ML19320B408

From kanterella
Jump to navigation Jump to search
Forwards Draft Memo Summarizing Individual Commissioner Comments on SECY-80-088,fire Protection Actions.Requests Comments or Concurrence in Time to Affirm Paper on 800319. Draft Memo,Modified Pages & Draft Fr Notice Encl
ML19320B408
Person / Time
Issue date: 03/17/1980
From: Parry S S
NRC OFFICE OF THE SECRETARY (SECY)
To: Eysymontt G, Funches J, Guibert J
NRC COMMISSION (OCM)
Shared Package
ML19320B404 List:
References
FOIA-80-303, FRN-45FR36082, RULE-PR-50 NUDOCS 8007100334
Download: ML19320B408 (17)


Text

.

b

,f'

'o UNITED STATES gj g

NUCLEAR REGULATORY COMMISSION CJ -

, e, W AS H tf?GT Ord, D.C. 20555 s

kd U, MM e,,,c, o p,g, SECR ETAR1C V. Funches, OCM MEMORANDUM FOR:'

J G. Eysynontt, OCM J. Guibert, OCH H. Fontecilla, OCM H. Thompson, OCM FROM:

> S.J.S. Parry, SECY

SUBJECT:

SECY-80 FIRE PROTECTION ACTIONS (CONSENTCALENDARITEM)

This paper is scheduled for affirmation on March 19, 1980.

The attached draft

, memo sumarizes individt0c Comissioner coments.

May I have any coments on or concurrence in this memo promptly to permit the papti to be affirmed on 3/19/80. _

Attachment:

Draft, Memo cc:

S. Chilk e

e e

9 6

e O

9

,f,.jft.

Avf/;3,f..,,

.r -

s-MEMORANDUM FOR:

William J. Dircks, Acting EDO

' Samuel b. Chilk, Secretary FROM:

SUBJECT:

SECY-80-BB FIRE PROTECTION ACTIONS (CONSENT CALENDAR ITEM)

This is to advise you that the Commission (with three Comnissioners concurring) has approved the staff's recommendation and proposed FRN rubject to the modifications as attached and as noted below.

Commissioner Gilinsky did not participate in this action.

Commissioner Bradford disapproved the staff's recommendation.

The staff is requested to make the following additional changas:

1)

The,FRN is to be modified to make.the minimum provisions for fire protection immediately effective.

2)

Enclosures A & B, p.8, reword the phrase " visually indicating".

Individual Commissioner comments have been provided to you previously.

Attachment:

Modified pages cc:

Commissioners Commission Staff Offices Director, Standards Deve.lopment Y

g

u.v vu f.'.

A.

In response to the first recommendation, NRR developed Branch Tech-nical Position Auxiliary Power Conversion Systems Branch 9.5,-1,," Guide-lines for Fire Protection for Nuclear Power Plants" (BTP 9.5-1), and Appen-dix A to BTP 9.5-1, " Guidelines for Fire Protection For Nuclear Power Plants Docketed Prior to July 1, 1976".1 The guidance contained in BTP 9.5-3 was published for public comment in June 1976 as Regulatory Guide 1.120,

" Fire Protection Guidelines for Nuclear Power Plants."

As a result of

~

pub (ic comments received, the staff proposed extensive changes to the guide and presented the proposed changes to the ACRS in an open meeting in May 1977.

Additional written comments were solicited from the public following that meeting.

Nineteen adbitional comment letters were received and they were also considered in Revision 1 of Regulatory G'uide 1.120, which was published for a'new one year public comment period in November 1977.

Comments received on Revision 1 of Regulatory Guide 1.120 were generiilly restatements of comments received during earlier comment periods and had already been considered and evaluated by the staff.

The guidelines in both the BTP 9.5-1 and Appendix'A to BTP 9.5-1 were develop _ed to ' provide a fire protection program that' has two basic objectives:

\\

1.

to identi'fy and distinguish between those consequences of fire that are acceptable and those consequences that are not.

2.

to provide necessary means to minimize all consequences of fire

'f-and to prevent unacceptable consequences from occurring.

iBranch Technical Position 9.5-1 and its Appendix A are available from David P. Notley, Office of Standards Development.

u p 4;~ A Y fj f /"" $ f k f W Y - W ? ? l.

- 6uc j c' W

w,, a y s u y. s 1 s h u. & A,, i J 6w-ma ap%g+ "tw%~

.s e p

~ W Jm. -u.'A:4./e h y 4.<iv/. d W "' " *y / 8 bC,W

=

3 r

\\.

h.

