ML20045G385
| ML20045G385 | |
| Person / Time | |
|---|---|
| Issue date: | 06/16/1993 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20045G374 | List: |
| References | |
| PROC-930616-01, NUDOCS 9307130285 | |
| Download: ML20045G385 (15) | |
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FIRE PROTECTION i
TASK ACTION PLAN.
1 (FP-TAP) t I
L 1
t a
f June 16,1993 i
Office of Nuclear Reactor Regulation 1
Plant Systems Branch j
Special Projects Section 9307130295 930707
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PDR COMMS NRCC CORRESPONDENCE PDR w-
FIRE PROTECTION TASK ACTION PLAN EXECUTIVE
SUMMARY
A reassessment of the NRR reactor fire protection program was performed in response to the programmatic concerns raised during the review of Thermo-Lag fire barriers (Part IV of the Thermo-Lag Action Pian). The results were provided in the Report on the Reassessment of the NRC Fire Protection Program of February 27, 1993. This Fire Protection Task Action Plan (FP-TAP) addresses implementation of the recommendations made in the reassessment.
NRC STAFF ACTIONS ALREADY COMPLETED o
Issued two information notices discussing test results of fire barriers other than Thermo-Lag (FP-TAP Part I)
Requested information from vendors of fire barriers other than Thermo-o Lag (Part I) o Planned small-scale fire testing of fire barriers other than Thermo-Lag (Part I) o Assessed staff resources needed for implementation of the Thermo-Lag Action Plan and of the Fire Protection Task Action Plan (Part I)
ELANNED ACTIONS o
Revise NRC fire protection regulation (Appendix R) (Part I) o Complete the review of fire barriers other than Thermo-Lag (Part I) o Assess current information management systems (Part I) o Develop fire protection training program for NRC staff reviewers (Part I) o Assess recommendations for further study and need for new initiatives (Part II) o Confirm that current Fire Risk Scoping Study addresses all safety-significant issues (Part IV) o Apply lessons learned from the reassessment of the fire protection program to other NRR programs if warranted (Part V) 1
- FIRE PROTECTION TASK ACTION PLAN (FP-TAP) t IMPLEMENTATION OF THE RECOMMENDATIONS MADE IN THE REASSESSMENT OF THE NRC FIRE PROTECTION PROGRAM REPORT OF FEBRUARY 27, 1993 INTRODUCTION A reassessment of the NRR reactor fire protection program was performed in response to the programmatic concerns raised during the review of Thermo-Lag fire barriers (Part IV of the Thermo-Lag Action Plan). The results were provided in the Report on the Reassessment of the NRC Fire Protection Program of February 27, 1993. This Fire Protection Task Action Plan (FP-TAP) addresses implementation of the recommendations made in the reassessment.
The FP-TAP is divided into four parts.
It addresses implementation of the following reassessment report recommendations and followup items.
Part !
Eight major recommendations for action' Recommendations 1-1 through 1-8 Part II Four recommendations for further study Recomendations 2-1 through 2-4 Part III Five confirmation issues Recommendations 3-1 through 3-5 Part IV Other Issues A personal computer-based project management program is used to track the subtasks needed to implement the reassessment recommendations. The program identifies the recommendations, implementing tasks and subtasks, schedules, and assigned resources. A Gantt chart is attached to the FP-TAP.
The FP-TAP will be revised as needed to incorporate new tasks and to account for changing resources, work assignments, and priorities.
Some of the recommendations for further study (Part II) and the confirmation issues (Part III) may involve significant resource implications. The staff will first perform preliminary assessments to determine whether or not any of the recommendations or issues will require new initiatives.
If so, the staff will first consider at least a qualitative cost / benefits analysis before fully implementing the recommendation. The action plan will be completed within the stated schedules if sufficient resources are available.
The following sections identify the individual recomendations, the scope of the implementing tasks, the estimated staff effort and technical assistance (resources), durations and completion dates, and status.
1 Implementation of the part of Recommendation 1-2b that addressed reevaluating the reviews done for qualification testing of electrical equipment is addressed in the Equipment Qualification Task Action Plan (EQ-TAP).
FP-TAP June 16, 1993
PART I RECOMMENDATIONS FOR ACTION This part of the FP-TAP addresses the recomendations characterized as most significant in the reassessment of the NRC fire protection report of February 27, 1993.
