ML20151S520
| ML20151S520 | |
| Person / Time | |
|---|---|
| Issue date: | 07/29/1982 |
| From: | Crews J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | Taylor J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| Shared Package | |
| ML20151H089 | List:
|
| References | |
| FOIA-88-92 NUDOCS 8808150250 | |
| Download: ML20151S520 (10) | |
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MEMORANDUM FOR:
James M. Taylor, Director, Division of React 2
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Jesse L. Cr$ws, Director, Division of Residht;rhactcrtM'df FROM:
Projects and Engineering Programs
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SUBJECT:
TI 2515/XX - INSPECTION OF FIRE PROTECTION BACKFIT /e "C.
REQUIREMENTS OF 10 CFR 50, APPENDIX R g&@l 5 % J p...
By memorandum dated June 30, 1982, w'e provided comments on the subject
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draft TI.
One of the principal concerns expressed was that the draft TI called upon the inspector to perform a detailed evaluation of safe
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shutdown cooling that would normally be done by NRR.
In a recent telephone call to Jerry Zwetzig, Jim Stone explained the reason.for pggg this; namely, that if the licensee determines no modifications are 664b~w I
necessary to meet 10 CFR 50, Appendix R, Section III.G, a statement to Qo this effect is all that is required.
Thus, in this case, no detailed submittal is made for this area, no NRR review is performed, and no SER d., y Q -
is prepared.
The draft TI thus appears to at tempt to comper.wte for t'ie lack of NRR review by requiring the inspector to conduct a detailed tecInical review to confirm the adequacy of the licensee's overall design.
In view of the limited resources available in the regions, we question the desirability and need for the proposed action.
The basis for our position is as f.ollows:
,, In general, the licensees of all operating plants have already sul>mitted a Fire Hazards Analysis which has been reviewed by NRR.
According to the Statements of Consideration, which accompanied issuance of 10 CFR 50.48 and Appendix R, the reason that some installations which had been approved'previously by NRR were unacceptable under Section III.G of Appendix R was because they relied upon the use of fire retardant coatings 3r.d fire detection and suppression systems without specifying a physical separation distance to protect redundant systems.
Thus, previously approved systems need to be reevaluated under Section III.G to determine the reliance placed upon fire retardant coatings rather than physical separation.
If the licensee determines that he has taken credit for fire retardant coatings, he must propose modifications, which are reviewed by NRR, with conclusions documented in an SER.
In this case, the inspector can inspect the modifications defined in a written SER.
If no reliance was placed upon fire retardant coatings, however, the licensee can merely affirm this and no description of modifications is needed.
If, in this case, confirmation of the 3
licensee's evaluation is needed by the NRC, this is best accomplished e
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not by,, inspection, but by reviewing the licensee's original Fire Hazardf Analysi' ~and the staf f's SER.
If these documents do not s
indicate the granting of credit for fire retardant coatings, the licensee's affirmation of adequacy is confirmed.
If the documents do reflect the granting of credit for fire retardant coatings, however, further explana' tion by the licensee is indicated.
In summary, the justification for requiring a detailed technical review by the inspector is that, if the licensee claims no modifications are needed to meet Appendix R,Section III.G, the licensee need not make a technical submittal and there is, hence, no SER against which to in-spect. We maintain that if the licensee makes this claim, the most cost-effective verification is provided not by a detailed and compre-hensive technical review performed by the inspector (s), as proposed in the draft TI, but by having NRR "review again those portions of the licensee's Fire Hazards Analysis and the staff's SER dealing with credit for the use of fire retardant coatings.
Based on the foregoing, we affirm the comments in our memorandum of June 30,1982, on this subject.
In this regard, we note that the reference for comment No. 3 transmitted by that memorandum should be "Appendix 1, III.G.3."