~

instance, all agree on the need for a fire brigade on all shifts.

The disagreement is ",how large?" The staff says that five should be fhe minimum size permitted while._some licensees say that a brigade of only three or four will be adequa'te.

Similar disagreements exist with each of the basic requirements covered by this proposed rule k'here the staff's safety evaluations contain open items, the position of the staff and the licensees tre documented and well-known.

~

There are, however, a few instances where the staff has accepted certain fire protection alternatives that would not satisfy some of the reouirements

  • of this prooosed rule.

The minimum reouirements contained in this rule were develooed over a three-year period and, in each of these instances, the staff accepted a oroposed alternative before these minimum reauirements

'were established.

All licensees will be expected to meet the reauirements of this rule, in its effective form, includina whatever chanaes result'from public comments.

Th e -i s s W e s - a r e-s e t-n ew;- e i th e r-f e r-t h e-s taf f-e r-fe r-th e 14 e ens e es -i nvelve d r--Thi s - p r e pe s e d-r el e-an d-i t s -Ap p en d ix-R- a dd /e s s -e nly-the s e i s s e es - t ha t-a r e-g en e.F i e-i n -R atWr e i-R e-pI aS t-s p e e i fi e-i s s W e s - a re-iR el ede dt Because of the above-mentioned differences between the staff and the Ticensees in the interpretation of the staff's guidelines, it is timely and necessary for the Commission to state what the minimum fire protection requirements.

will be in each of these contested areas of concern.

This proposed rule-and its Appendix R have been developed to establish the minimum these acceptable sinimum fire protection requireneits necessary to resolve these contested areas of concern for nuclear power plants operating prior to January 1. 1979.

s Other fire orotection criteria that have been used by the staff durino its olant-soecific fire protection orocram reviews are contained in Accendix A to BTP 9.5-1.

The combination of the auidance contained in Accendix A to BTP 9'.5-1 and the reovirements set forth in this proposed rule define the essential elements for an acceptable fire protection program at nuclear power plants docketed for Construction Permit prior to July 1,1976, for demonstration of comoliance with General D.esion Criterion 3 of Accendix,to 10 CFR Part 50.

Similar acceptable c

guidance is provided in BTP 9.5-1 for nuclear ocwer plants docketed for Construction Permit after July 1,1976.

These-regWlatiens-state thes e - fir e -p re te e t i e n-r e qu i reme nt s -fe r-av el e a r-p ewe ~r-f a c ili ti e s-th at-a re-eensidered-minimes-ge$er?e-requirements-te-satisfy-General-Besigr.-Griterien

'n's : e f-Ap p e ndi x-A-ts G FR-s 9 r--The-p re p e s ed-Ap p e nd ? x-R-s pe ci fi e s -h e th gene ral-an,d-s p ecifie-requi resents-ef-an-asse ptable-fire-pretectien-pregram All modifications (exc'ept for alternate shutdown capability) would be reouired to be implemented by November 1,1980, [or, for--ceed-ce%

-by--the--enM the est reftd-?ng-outage thweaf-ter,-Un olant--would be serni++ed +n mrt "uftsr that de:r.lc : :M-c.od4fkations hwe been 44r,alemnted.

In the-c$se of citerMe-shtdot n capability,-the-Wensee woMd he-ceh.d.re c -schedde-to-bc scccctable--to-and-+oor-oved

-by--tit: s icU.

ADO NSERT 2 e

. +

L~ n o-01],

i Vi.EEE:

"WEM?

1h.i.l.

A brief description of the major parts of the proposed rule, includ-ing the need for each of the specific requirements, follows.-

I.

Introduction and Scope This section states that the basic objectiv~.

. the proposed Appen-WN dix R is to specify a minimum fire protection requirementsj,for nuclear Y

power plants operating prior to January 1,1979.

It limits application cofu '

to commercial nuclear power electric generating stations and also states

-g w.i that the proposed Appendix R does not rescind any requirements set forth M

in any Safety Evaluation Report "for any nuclear power facility.

II.

General Recuirements This section states in general terms'the need for a cc prehensive fire protection program at each nuclear power plant.

A.

Fire Protection Prooram The concept of. defense in depth is here e'xtended to fire protec-tion (1) to prevent fires from starting, (2) to rapidly detect, control, and promptly extinguish those fires that do occur, and (3) to arrange the, structures, systems, and components important to safety so that a fire that starts in spite of the fire prevention activities and that is not promptly extinguished by the fixed automatic or manual fire suppression activities will not prevent the safe shutdown of the plant.

B.

