ML20202D344
| ML20202D344 | |
| Person / Time | |
|---|---|
| Issue date: | 11/21/1997 |
| From: | Stolz J NRC (Affiliation Not Assigned) |
| To: | Lochbaum D UNION OF CONCERNED SCIENTISTS |
| References | |
| NUDOCS 9712050006 | |
| Download: ML20202D344 (5) | |
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I November 21, 1997 Mr. David A. Lochbaum-Union of Concerned Scientists 1616 P Street NW, Suite 310 Washington, DC 20036
Dear Mr. Lochbaum:
On September 10, 1997, the Nuclear Regulatory Commission (NRC) staff met with you and Mr. Paul Gunter of the Nuclear Information and Resource Service to discuss fire barrier penetration seals at nuclear power plants.
The meeting summary, which included a transcript of the meeting, was issued on September 29, 1997, and copies were sent to you, Mr. Gunter, and the Public Document Room. The NRC staff has reviewed the transcript for items that require follow-up.
Enclosed is a list of these items and our response to each item.
If, after reviewing the transcript, you have additional items that require follow-up, or if you have further questions on our responses in the enclosure, please let us know.
The staff is preparing a response to Congressman Edward J. Markey's letter of May 8,1997, on penetration seals and will provide you a copy after it has been completed.
Sincerely,
/S/
John F. Stolz, Director Project Directorate I-2 Division of Reactor Projects - I/II Office of Nuclear Rea: tor Regulation
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List of Follow-up Items DISTRIBUTION
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Ibvember 21, 1997 Mr. David A. lochbaum Union of Concerned Scientists 1616 P Street NW, Suite 310 Washington, DC 20036
Dear Mr. Lochbaum:
On September 10, 1997, the Nuclear Regulatory Cossaission (NRC) staff met with you and Mr. Paul Gunter of the Nuclear Information and Resource Service to discuss fire barrier peaetration seals at nuclear power plants. The meeting summary, which included a transcript of the meeting, was issued on September 29, 1997, and copies were sent to you, Mr. Gunter, and the Public Document Room. The NRC staff has reviewed the transcript for items that require follow-up.
Enclosed is a list of these ite;ns and our response to each item.
If, after reviewing the transcript, you have additional items that require follow-up, or if you have further questions on our responses in the enclosure, please let us know.
The staff is preparing a response to Congressman Edward J. Markey's letter of May 8,1997, on penetration seals and will provide you a copy after it has been completed.
Sincerely, O
o n F. Stolz, Director P oject Directorate I-7 ivision of Reactor Projects - I/II Office of Nuclear Reactor Regulation
Enclosure:
List of Follow-up Items
4 i FOLLOW-UP ITEMS FROM SEPTEMBER 10, 1997 MEETING BETWEEN THE NUCLEAR REGULATORY C0ftlISSION (NRC),
THE UNION OF CONCERNED SCIENTISTS (UCS), AND THE NUCLEAR INFORMATION RESOURCE SERVICE (NIRS)
TO DISCUSS FIRE BARRIER PENETRATION SEALS 1.
Page 25 of the transcript, line 12: The staff mentioned SECY papers and Staff Requirements Memoranda (SRMs) related to the fire protection rulemaking, but did not provide the specific numbers.
Response
The SECY papers and SRMs related to the fire protection rulemaking are as follows:
" Options for Pursuing Regulatory Improvement in Fire Protection Regulations for Nuclear Power Plants," June 21, 1996
" Staff Requirements - SECY-96-134 - Options for Pursuing Regulatory Improvement in Fire Protection Regulations for Nuclear Power Plants,"
October 2, 1997 SECY-97-127, " Development of a Risk Informed Performance Based Regulation for Fire Protection at Nuclear Power Plants," June 19, 1997
" Staff Requirements - SECY-97-127 - Development of a Risk Informed Performance Based Regulation for Fire Protection at Nuclear Power Plants,"
September 1, 1997 2.
Page 27, line 8: The staff stated that it needed to close the loop on Duane Arnold and Maine Yankee, the two plants that may not be in compliance with Section III.M of Appendix R.
