 1976, it would EJB4 GEN General The draft NUREG/CR appears to contain significant Accepted. The NUREG/CR has been revised keeping this in mind avoiding repetition and when Y repetition between sections. In several cases, the repetition occurs the same meaning/text is carried over.

same material is discussed multiple times, in slightly re-worded fashion. Exelon believes that this could introduce subtle changes in meaning. Therefore, Exelon recommends that repetition be avoided if at all possible, and instead, present the information once in a complete and concise manner. This might help to avoid any confusion and misinterpretation.

63 EJB5 TS General There are numerous examples in existing plants' TS Accepted. No Change? Y where alternative monitoring arrangements can be credited to meet a Limiting Condition for Operation (LCO) (e.g., grab samples, read local gauge, etc.).

Where these actions are allowed, no time limit or mode restraint is imposed by the TS. This is typically discussed in the limiting condition for operation and surveillance requirement applicability sections of each site's TS.

64 19 of 27 03/26/2018

BNL PROPOSED RESOLUTION TO NRC PEER REVIWER COMMENTS ON NUREG/CR7135 ( DRAFT INITERNAL REVIEW, REV.2, OCTOBER 2012)

COMMENTS RECEIVED NOVEMBER 13, 2013 A B C D E F G No. Technical Topic Pg. Sect Comment RES Proposed Resolution BNL Concur?

and Comment 1 Type EJB7 FW General As discussed in this draft NUREG/CR, the definition Not Accepted. Table 4-2 definition of fire watch has been revised to: "A continuous fire watch Y of a continuous fire watch is an uninterrupted fire is an individual the that serves as an uninterrupted fire watch in a single fire area (see section watch that is posted in a single fire area. Exelon below on Fire watch for more details). If all parts of the single fire area are not in the line of sight believes that it would be beneficial to explain or from a fixed watch station (e.g., line-of-sight vision is obstructed by equipment), the fire watch is define the term "uninterrupted." to maintain watch over the entire area by patrolling the assigned fire area. "

See response to comment NEI12 and the definition of a Fire Area.

65 EJB8 FW General The draft NUREG/CR describes two different types of Accepted with no change. Section 4.2.1 , subsection on Fire Watches differentiates what Y fire watches; a hot work fire watch and a fire watch differentiate hot work fire watches vs other types of fire watches.

implemented due to inoperable/degraded fire protection Structure, System, or Component (SSC).

However, as the document progresses, Exelon believes that the distinction and difference between the two seem to blur, particularly with respect to training. A fire watch implemented for inoperable/degraded SSC has no need to differentiate between the different classifications of fires and the types of extinguishing agents since these fire watches are not typically authorized to engage in manual suppression. Instead, these individuals are briefed on what the fire watch is, what are the affected areas, what to look/smell for, how to document their fire watch, and what to do/who to call if a fire or pre-fire conditions are discovered. This briefing does not meet the definition of training. Hot work fire watches, however, do receive in-class and hands on training in all of the items previously mentioned, as well as fire classifications and types of extinguishing agents since these could change based on the job. These individuals are required to engage in manual suppression sotraining is appropriate. Exelon believes that the NRC should further clarify the distinction between the two types of fire watches in order to avoid any potential confusion and misunderstanding.

66 EJB9 MSO General The draft NUREG/CR discusses Multiple Spurious Accepted in part: Section 4.2.2, sub section titled "Use of Operator Rounds to Compensate for Y Operation (MSO) as if it is part of the licensing basis, Potential Circuit Vulnerabilities" describes the history of the MSO issues. Other than this MSO rather than a voluntary initiative. Exelon believes are mentioned in section B.1.1. See comments and changes on comment EJB3.

that this could be misleading to Resident Inspectors unfamiliar with the MSO project who will look to enforce the "requirements" of MSO. Exelon suggests that this be clarified in the draft NUREG/CR.

67 EJB29 GEN 21-22 Table 4- The table states that degraded conditions are Accepted. RG 1.189 defines an impairment as "The degradation of a fire protection system or Y 1 considered impairments. Exelon does not believe feature that adversely affects the ability of the system or feature to perform its intended that this is true. Many degraded conditions are not function." (also see Glossary in NUREG/CR-7135). RES would need an actual example like considered to be impaired and no compensatory comment EJB30.

measures are assigned. Therefore, Exelon is requesting further clarification and suggests that the table be revised to better portray actual plant conditions.