Loss of Offsite Pcwer This section requires that any fire detection or suppression system protecting systems necessary to achieve and maintain safe plant shutdown be capable of functioning with or without offsite power.

o O

e

[7590-01]

c that fires in electrical equipment (which may be subject' to water damage) should be extinguished as quickly as possible.

'n'ater may not be excluded from an area as a fire extinguishant only on the basis of potential water damage to safe shutdown equipment.

If such water damage hazard is severe, other protective measures such as shields for equipment or alternate shut-down capability would be required.

A separate fire water distribution system would be required at each plant to ensure the necessary water supply with adequate pressure and volume for any combination of automatic and manual fire suppression demands.

A looped fire main with appropriate isolation valves provides a higher reliability of furnishing this necessary water supply to fire suppression systems by providing alternate directions of flow during maintenance or repair on part of the system.

Similarly, at least two water sources--tanks and pumps or pumps alone from a large body of water such as a lake or a river--are necessary to ensure continuity of water supply.

In the case of two intakes from a

~

single large body of water, the intakes must be separated W m each other so as to really ensure two separate sources.

B.

Sectional Control Valves This item requires that valves installed in the yard fire main to permit isolation of part of the main for maintenance or i epair without shutting off the entire system be visually indicatino.

C.

Hydrant Block Valves

~

This item requires block valves to be installed in hydrant

, laterals if necessary to isolate a hydrant from the yard main without

Pursuant to the Atomic Energy Act of 1954, as amended, the Ene'rgy Reorcanization,Act of 1974, as amended, and section 553 of title 5 of the United States Code, notice is hereby given that adoption of the following amendments' to 10 CFR Part 50 is contemplated.

PART 50 - DOMESTIC LICENSING OF PRODUCTION AND UTILIZATION FACILITIES 1.

A new Section 50.48 is added t'o read as follows:

5 50.48 Fire Protection:

(a)

Each operating nuclear power facility shall 'have a fire protection plan which meets the reouirements of Criterion 3 of Accendix A to this part.

This fire protection plan should consist of two sections.

The first section should describe the overall fire protection program for the facility, identify the various positions within '

the licensee's organization that are responsible for the program, state the authorities that are delegated to each of these positions to implement those responsibilities, and outline the ol'ans for fire protection, fire detection and sucoression caoability, and limitation of fire damace.

The second section should describe soecific features necessary to implement the first section, such as:

administrative controls and personnel reauirements for fire crevention and manual fire suppression activities; automatic and manually operated fire

~

detection and suporession systems; and means to ensure capability to safely shutdown the olant in soite of fire damage to safety related or safe shutdown structures, systems or components.

e

(b)

For nuclear pow 2r facilities that comenced ooeration orior to January 1,1979, appropriate portions of Criterion 3 of Accendix A to this part will be satisfied by meeting the recuirer.ients contained in Appendix R to this part.

CpeFat4RS-RWeIGaF-peVeF-fas4I4 ties-that-seEEeReed-eyeFatien-pFieF-tG-JaRWEFy-ly-979 -Shall-Reet-the-FeqWiFeEeRts-ef-GF4teFieR-2-ef-AppeRd?x-A-

,3 t e - thi s-p aF t-by-s a ti s fy4 R S-the-reqWi FeBer.ts-ee nt a ? R e d-4 R-Ap p e R d4 x-R-te-this-paFt, ADD IM5ERT 3 fe)

The-- imr,1+mereat4en-of--the rcouirements ccr.thined 9 f.:: n&-R-

~

io-thh-cart-fexcept doc-altemate-shetdown-cecab4MtvMa'r1 f,

-be-comphted4y "cvernher 1,1980,-or-for-ce 4-cause-shownt-the

-f4r+t--r45uel hg outage-there rf t er. -In-the-case-crf-alt s cte

-shutdown ca nahility - +he 14cen:ce sh:11 crc;.re-a-schedt'la +n-

' ba acceptabla to > h oroved-by the st:ff:

2.

A new Appendix R to 10 CFR Part 50 is added to read as follows:

APPENDIX R--FIRE PROTECTION PROGRAM FOR NUCLEAR POWER FACILITIES OPERATING PRIOR TO JANUARY 1,1979 If The combination of the guidance contained in Appendix A to Branch

~

Technical Position 9.5-1, " Guidelines for Fire Protection for Nuclear Power Plants Docketed Prior to July 1,1976", as implemented by the staff in its plant-specific fire protection program revi.ews of operating nuclear ' power plants, and the requirements set forth in Appendix R to this Part define the minimum necessary conditions for demonstration of compliance with General Design Criterion 3 of Appendix A to this Part.for nuclear power facilities that comenced operation pri.or to January 1, 1979.