RECOMMENDATION 1-1. FIRE PROTECTION REGULATION REVISION Reconnendation:
The activities in the NRC Office of Research (RES) relating to a potential revision of the fire protection regulations should by strongly supported.
Scope:
Coordinate RES activities relating to the proposed revision of the fire protection regulations.
t Staff effort:
Under development.
Tech assistance: Under development.
Duration:
3 years.
Completion date: August 1995.
Status:
Started. The Plant Systems Branch (SPLB) is closely coordinating with RES activities relating to the proposed revision of the fire protection regulations.
Technical assistance funds, currently planned for fiscal year 93, need to be estimated for the duration of the effort.
Additional efforts related to this recomendation are addressed under Recommendation 1-7.
RECOMMENDATION 1-2a. FIRE TEST ACCEPTANCE CRITERIA i
Recommendation:
Current staff activity to clearly document a set of criteria for reviewing fire barrier endurance tests should continue i
to receive high priority and continue to receive close management oversight.
Scope:
Complete development and issuance of the staff position on fire endurance test acceptance criteria.
Status:
No action is needed through the FP-TAP.
Implementation of this recommendation is currently incorporated in the Thermo-Lag Action Plan.
RECOMMENDATION 1-2b. FIRE BARRIER SYSTEMS OTHER THAN THERMO-LAG AND E0 TESTING Recomendation:
The Plant Systems Branch, NRR, should reevaluate the reviews done for fire barriers other than Thermo-Lag and for electrical equipment qualification testing (EQ).
1 FP-TAP June 16, 1993
.9
Scope:
Assessing the previous staff reviews of qualification testing of fire barrier systems other than Thenno-Lag.
Assess the ability of fire barrier systems other than Thenno-Lag to meet NRC fire protection guidelines and requirements.
Staff effort:
12 months.
Tech assistance: $125K Duration:
15 months.
Completion date: May 1994.
Status:
Started.
The staff's intention to review fire barrier systems other than Thermo-Lag was identified in Parts I and II of the Thermo-Lag Action Plan. A detailed plan for assessing the reviews done for qualification testing of other fire barrier systems and to review each system is now provided in the FP-TAP. This activity will be deleted from the Thermo-Lag Action Plan.
Implementation of the part of Recommendation 1-2b that addressed reevaluating the reviews done for qualification testing of electrical equipment is addressed in the Equipment Qualification Task Action Plan (EQ-TAP). This activity will not be tracked in the FP-TAP.
RECOMMENDATION 1-3. ASSESS MANAGEMENT INFORMATION SYSTEM NEEDS Recommendation:
Management should initiate follow-up actions to identify specific areas to be improved in developing an integrated management infonnation system.
In addition, senior agency management should set clear expectations for the staff's use of such a system.
Scope:
Near term:
Identify the databases that currently reside within NRR, determine their limitations and capabilities, and make the information available to others in NRR.
Long term: Evaluate existing management tracking systems and information retrieval systems to assess the extent to which they meet NRR office needs.
Staff effort:
Under development.
Duration:
18 months.
Completion date: December 1994.
FP-TAP June 16, 1993
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'l Status:
Started.
PMAS has.the lead for implementing this recommendation.
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RECOMMENDATION 1-4. ASSESS RESOURCES NEEDED FOR THERMO-LAG AND FP-TAP REVIEWS Recommendation:
Additional staff resources may be appropriate,.in the short term, to address the Thermo-Lag Action Plan and to address these recommendations.
Scope:
Determine resources needed to address the Thermo-Lag Action l
Plan.and to implement the fire protection program i
reassessment-report recommendations.
Staff effort:
2 weeks.
l Duration:
2 months.
Completion date: June 1993.
Status:
Done. SPLB assessed the NRR resources available to f
implement the Thermo-Lag Action Plan and the FP-TAP in accordance with the schedules identified in the action pl ans. A Senior Fire Protection Engineer has been added to the NRR staffing plan to ' assist in the completion of the action plans.
Efforts are currently underway to fill the position.
l As noted in the FP-TAP, agency resources needed to fully implement some recommendations are still being developed.
Both the Thermo-Lag Action Plan and the FP-TAP will be-revised to reflect resource needs as appropriate.
i RECOMMENDATION 1-5. DEVELOD FIRE PROTECTION TRAINING PROGRAM
. Recommendation:
The Plant Systems Branch Chief, NRR, should initiate discussions with the other NRR branches, the Office for Analysis and Evaluation of Operational Data, and the Office of Research with the goal of developing a fire protection training course (or courses) for staff reviewers, regional i
and resident inspectors, and for the staff involved in l
following up on problem indications.