68 20 of 27 03/26/2018

BNL PROPOSED RESOLUTION TO NRC PEER REVIWER COMMENTS ON NUREG/CR7135 ( DRAFT INITERNAL REVIEW, REV.2, OCTOBER 2012)

COMMENTS RECEIVED NOVEMBER 13, 2013 A B C D E F G No. Technical Topic Pg. Sect Comment RES Proposed Resolution BNL Concur?

and Comment 1 Type EJB30 GEN 21-22 Table 4- The table states that False or Spurious Alarms are Accepted. Revised to: "False / spurious alarms in cases where the cause of the spurious alarm Y 1 considered impairments to the system. Exelon this impedes the ability to detect an actual fire."

does not believe that is necessarily an impairment to the function of the system if the alarm does not impede the ability of an actual alarm to come in.

69 EJB36 FW 24 Table 4- The first item in Table 4-2 states: "...a continuous fire Accepted. Y 2 watch is an individual the serves...." Exelon believes that the statement should read as follows:

"..a continuous fire watch is an individual that serves..."

70 EJB37 FW 24 Table 4- The second item in Table 4-2 provides a definition of Accepted. The following paragraph(s) were added to the discussion of Example "Improper Y - However, tsuggested revision to Improper Definition of a Continuous Fire Watch (Section 4.2.2.1 ) to read as follows:

2 hourly fire watch which states: Definition of a Continuous Fire Watch" on section 4.2.2.1: An inspection conducted by NRC Region IV in 1995, found a licensee had revised the firewatch procedure to allow a single continuous fire-watch to patrol multiple fire-areas. The inspectors also noted that a previous version of the procedure specified that a continuous fire watch was restricted to a single fire-area. The licensee stated that it had based its new

'An individual assigned to observe posted area(s) 24 "In this case the licensee informed the Region IV inspector that it had based its new criteria for a criteria for a continuous fire watch on an NRC letter to another licensee, and informed the inspector that its revised times in 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, at 60 minute intervals. A roving continuous fire watch on a letter from the NRC to the Licensee of Donald C. Cook NPP (Ref. NRC procedure would not decrease the effectiveness of its own fire protection program The inspector questioned the onceper- shift fire watch patrol assigned to tour Letter 1986). In the case in point, the NRC staff did not agree with the adopted definition adequacy of the licensee's interpretation and concluded that additional NRC review was required. Subsequently, NRC specific fire areas once every eight hours has been because the fire area would not be continuously manned. " Region IV asked NRRs staff to review the adequacy of the licensees revised criteria.

approved by the staff for certain specific circumstances such as impairments located inside Continuous Fire Watch description in Table 4-2 was changed to:

containment." "A continuous fire watch is an individual the that serves as an uninterrupted fire watch in a single fire area (see section below on Fire watch for more details and example in section 4.2.2.1 on A 25% grace on hourly fire watches (15 minutes) is Improper Definition of a Continuous Fire Watch). If all parts of the single fire area are not in allowed via TS. Per TS, the repetitive use of grace is the line of sight from a fixed watch station (e.g., line-of-sight vision is obstructed by equipment),

not permitted in order to simply perform fewer the fire watch is to maintain watch over the entire area by patrolling the assigned fire area. "

inspections.

Roving Fire Watch description in Table 4-2 was changed to:

Exelon believes that this issue should be addressed "An hourly (roving) fire watch (e.g. hourly fire watch) is an individual assigned to observe posted and clarified in the report. It has been reviewed and area(s) 24 times in 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, at 60 minute intervals. A roving once-per-shift fire watch patrol found to be acceptable via TS to allow a 25% grace assigned to tour specific fire areas once every eight hours has been approved by the staff for on hourly fire watches. certain specific circumstances such as impairments located inside containment. The frequency of the hourly fire watch patrols is defined as intervals of sixty minutes with a margin of fifteen minutes which is consistent with other Technical Specification surveillance frequencies which allow margins of 25% (Ref. NRC Letter 1986). The repetitive use of 15 minute margin or 25%

grace would not be permitted in order to perform fewer patrols.

A roving once-per-shift fire watch patrol assigned to tour specific fire areas once every eight hours has been approved by the staff for certain specific circumstances such as impairments located inside containment. "

71 EJB38 ED 24 Table 4- Item 5 in Table 4-2 appears to contain a Accepted. Y 2 typographical issue. The definition of temporary repairs seems to contain an erroneous "i" at the end of the sentence, which probably should be deleted.

72 21 of 27 03/26/2018

BNL PROPOSED RESOLUTION TO NRC PEER REVIWER COMMENTS ON NUREG/CR7135 ( DRAFT INITERNAL REVIEW, REV.2, OCTOBER 2012)

COMMENTS RECEIVED NOVEMBER 13, 2013 A B C D E F G No. Technical Topic Pg. Sect Comment RES Proposed Resolution BNL Concur?

and Comment 1 Type EJB39 ED 24 Table 4- Exelon suggests rewording the statement concerning Accepted. Y 2 "Backup Suppression" to read as follows:

'A backup means of suppression that is provided to compensate for an impaired fire suppression feature.