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W Je e r. cr as, Directer D'ision(o Resident, Reactor Projects nd Engineering Pronrams cc:
J. C. Stone, IE D. M. Sternberg, RV T. W. Bishop, RV G. B. Zwetzig, RV i
CONTACT:
G. B. Zwetzig, RV
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,I TO ALL LICENSEES AND APPLICANTS FOR OPERATING LICENSES Gentlemen:
SUBJECT:
IMPLEMENTATION Of FIRE PROTECTION REQUIREMENTS i
i In the spring of '1984, the Comission held a series of Regional Wor (shops on 1
the implementation of NRC fire protection requirements at nuclear power plants. At those workshops, a' package of recently-developed NRC gu,idance was distributed to each attendee which included NRC staff responses to industry questions and a document titled "Interpretations of Appendix R."
Tbecover memo for the package explained that it was a draft package which would b'e issued in final form via Generic Letter 4110 wing the workshops.
The final guidance is appended to this letter, and is in the same format as the draft package. i.e., "Interpretations of Appendix R" and responses to '
industry questions.
Both the "Interpretations *' and the responses h ve been
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'mooified from the draft package, and a number of industry. questions; raised at..
s or subsequent to the workshops have been added and answered.
This package
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.tl represents the official agency position on all is' sues covered.
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.In the lettered sections below, some additional topics are covered hhich also i
bear on the interpretation and implementation of NRC fire protection l
requirements. The topics are: (A) schedular exemptions (B) revised
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inspection program, (C) docunientation required.to demonstrate compliance, (D)
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applicability of'GDC-1 to firs protection systems,'End'(E)'no.tification cf the NRC when deficiencies are discovered.
l-i A.
Schedular Exempt'fons The Appendix R implementation schedule was established by the Comission in 30 CFR!SO.48(c), promulgated together with Appendix R in November of 1980.
Allowing time to evaluate the need for alternative or dedicated shutdown systems, which require prior NRC approval before installation, and time for design of and NRC review of such systems, the Commission envisioned that implementation of Appendix R would be co[nplete in four to five years, or-approxiraately by the end of 1985. Many schedule extensions were granted by
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the staff'under the "tolling provision," 50.4B(c)(6), and under 10 CFR 50.12, the longest of which now extends into_1986.
Some licensees have proceeded expeditiously to implement Appendix R and are now finished or nearly finished with that effort.
Others have engaged in lengthy negotiations with the staff while continuing to file requests for schedule extensions, and thereby have barely begun Appendix R modifications needed to' comply with Sections Ill.G and Ill.L.
Schedule extension requests have been received seeking implementation dates of 1990 or beyond.
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Astile50.48(c)s~chedulewasintendedtobeaone-timeschedule comencing in the 1980-1982 timeframe and ending in the 1985 timeframe, extensions well beyond this sthedule (particularly where major modifications..
remain to be completed) undermine the purpose of the schedule, which was to..,
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achieve expeditious compliance with NRC fire protection requirements. The NRC will therefore grant no 'further extensions to the 50.48(c) schedules. When a f
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licensee's schedule expires, compliance will be expected.
If compliance cannot be achieved by that date, the licensee will be required to submit and justify a minimum schedule for completion of fire protection modifications, and to supply interim measures to compensate for the lack of compliance.
Whether or not enforcement action will be taken will be decided by the NRC Region in consultation with NRC headquarters.
In submitting a schedule which
.goes beyond the current 50.48 deadline, the licensee will be required to --
1 demonstrate that it has endeavored in good faith to complete modifications on schedule. A ' showing of a good faith attempt to complete implementation on
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schedule may mitigate any enforcement action which may be taken for substantial noncompliance with NRC requirements.
The NRC is currently reviewing all dockets of plants covered by the 50.43 schedule to detsemine schedule deadlines.
When this review is completed, each licensee will be informed of the deadlines and asked to confirm whether, in the licensee's view, they are correct.
i B.
Revised Insoection Program (to be supplied by IE)
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' - ~c-i C. - Documentation Required to Demonstrate Compliance l
The "Interpretations" document attached to this letter states that.,
where' the licensee chooses not to seek prior NRC review and approvai of, for example, a fire area boundary, an evaluation must be performed by a fire protection engineer (assisted'by others as needed) and retained for future 1
NRC audit.
Evaluations'of this type must be written and organized to facilitate review by a person not involved in the evaluation.
Sect on B of
'$ Appendix P may be used as a guideline for what the evaluation should contain.