Scope:
Identify key personnel within the Office of Personnel, AEOD, RES, TTC, NRR, and the' regions-and solicit their needs and j
ideas for fire protection training. ' Formation of a task force or working group-will be considered.
l Propose to NRC management a fire protection training program for staff reviewers, regional and resident inspectors and for the staff involved in problem indicators follow-up.
Staff effort:
6 months.
t FP-TAP June 16, 1993 i
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Tech assistance: $200K.
Duration:
16 months.
Completion date: June 1995.
Status:
Future. Technical assistance will be needed to develop the training program. Full implementation of the training program, which is expected to take several years, will not be tracked in this action plan.
This task will end when the final training program is finalized.
RECOMMENDATION 1-6. COORDINATION OF FIRE PROTECTION REVIEWS AND INSPECTIONS Recomendation:
The Plant Systems Branch Chief, NRR, should initiate discussions with the other NRR branches and the regional offices with the goal of developing a coordinated approach to fire protection and systems reviews and inspections. A pilot project to undertake one coordinated review and one coordinated inspection may be an appropriate step in such a program. The scope of the staff's fire protection inspection should be reevaluated in light of the insights from the Region I special fire safety inspections. The scope of the fire protection review and inspection should be checked against the recommended list of areas in Table 10.2.2 of Enclosure I to the reassessment report.
Scope:
Reevaluate the scope of the staff's fire protection inspections in light of the insights from the Region I special fire safety inspections.
Assess the areas listed in Table 10.2.2 of Enclosure 1 of the reassessment report and determine if the fire protection review and inspection programs address the following issues.
Adequacy of manual fire fighting effectiveness Adequacy of local control capability for ventilation systems / dampers Adequacy of fire brigade notification and response procedures I
Adequacy of fire barrier elements Adequacy of protection from control systems interactions
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Adequacy of equipment protection from fire suppression system actuations Potential vulnerabilities due to broken or leaking flamable gas lines FP-TAP June 16, 1993
4 Potential vulnerabilities due to seismic / fire interactions Adequacy of sprinkler installations Adequacy of fire safe shutdown capability and procedures Adequacy of Technical Specifications in addressing upgraded fire barriers Adequacy of in-place detector testing Adequacy of fire damper testing Adequacy of licensee QA programs for fire protection Adequacy of Fire Hazards Analyses and fire analyses performed by licensees (i.e., 50.59 reviews)
Effect of fire barriers and cable coatings on ampacity Review documents such as current review and inspection guidance and procedures (for example, Standard Review Plan, inspection modules, and office letters); reports documenting reviews and inspections; and recent generic communications.
The assessment will be used to determine whether or not there are weaknesses with the staff's current review and inspection practices.
Advise management of the results of the assessment and recommend revised review and inspection approach, if warranted.
If needed, revise SRP, inspection modules, office letters, etc. to incorporate revised approach.
Staff effort:
13 months.
Duration:
24 months.
Completion date:
February 1996.
Status:
Future.
Preliminary assessment indicates that adequate coordination between fire protection engineers and systems engineers currently exists. However, SPLB (with support from other branches and regions, as appropriate) will assess the scope of the fire protection reviews and inspections and will propose, if warranted, a revised approach that is better focused on safety.
RECOMMENDATION 1-7. SELF-INDUCED STATION BLACK 0UT STUDY Recommendation:
The Plant Systems Branch, NRR, should give high priority to the recent study of self-induced station blackout to deal FP-TAP June 16, 1993
i with fires.
In addition, the study should be expanded since the Region I inspections have indicated that concerns can remain even for those plants which only selectively shut down electrical power systems.
Scope:
Continue the current review of self-induced station blackout with contractor. support.
SPLB will review the recomendation to expand the study to include those plants which only selectively shutdown electrical power systems.
Staff effort:
3 months Tech assistance: $234K.
Duration:
18 months Completion date: November 1994 Status:
Started. A technical assistance contract is currently in place for the study of self-induced station blackout.
If l
the study is expanded, additional TA funds may be required.
RECOMMENDATION 1-8. REASSESS THE "FIVE" HETHODOLOGY Recomendation:
The effectiveness of the Fire Induced Vulnerability Evaluation (FIVE) Hethodology should be reassessed for use in the Individual Plant Examination External Events (IPEEE)
Program.