Examples include backup pumping capability, Supplemental water source(s), or additional lengths of fire hose."

73 EJB6 LT Sub Section "Timing of Corrective Actions" was added to section 4.1 "Fire Protection Y In several places, the document asserts that the NRC Impairments". Also Example on "Untimely Corrective Actions" was added to section 4.2.2.1 does not accept long-term compensatory measures. "Examples of Issues and Findings related to Compensatory Measures" in relation to the Director's References are cited that appear to be internal NRC Decisions comments.

documents, or other communications that are not formal NRC staff positions, and licensees might consider these as non-binding. As evidenced by licensee TS, the NRC has clearly given the allowance for long-term compensatory measures, in very specific circumstances.

74 NEI2 REG N/A 2.2 In particular, it should be noted that Section 2.2 Added at the end of section 2.2 the following statement "The views expressed in this report are Y states that "The report's overall objective is to serve those of the authors and it is the responsibility of the reader to verify the language of applicable as a consolidated source of regulatory and technical regulations and NRR positions. "

information for the NRC staff responsible for assessing the appropriateness of fire-safety compensatory measures at commercial NPPs." This appears to indicate that this report will be used in a regulatory capacity, and licensees cited when they do not meet the report's positions. As noted above, this is not appropriate for a NUREG document, and such language should be removed from the draft document.

75 NEI3 805 8 2.3 It is noted that NFPA 805 is discussed for historical Agree with this statement, but this statement was put as a request by NRR because NFPA 805 Y purposes only and discussions on compensatory still has a Frequentley Asked Question Program that has not been finalized. The statement was measures do not apply to NFPA 805 unless stated revised to:

otherwise. However, significant portions of the draft "Due to the ongoing NRR NFPA 805 isFrequently Asked Question Program, the NFPA 805 is NUREG are in no way contradictory to the term discussed for historical purposes only. Discussions on compensatory measures do not apply to "compensatory actions" as identified in section 3, NFPA 805 unless stated otherwise."

item 12.

76 22 of 27 03/26/2018

BNL PROPOSED RESOLUTION TO NRC PEER REVIWER COMMENTS ON NUREG/CR7135 ( DRAFT INITERNAL REVIEW, REV.2, OCTOBER 2012)

COMMENTS RECEIVED NOVEMBER 13, 2013 A B C D E F G No. Technical Topic Pg. Sect Comment RES Proposed Resolution BNL Concur?

and Comment 1 Type NEI5 GEN 21 4.1 Table 4-1 provides a general list of common fire Accepted. Table 4-1 was modified to include the impairments related to Fire PRA Significant Y protection impairments. This list should include Features.

additional impairments related to Fire PRA analyses.

The Fire PRA analyzes the existing plant conditions to determine the risk significance of all the plant features. For these analyses to remain applicable, the condition of the significant features related to the fire PRA must remain in a similar condition for the life of the plant.

The following list identifies some examples of features that, if damaged, would degrade the defense-in-depth, and therefore could significantly impact the risk significance for the Fire PRA analysis.

Fire PRA Significant Features Ventilation System becomes inoperable ERFBS loses functionality Update to Fire Initiator Specifications Door on electrical cabinets lose functionality Drains near potential source of oil lose functionality 77 NEI4 ALT 17 3.2.1 Suggest providing a comprehensive list of detection Accepted. Conventional ionization and photoelectric smoke detectors and heat detectors and Y and alarm systems (ionization, photoelectric, duct, continually manned location where added as common fire protection features.

continually-manned Control Room, etc.) similar to fire suppression systems in next bullet.

78 23 of 27 03/26/2018

BNL PROPOSED RESOLUTION TO NRC PEER REVIWER COMMENTS ON NUREG/CR7135 ( DRAFT INITERNAL REVIEW, REV.2, OCTOBER 2012)

COMMENTS RECEIVED NOVEMBER 13, 2013 A B C D E F G No. Technical Topic Pg. Sect Comment RES Proposed Resolution BNL Concur?

