ML20045F897
| ML20045F897 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 06/16/1993 |
| From: | Andersen J Office of Nuclear Reactor Regulation |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 9307090163 | |
| Download: ML20045F897 (4) | |
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UNITED STATES y. ' %g' 1 j NUCLEAR REGULATORY COMMISSION
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WASHINGTON, DM 20$ 3 0001 June 16. 1993 Docket No. 50-245 MEMORANDUM FOR:
File FROM:
James W. Andersen, Acting Project Manager Project Directorate I-4 Division of Reactor Projects - I/II
SUBJECT:
MILLSTONE UNIT 1 - CONFERENCE CALL TO DISCUSS VIDEO CAMERA REQUEST On June 9, 1993, the NRC staff and Northeast Nuclear Energy Company (NNECO) held a telephone conference call to discuss NNECO's request dated December 23, 1992, to install video cameras in lieu of continuous fire watches at Millstone Unit 1.
NNECO has continuous fire watches stationed in areas with Thermo-Lag 330 per Bulletin 92-01 guidance which states, " implement compensatory measures, such as fire watches, in accordance with plant procedures, consistent with those which would be implemented by either plant technical specifications or an operating license condition for an inoperable fire barrier."
In the December 23, 1993, letter, NNEC0 proposed to install cameras in the areas with Thermo-Lag, directed in such a way as to detect the presence of fire. NNEC0 also stated that the remote camera system would be monitored continuously. The staff has completed its review of NNECO's request and has determined that a remote camera monitoring system, in lieu of continuous fire watches, is not acceptable. The purpose of the June 9, 1993, telephone conference call was to present the bases for denying NNECO's request and to discuss possible alternatives NNEC0 may want to consider in lieu of the continuous watches currently employed at Millstone Unit 1.
The following major items were discussed during the conversation:
The staff stated that NNECO's request to install video cameras in lieu of continuous fire watches was being denied.
The staff stated that nuclear power plant fire protection programs are developed using defense-in-depth principles. The defense-in-depth principle holds that strengthening any one echelon can compensate for weaknesses in the other echelons. NNECO argued that a remote camera monitoring system is the equivalent of a continuous fire watch. The staff does not agree. As part of the defense-in-depth principle, a continuous fire watch enhances the fire prevention echelon by recognizing and immediately reporting fire hazards such as transient combustibles introduced into the area.
The fire watch can also compensate for an inoperable fire barrier in that the fire watch enhances the fire detection echelon by detecting the fire prior to the fire detectors activating and promptly notifying the control room of the size and nature of the fire and upon arrival of the f
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LlS0I 9307090163 930616 PDR ADOCA 05000245 F
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June 16, 1993 j
l fire brigade, directing it to the exact location of the fire. A remote 1
camera monitoring system cannot offer the same fire prevention or fire detection capabilities of a fire watch. Therefore, NNECO's request to i
utilize a remote camera monitoring system in lieu of continuous fire watches is not acceptable.
l The staff pointed out that in a limited number of cases, the staff has approved the use of camera monitoring in lieu of fire watches. Where camera monitoring was approved, it was mostly to mitigate overriding I
high radiation and ALARA concerns for the fire watches and, in some cases, to alleviate significant access problems.
The staff discussed possible alternatives to the continuous fire watch l
prior to the restoration of the degraded fire barriers. NNECO remarked that they are participating in the NUMARC testing program and the results will not be available until the end of the year. The staff stated that a possible near term alternative to the continuous fire.
watches, would be to use temporary detection systems in the areas with Thermo-Lag and employ an hourly roving fire watch. The staff, however, noted that this would require a Technical Specification (TS) change request (expedited request may be appropriate).
The staff also noted that suppression or video cameras combined with a 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> roving watch would not be acceptable to the staff for Millstone Unit 1.
As an alternative to a new TS change, NNECO inquired about the ongoing staff review of its request to remove the fire protection portion of the i
TSs out of the TSs and place them in a Technical Requirements Manual (TRM). The staff indicated that it is awaiting two things from NNECO to complete its review. The first being that_ NNECO-place the Fire Protection portion of the TSs into the Final Safety Analysis Report (FSAR) and, second, that NNECO supplement it's April 16, 1993, TS change l'
request to include a discussion of the relationship between the FSAR and the TRM. The staff indicated that it would process the TS change request as quickly as possible following receipt of the NNECO j
supplement.
i NNECO inquired about the status of the Haddam Neck exemption request concerning Thermo-Lag. The staff stated that the exemption is currently in concurrence and as written would be denied.
The staff noted that if the removal of the Fire Protection portion of the TSs is approved, NNEC0 may make changes to the approved fire protection program without prior approval of the Commission only if-those changes would not_ adversely affect the ability to achieve and maintain safe shutdown in the event of a fire.
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June 16, 1993 I
NNECO inquired about replacing Thermo-Lag with 3M materials, 3M is currently working with NUMARC regarding qualification.
In reference to the NNECO request for examples of qualified Thermo-Lag fire barriers, the staff cited Commanche Peak. The staff cautioned that NNECO should carefully review any replacement materials.
NNEC0 will contact the NRC staff regarding its decisions on alternatives and j
need for a meeting, meanwhile, the staff plans to issue its letter and supporting safety evaluation regarding NNEC0's December 23, 1992, request.
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James W. Andersen, Acting Project Manager.
Project Directorate I-4 s
Division of Reactor Projects - I/II t
i e
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a File June 16, 1993 NNECO inquired about replacing Thermo-Lag with 3M materials.
3M is currently working with NUMARC regarding qtalification.
In reference to the NNECO request for examples of qualified Thermo-Lag fire barriers, the staff cited Commanche Peak. The staff cautioned that NNECO should carefully review any replacement materials.
NNECO will contact the NRC staff regarding its decisions on alternatives and need for a meeting, meanwhile, the staff plans to issue its letter and supporting safety evaluation regarding NNECO's December 23, 1992, request.
Original signed by:
James W. Andersen, Acting Project Manager Project Directorate I-4 Division of Reactor Projects - I/II DISTRIBUTION:
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