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UNITED STATES 8
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WASHINGTON, D. C. 20655 April 11, 1986 MEMORANDUM FOR:
Those on Attached List FROM:
James G. Partlow, Director Division of Inspection Programs Office of Inspection and Enforcement
SUBJECT:
MEETING TO DISCUSS THE EFFECT OF SECY-85-306 The Comissioners have voted approval of SECY-85-306, Staff Reconynendations Regarding the Implementation of Appendix R to 10 CFR 50. This document in-cludes the draft Generic Letter on Fire Protection, guidance for enforcement actions concerning fire protection requirements, guidance on the granting of schedular exemptions, policies regarding inspection scheduling, requirements 4,
on the documentation of analyses, clarification on quality assurance, licensee notification and event reporting requirements, and a standard fire protection m
license condition.
A meeting will be held on May 7,1985 in Bethesda, Maryland to review the impact of the Comission's vote on the Post-fire Safe Shutdown Inspection Program. This meeting will commence at 9:00_a.m. and end at approximately 4:00 p.m.
It w'11 be held in the f_ urth floor c_onfEence_ roqm (Room 465) in the East West Towers, o
Snuth Buildin. 5peakers will include representatives from NRR and IE.-~7t~is important7 at at least or,e working level inspector from each region attend.
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All other addressees are strongly urged to be represented at this meeting. An agenda for the meeting is enclosed.
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6,v Jame[ G. P rtlow, Director Divition of Inspection Programs Office of Inspection and Enforcement
Enclosure:
As stated
Contact:
Leon E. Whitney 49-29668 cc:
J. Taylor, BNL R. Starostecki, RI R. Walker, RII C. Norelius, RIII W
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Multiple Addressees Stewart D. Ebneter, Director Division of Reactor Safety j
Region I Al Gibson, Director Division of Reactor Saf ty i
Region II Carl J. Paperiello, Director Division of Reactor Safety Region III Eric H. Johnson, Acting Director Division of Reactor Safety and Projects Region IV Dennis F. Kirsch, Directcr Division of Reactor Safety and Projects Region V Robert E. Hall, Head Division of Engineering Technology Brookhaven National Laboratory f
Jane A. Axelrad Director
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Enforcement Staff Office of Inspection and Enforcement Robert M. Bernero, Director Division of Boiling Water Reactor Licensing Office of Nuclear Reactor Regulation Hugh L. Thompson Jr., Director Division PWR Licersing - A Office of Nuclear Reactor Regulatica Frank J. Miraglia, Director Division PWR Licensing - B Office of Nuclear Reactor Regulation e
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Meeting on SECY-85-306, Appendix R Safe Shutdown May 7, 1986 4th Floor Conference Room, Room 465 last West Towers, South Building Bethesda, Maryland Agenda Time Function / Topic Speaker / Division Leader 9:00 Introduction and R. Vollmer, DD:IE
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Discussion of Agenda L. Whitney, ORPB 10:00 SECY-85-306/J01BlandResultant L. Whitney, ORPB B
Staff Requirements 11:30 Enforcement Policy T. Poindexter, Enforcement 12:00 Lunch
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1:00 Generic Letter J. Stang, NRR 2:00 Changes to TI 2515/62 L. Whitney 2:30 SAFFIRE Computer Code L. Whitney 3:00 Open Discussion All 9-O aut -
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UNITED 8TATES
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WASHING TON, 0. C. 206H JUL 171986
[. '. c d I.0: 15 EGM 86-04 MEMORANDUM FOR: Thomas E. Murley, Regional Administrator, Region 1 J. Nelson Grace, Regional Administrator, Region II Ja.mes G. Keppler, Regional Administrator, Region III Robert D. Martin, Regional Administrator, Region IV John B.' Martin, Regional Administrator _Eggion y FROM:
James -M Taylor, Director Office-of Inspection and Enforcement
SUBJECT:
ENFORCEMENTGUIDANCEONFIREPikOTECThN
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By memorandum dated March 7,1986 from S. J. Chilk to Y. Stello the staff was directed to revise its proposed fire protection Severity Level guidelines so they tre consistent with 10 CFR Part 2.
The Canission was concerned that the proposed guidelines required an actual fire for Severity Levels I and II.
After receiving regional comments on proposed revisions dated April 17, 1986, the staf f has further revised the guidance and is now issuing it for implementation.
You should now begin to process any fire brotection cases you have pending using this enclosed guidance, and sutait'4he~ cases to IE for concurrence.
Fire protection cases that have already been submitted should be reevaluated in accordance with the guidance and resubmitted.
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tor ice of Inspection and Enforcement
Enclosure:
As stateo R. Vollmer, NRR 6M 0Icla.Copf
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L Fire Protection Enforcement Guidance 1.
General Guidance A.
Fire protection requirements are delineated by 10 CFR 50 Appendix A General Design Criterion 3,10 CFR 50.48,10 CFR 50 Appendix R.
