ML19309B563

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Certified Summary of ACRS Ad Hoc Subcommittee on Fire Protection 791205 Meeting in Washington,Dc Re Intended Objective of Proposed Fire Protection Rule
ML19309B563
Person / Time
Issue date: 12/17/1979
From:
Advisory Committee on Reactor Safeguards
To:
Advisory Committee on Reactor Safeguards
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ML19309B560 List:
References
ACRS-1699, NUDOCS 8004040287
Download: ML19309B563 (8)


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~ OFFICIAL USE DET ISSUE DATE: 12/17/79 MINUTES OF THE ACRS AD H0C FIRE PROTECTION SUBCOMMITTEE MEETING WASHINGTON, DC DECEMBER 5,1979 The ACRS Ad Hoc Subcomittee on Fire Protection met on December 5,1979 at 1717 H St., NW, Washington, DC. The main purpose of the meeting was to review the intended objective of the proposed Fire Protection Rule, and the general contents of it.

Notice of the meeting was published in the Federal Register on November 20, 1979.

Copies of the notice, meeting attendees list, and meeting schedule are included as Attachments 1, 2, and 3, respectively. No written statements were received from any member of the public.

EXECUTIVE SESSION Mr. M. Bender, Subcommittee Chainnan, convened the meeting at 2:15 p.m., in-troduced the ACRS members who were present, and indicated that the meeting would be conducted according to the Feder.11 Advisory Committee Act and the Government in the Sunshine Act. Mr. J. McKinley was the Designated Federal Employee and Mr. P. Tam of the ACRS Staff was also present.

Mr. Bender stated that fire protection has been an open question since the Browns Ferry fire. The regulatory staff has attempted to put fire protection requirements in a Regulatory Guide but the Subcommittee objected to the issuance of a Guide at that time on grounds that practices were not well estaolished.

Now the Staff attempts to put the requirements in a rule and Mr. Bender felt even more uneasy about such an attempt.

DISCUSSION WITH THE NRC STAFF Mr. R. Fergusen, Division of Operating Reactors Mr. Ferguson said when he first particpated in the fire protection program in 1976, he questioned why nothing was being done about fire protection in operating plants. Guidelines prepared by the Staff, based on its study of the Browns Ferry fire, were applicable to new plants only. The Staff visited three older plants (Dresden, Yankee Rowe, and Browns Ferry) to see what kind of problems 0FFICIAL USE ONLY 8004040 gg

, Fire' Protection Since there are to apply guides developed for new plants to old plants.

1976, all of the licensees have evaluated their operating plants for fire protection against the criteria in Appendix A of Branch Technical Position The Staff has issued an SER for each of these analyses, and has 9.5-1.

noted a total of ~530 open items in the SERs. To resolve these items, the rulemaking Office of the Executive Legal Director proposed two alternatives:

The Staff prefers rulemaking. The rule would establish a base er order.

line of minimum requirements of fire protection; thus, all items that the Staff felt could be resolved by the rule are included.

Several characteristics about the proposed rule are:

This rule is specifically written for operating plants (there is no other rule like this).

Although -it is detailed, none of the requirements it contains would be a surprise to licensees.

The rule would be a first attempt to formalize informal requirements, currently contained in an Appendix to a Branch Technical Position.

Mr. D. Notley, Division of Engineering Standards, OSD (Aisach e.;t 4)

As a reuslt of the recom-Mr. Notley summarized the history of the proposed rule.

mendations of the "Hanuaer Report" (NUREG-0050), the Staff has daveloped and been using a Branch Technical Positi:n, "6;ideline for Fire Frotection For Nuclear Power Plants," (APCSB 9.5-1), and its Appendix A, "Guidulines For Fire Protection These documents have for Nuclear Power Plants Dockcted Prior to July 1,1976."

been in use for about-three years and all operating plants have been evaluated Most of ti,e provisions have been against provisions contained in Appendix A.

because of difference of opinion.

accepted by most of the licensees, but open items exist Mr. Notley believes that the level of fire protection required should be a policy matter and should be established by the NRC. The prorosed rule will serve this purpose, but none of the issues it provides are new.

Mr. Bender observed that much of tne rule is prescriptive, and indicated that He thinks that since there are such may be subject to over zealous scrutiny.

only a few specific problems (such as the size of fire brigades), the detailed Mr. Ferguson said that while it may be debatable, rule-rule seems an overkill.

making is the NRR management ch'oice. He further said that there is no intention to make a similar rule for new plants.

