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MEtCPMOUM FOR: Those on Attached List l FROM: J. Nelson Grace. Director Division of Quality Assurance, Safeguards, and Inspection Programs j Office of Inspection and Enforcement l l
SJFJECT: PROP 0:,ED AGEND; FOR APPENDIX R LESSON. I LEARNED WOMSu.0PS l
1 IE p-c;:ses tne followin5 agenda for the subject workshops. The w0rishops are intencec to be technical in nature and will cover those subjects cescribed I in IE Infcmation Notice U-09. Ine de.sigr.ated speakers will present a snort talk or, their assigned subject (s). Members of the tect.nical staff will then t:r.ter:ain plant specific questions it crder to illustrate the guidance cen-tained in IE Infor..ation t otice 84-09. Meeting arrange.ents and notifications te lice. sees and applicuts are to be conducted by Regional Offices. Assigned te:hnical s;,eakers and agreed upon worishop dates are contained in enclosure (l).
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Tirs Subject Speaker 0900-0915 Opening Remarks Region 1
091f-0930 Development of the IE Information Notice Topical Area Presentations:
0930-11:00 3% Fire Areas CMEB Fire Barrier Testing CMEB and Cor.;iguration Protection t! Equipment IE s Necessary to Achieve Hot Shutoown 1 A5B M-g.icensee nforn,ance Reassessment with A:pendix J for R '
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2 Identification of Safe IE Shutdown Systems and. .
Componentsi Combustibility of Electrica) lMEB.
Cable Insulation 11:00-12:00 Lunch Break 12:00-1:30 -
Detection and Automatic CMEB Suppression CF - Applicability of 10 CFR 50, ELD Apper. dix R,Section III.L.
InstruT.entation Necessary ASB f
for Alternative Snutdown
// Frocedures for Alternative ASB Shutdown Capability
// Fire Protectivn Features ASB for Cold Shutdawn Syster.s RCP Oil Collection Systems CMEB 1:30 - 4:00 General Question and Ar.swer All Session 1
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!c{i son Grace,
- J ector Division cf Qualit ' Assurance, Sofeguards, and Inspection Programs Of fice of Inspection and Enforce:ent Er'. closure: Listing of Speakers and Wo-kshop Cates e
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- Addressees - Memorandum dated February 22, 1984 Thomas T. Martin, Director Division of Engineering and Technical Programs .
Region I John A. Olshinski, Director Division of Engineering and Operational PFograms.
Region II R. Lee Spessard, Director Division of Engineering Region III Richard P. Denise, Director Division of Resident Reactor Projects-and Engineerins Progracs Region !Y Thoc,es W. Bishop Director Divisior, of Reactor Safety and Projects Ee; ion V Darrell G. Eisenhut, Director Divisicn of Licensing Office of Nuclear Reactor Regulation -
Ric..ard H. Vollner. Director :
Civision of Engir.eering 1 Cffice of Nuclear Re6ctor Regulation i Roger J. Mattson, Director i Divisicn of Systen.s Integration Office of N; clear Reactor Regulation Edsard L. Jerdan Director Civision of Energency Preparedness ,
and Engineering Response '
Office of Inspection and Enforcement William J. Olcstead Regulations Division Director and Chief Counsel .
Office of the Executive Legal 0; rector l
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Distribution: .
DCS 058, ORPS reading DQASIP reading, '
P. F. McKee, IE .
S. Richardson, IE,.
J. G. Partlow, IE W. M. Shields, ELD J. A. Wermiel, NRR V. Benacoya, NRR T. V. Wambach, NRR W. F. Xane, ED3 C. J. Anderson, RI T. E. Conlon, R11 l C. C. Williams, RIII ;
M. E. Mgrphy, RIV . l L. E. Whitney, IE 7 ',- l E. L. Jorcan, IE G. N. Nelson, lE l
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._. f Listing of Speakers an_d Workshop Dates -
Techn_ical Speakers _
Leon E. Whitney IE Nicholas E. Fioravanta ASB Randall Eberly CNEB or i.
