ML20207D921

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Requests Div of Safety Technology to Take Lead in Providing Estimate Re Commission Paper on Fire Protection & Input to Be Provided by 850215
ML20207D921
Person / Time
Issue date: 12/31/1984
From: Vollmer R
Office of Nuclear Reactor Regulation
To: Speis T
Office of Nuclear Reactor Regulation
Shared Package
ML20151H089 List:
References
FOIA-88-92 NUDOCS 8808160217
Download: ML20207D921 (1)
v • d • e


Text

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MEMORANDUM FOR: Themis P. Speis. Director Division of Safety Technology M f_ dss *4 titi FROM: Richard H. Vollmer, Director Division of Engineering AMI

SUBJECT:

COMMISSION PAPER ON FIRE PROTECTION In a memorandum dated December 10, 1984 (copy enclosed) the EDO tasked NRR with the lead for preparation of a Commission paper on fire protection. As part of that paper, NRR is to "... provide a quantitative estimate of the public risk associated with fire from operating plants based on their current stctus; i.e., incomplete compliance with Appendix R. This estimate should be based on your review of pertinent existing PRAs that have been reviewed by NRC."

As we had previcusly discussed, DST should take the lead in providing this estimate. DE will provide :ny support you request. To meet the new date of March 15, 1985, for a paper to CRGR, your input will be needed by I

(. February 15.

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Richard H. Vollaer, Director I Division of Engineering

Enclosure:

As stated l cc: H. Denton w/o enci '

E. Case + 1 W. Johnston # F' FP Steering Co=,ittee A _/

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  • /f l JAN 3 1995 MEMORANDUM FOR: Faust Rosa, Chief, Instrumentation & Control Systems Branch, DSI FROM: Richard H. Vollmer Director Divisior of Engineering

SUBJECT:

COMMISSION PAPER ON FIRE PROTECTION In a meno dated December 10, 1904, the EDO tasked NRR with development of a Commission paper on fire protection. Part of this effort will involve revising the generic letter and its attachments, if appropriate, in light of convents already received from the Offices and Regions and af ter evaluatirg any corcents received from the public. A final generic letter and attachments, internally consistent and with a commentary on disposition of unused comments, would be needed by February 15.

Please convene those n' embers of your Fire Protection Working Group that are appropriate for this effort. The Director, DSI, concurs in your participation.

If other management concurrences are needed, please let me know.

r$ h Richard H. Vollmer, Director Division of Engineering cc: H. Denter.

E. Case FP Steering Comittee R. Bernero Aa

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Enclosure 3 LIST OF MEMORANDA (ATTACHED)

RELATED TO TA5KS OF THE FIRE PROTECTION WORKING GROUP Comments en Proposed STS Changes:

1. Memo from P. R. Bemis (Ril) to F. Rosa dated 1/8/85.
2. Memo from W. S. Little (RIII) to F. Rosa dated 1/8/85.
3. Note from W. Shields to F. Rosa dated 12/11/84.

(Note: The RI comments were conveyed to C. Grimes by C. Anderson by telephone.)

Comments on the Steering Committee Report

4. Memo from T. E. Murley (RI) to V. Stello dated November 27, 1984.
5. (Rll) to V. Stello dated November 15, 1984
6. Memo from Mero from J. J.

G.P. O'Reilly(R]II) to V. Stello dated November 14, 1984 Keppler

7. Memo from R. D. Martin (RIV) to V. Stello dated November 14, 1984
8. Memo from J. B. Martin (RV) to V. Stello dated November 14, 1984
9. Meno from R. C. DeYoung (IE) to V. Stello dated November 15, 1984 -
10. Meno from R. C. DeYoung to V. stello dated December 28, 1984.
11. Memo from H. R. Denton to V. Stello dated November 19, 1984.
12. Memo from G H. Cunningham III to V. Stello dated November 13, 1984
13. Memo from /. Stello to R. H. Vollmer dated January 3, 1985.

Other Documents 14 Federal Register 2056 dated January 15, 1985.

15. Draft of G.L. 85-01.
16. TAC e40015.

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i HEMORANDUM FOR: Richard H. Vollmer, Director  !