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12/5/79 Fire Protection Mr. Ebersole pointed out that the rule still does not consider fire as a design-basis accident, and does not require safety-grade suppression systems.

Furthermore, the rule seems to concern itself mostly with fire detection The rule as it stands does not B

and suppression, rather than prevention.

clearly define the need for alternative safe shutdown systems.

Mr. Ferguson said that without the rule, the Staff would have to use orders The rule is not made to avoid which are subject to hearings, appeals, etc.

hearings, but to consolidate many potential hearings into one.

Mr. Ebersole brought up the issue of independent and isolatable shutdown Mr. Ferguson sai,d that the Staff would relax fire protection capability.

requirements for plants with completely independent, dedicated shutdown

. Benaroya added that the Staff encourages use of dedicated systems. Mr.

shutdown systems in new plants.

ORAL STATEMENTS FROM THE PUBLIC_

Mr. D. Ward, Baltimore Gas & Electric (Written statement also submitted Attachment 6)

Mr. Ward read directly from his written statement, highlights are sumarized as follows:

It is extremely difficult to backfit a full system of He believes that bar-barriers in an operating plant.

riers E automatic fire suppression systems backed up by manual fire-ftghting efforts would be adequate.

Cost-benefit studies should be done for some reouire-ments in the proposed rule; even what appears to be minor changes may require large expenditure of resources.

Mr. Ward said that Mr. Bender asked what cost-benefit criteria Mr. Ward used.

the cost, and that the NRC Staff should do such

' the benefits should out-weigh Mr. Bender indicated that the an analysis before the rule goes into effect.

Staff should have an obligation to examine the cost-benefit of the require even though specific cost-benefit analysis for each operatins plant should Mr. Ferguson said that there were examples of done by individual licensees.

utilities doing such calculation and found the costs to be lower than e

, 12/5/79 Fire Prot 2ction Mr. Bender indicated that he will report to the full ACRS that the Sub-committee recognizes the present developmental status of the rule (out for public comment). The Subcommittee will review the rule in detail when public comments are in.

B Whereupon, at 3:25 p.m. the meeting was adjourned.

(A written statement from Mr. Edward A. Sawyer was also received and is included as Attachment 7).

For additional details, a complete transcript of the meeting NOTES:

(1) is available in the NRC Public Document Room,1717 H St., NW, Wa'shington, DC 20555, or from Ace-Federal Reporters Inc.,

20001.

444 North Capitol Street, NW, Washington, DC (2) Materials provided to.the Subcommittee at this meeting are on file in the ACRS Office.

A* L ly

  • vl Feder:1 Register / Vcl. 44. No. 225 / Tu:sd:y. Nov:mber 20. 1979 / Notices G6715 ne Subcominittee will hear presentations f

=

Information in connection with the and the time allotted therefor can be and hold round table discussions with satitrust review of this application can obtained by a prepaid telephone call to representatives of several Government be obtained by writing to the U.S.

the Designated Federal Eciployee for i

Nuclear Regulatory Commission, this meeting. Mr. Raymond F. Fraley.

gide ed que t$aSe ris sesessmen d

Washington;D.C ATIN: Antitrust and (telephone 202/634-3265) between 8.15 methoda in their dedston making process.

indemnity Group. Office of Nuclear a.m. and 5:00 p.m EST.

Information discussed during this sad succeeding meetings will be used by the Reactor Regulation.

Dated: November 14.1979.

ACRS as one basis for the development of Any person who wishes to have his John C. Ho)le' recommendations regardmg quantitative views on the antitrust matters with Advisory CommitteeMagement Micer.

safety goals and enteria for nuclear power Macton for consideration by the NRC.

respect to Kansas Electric Power in Du Sasm W ue % ses sal Cooperativ'e. Inc. presented to the 8'81** CC'8 "***

  • Further information regarding topics Attorney General for consideration to be discussed, whether the meeting should submit such views to the U.S.

has been cancelled or rescheduled, the Nuclear Regulatory Commission.

Advisory Committee on Reactor Chairman a ruling on requests for the Washington,D.C 20555. Attention:

Safeguards Subcommittee on opportunity to present oral statements Chief. Antitrust and indemnity Group.

Reliability and Probabilistic and the time allotted therefor can be Office of Nuclear Reactor Regulation on Assessment; Notice of Meeting obtained by a prepaid telephone call to or before january 11.1980.