In addition, the IPEEE program plays such a significant role in addressing seismically-induced fire scenarios that the staff should place special emphasis on this part of their review of the IPEEEs.
Scope:
A potential weakness has been identified in the "FIVE" methodology diagram (screening process) that is not consistent with staff expectations. RES will determine what EPRI did during training, determine if what the chart states is true in the way industry conducts the methodology, and determine what is being done in IPEEEs.
The staff will place appropriate emphasis on seismically induced fire scenarios in their review of the IPEEEs.
Staff effort:
Under development.
Duration:
6 months.
Completion date: December 1993.
j Status:
Started. RES has the lead on this issue and is currently preparing a response to the recomendation for NRR consideration.
FP-TAP June 16, 1993
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PART II RECOMMENDATIONS FOR FURTHER STUDY 1
This part of the FP-TAP addresses the recommendations for further study from the reassessment of the NRC fire protection report of February 27, 1993. Some of the fo11cwing recornendations may involve significant resource implications. The staff will first perform preliminary assessments to determine whether or not any of the recommendations will require new initiatives.
If so, the staff will first consider at least a qualitative cost / benefits analysis before fully implementing the recommendation.
RECOMMENDATION 2-1. BI0 FOULING OF FIRE WATER SYSTEMS Recommendation:
The Plant Systems Branch, NRR, should assess the implications of biofouling on the fire protection system and develop a recommendation for management review.
Scope:
Assess the implications of biofooling on the fire protection system and develop recommendations for management consideration.
1 Staff effort:
6 weeks.
Duration:
6 months.
Completion date: June 1994.
Status:
Future.
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RECOMMENDATION 2-2. OPERABILITY RE0VIREMENTS FOR SAFE SHUTDOWN E0VIPMENT Recommendation:
The Plant Systems Branch, NRR, should work with the i
Technical Specifications (TS) Branch, NRR, to determine:
whether existing operability requirements and/or I
administrative controls for Appendix R safe shutdown equipment during operating and shutdown conditions are adequate and to determine if any additional requirements are appropriate for Appendix R safe shutdown equipment.
Scope:
SPLB will work with the TS Branch to address the recommendations above which includes all aspects of backfit and current implementation.
Staff effort:
4 months (TA funding or RES may be needed to do cost-benefit analysis.)
Duration:
18 months.
Completion date: November 1995.
Status:
Future.
FP-TAP June 16, 1993 4
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RECOMMENDATION 2-3. FIRE BARRIER SURVEILLANCE RE0VIREMENTS Recomendation:
The Plant Systems Branch, NRR, should determine whether pre-1979 Technical Specifications for active fire barriers (e.g., dampers, fire doors, etc.) are adequate.
Staff effort:
3 weeks.
Duration:
4 months.
Completion date: February 1995.
Status:
Future.
Preliminary assessment indicates that adequate procedures are in place for active fire barriers. Ongoing plant specific inspections will continue to verify that the procedures are adequate. SPLB will reconsider this recomendation at a later date.
RECOMMENDATION 2-4. FIRE BARRIER RELIABILITY Recomendation:
Fire barrier elements are qualified with negative pressure cond tions existing on the side of the barrier exposed to the fire. This may not be conservative if fires can occur where the pressure on the exposed side of the barrier is actually positive. Also, seals that contain air passages can allow flames and hot gases to pass through. The Plant Systems Branch, NRR, should consider specific testing to determine whether fire barriers are sufficiently reliable.
Scope:
RES is currently reviewing fire barrier reliability under Generic Issue 149.
SPLB will assess the scope and priority of the RES effort.
SPLB will advise RES of the results of its assessment if changes in the scope or priority are warranted.
Staff effort:
3 months.
Duration:
12 months.
Completion date: February 1995.
Status:
Future.
PART III CONFIRMATION ISSUES This part of the FP-TAP addresses the confirmation issues identified in the l
reassessment of the NRC fire protection report of February 27, 1993. Some of the following confirmation issues may contain significant resource implications. The staff will first perform a preliminary assessment to determine whether or not any of the following renmendations will require new j
initiatives.
If so, the staff will first consider at least a qualitative cost / benefits analysis before fully implementing the recomendation.
FP-TAP June 16, 1993
RECOMMENDATIONS 3-1. 3-2. 3-3 AND 3-4. GENERIC ISSUES Recommendation:
The Plant Systems Branch, NRR, should review the following issues and confirm that the NRC's current requirements or on-going programs adequately address the underlying safety concern:
GI-148 Adcquacy of Manual Fire Fighting Effectiveness (3-1).