Division of Engineering, NRR l FROM: Victor Stello, Jr. I Deputy Executive Director Regional Operations and Generic Requirements

SUBJECT:

I COMMISSION PAPER Oft FIRE PROTECTION (YOUR ftEMORANDUti DATED DECEMBER 28,1984)

This is to confim Bill Kane's conversation with you. I do not plan to provide input to f(RR on the subject Comission paper at this time since it is a matter that will be reviewed by CRGR. It is important, however, that the ROGR staff contact (J. Conran) be kept informed of progress and any significant meetings that may occur between now and the CRGR meeting.

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Victor Stello, Jr.

Deputy Executive Director Regional Operations and Generic Requirenents ,

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T. E. Conlon, RI! -

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( S. D. Richardson, IE W. M. Shields., ELD -

FROM: F. Rosa, Chairman W ,, ,3 Fire Protection Policy Working Group -f m)

SUBJECT:

FIRE PROTECTION POLICY WORKING GROUP - REMAINING TASKS The purpose of this memorandum is to provide the W.G. with: 1) A status sumary of the Fire Protection Policy effort and related W.G. tasks, 2) The schedule and proposed agenda for the next W.G. meeting, and 3) A ccoy of recent documents related to this ef fort.

The Steering Comittee report is being placed in the POR and a request for public coments was published in the Federal Pegister on January 15, 1985.

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g Concurrently, a copy of the report is being sent to the nuclear utilities via Generic Letter 85-01 dated January 9,1985. It is expected that this G.L.

will be dispatched this week. The corcent period is 30 days. Coments on the report from the NRC Offices and Regions have already been received.

Enclosure 1 directs NRR, with assistance from IE and ELD, to prepare a Cormission paper on fire protection addressing activities tn date and the specific questions raised, and including recorrnendations for Comission approval. The proposed Comission paper will be submitted for CRGR review.

In support of the Comission paper effort, the Working Group has been assigned (s'eb Encl 6sure 2) the task of, "---revising the generic letter and its attach-ments, if appropriate, received from the Offices and Regions and af ter evalua-ting any coments received from the public." A comentary on disposition of unused coments is also required. The target date for completion of this task is February 15. (We are unlikely to meet this date since the public coment period expiration date is February 14.)

The W.G. (as a group) remains uninvolved with the Temporary instruction being l prepared by IE. Steve Richardson is interacting directly with the Steering Comittee on this. I 4

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Var. Addressees The status of our previously assigned task, the revision of the STS on fire protection, is as follows: Ccements on the STS draft transmitted to the W.G.

by my memorandum dated December 7,1984 have been received. These coments are being incorporated into the draft by Chris Grimes, in consultation with Don Brinkman (SSPB) in regard to STS format and policy. Chris is also pre-paring the rationale for rejected comments.

I am scheduling a meeting of the W.G. for January 24 (and 25 if necessary),

1985, at 9:00 A.M. in P-204 in Bethesda with the following agenda.

1. Review and approval of a final draf t of the STS.
2. Discussion of Office and Region comments on the Steering Cormittee report.
3. Determination of specific task assignments and schedule for completing the new W.G. assignment cited above.

The W.G. objectives at this meeting should be the completion of the STS task, and the establishmert of assignments for the new task that will result in a prcposed draf t revision of the G.L. and its attachments to incorporate the Office and Region comments prior to receipt of the public comments (expected about 2/22/85). The evaluation and incorporation of public comments can then be accceplished during the week of February 25, 1985 with a target date for i

\ submission of a final package to the S.C. of March 4,1985.

I believe that the Bethesda based members of the W.G. (V. Benaroya, C. Grimes, W. Shields, and F. Rosa - V. Moore is retiring from the NRC at the erd of this month) assisted by Tom Wambach can acccmplish the remaining W.G. tasks. Hew-ever, the Regional members of the W.G. (C. Anderson, T. Conlon, W. Little) are welcome to continue full participation; in any event, you will be kept fully informed and consulted prior to any final W.G. actien. Your comments on this arrangement are invited.

Enclosure 3 lists the memoranda and other documents contained in the attached pacYage. These documents are relevant to the material to be addressed at the upcoming meeting. (You may already have most of them.) Please review them prior to the meeting, f '

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Faust Rosa, Chairman

. Fire Protection Policy Working Group

Enclosures:

As stated cc: See attached list .. .