The ACRS Subcommittee on the Designated Federal Employee for Dated at Bethesda. Maryland, thia 2nd day Reliability and Pmbabilistic Assessment thic meeting. Mr. Gary Quittschreiber.

of November.1979 will hold a meeting on December 5,1979 (telephone 202/634-3267) between 8.15 For the Nuclear Regulatory Commission.

in Rum 1048,171711 St. NE a.m. and 5:00 p.m EST.

Olan D. P'"'

Washington D.C.20555. Notice of this Da%d; N ber 14.1979 Chief. Light Water Reactors. Branch No. 3.

meeting, previously scheduled to be held

'ohn H

, Division ofProject Management.

on December 4.1979, was announced in

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in on m w oeruw n-w a a4s..)

the Federal Register on October 18,1979. [m Da masm M u-sea aos amt em coca neo4w in accordance with the procedures

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  • outlined in the Federal Register on Oct.

1.1979. (44 FR 56408) oral or written Advisory Committee on Reactor statements may be presented by Advisory Committee on Reactor Safeguards Procedures and members of the pubhc. recordings will Safeguards Subcommittee on Fire Administration Subcommittee; Notice be permitted only dunng those portions Protection; Notice of Meeting c,f Meeting of the meeting when a transcript is being The ACRS Subcommittee on Fire The ACRS Procedures and kept. and questions may be asked only Protection will hold an open meeting on Administration Subcommittee will hold by members of the Subcommittee,its December 5.1979 in Room 1187.171711 an open meeting on December 5.1979 in consultants, and Staff. Persons desiring St NE Washington.DC 20555 Room 1010.171711 St NW. Washington. to make oral statements should notify In accordance with the procedures DC 20555.

the Designated Federal Employee as far outlined in the Federal Register on In accordance with the procedures in advance as practicable so that October 1.1979 (44 FR 56408) oral or outlined in the Federal Register on appropriate arrangements can be made written statements may be presented by October 1.1979. (44 FR 56808), oral or to allow the necessary time during the members of the public. recordings will written statements may be presented by meeting for such statements.

be permitted on) during those portions members of the public. recordings wil!

The agenda for subject meeting shall of the meeting w en a transcript is being be permitted only during those portions be as follows:

kept, and questions may be asked only of the meeting when a transcript is being kept. and questions may be asked only M*,s)[cembers a by members of the Subcommittee,its gg consultants, and Staff. Persons desiring b) members of the Subcommittee.its ne Subcommittee will discuss items i

to make oral statements should notify consultants, and Staff. Persons desiring pertaining to the budget and program of the i

the Designated Federal Employee as far to make oral statements should notify Office of Nuclear Regulatory Research. Since

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the Designated Federal Employee as far NRC budget proposala are now part of the i

in advance as practicable so that l

Pruident's budget-not yet submitted to appropriate arrangements can be made in advance as practicable so that Congress.-pubbe disclosure of budgetary to allow the necessary time during the appropriate arrangements can be made inf rmation is not permitted.See OMB j

meeting for such statements.

to allow the necessary time during the Circular No. A-10. He ACRS, howeve. is The agenda for subject meeting shall i

The agenda for subject eneeting shall M"[t o be as follows: Wednesday. December 5.

meeting for such statements.

o revt t e RC 1979; 22 p.in. until the conclusion of be as follows:

research program and budget and report the business.

results of its review to Congress. In order to The Subcommittee will review the Wednesday December 5.1979 1:30p.m. until the conclusion of business.

perform this review. the ACRS must be able proposed Fire Protection Rule for to engage in frank discussion with members De Subcommittee will discuss of the NRC Staff. For the reason just stated, a operating nuclear power plants.

neommendations of the President's discussion would not be possible if held in Further information regarding topics Commission on the Accident at Three Mile to be discussed, whether the meeting Island relatina to ACRS activities and pubhc session-Ihave determined therefore,thatitis has been cancelled or rescheduled, the proposed ACRS comments regardmg the necessary to cbse this sesalon to protect Chairman's ruling on requests for the nuclear regulatory process.

Further information regarding topics whEm cantl[f CPportunity to present oral statements d

and the time allotted thenfor can be e

to be discussed. whether the meeting implementation of proposed action obtained by a prepaid telephone call to has been cance!!ed or rescheduled, the

[sszb(c)(9)(B)).

the Designated Federal Employee for Chairman's ruling on requests for the p.30 a.m. until the maclusion of business.

this meeting. Mr. John C. McKinley opportunity to present oral statements OPEN i

o2 lg 98*/1C Federal Register / Vcl. 44 No. 225 / Tuesd:y, November 20, 1979 / N:tices

(

p e 202

)between 8-15 sylvania 15001. A copy ofitems (2) available for public inspection at the an (3) may be obtained upon request Commluton's Public Document Room.