Facility Lice'nse Conditions, facility technical specifications and other legally. binding requirements, as applicable. A Notice of Violation will be issued for violation of requirements.
However, failure to meet fire protection comitments other than requirements will be designated as deviations.
B.
Failurestomeetregulatoryrequirements7orprotectingtrainsof equipment required for achieving and maintainitqrsafe shutdown are serious violations. The specific violations should be reviewed individually and as a group to determine their root cause(s).
This guidanco gives exampl.es.of violations at various severity levels and should be used to determine the approprITte enforcement action.
For purposes of this guidance, required structures, systems, and components are those which are necessary to achieve and maintain safe shutdown and which require the application of fire protection features as described in the licensee's fire hazards analysis i
. report and NRC's safety evaluation report.
Fire protectio [ violations may involve inoperable or inadequate:
C.
fire barriers, separation, suppression or det.ection systems, repair parts, procedures or other conditions or items required to prevent fires, protect safe shutdown equipment during a fire or to restore safe shutdowp, muipment to service following an actual fire, t i.
D.
' Numerous violations of fire protection requirements which individually may be classified at lower severity levels may cumulatively be classified at a higher severity level due to inadequate ir.plenentation of the fire protection program.
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Severity Categories A.
Severity'I.
Violations of fire protection requirements established-to protect or enable operation of safe shutdown equipment concurrent with an actual fire which damages that equipment such that safe shutdown could not be achieved or maintained.
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Severity II.
Vio'lations Of fire protection requirements established to protect or. enable operation of safe shutdown equipment such that a fire in the area would damage that equipment to the extent that safe' shutdown would not have been achieved and maintained.
C.
Severity III. Violations of fire protection rqquirements established to protect.or enable operation of safe shutdown equipment such that a fire in the area, in the absence of additional eve %etkn; could damage that equipment to the extent that safe shutdown could not have been achieved and maintained using the equipment identified i
in the fire hazards analyses for.iihis purpose in accordance with applie ble requirements. Failure to have an adeqTate written evaluation available for an area where compliance with Appendix R is not apparent will be taken as an indication that the area does not comply with NRC requirements and may result in enforcement action at this Severity Level.
D.
Severity IV.
Violations of one br more fire protection requirements that do not result in a Severity Level I, II, or III violation and which have more than minor safety or environmental significance.
E.
Severity V.
Violations of one or more fire protection requirements that have minor safety or environmental significance.
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WASHING TO N, D. C. 20555
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MEMORANDUM FOR:
Those on Attached List THRU:
Phillip F. McKee, Chief Operating Reactor Programs Branch Division of Inspection Programs Office of Inspection and Enforcement FROM:
Leon E. Whitney, Lead Contact for Fire Protection Operating Reactor Programs Branch Division of Inspection Programs Office of Inspection and Enforcement
SUBJECT:
MINUTES OF MAY 7, 1986 MEETING TO DISCUSS THE EFFECT OF SECY-85-306, APPENDIX R, POST-FIRE SAFE SHUTDOWN Enclosed please find an agenda, a list of attendees, and meeting minutes for M
986 meeting in Bethesda, Maryland, to discuss the effect of Contrary to a decision made during the meeting, SAFFIRE viewgraphs are not en-closed. Current SAFFIRE work is being closad out by NRR and RES.
Future SAFFIRE use within the NRC is planned only in connection with the LaSalle PRA.
Enhancements useful in support of the inspection process (such as secondary ignition) are not currently identified for funding. DI will monitor inspection results to determine if a need develops for a SAFFIRE type computer code to assist in a review of licensee analyses The active and thoughtful participation of those in attendance made this a productive and useful meeting.