GI-147 Fire Related Control Systems Interactions (3-2).
GI-57 Equipment Protection from Fire Suppression Systems (3-3).
.GI-106 Broken or Leaking Flammable Gas Lines (3-4).
Scope:
SPLB will review the issues above and provide confirmation or alternative action.
Staff effort:
4 months.
Duration:
19 months.
Completion date: October 1995.
Status:
Future.
RECOMMENDATION 3-5. FIRE PROTECTION CONFIRMATORY ISSVES L
Recommendation:
The Plant Systems Branch, NRR, should review the technical issues identified in Table 10.2-1 of Enclosure 1 of the reassessment report and confirm that the they do not raise significant safety concerns or require additional staff review. The Plant Systems Branch, NRR, should initiate a dialogue with NRR and the Office of Research to confirm that there are no safety significant issues from the Fire Risk Scoping Study which remain unresolved. The Plant Systems Branch, NRR, should identify any additional actions necessary, in their view, to strengthen the NRC Fire Protection Program.
Scope:
Assess the following technical issues and determine whether or not they raise any significant safety concerns.
Capability to man the fire brigade and shutdown the plant from outside the control room simultaneously.
Acceptability of the fire brigade responding to a fire outside the plant or protected area Adequacy of local control capability for ventilation systems / dampers FP-TAP June 16, 1993
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Adequacy of fire brigade notification and response procedures Acceptability of the thermal damage threshold currently assigned to electrical cables in light of the Sandia test results' Effect of fire barriers and cable coatings on ampacity f
(Thermo-Lag Action Plan)
Effects of fire and smoke on plant equipment Adequacy of sprinkler installations
- l Acceptability of using foam'and deluge nozzles in high fire hazard areas Adequacy of fire safe shutdown capability and procedures Adequacy of in-place detector testing Adequacy of licensee QA programs for fire protection Adequacy of Fire Hazards Analyses and fire analyses (i.e., 50.59 reviews) performed by licensees Adequacy of NRC reporting requirements for fire events Reassess the fire risk scoping study and coordinate any unresolved issues with RES (SPLB).
Perform a programatic review of the fire protection review and inspection programs and identify any additional action necessary to strengthen the programs (SPLB).
Staff effort:
Under development.
Duration:
24 months (preliminary estimate).
Completion date: May 1997 (preliminary estimate).
Status:
Future. There is overlap between most of the following-confimation issues and those previously identified under Recomendation 1-6 and Recomendations 2-1 through 3-4.
To the extent practicable, SPLB will assess the confirmation-issues as part of and integral to the reviews and assessments performed under Recommendation 1-6 and 2-1 through 3-4.
Any confirmation issue that is not fully assessed and disposed of during these reviews will be scheduled for review as resources allow.
FP-TAP June 16, 1993
we PART IV OTHER ISSUES This part of the FP-TAP identifies issues for staff action that are related to the fire protection program reassessment, but that were not specifically identified in the reassessment of the NRC fire protection report of February 27, 1993.
LESSONS LEARNED Issue:
In a memorandum of August 17, 1992, to J. Taylor, EDO, the Commission requested that the staff address several issues raised in the OIG's report on the staff's review and acceptance of Thermo-Lag fire barrier material.
T. Murley, NRR, stated in a memorandum to J. Taylor, EDO, of August 21, 1992, that the staff would apply the lessons learned from the fire protection program reassessment to other NRR programs and would include corrective actions for programmatic improvements where necessary.
Responsibility for this assessment was assigned to PMAS.
(This activity is also being tracked as WITS Item 9200200.)
Scope:
To determine the applicability of the lessons learned from the staff reassessment of the fire protection program to other NRR technical areas.
Staff effort:
Under development.
Duration:
18 months.
Completion date: December 1994.
Status:
Started. The assessment is being performed by NRR/PMAS.
Application of lessons learned to the qualification testing of electrical equipment is. addressed in the EQ-TAP. This activity will not be tracked in the FP-TAP.
GARTT CHART The attached Gantt chart shows the recommendations with the scheduled duration for completion and the completion status. Triangles (deltas), if any, indicate zero duration tasks such as milestones or tasks that have not yet-been assigned a specific duration.
[ Filename: G:\\THERMOLA\\FP-TAPO.D0]
FP-TAP June 16, 1993
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