F All calculations supporting the evaluation should be available and all S
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assurrptions clearly stated at the outset.
Failure -to have such an evaluation
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available for an area where Appendix R is clearly not met will be taken as prima facie evidence that the area does not comply with NRC requirements, and may result in enforcement action.
i O.
Arplicability of GDC-1 to Fire Protection Systems Fire protection systems are considered to be "important to safety" within the meaning of General Design Criterion 1 of Appendix A to 10 CFR Part 50.
For such systems the licensee is therefore required to have'and maintain aqualityassuranceprogramadequatetoassurethatthesesystemswill perform their functions when called upon.
Fire protection systems Ire not i
"sasety-ralated" and are therefore not within the scope of AppendixjB to 10
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CFR Part 50.
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E.
Notification of the NRC When Deficiencies are Discovered Licensees are reminded of their general obligation to notify the NRC promptly of any deficiency discovered in the fire protection program which reduces the level of fire protection in the plant below NRC requirements.
Such notification should include a description of the deficiency, its safety significance, the proposed corrective actions and schedule, and interim i
corpensating measures.
Such notifications should be directed to the appropr16te NRC Regional Of fice.
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s FIRE PROTECTION POLICY AND PROGRAM REVIEW REFERENCES 1.
Memorandum from W. J. Dircks to H. R. Denton (and others), Review of NRC Fire Protection Policy and Programs, dated September 13, 1984.
2.
Memorandum from R. H. Vollmer to H. R. Denton (and others), Work Group to Assist Fire Protection Policy Steering Committee, dated September 20, 1984.
3.
Memorandum from R. H. Vollmer to H. R. Denton and R. C. DeYoung, First Meeting of Fire Protection Policy Steering Committee, dated September 21, 1984.
4.
Code of Federal Regulations Title.10, Section 50.48, "Fire Protection."
5.
--, Part 50, Appendix R, "Fire Protection Program for Nuclear Power Facilities Operating Prior to January 1,1979."
6.
Federal Register Notice 45, 76602, "Fire Protection Program for Operating Nuclear Power Plants (Final Rule), November 19, 1980."
- 7.
Generic Letter 83-33 from D. G. Eisenhut to All Licensees and Applicants of Nuclear Power Reactors, NRC Position on Certain Requirements of Appendix R, dated October 19, 1983.
- 8.
Guidance Package Handout (unsigned) at Regional Fire Protection Workshops, "To All Licensees Subject to Appendix R to 10 CFR Part 50," dated March 23, 1984. :
"Interpretations of Appendix R." :
"Questions Raised During the Nuclear Utility Fire Protecticn Seninar." :
"Questions Raised by Other Utili ties. " :
"Chemical Engineering Brar,ch/ Fire Protection Section Staff Guidance for Compliance With Appendix R to 10 CFR 50."
- 9.
Memorandum from R. Eberly, et al (Fire Protection Engineers) to R. L.
Ferguson, Differing Professional Opinion - "Interpretations of Appendix R," dated May 2,1984. :
" Amended Interpretations of Appendix R."
4 10.
Memorandum from R. H. Vollmer to DSI Division Directors, DP0 and Inter-pretations of Appendix R, dated May 3,1984.
l 11.
Memorandum from R. L. Ferguson to R. Eberly, 'et al (Fire Protection Engineers), Differing Professional Opinion - "Interpretations of Appendix R," dated May 7,1984.
12.
Memorandum from V. Benaroya to R. H. Vollmer through W. V. Johnston.
Differing Professional Opinion -
"Interpretations of Appendix R,"
dated May 11, 1984.
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- 13. Memorandum frem R. H. Vollmer to H. R. Denton, Differing Professional Opinion - "Interpretations of Appendix R," dated May 31, 1984.
Memorandum from W. V. Johnston fo R.
H'. Vollmer, Differing Professional 14.
Opinion - "Interpretations of Appendix R," dated June 13, 1984.
15.
Memorandum from C. B. Ramsey and J. M. Ulie thru C. C. Williams to R. L. Spessard, Supporting Information for Differing Progessional Opinion -
"Interpretations of Appendix R."
dated May 24, 198,4.