I.

INTRODUCTION AliD SCOPE This Appendix sets forth the minimum fire protection requirements needed for nuclear power facilities to satisfy Criterion 3 of Appendix A to thic part with respect to certain recurrina ceneric issues for nuclear power plants that were operating prior to January 1,1979.

This Appendix applies only to licensed co.mercial nuclear power electric generating stations operating prior to January 1,1979; it does

~

9 0

+

G G

k e

a 4

9 9

l G

O e

9 0

e 4

(

[7590-01]

f.,.,.

,1

.. ~

'.' ', -/

,(

~

The drills shall be preplanned to establish the train-

. c..

'e" ing objectives of the drill and shall be critiqued to determine how well the training objectives have

.~.:

been met..

Unannounced drills shall be planned and

, critiqued by members of the management staff respon-sible for plant safety and security.

Performance deficiencies of a fire brigade or of individual fire brigade m, embers shall be ' remedied by -scheduling a,ddi-tional training for the brigade or members.

Unsatis-factory drill performance shall be followed by 'a repeat drill within 30 days.

d.

At three year intervals, drills shall be critiqued by qualified individuals independent of the licensee's a

staff.

A copy of the written report from such indi-viduals shall be submitted to NRC for evaluation.

Drills shall as a minimum..iclude the following:

e.

(1)

Assessment of fire alarm effectiveness, time required to notify and assemble fire brigade, and selection, placement and use of equipment, and firefighting strategies. -

mtd (2)

Assess each brigade member's knowledge of his n

i L

role in the firefighting strategy for the area m t ci

/

l assumed to contain the fire.

Assess the brigade 3

r l

1 c

[7590-O'1]

These records of training shall be available for review.

Retraining or broadened training for fire fighting within buildings shall be scheduled for all those brigade members

'whose performance records show deficiencies.

J.

Emergency Lighting (tadily (?)

Emergency lighting consisting of either lighting not damaged

/'

by fire in a given area or fixed sealed beam or fluorescent units with an individual 8-hour minimum battery power supply shall be provided in all areas needed for operation of safe shutdown equipment and in access routes to all safety related areas and other areas presenting a fire hazard to safety related areas.

K.

Administrative Controls Administrative controls shall be established to minimize fire a

hazards in areas containing structures, systems, and components important to safety.

These controls shall establish procedures to:

1.

Govern the handling and limitation of the use of ordinary,.

combustible materials, combustible and flammable gases an,d liquids, high efficiency particulate air and charcoal filters, dry ion exchange resins, or other combustible supplies in safety related areas.

~

2.

Prohibit the storage of ccmbustibles in safety-related areas or establish designated storage areas and fire protec-tion therefor.

~

3.

Govern the handling of and limit transient fi,re loads such as combustible and flammable liquids, wood and plastic

a

[7590-01) 3.

The reactor heat removal function shall be capable of achieving and maintaining decay heat removal.

4.

,The process monitoring function shall be capable of providing direct readings of the process variables neces-sary to perform and control the above functions.

5.

The supporting functions shall be capable of providing the process cooling, lubrication, etc., necessary to permit the operation of the equipment used for safe shutdown

  • / b functions.

h r_ig %

Q v k ma4 r.4. p. ~ I A.-

g a

The equipment and systems used to achieve and maintai hot standby conditions (hot shutdown for a SWR) shall be (1) Ree of fire k damage,.(2) capable of maintaining such conditions for at least 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> if th$ equipment required to achieve and maintain cold shutdown is'not available because of fire damage, and (3) capable of being powered by both onsite and offsite electric power systems or by onsi,te power systems that are indepe,ndent of the onsite and offsite electric' power systems.

The number of operating shift personnel, exclusive of fire brigade members, required'to operate the equipment and systems shall be onsite at all times.

The equipment and systems used to achieve and maintain cold l

shutchown conditions shall be _ free of fire damace, or the fire damage to such systems shall be limited such that repairs can be made and cold shutdown conditions achieved within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

Materials for such repairs shall be readily available onsite and procedures shall be in effect to implement such repairs.

Equipment and systems used prior to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> l

[7590-01]

U. S. NUCLEAR REGULATORY COMMISSION 10 CFR Part 50 Fire Protection Program for Nuclear Power Plants Operating Prior to January 1, 1979 AGENCY:

U. S. Nuclear Regulatory Commission ACTION:

Proposed Rule

SUMMARY

The Nuclear Regulatory Commission (NRC) is proposing to amend its regulations to require certain minimum provisions for fire protection in operating nuclear power plants.