Dennis J. Kubicki CMEB William M. Shields ELD Workshop _ Dates
- RII 16 March 1984 Atlanta, GA Rill 23 March 1984 0' Hare International Airport RV 5 April 1984 Walnut Creek, CA RI IS April 1984 King of Prussia, PA RIV 26 April 1934 Dallas, Texas 1
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MEMORANDUM FOR: Harold R. Denton, Director -
Office of Nuclear Reactor Regulation ;
THRU: f'I Richard of Division H.Engineering Vollmer, Director4 .g'46 William V. Johnston, Assistant Director /Y Materiais, Chemical &EnvironmentalTechd(olo s
FROM: . Victor Benaroya, Chief Chemical Engineering Branch
SUBJECT:
DIFFERING PROFESSIONAL OPINION On February 24, 1984 I received the memorandum (Enclosure 1) from tr. Robert Ferguson, Section Leader, Fire Protection Section, Chemical Engineering Branch, offering his own Differing Professional Opinion (DPO) from the Safety Evaluation Report written by Mr. Dennis Kubicki of the Fire Protection Section, and reviewed end concurred in by myself and the
( Assistant Director. In accordance with Manual Chapter NRC-4125-035f, I am forwarding to you, through Messrs; Johnston and Vollmer, Mr. Ferguson's DPO. Enclosure 2 attaches my comments on the DPO.
Enclosure 3 attaches
. William V. Johnston's memo to R. Vollmer. commenting on the DPO.
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Victor Benaroya, Chief 6 l Chemical Engineering Branch j
Enclosures:
As stated ec: R. Vollmer W. Johnston i R. Ferguson T. Wambach 0
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Enclosure 1 FEB 2 41984 -
MEMORANDUM
- FOR: Victor Benaroya, Chief '
Chemical Engineering Branch t
FROM: i Robert L. Ferguson, Section Leader Fire Protection Section- {
. Chemical Engineering Branch *
)
SUBJECT:
DIFFERING PROFESSIONAL OPINION - HADDAM NECK REQUES FOR EXEMPTION FROM SECTION III.G.2 FOR THE CONTROL ROOM
- 1. Prevailino Staff View The licensee should be granted an exemption from the requirements of Section III.G.2 of Appendix R to 10 CFR 50 for the fire protection of the-Control Room.
- 2. Orioinator's Ooinion 2.1
( The requirements of Section III.G.2 should not be considered appli-cable for control rooms where reasonable separation does not exist.
They require separation be 1 or 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire barrier or 20 feet of horizontal distance which is f ree of intervening combustibles.
Section III.G.3 sets forth the. NRC's. requirements for control rooms which do not have reasonable separation of redundant systems:
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Alternative or dedicated shutdown capability and its associated circuits, independent of cabics, systems or shall be provided: components in the area, room or zone under consideration, a.
Where the protection of systems whose function is required for hot shutdown does not satisfy the require-ment b.
of paragraph G.2 of this section; or Where redundant trains of systems required for hot shutdown . located in the same fire area may ba subject to damage from fire suppression activities or from the rupture or inadvertent operation of fire suppression systems.
In addition, fire detection and a fixed fire suppression system shall be installed in the area, room or zone under consideration." -
These design basis protective features are specified in the rule '
tecause it is not possible to predict the specifir: conditions under which fires may occur and propagate. -
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j Victor Beryaroya 2'- . FEB 2 4 Iga
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The stahf has accepted the proposed alternate shutdown capabili
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(ACP) room. for the contrni room which is not independent of the control The proposed capability requires that the licensee rees-
.tablish control'of the plant from the control room within one hour and that certain equipment in the t '
either the fire or the firefighting activities.ntrol, room be undamaged by 2.-3 The licensee has not justified that the ACP should not be inde-
- pendent of the control room and be capable of maintaining the plant in the hot shutdown conditions for a prolonged time period
. from outside the control room as required by Section III.G:3.
2.4 The licensee has not investigated the safety cobsequences of the control room not being habitable for a prolonged time period (i.e. , significantly longer foi 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />). ~
2.5 The licensee has not investigated the safety consequences of com-ponent damage in the control room which exceeds that assumed in his analysis. For example, the licensee hasJnot considered the effects of a descending hot layer associated with the postulated control room fires, the licensee has not estimated the environment produced by such a hot layer, and has not estimated the effects of such environments on the instrumentation in the control room. The licensee has not estimated the effects of a fire in the main con-( trol panel should the automatic suppression system fail to function.
The plant's licensee hassystemi'and ventilation not estimated .the effects the effects of a of of the loss cabinet scch fire on the ventilation the shutdown systems systems.on the conditions in the control room and on 2.6 In view of the unknowns associated with control room fires, the staff does not have reasonable assurance that safe hot shutdown conditions Control can be maintained if the ASC is not independent of the room.
- 3. .