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R. H. Vollmer R. M. Bernero R. W. Housten cc w/

Enclosures:

T. Wambach

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., .. DEC 10 ES4 MEMORANDUM FOR: Victor Stello, Jr. , DEDROGR Harold R. Denton, Director, NRR Richard C. DeYoung, Director, IE FROM: William J. Dircks Executive Director for Operations

SUBJECT:

FIRE PROTECTION p0LICY STEERING COWi!TTEE RECOMMENDATIONS In a memorandum dated October 26, 1984, the Fire Protection Policy Steering Cemittee provided me with their recomended actions on the fire protection policy and program. Cements on these recomendations have been received from the appropriate program and regional offices. The individual comants are enclosed.

Tiiese coments, although generally supportive of the Steering Comittee's work, raise a nunter of serious. questions which need to be answered before we can proceed to the Comission on this matter. They are:

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1. Are all the recemendations technically justified from the safety standpoint?
2. Are the resource estimates correct?
3. How will the inspection program be impacted to the extent that resources will be diverted from other activities?
4. Considering the current status of fire protection capability at, operating plants, does the current risk dictate the reprograming of inspection resources for fire protection inspection?

'b. Is' the magnitude of the safety problem comensurate with the proposed actions; e.g., no further schedular exemptions?

6. Should the revised interpretations and questions and answers be issued and what impact will they have on the overall program?
7. Do the recomendations go beyond what the Con.nission intended in promulgating Appendix R7 In light of the above, I have decided to proceed in the following way:

1.. The Director, NRR, should release the report of the Steering Comittee to the pDR and invite coment by interested parties. Coments should be analyzed by NRR with assistance from IE and ELD as needed. This analysis should be provided as part of a Comission paper. -

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2. The Director, NRR, should provide a quantitative estimate of the public risk associated with fire from operating plants based on their current status; i.e., incomplete compliance with Appendix R. This estimate should be based on your review of pertinent existing PRAs that have been reviewed by.NRC. The ROGR staff should be kept infomed of progress in'this area. This estimate and associated basis should be provided in the Comission paper.
3. The Director, IE, should provide an evaluation of the reprograming of inspection activities that will be necessary in order to implement the Steering Comittee's recomendations regarding inspection. Inspection activities to be reprogramed shall be identified and a basis provided.

This report shall be provided to NRR for the Comission. paper and shall be consistent with the results of Task 2. --

4. The Director, NRR, with assistance from the Directors of IE and ELD should prepare a Comission paper that addresses the activities to date and provides specific recomendations for Comission approval. That paper should address the specific questions identified above. Target date for providing the paper to the CRGR for review is February 1,1985.
5. CRGR should review the proposed Comission paper, address each.of the

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above questions, and make specific recomendations to me not.later than f . '30 days after receipt from NRR.

I expect appropriate ranagement representatives from NRR, IE and the Steering Comittee to attend the CRGR meetings on this issue to respond to CRGR questions.

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William rcks Executive Director

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for Operations

Enclosures:

As stated cc: R. Minogue G. Cunningham .

Regional Administrators l

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..... JAN 3 7995 Faust Rosa, Chief, MEMORANDUM FOR: Instrumentation & Control Systems Branch, DSI Richard H. Vollmer, Director FROM: - Division of Engineering

SUBJECT:

COMMISSION PAPER Oft FIRE PROTECTION .

the E00 tasked NRR wi+.h development of a In a mer.o dated December 10, 1904, Part of this effort will involve Comission paper on fire protection. light of revising the generic letter A final and itsletter generic attachments, and if ap any corments received from the public. attachments, internally co unused comments, wuld be needed by February 15.

Please convene those members of ycur The Director, OSI,Fire Protection concurs in your Working Group tha appropriate for this effort.

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participation. '

If other management concurrer.ces are needed, please let me know.

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Richard H. Vollmer, Director Division of Engineering cc: H. Denten E. Case

- FP Steering Corrmittee R. Bernero

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Enclosure 3 LIST OF MEMORANDA (ATTACHED)

RELATED TO TASXS OF THE FIRE PROTECTION WORKING GROUP Comments en Proposed STS Changes:

1. Memo from P. R. .Bemis (RII') to F. Rosa dated 1/8/85. m.
2. Memo from W. S. Little (RIII) to F. Rosa dated 1/8/85.
3. Note from W. Shields to F. Rosa dated 12/11/84. n (Note: The RI comments were conveyed to C. Grimes by C. Anderson by telephone.)

Comments on the Steering Committee Report 4 Memo frca T. E. Murley (RI) to V. Stello dated November 27, 1984

5. (RII) to V. Stello dated November 15, 1984.
6. Memo Memo from frca J.