16-Memorandum from James P. O'Reilly to R. H. Vollmer, Feedback from Region II Workshop Meeting on Interpretations of Appendix R, dated May 25,198t 17.
Memorandum from John A. Olshinski to D. G. Eisenhut, Fire Protection Features -- Watts Bar, Docket Nos. 50-390 and 50-391, dated August 8, 1984
- 18. Memorandum from R. L. Spessard to J. G. Keppler, NRC Appendix R Workshop Input (F03031584), dated May 29, 1984.
19.
Memorandum from S. L. Trubatch to D. Garner, et al, Guidance for Implementation of Fire Protection Requirements for Operating Reactors,10 L.F.R. 50, Appendix R, dated May 29, 1984.
20.
Vugraphs, "History of Fire Protection for Nuclear Power Plants,"dated May 29, 1984.
(These were presented at the Comission Meeting
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on May 30,1984. )
21.
Vugraphs, "Basic Staff Criteria for Evaluating Exemption Requests."
(These were presented at the Comission Meeting on May 30,1984.)
- 22. Transcript of Comission Meeting, "Discussion of Appendix R (Fire Protection)," held on May 30, 1984.
- 23. Memorandum from Wm. Olmstead to R. H. Vollmer, Fire Protection - Response to Trubatch Memo on Appendix R Guidance, dated June 27, 1984.
24.
Memorandum from R. L. Spessard to R.' H. Vollmer, Additional Feedback from Regional Workshops on Fire Protection (AITS F03033184), dated July 27, 1984.
25.
Memorandum from J. G. Keppler, to R. C. DeYoung, Comissioners' Request for Infomation on Fire Protection Differing Professional Opinion and Inspection Experience, dated July 17, 1984.
- 26. Memorandum from R. L. Spessard to J. N. Grace, Additional Infomation on Inspection Findings to Support a Commissioners' Request, dated July 27, 1984.
27.
Vugraphs, NRC Visit to the Haddam Neck Plant, dated September 4,1984.
m e j 28.
Letter from Nuclear Utility Fire Protection Group to Chairman Palladino, Fire Protection Program Under 10 CFR Part 50-Appendix R, dated September 6,1984 l
29.
Letter from Richard P. Crouse to Chainnan Palladino, Commission Meeting of May 30, 1984 on the Status of the Implementation of Fire Protection Requirements, dated August 28, 1984.
30.
Memorandum from V. 8enaroya through W. V. Johnston & R. H. Vollmer to H. R. Denton, Differing Professional Opinion, dated March 12, 1984.
31.
Memorandum from D. G. Eisenhut to Jesse L. Fuches, Board Notification for DPO, dated April 13, 1984.
32.
Memorandum from H. R.'Denton to L. W. Barry, Quarterly Report:
Differing Professional Opinions, dated May 9,1984.
33.
MeNrandum from F. Rosa to H. R. Denton, Recommended Resolution of R. L. Ferguson DPO, dated May 30, 1984.
34.
Memorandum from H. R. Denton to F. Rosa, Differing Professional Opinion:
Interpretation of Appendix R, dated July 12, 1984.
35.
Memorandum from F. Rosa to H. R. Denton, Differing Professional Opinion:
Interpretation of Appendix R, dated July 6,1984.
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36.
Memorandum from H. R. Denton to F. Rosa, Differing Professional Opinion:
Interpretation of Appendix R, dated August 9,1984.
Issue (I'nfomation), Fire Protection Rule 37.
SECY-83-269, Rulemaking(SECY-82-267), dated July 5,1983.
for Future Plants 38.
SECY-83-77, Policy Issue (Infomation), Fire Protection Rule Schedules and Exemption (Quarterly Report No. 8), dated February 25,.1983.
39.
.SECY-84-77, Policy Issue (Information), Post-Fire Safe Shutdown Capability Inspections, dated February 14, 1984.
40.
U. S. Nuclear Regulatory Commission, Inspection and Enforcement Manual, TI 2515/62/Rev.1, Inspection of Safe Shutdown Requirements of 10 CFR 50, Appendix R (Section III.G) at Nuclear Power Plants Licensed to Operate Before January 1,1979, dated September 11, 1983.