0-ioinator's Assessment of Consecuences The granting of this exemot-ion undermines the NRC's req =irements for the fire protection for safe shutdown capability.
- 4. Related Efforts
- None. ,
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Robert L. Ferguson, Section Leader Fire Protection Section
- Chemical Engineering Branch t cc: H. Denton .
.R. Vollmer DGo.hst'onT .
T. Wambach
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. * .** ..- MAR 5 1984 Encloture 2 f, . . -
MEMORANDUM FOR: Robert L. Ferguson, Section leader Fir:e Protection Section, CMEB FROM: Victor Benaroya, Chief Chemical Engineering Branch
SUBJECT:
D]FFER]NG PROFESSIONAL OP]NION - HADDAM NECK REQU FOP. EXEMPT]ON FROM SECTION III.G.2 FOR THE CONTROL ROOM -
l By your memorandum to me of February 24, 1984, you commented on the i exemption room.
from Section III.G.2 of Appendix R for the Haddam Neck control You disagree with the granting of the exemption. .
2.1 The only area in a nuclear power plant that the Rule makes a distinction regarding the acceptable level of fire protection is inside containment.
Therefore, a licensee can achieve compliance 'in the control room by '
meeting either Section 1)).G.2 or ))I.G.3. The Rul t provides relief . ,
through the exemption process. -
Where a licensee can demonstrate to -
the staff's satisfaction that an equivalent level of safety has been provided in any area, an acceptable basis for granting an exemption exists.
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As you now, to meet the requirements of Appendix R,. control
/ rooms need an area-wide fixed fire suppression system; however, we ~
k have i t. granted relief from that requirement to all those who requested j
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Additional guidance regarding potential control room fires and the appropriate methods for providing protection f rom the ef fects of such fires is given in the letter from H. R. Denton to S. A. Bernsen of Bechtel Power Corporation dated April 20, 1982.
With regard te the control room at Haddam Neck, the licensee, con' sistent with our guidelines and positions,Thas proposed a combination of system modifications and fire protection which. in the opinion of' the reviewer in CMEB, provides a level of fire protection safety equivalent to that required by Section III.G.2 of Appendix R. I have teviewed the reviewer. this. evaluation ano agreed with the conclusion reached by 2.2 Dur position on Safe Shutdown Capability is dalineated in Section 5.b of BTP CP.EB c.5-1, and our guidelines on Alternative Shutdown capability are in Section 5.c of BTP CMEB 9.5-1 (Section III.G.3 and III.L of Appendix R). To my knowledge, the requirement is .
that alternate shutdown capability has to be independent of the "
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. Robert L. Fergusen. .
specific fire area, . room or zone under consideration. Our evaluation
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of the control room at Ha'ddam Neck is consistent with this criter; ion.
lhe the area of consideration'is auxiliary control panel, a fire at the main control console or t
Although most licensees / applicants have proposed alternate shut-down systems which are independent of the control room, the safe shutdown system you approved for Fermi 2 does not meet the i criterion you stated. ] agree with you that from a fire protec ' ,
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tion point of view, alternate shutoown capability whi a is i independent level of the control room probably would provide a higher of protection. !
'The system found acceptable meets ou'r minimum requirements, and gives us reasonable a'ssurance that the }
plant can be shut down safely. .
j The extent of postul;ted damage and the period of time that the 1 control room -is inaccessible to plant personnel is discussed in !
the previously mentioned Denton to Bernsen letter. By memo from !
me to 0. Parr (ASB), dated December 12, 1983,. we informed ASB that, "As stated in the letter from H. R. Denton to S. A. Bernsen of April 20, 1982, we consider that for licensing purposes it would !
l take approximately one hour for o'perators to return te the control room after it was evacuated as a result of a fire in the control room.
.Outside of the circumstances under which the operators can
(' return to the control room, and the actions they can take are
\ delineated in the above mentioned letter." You concurred in the
. transmittal of the meno tb.at gave the position stated in the letter.
2.3 As i stated III.G.2 previously, compliance can be achieved by.raeeting either or 1]I.G.3. Since in our opinion the licensee .has justifi'ed the. adequacy of the fire protection by meeting the requirements of III'.G.2, there was no need to address the requirements of III.G.3.
2.4 Based on the guidance we provided ue licensee (Denton to Bernsen letter) that the control room would not be habitabl,e for approxi-mately one hour, the licensee showed that the plant can be safely shut of down and maintained in a safe condition during that period time.