and Comment 1 Type NEI12 LT 27 4.2.1 Some specific characterizations of long-term Not accepted. The Draft NUREG cited the following: "...A continuous fire watch may, however, Y FW compensatory measures could be improved. For be assigned to monitor several fire zones or rooms that are located within a single fire area, example, the draft NUREG offers that more than one provided that the zones or rooms are readily accessible and easily viewed by a single fire watch area can be covered in a continuous fire watch, if this at a frequency of about every fifteen minutes, with a margin of five minutes. This approach is can be accomplished in 15 minutes and if the areas acceptable because the fire area would be continuously monitored. As described by the staff are all within a "single fire area." This limitation is in a 1998 Task Interface Agreement (TIA) (Ref. NRR 96TIA0008), a continuous fire watch is unnecessary, as many plant fire areas are small, defined as follows:

some as small as just one room, and multiple areas could easily be covered in less than 15 minutes. The Continuous Fire Watch - A fire watch who performs a continuous watch over an assigned limitation to one single fire area should be removed, area(s), room(s), or object(s). All parts of the area may not be in the line of sight from a fixed and the performance-based criteria of 15 minutes watch station due to location of equipment, therefore the fire watch is to maintain watch over should stand on its own merits. the entire area by patrolling the assigned area. The continuous fire watch can be assigned to watch more than one room as long as the rooms are in the same general area; the fire watch remains in the same general area; welding, grinding or burning is not in progress within the area; and the assigned patrol is made every 15 minutes."

96TIA008 section 2.5 last paragraph says in reference to a letter dated July 15, 1986 in regards D.C. Cook NPP and its continous fire watch definition: "This staff action approved the use a single fier watch to patrol multiple fire zones withing a specific fire are".

From the comment it seems that the commenter might be referring to fire zone rather than fire area.

Added the TIA definition of a "fire area" to the Glossary which reads: "a plant area that is sufficiently bounded to withstand the fire hazards associated with the area and, as necessary, to protect important equipment within the area from a fire outside the area. Redundant post-fire safe shutdown systems located within a fire area are protected to provide reasonable assurance that one train of systems will be free of fire damage and available to achieve and maintain safe shutdown conditions. Licensees establish the post-fire safe shutdown systems and the plant fire areas on the basis of their plant fire hazards and safe shutdown analyses.

79 NEI1 LT N/A General The industry is concerned that the draft NUREG may Not accepted with changes. Y be framed in a way that implies regulatory expectations, which is inappropriate for a NUREG Sub Section "Timing of Corrective Actions" was added to section 4.1 "Fire Protection document. In several places, the draft NUREG implies Impairments". Also Example on "Untimely Corrective Actions" was added to section 4.2.2.1 that the NRC does not accept long-term "Examples of Issues and Findings related to Compensatory Measures" in relation to the Director's compensatory measures. NRC has previously Decisions comments.

addressed this issue in Director's Decisions DD-96-03 (all licensees with thermo-lag) and DD-07-03, which clarifies that compensatory measures are allowed by licensee's operating license and approved fire protection program, with no time limit. Further, many licensee technical specifications demonstrate that the NRC has accepted long-term compensatory measures in very specific circumstances. This change in agency position would need to be pursued via a formal regulatory change.

80 NEI13 GEN General Additional insight on operating experience with Accepted with no change. To the extent possible examples of findings have been added. Actual Y compensatory measures would enhance this report. examples of fires are difficult to track because current fire Event Database does not list if a Specifically, examples of instances when Compensatory Measure was in place during fire events.

compensatory measures have been successful, or instances when lack of appropriate compensatory measures resulted in a fire with more damage, would be useful.

81 24 of 27 03/26/2018

BNL PROPOSED RESOLUTION TO NRC PEER REVIWER COMMENTS ON NUREG/CR7135 ( DRAFT INITERNAL REVIEW, REV.2, OCTOBER 2012)

COMMENTS RECEIVED NOVEMBER 13, 2013 A B C D E F G No. Technical Topic Pg. Sect Comment RES Proposed Resolution BNL Concur?

and Comment 1 Type NEI14 FW General There are multiple typographical errors in the Accepted. Thru this review several errors have been corrected. Also, Brookhaven National Y document, including extra spaces, extra periods, Laboratory and main author of this report has Tech Edited the report before submitting the incorrect words (ex: "the" should be "that" in the report for public comment.

first sentence of the description of a Continuous Fire Watch in Table 4-2), and stray characters (ex: "i" appears between words "and" and "emergency" in the discussion of Temporary Repairs in Table 4-2).

82 WH1 FW General Draft NUREG/CR-7135 discusses continuous fire Not accepted. This is a direct citation to 96TIA008 Section 2.1 paragraph 6. See response to Y watch and the option to cover more than one area comment NIE12 and the definition of a Fire Area. It is possible that if a fire area has several provided it is done in 15 minutes. However, it says rooms that might not be easily accessible the fire marshall or responsible dessignee for assigning the areas covered must be within a "single fire area". fire watches should select appropriate quantity of fire watches.