J.G. P.Keppler O'Reilly(RIII) to V. Stello dated November 14, 1984.

7. Memo from R. D. Martin (RIV) to V. Stello dated November 14, 1984.

/' i 8. Memo from J. 8. Martin (RV) to V. Stello dated November 14, 1984

', 9. Memo fron R. C. DeYoung (IE) to V. Stello dated November 15, 1984

10. Memo from R. C. DeYoung to V. stello dated December 28, 1984
11. Memo from H. R. Denton to V. Stello dated November 19, 1984.
12. Memo from G. H. Cunningham III to V. Stello dated November 13, 1984
13. Memo from V. Stello to R. H. Vollmer dated January 3, 1985.

Other Documents

14. Federal Register 2056 dated January 15, 1985.
15. Draft of G.L. 85-01.

16.. TAC #40015.

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..... JAN 6E MEMORANDUM FOR: Faust Rosa, Chairman Fire Protection Policy Working Group FROM: Paul R. Bemis, Acting Director Division of Reactor Safety

SUBJECT:

REVIEW 0F PROPOSED CHANGES TO FIRE PROTECTION STANDARD TECHNICAL SPECIFICATIONS As requested by your memorandum of December 7,1984, the Region 'II staff has reviewed the proposed changes to the fire protection sections of the Westing-house Standard Technical Specifications (STSs). It is recoerended that the enclosed changes be incorporated into the final revision of the sub,iect STS sections. Also, it is our opinion that an additional STS section which addresses the limiting conditions of operation and surveillance requirements for the reactor coolant pump oil collection system is required and should be incorporated into the STSs.

., If you have any questions, please advise. ~ ] .

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Paul R. , mis)t.(p _ , .

Enclosure:

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Coments on Proposed Standard Fire Protection Standard Technical Specifications cc w/ encl:

C. Anderson,'RI I W. Little, RIII C. Grimes, NRR V. Benaroya, NRR V. Moore, NRR

0. Parr, ASB i S. Richardson, IE CONTACTi T. E. Conlon -

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l gg_w ENCLOSURE COMMENTS ON PROPOSED STANDARD FIRE PROTECTION STANDARD TECHNICAL SPECIFICATIONS The Region 11 staff has reviewed the proposed revisions to the STSs pertaining to fire protection. The following recommanded changes should be incorporated into the STSs.

3.3.3.8 Action Statement. Revise this section as follows:

a. With any Function A fire detection instrument ~ in any fire detection zone or fire area shown in Table 3.3-11 inoperable, within the next one hour, establish a fire watch patrol to inspect the zone (s) with the inoperable instrument (s) at least once per hour, unless the instrument (s) is located inside the containment, then inspect the containment zone at least once per eight hours (or monitor the containment air temperature at least once per hour at the locations listed in STS 4.6.1.6).

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b. With any function B fire detection instrument within any fire zone or fire area shown in Table 3.3-11 inoperable, within one hour establish a continuous fire watch with backup fire suppres-sion equipment for those areas in which redundant safe shutdown systems or components could be damaged; for other areas, establish an hourly fire watch patrol,
c. Restore the inoperable instrument (s) to OPERABLE status within 14 days, or in lieu of any other report required by STS 6.9.1, prepare and submit a Special Report to the Commission pursuant to STS 6.9.2 within the next 30 days outlining the action

. taken, the cause of the inoperability and the plans and sched-ule for restoring the instrument (s) to OPERABLE. status,

d. The provisions of STSs 3.0.3 and 3.0.4 are not applicable".

The basis for adding the additional action statement to the fire detection STS is to assure that the action statements of STSs 3.7.11.2, 3.7.11.3 and 3.7.11.4 are implemented. This is impera-tive, since some types of fixed automatic fire suppressions systems (i.e., pre-action, water spray and deluge sprinkler systems and gaseous CO, and Halogen suppression systems) are actuated or tripped by a fire detection system.

4.3.3.8.2. Concur.

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Enclosure 2 Table 3.3-11. Concur; however, the above recomended change to STS 3.3.3.8 would list the limiting conditions for the Function 8 detection instruments.

3.7.11.1 Concur.

4.7.11.1. Do not concur. Fire protection systems supplied by untreated river 1.d. and lake water should be flushed at frequent intervals. For these type systems, a flusn once per six months is not considered excessive.

4.7.11.1. 2 & 4 Concur.