Deted: November 14.te79.

addrened to the U.S. Nuclear 1717 H Street. NW, Washington, D.C.

Jehe C. Hoyle, Regulatory Commission Washington.

and at the B. F. Jones Memorial Ubra D.C.20655. Attention: Director Division esaFrenklin Avenue. Aliquippa, Advisory Committee Mangement Officer.

9 peratingReactors.

Pennsylvania 15001. A copy of items (2) fO traon maerse m ais-wrmam 63 Deted at Betbeeds. Maryland this 3rd day and (3) may be obtained upon request esAase coot reeHHs

_ L of November.197s.

, addressed to the U.S. Nuclear

' ' For the Nuclear Regulatory rhmission.

Regulatory Commission. Washington, D.C. 20555. Attention: Director, Division (Dukm m}

A. Seweccer, of Operating Reactors.

Chi'/.O emting Reacton Smach No.2, P

Ductueene Ught Co.,et al.t Notice of halon of Opemting Reactors.

Dated at Bethuda, Maryland, this 3rd day k

leeuence of Amendment to FecWty of November,1979.

Pa nur.Saanima is-ts.pa em Operating Ucense For the Nuclear Regulatory Commission.

s u ma cena resa4 w

%e U.S. Nuclear Regulatory

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Commission (the Commission) has Chief, Opemtig Reactors Bmnch No. f.

tesued Amendment No. 20 to Facility (Docket 880.80-3841 8

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  • Operating Ucense No. DPR-66 issued to Duquene Ught Co, et al.t Notice of Pt D= *mn' ma nanan se =)

Duquesne Ught Company, Ohio Edison leeuence of Amendment to FacWty eussecootrosee w Company, end Pennsylvania Power Opereung Ucense Company (the licensees), which revised Technical Specifications for operation of

%e U.S. Nuclear Regulatory

[Dockoue.gne so.442-spl the Beaver Valley Power Station, Unit Commission (the Commission) has No.1 (the facility) located in Beaver tesued Amendment No. 21 to Facility Kansee Gas & Electric Co, and Kansas County, Pennsylvania.%e amendment Operating Ucense No. DPR-46 issued to City Power & Ught Co.t Estatdiehment la affective as of the date of (ssuance.

Duquesne Ught Company. Ohio Edison of Atomic Safety and Ucensing Board

%e amendment provides for changes Company, and Pennsylvania Power To Presidein Proceeding in the allowable nuclear entnalpy hot Company (the licensees), which revised Pursuant to delegation by the channel factor, and core radial peaking Technical Specifications for operation of Commission dated December 29,1972.

factor and deletes the license condition the Beaver Valley Power Station Unit published in the Federal Register (37 FR 2.C on Rod Bow Penalty onTotal No.1 (the facility) located in Beaver 28 and Secdons 2.105. 2.700,2J02, Peaking Factor.

County, Pennsylvania. The amendment 2314,2.714a,2.717 and 2.721 of the

%e application for the amendment is effective as of the date ofissuance.

CMubni Regulanons, au se comp!!es with the standards and De amendment revises the Technical requirements of the Atomic Energy Act Specifications to reduce the. time

("ce Bo iste esta lishedin of 1954, as amended (the Act), and the constant of the neutron flux rate reactor 13 P"C"

,,g' Commission's rules and regulations.The trips from two seconds to one second, O'mns fodean to intenene an#or Pe Commission has made appropriate and to reduce the trip setpoint of the findings as required by the Act and the high negative rate from five percent to

'g*[p'

","d t yent that a Commission's rules and regulations in 10 three percent.

hearing is ordered.

CFR Chapter I, which are set forth in the The application for the amendment Kansas Gas & Electric Co., and license amendment. Prior public notice complies with the standards and Kansas City Power & Light Co. (Wolf of this amendment was not required requirements of the AtomicEnergy Act Creek Generating Station. Unit No.1) since this amendment does not involve a of1954, as amended (the Act), and the Construction Permit No.CPPR-147 Commission's rules and regulations.The

%is action is in reference to an Order significant hazards consideration.

ne Commission has determined that Commission has made appropriate published by the Commission on the issuance of this amendment will not findings as required by the Act and the September 24.1979. In the Federal result in any significant environmental Commission's rules and regulations in 10 Register (44 FR 55071-72) entitled impact and that pursuant to to CFR CFR Chapter 1, which are set forth in the " Kansas Cas & Electric Co. and Kansas license amendment. Prior public notice City Power & Ught Co.: Proposed 51.5(d)(4) an environmentalimpact of this amendment was not required Issuance of Amendment to a statement or negative declaration and since this eanend:nent does not involve a Construction Permit."

environmentalimpact appraisal need significant hazards consideration.