However, ASB, using our guidelines.' in their independent ,
evaluation, concluded that at Haddam Neck ine control rocm can be i I
evacuated safely for much longer than one h'our.
2.5 Our guidance to the licensee for fires ia the control room was that the two adjacent cabinets to the cabinet involved in a f Oe
.will.also experience fire damage and, thus, equip.ent associn.ed with these three cabinets would 'not be available to the operhter.
I believe room these same criteria wer~e used in the Fermi 2 control evaluation. .
The licensee based the analysis on the conse-quences associated with the loss of function of either the entire ' l main control console or all of the auxiliary control panel. The. i
- l. l'icensee complied with our criteria. !
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Robert L. Ferguson MAR ' 5 1.cN I do not believe that there is any evidence from any actual' data
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. or tests performed to date that a "desconding hot layer" will be characteristic of a-control room fire. There is, and probably '
always will be, uncertainty associated with fire propagation and effect.
- Howeve'r, based on the continuous presence of licensed i operators, the existence of a detection system, the understanding
' o,f the importance of the control room by all personnel who have
- access to the control room, and.the relatively low fuel load,1 am of the opinion that we have reasonable assurance that, with the -
I proposed modifications, a fire that 4ould start in the control room '
will be extinguished before an extensive hot layer could be formed' jresulting in damage that would affect safe shutdown. '
2.6 In my opinion, the licensee performed the control room fire pro-tection evaluation acccrding to our guidelines. Based on our evaluation, requirements. our reviewer has concluded that they meet o.ur minimum As I stated previously, I agree with you that from a fire protection point-of-view, alternate shutdown capability which a higheris independent of the control room probably would provide level of protection. As you know, independence of con-trol room incorporates design changes. 'BNL will evaluate the' petits of these changes. ~
3.
Both the fire protection engineer and 'the systems engineer who ' '
have reviewed the fire protection proposed for Haddam Neck control
( room have concluded that ,the level of fire protection meets our requirements.11 have reviewed their evaluation and concur with their conclusion. Since the proposed level of fire protection meets 'our requirements, granting of the exemption is consistent (,. ., ,
with our regulations in general a'n'd Appendix R in pafticular. *
'. Therefore, I do not agree with you that granting of this exemption -
undermines shutdown the NRC's requirements for the fire protection for saf e capability.
\. , 3en Victor Benaroya, ChiefL ,
Chemical Engineering Brancr.
cc: H. Denton .
R. Vollmer -
W.JJohn m e .
T. Wambach e
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MAR 6 , %34 MEMORANDUM FOR: Richard M. Vollmer, Directcr Division of Engineering FROM:
William V. Johnston, Assistant Director .
Materials, Chemical & Environaental Technology
SUBJECT:
DIFFERING PROFESSIONAL .
OPINION OF ROBERT FERGUSON
Reference:
4 Memorandum dated February 24, 1984 from Robert Ferguson to Victor Benaroya. -
I have reviewed the differing professional opinion proffered by Mr. Ferguson.
In addition, I reviewed in detail and concurred in .the Safety Evaluation Report Appendix onRthe forHaddam the control Neck request for exemption from Section III.G.2.of room.
1 Mr. Benaroya, in his response to Mr. Ferguson, outlined what I agree to be theythe aresalient that: points in response to Mr. Ferguson's concerns. In summary,
( (a)
Exemptions to the requirements of Section III.G.2 are appropriate ano have been granted in a large number of previous reviews where the requirements are either impractical (or inappropriate) as for the case of fixed suppression. systems in the control room, and/or -
. equivalent protection can be provided by other means.
(b) Specific guidance on the duration of time when the control room could be considered uninhabital was given in a public letter from Mr. Denton to Mr. Bernsen in 1982. This letter also recognized the concept of limited damage to the . control room from a fire because of the low fuel load, continuous presence of licensed personnel, and sensitive detection systems. This letter was sub-ject t.o co_nsiderable thoughtful review and concurrence before it was issued. Mr. Ferguson was in concurrence.
(c) The licensee has provided procedures .and proposed modifications and analyses which reviewers in CMEB and ASB have found to be acceptable in the light of the above considerations. I found i
the matic. SER to be rigorous and technically sound, and very syste- !
This was among the best SERs I have reviewed.
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( I do not consider Mr. Ferguson's concern that the exemption undermines NRC's requirements to.be* compelling.
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_ William V. Johnston, Assistant Director Materials, Chemical & Environmental -
Techn' ology ,
cc: H. Denton ~
V. Benaroya R. Ferguson T. Wambach
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