I disagree with this limitation. Many plant fire areas are small (one room) and walking between these single room fire areas can easily be done in far less than 15 minutes. I cannot think of a valid reason to limit the 15 minute option to a single fire area.

Whether the person walks through a fire area boundary fire door into another fire area or whether the person walks through a non-rated door into a different room of the same fire area, it takes the same amount of time. This expectation may make sense for a huge fire area like the turbine building, but has no safety benefit for the rest of the plant.

In the infrequent times where we use this 15 minute option (typically when power to the fire detection is OOS for maintenance), the areas cannot be so far apart that 15 minutes walking to each area is not possible. Plus, the person cannot cross containmented area step off pads.

Please remove the expectation that the 15 minute option only be used for multiple impairment within a "single fire area".

83 WH2 ALT General Other comp measures can include the use of Accepted. Portable detection units are mentioned under section 4.2.1 under Temporary Repairs Y portable detection units. Various plants use these; and Modification Subsection.

84 WH3 ALT General There is very little discussion about getting the comp Accepted. Second Paragraph of Section 4.2 was revised to: Y measures in-place with 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. In cases where the "When a fire protection feature is not capable of performing the function(s) specified in the FPP, area is high rad, some plants allow more time to appropriate compensatory measures should be promptly implemented to restore, in some installing video systems with the monitor outside measure, the reduction in defense-in-depth created by the degraded, inoperable, or where the dose is lower; nonconforming condition. The original standard fire protection technical specifications (circa 1978) had established a requirement to implement compensatory mesures within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> after discover of the impairment. The timing of implementation was deemed to be a reasonable approach to compensate for the safety of the impaired structure, system or component after discovery. Consideration should also be given for extraneous circumstances such as high radiation, high contaminated area and confined space areas which would requires extra safety precautions prior to implementing the compensatory measure."

85 WH4 GEN General I find chapter 5 confusing. This could be better Chapter 5 was revised to improve readability and clarity.

86 explained/presented.

25 of 27 03/26/2018

BNL PROPOSED RESOLUTION TO NRC PEER REVIWER COMMENTS ON NUREG/CR7135 ( DRAFT INITERNAL REVIEW, REV.2, OCTOBER 2012)

COMMENTS RECEIVED NOVEMBER 13, 2013 A B C D E F G No. Technical Topic Pg. Sect Comment RES Proposed Resolution BNL Concur?

and Comment 1 Type NEI10 GEN 24 Table 4- Recommend adding a Compensatory Measure Accepted. Y 2 "Temporary Procedure Changes." This is subsequently identified in section 4.2.2.

87 NEI6 FW 24 Table 4- Table 4-2 lists examples of the common Types of Accepted. Y 2 Compensatory Measures. "Hourly Fire Watch" should be replaced with "Roving Fire Watch,"

because it may not always necessarily be "hourly".

88 NEI7 ALT 24 Table 4- Suggest adding "Wireless Smoke Detection Systems" Accepted. Y 2 as a compensatory measure. In the description field, suggest "wireless smoke detectors as a backup means of detection that is provided to compensate for an impaired detection system."

89 NEI8 ALT 24 Table 4- In the Backup Suppression description, suggest Not accepted. This is covered under new technologies. Table 4-2 is for common type of Y 2 adding Compensatory "transportable fire Compensatory Measures.

suppression system" as an example.

90 NEI9 ALT 24 Table 4- For "Standard Video Monitoring", suggest removing Not accepted. This is covered under new technologies. Table 4-2 is for common type of Y 2 "standard". In the description, suggest adding Video Compensatory Measures.

Image Detection System as an example. CCTV only provides an image. The Video Image Detection System can identify smoke or flame from a fire using detection algorithms. Alternatively, add new category for "Backup detection" and include this technology as an example.

91 NEI11 GEN Table 4- Recommend adding to Table 4-2 a Compensatory Accepted. Y 2 Measure "Temporary Procedure Changes." This is subsequently identified in section 4.2.2.

92 26 of 27 03/26/2018

Note: On previous iterations after Public Comments Chapter 1 and 2 where merged so Chapter 3 became 2, 4 became 3, and 5 became 4.

REVIEWER COMMENT TYPE COMMENT TYPE/TECHNICAL TOPIC NEI = Victoria Anderson Q = Question LT = Long Term Compensatory Measures WH = Wayne Harper S = Statement FW = Fire Watches EJB = Exelon, James Barstow T = Technical MSO = Multiple Spurious Operations G = General REG = Regulatory E = Editorial 805 = NFPA 805 ALT = Alternative Systems GEN = General Compensatory Measures ED = Editorial