1.f (new e).

4.7.11.1. Concur only for those plants which have fire pumps that 19 (new f) take suction from water tanks which contain potable water. Refer to above coments for item 4.7.11.1.1.d.

4.7.11.1.2.. Concur, a.(2).

3.7.11.2. Concur.

4.7.11.2.c. Concur.

(1)(c).

4.7.11.2. Concur.

c.(2) 3/4.7.11.3. Concur.

3/4.7.11.4. Concur.

3/4.7.11.5. Concur. However, for Section 4.7.11.5.a., the reference to "in

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~ accordance with an established procedure" does not appear to be needed since STS 6.8.1 requires written procedures to be established, implemented and maintained for the fire protection program implementation.

3/4.7.11.6. Refer to the above comments on STS 3/4.7.11.5.

4.7.12.1 Concur. I l

3.7.13 Do no) concur. This section only requires the instrumentation, l switches and control circuits listed in Table 3.3-x to be operable. j lt does not address the operability of pumps, storage tanks, diesel l generators, batteries, etc., which are also required for the alter-native / dedicated system to be operable. This section should be modified accordingly. e 3.7.13 Action Statements. Do not concur. Safe shutdown equipment being inoperative for 60 days is considered excessive. This equipment i should not be inoperative for more than seven days.

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Enclosure 3 4.7.13.1 Concur.

through 4.

Table 3.3-x Concur.

3.7.14. Revise Applicability to read: "At all times."

The fire extinguishers provided within a plant are the first line of defense and should always be available for use in the event of a fire or emergency.

4.7.14. Concur in part. The following addition to the surveillance require-ment should be made:

" ....... manufacturers' recommendations and verifying that each extinguisher is located as designated in the Fire Hazards Analysis."

3.7.15. Concur.

4.7.15. Do not concur. The surveillance requirements for the battery powered emergency powered lighting units should be revised to read:

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Each of the abc.c emergency lighting units shall be verified to be

\ OPERABLE:

a. At least once per 31 days by:

(1) Performing an operational test to include verifying unit operation, electrolyte level and position of hydrometer discs (lead acid oni.v) of the emergency lighting units accessible J"ring plant operations to assure their operability and to verity it'+ the lamp are properly aimed.

(2) Conducting a maintenance test to include cycling battery and checking change-over setting of the emergency lighting units accessible during plant operationc to assure their operability,

b. At least once per 18 months:

(1) By performing an 8-hour capacity illumination test on at least 10% of the lighting units installed. if any nonconformicg lighting units are found, an additional 10% will be functional- l ly tested until a 10% sample with no apparent nonconformity is l identified. Samples shall be selected such that each lighting unit will be subjected to a capacity test eveiy 15 years.

(2) By performing an operational and maintenance test of the .

emergency lighting units not accessible during plant operations i to assure their operability. I

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c. Prior to returning an emergency lighting unit to functional status following any event which could affect its operability, performance of an operational test shall be conducted on the affected lighting unit. If more than one unit is involved an operational test shall be performed on a random sample of at least 10% of the lighting units to verify operability.

Bases 3/4.3.3.7. Concur.

Bases 3/4.7.11. Concur. ,

Bases 3/4.7.12. Concur.

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Bases 3/4.7.13. Concur, e Bases 3/4.7.14. Do not concur. The portable fire extinguisher and emergency lighting section should be divided into two sections as follows:

Portable Fire Extinguishers The portable fire exti .guishers are the first line of fire defense and are most effective when fires are in their early stages of

[. - developeent. Portable extinguishers provide the capability to protect safety-related equipment from fires in their incipient stages, but must be properly distributed throughout the plant and maintained in good operating condition to be effective. When an extinguisher is inoperable, it should be proeptly repaired or replaced.

Emergency Lighting Units The 8-hour emergency lighting units are provided in areas needed for l

. operation of safe shutdown equipment and in access and agrees routes l thereto. This equipment provides illumination for operators to manipulate required equipment concurrent during plant emergency shutdown operations with the lost of the normal illumination within the area. This equipment should be properly maintained and if inoperative should be promptly repaired or replaced consistent with the defense-in-depth philosophy.

6. 5. 2.8.e We do not understand why the frequency of the Emergency Plan and and f. Security Plan reviews is changed from 24 to 12 months under the review of the STS fire protection sections. It is suggested that this proposed change not be included with these fire protection cca ents.

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