He Chairman of this Board and his not be prepared in connection with The Commission has determined that address is as follows: Herbert issustee of this amendment.

the issuance of this amendment will not Grossman,Esq., AtomicSafety and For further details with respect to this result in any significant environmental UcensingBoard Panel U.S. Nuclear action, see (1) the application for impact and that pursuant to to CFR Regulatory Commission, Washington, amendment dated September 22.1978 as 51.5(d)(4) an environmentalimpactD.C.20555.

supplemented by letter dated February statement or negative declaration and The other members of the Board and 8,1979 and portions ofletters dated environmentalimpact appraisalneed their addresses are as follows:

October 27,1978 and December 14.1978, not be prepared in connection with Dr. Richard F. Cole. Atomic Safety and (2) Amendment No. 20 to Ucense No.issuance of this amendment.

ucsasins Board Panel.U.S Nuclear DPR-e6 and (3) the Commission's For further details with respect to this gegulatory ra==winn wohington.DC related Safety Evaluation. All of these action, see (1) the application for 306s5 Items are ava!!able for publicinspection amendment dated June 26,1979,(2)

Mr. Glenn O. Bright. Atomic Safety and Ucensin8 oard Panet.U.S. Nuclear at the Commission's Public Document Amendment No. 21 to Ucense No.DPR-B Room,1717 H Street, NW., Washington, se and (3)the Commission's related

- Regulatory t'n= mission. Washington,DC i

D.C. and at the B. F. Jones Memorial Safety Evaluation. All of these items are aosss.

Ubrary, ses Franklin Avenue. Aliquippa, l

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ATTACHMENT 2 ATTENDEE LIST ACRS AD H0C SUBCOMMITTEE MEETING ON FIRE PROTECTION WASHINGTON, DC DECEMBER 5,1979 ACRS NRC STAFF M. Bender, Chairman D. Notley J. Ray R. Ferguson H. Etherington L. Derderian J. Ebersole C. Heft J. McKinley, Designated Federal Employee G. Harrison P. Tam,ACRS Staff PUBLIC D. Ward, Baltimore Gas & Electric J. McLeod, Southern Company Services E. Sawyer, Yankee Atomic Electric J. Hendricks, Duke Power Company G. Powell, Baltimore Gas & Electric I. Asp, Gage-Babcock & Assoc.

R. Hunt, Baltimore Gas & Electric M. Antonetti, Gage-Babcock & Assoc.

E. MacDougall, Brookhaven National Lab.

A. Caputo, Boston Edison Co.

J. Townley, Brookhaven National Lab.

T. Venkatanaman, Boston Edison Co.

C. Yeh, Gibbs & Hill, Inc.

R. Cooney, Offshore Power Systems F. Farkouh, Gibbs & Hill, Inc.

D. Stadler, Carolina Power & Light J. Roncaioli, Northeast Utilities J. Klevan, Rolf Jensen & Associates, Inc.

B. Horin, Debevoise and Liberman D. Knuth, KMC R. Berry, Consumers Power Co.

B. Montgomery, Bechtel Licensing W. Hall, Consumers Power Co.

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REVISED DECEMBER 3,1979 TENTATIVE SCHEDULE ACRS FIRE PROTECTION SUBCOMMITTEE MEETING WASHINGTON, DC DECEMBER 5,1979 EXECUTIVE SESSION Mr. Bender 2:00 pm - 2:05 pm DISCUSSION WITH NRC STAFF ON THE PROPOSED FIRE PROTECTION RULE 2:05 pm - 2:40 pm Speakers:

D. Notley and R. Ferguson ORAL STATEMENTS FROM T..E PUBLIC 1.

Mr. Donald Ward - Baltimore Gas & Electric 2:40 pm - 2:50 pm 2.

EXEUCTIVE SESSION 2:50 pm - 3:00 pm 1.

Recommendation to ACRS on Proposed Fire Protection Rule 2.

Action on report, "The Hazard to Reactor: from Oil 4

Industry Operations."

3.

Future meeting?

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