Response
The staff will provide the UCS and NIRS the update of NUREG-1552 after it has been completed (estimated for the end of 1997). This report will address plant-specific compliance with Section III.M of Appendix R.
3.
Page 33, line 17: The staff said it recently had processed, or was currently processing, a change to NRC Inspection Procedure 64704 which provides guidance to inspectors on penetration seals.
Response
A revision to Inspection Procedure 64704 was issued on September 8, 1997, and was sent to UCS, NIRS and the Public Document Room as Enclosure 7 to the meeting summary issued on September 29, 1997.
ENCLOSURE
I -
4.
Page 37, line 10: The staff was not certain that the Salem Updated Final Safety Analysis Report (UFSAR) incorporated by reference the fire hazards analysis and the safa shutdown analysis.
Response
Section 9.5.1.1 of the Salem UFSAR states, "The Salem Fire Protection Program is described in several docue nts:" Two of the documents listed in this section are "a report which establishes the basis for demonstrating a capability to achieve and maintain post-fire safe shutdown in accordance with Appendix R to 10 CFR 50" and "a report which outlines the Fire Hazards Analysis performed for the Salem Huclear Generating Station in accordance with USNRC Branch Technical Position BTP-APCSB 9.5-1 Appendix A ' Guidelines for Fire Protection for Nuclear Power Plants'."
5.
Page 40, line 20: Mr. Gunter discussed an interview with Mr. Hitoshi Takahashi of Dow Corning in which Mr. Takahashi said that if one out of 100 tests passes, the design can be qualified.
Response
The staff will review this issue and provide a response in separate correspondence.
6.
Page 41, line 9: Mr. Gunter stated that Mr Takahashi reported that hydrogen gas seeping from silicone foam barriers caused an explosion at the Perry plant.
Response
The staff will review this issue ar.d provide a response in separate correspondence.
7.
Page 62, line 14: Mr. Lochbaum asked about the risk significance of penetration seal deficiencies.
Response
The update of NUREG-1552 (see item 2) will address the risk significance of penetration seal deficiencies.
8.
Page 71, line 25: Mr. Lochbaum asked if the staff had witnessed any tests without the damming boards, dr
6
. Response:
1he fire protection staff has no records of having witnessed fire endurance tests of silicone-based fire barrier penetration seals without damming boards.
9.
Page 80, line 1: Mr. Gunter noted that the copy of BTP-APCSB 9.5-1 that was available in the Public Document Room had " superseded" stamped on it.
lie asked on page 81, line 16, about the legal standing of a superseded document.
Responsr.:
A plant is normally licensed to meet requirements or positiois that are in effect at a particular time.
If these requirements or positions are super *,eded by later documents, the olant is required to maet the new requirements or positions only aftvr the NRC has conducted the backfit l
process.
The backfit process is a formal, systematic review to ensure I
that thanges are proper 1/ justified and suitably defined. The process is intended to ensure order, discipline, and predictability to enhance optimal use of NRC staff and license resources. A backfit analysis is required and f' must be determined based en that analysis, that the backfit will provide a substantial increase in overall protection of public health and safety and that the direct and indirect costs for the facility are justified in view of the increased protection.
With res)ect to the fire protection plan, backfitting a piant that complies with tie guidance of Appendix A to BTP-APCSB 9.5-1 and the appropriate requirements of Appendix R would not provide a substantial increase in overall protc-tion of public health and safety.
10.
Page 95, line 15: Mr. Gunter asked whether the American Society for Testing and Materials (ASTM) E-136 was available to the staff when o
Appendix R was issued.
Response
The American Society for Terting and Materials originally published
' Method of Test E 136-65 for Determining Noncombustibility of Engineering Materials" as a full test standard in 1965. Therefore, it was available to the NRC staff in 1980 when Appendix R Pas issued. However, we could not find evidence that the NRC staff endorsed or considered thn stancard at the time of issuance of Appendix R.
For example, ASTM E-136 is not referenced in either the fire protection branch technical positions, the Standard Review Plan, or the Statement of Considerations for Appendix R.
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