DATES:

Comment period expires (30 days after publication).

The position of the' staff and the licensees regarding the provisions of this rule is documented and well known.

In addition, the public has been afforded several opportunities to comment on the provisions of the rule during two extensi <e comment periods and in open meetings with tife ACRS in which. _ -

a regulatory guide on fire protection was considered.

For these reasons no extension of the comment period will be granted.

App IWMT I ADDRESSES:

Written comments should be submitted to the Secretary of the Commission, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555, Attention:

Docketing and Service Branch.

FOR FURTHER INFORMATION CONTACT:

David P. Notley, Office of Standards Development, U.-S. Nuclear Regulatory Commission, Washington, D. C. 20555, phone 301-443-5921.

l 1

Enclosure "A" m

j.

Insert 1 - Enclosure A, page 1 i -

Further, since the issues involved are well known and have been under discussion for several years, the Commission does not anticipate changes in the rule's action deadlines as a result of further comments received.

9 4

i 9

O a

e l

t e

e G

9 e

g

=

N

{

--s w,

,+--~.-m,

,,y,

,.,,y

,g.

1 g

Insert 2 - Enclosure A, page 5a unless, for good cause shown the Commission approves 'an extension.

j Since the issues involved are well-known and have been under discussion for several years, the Commission anticipates approving few, if any, extensions.

No plant would be allowed to continue operating after

-November 1, if 30, or beyond an extended date approved by the Commission, unless all modifications (except for alternate or dedicated shutdown capability) have been implemented.

The Commission recognizes that, in a few instances, approval has previously been given to particular licensees to extend the implementation dates for some mo'difications beyond November 1 1980..The Commission will review these extensions on a case-by-case i

basis to determine whether continued approval or some revision of the extension is appropriate.

For alternate or dedicated shutdown capability, the proposed rule specifies-implementation dates which depend on which kind of capability is to be implemented and whether the plant is under review in the Systematic Evaluation Program (SEP)*.

For non-SEP plants, the proposed implementation dates are April 1,1981 for alternate shutdown capability and December 1 l

1981 for dedicated shutdown capability.

Licensees who have committed to i

earlier implementation dates will be expected to meet those commitments.

For SEP plants,.the proposed implementation dates are December 1,1981 for alternate shutdown capability and October 1,1982 for dedicated shutdown capability.

Licensees will be required to submit plans and schedules to meet these implementation deadlines by August 1,1980 (non-SEP plants) and November 1, 1980 (SEP plants).

The Commission may revise the implementation deadlines for SEP plants to earlier dates following completion by the NRC staff of its review of the status of fire protection

  • 1 at those plants.

The staff review is expected to be completed in

~

r August, 1980.-

i

}

4

~

i J

  • Plants under review in the SEP include Palisades Dresden 1 and 2, 0yster Creek, !!illstone 1,. Ginna, Haddem Neck, San Onofre 1, La Crosse, Big Rock Point, and Yankee Rowe.

..e.

i Insert 3 - Enclosure A, page 13a (c) The implementation of the requirements contained in Appendix R to this part (except for alternate or dedicated shutdown capability) shall be completed by November 1,1980 unless, for good cause shown, the Commission approves an extension.

For alternate or dedicated shutdown capability, the following implementation schedule will apply.

(1)

Plants not included in the Systematic Evaluation Program (SEP):*

Licensees implementing alternate shutdown capability shall complete implementation by April 1, 1981.

Licensees who have previously committed to earlier implementation dates will be expected to meet the earlier dates.

Licensees implementing dedicated shutdown capability shall complete implementation by December 1, 1981.

Licensees shall submit, by August 1,1980, plans and schedules for meeting these imolementation deadlines.

(ii) Plants included in the SEP:

Licensees implementing alternate shutdown capability shall complete implementation by December 1, 1981; licensees implementing dedicated shutdown shall complete implementation by October 1, 1982.

Licensees shall submit, by November 1,1980, plans and schedules for meeting these imple-mentation deadlines.

The Commission may revise these implementa-tion deadlines to earlier dates following completion by the NRC staff of its review of the status of fire protection at SEP plants.

The staff review is expected to be completed in August, 1980.

  • Plants under review in the SEP include Palisades, Dresden'l and 2,'

Oyster Creek, Millstor.e 1, Ginna, Haddem Neck, San Onofre 1, La Crosse, Big Rock Point, and Yankee Rowe.

[

.