f Wh Leon E. Whitney, lead Contact for Fire Protection Operating Reactor Programs Branch Division of Inspection Programs Office of Inspection and Enforcement
Enclosures:
s' As stated
Contact:
LeonWhiteynIE (49-29668)
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-Addresses for Memorandum dated 8/11/86 Stewart D. Ebneter, Director Division of Reactor Safety Region I Al Gibson, Director Division of Reactor Safety Region II Carl J. Paperiello, Director i
Division of Reactor Safety Regio's III Eric H. Johnson, Acting Director Division of Reactor Safety and Projects Region IV Dennis F. Kirsch, Director Division af Reactor Safety and Projects Region V Robert E. Hall, Head Division of Engineering Technology Brookhaven National Laboratory
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i Jane A. Axelrad. Director k'
Office of Inspection and Enforcement i
Enforcement Staff Robert M. Bernero, Director Division of Boiliig Water Reactor Licensing j
Office of Nuclear 9eactor Regulation Hugh L. Thompson, Jr., Director Division PWR Licensing - A Office of Nuclear Reactor Regulation i
i Frank J. Miraglia, Director Division PWR Licensing - B Office of Nuclear Reactor Regulation e
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C. Anderson, RI A. Krasopoulos, RI S. Pullani, RI W. Johnston, RI t
T. Conlon, RII W. Miller, RII J. Huffett, RIII J. Ulie, RIII J. Holmes, RIII R. Hall, RIV R. Mulliken, RIV M. Murphy, RIV T. Young, RV P. Phelan, RV C. Ramsey, RV J. Shapaker, NRR S. West, NRR A. Singh, NRR J. Milhoan, NRR
- 0. Parr, NRR J. Wermiel, NRR D. Kubicki, NRR T. Wambach, NRR J. Stang, NRR D. Notley, NRR J. Usher, BNL
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J. Taylor, BNL W. Shields, ELD R. Van Houten, RES T. Poindexter, IE
Meeting on SECY-85-306, Appendix R, Post-Fire Safe Shutdown
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May 7, 1986 Bethesda, Maryland Agenda Time Function / Topic Speaker / Discussion Leader 9:00 Introduction L. Whitney, ORPB 9:30 SECY-85-306 and Resultant L. Whitney, ORPB Staff Requirements 11:30 Enforcement Policy T. Poindexter, IE 12:00 Lur,a 1:00 Generic letter 86-10 J. Stang, NRR 1:30 SAFFIRE L. Whitney, ORPB
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2:00 Discussion of SECY-85-306 R. Vollmer, DD:IE 3:00 Safe Shutdown Specialist L. Whitney, ORPB Statement of Work 3:30 Upcoming Conceptual Review, L. Whitney, ORPB Inspection at Brown's Ferry 1/2/3 4:00 ADJOURN m
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list of Attendees Attendees Organization Richard H. Vollmer DD, IE Phillip F. McKee Chief, ORPB, DI, IE 3
Leon E. Whitney ORPB, DI, IE Thomas Poindexter IE Enforcerent Staff Ari Krasopoulos Region I Sada Pullani Region I William Johnston Region I William Miller Region II J. W. Muffett Region III Joseph M. Ulie Region III Jeff Holmes Region III Ramon E. Hall Region IV Michael Murphy Region IV Chuck Ramsey Region V J. W. Shapaker PADO (PWR-A), NRR Steven West PADO (PWR-A), NRR Amarjit Singh PADO (PWR-A), NRR J. L. Milhoan PADO (PWR-A), NRR J. S. Wermiel DPLB(PWR-B),NRR Dennis Kubicki DPLB (PWR-B), NRR T. V. Wambach BWD0 (BWR, NRR John Stang BWD0 (BWR, NRR David P. Notley BWD0 (BWR, NRR
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Robert E. Hall BNL John Usher BNL John Taylor BNL d
SfCY-85-306 Meeting May 7, 1986 Minates The purpose of the meeting was to discuss the effect of SECY-85-306 on Appendix R, post-fire Safe Shutdown inspections.
Some points raised during the discussions were:
o Whether Generic Letter 86-10 applies to post-79 licensees.
Note that Generic Letter 86-10 was addressed to all power reactor licensees.
Generic letter 86-10 applies to post-79 licensees except where superseded by specific connitments or agreements that have been documented during the licensing process, o
It was noted that the second paragraph of Generic Letter 86-10 stated that the included "Questions and Answers" provided guidance as to
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acceptable methods of satisfying Commission regulatory requirements, but that other methods would be considered on their own merits.
o It was noted that the second paragraph of Generic Letter 86-10 stated that Generic Letter 83-33 is superseded by Generic Letter 86-10 where conflict exists.
o It was noted that Question and Answer 3.1.1 indicates that fire barriers established under the RTP process need not necessarily be reanalyzed as a result of the approval of SECY-85-306.
o It was stated that in fire areas for which alternative safe shutdown has not been provided, an exemption for Section III.G.2. of Appendix R is required if the separation features of Section III.G.2 are not provided.
This statement was challenged with the line of reasoning that if Section III.G.1.a. of Appendix R is satisfied,Section III.G.2 need not be satis-fied.
ELD provided the following resolution to this question: Inter-pretation Three of Appendix R (which defines the term "free of fire damage" in Section III.G.I.a) was provided to clarify Section III.G.1.a., during the exemption process, for licensees attempting to justify the lack of III.G.2. separation features for redundant trains within a single fire area.
It was never intended that "other methods proposed by licensees" would be a
reviewed and approved at the Appendix R validation inspection.
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. For any fire area an approved exemption is required where neither alternative safe shutdown nor the separation features of Section III.G.2. are provided.
o It was noted that the three assumptions of Question and Answer 5.3.10 are neant for independent use (that is, only one assumption applies for any given configuration in a reactor plant). These assumptions are therefore consistent with the established NRR review practice of requiring licensees to enalyze for any and all spurious actuations or failures where no two such spurious actuations or failures occur simultaneously.
o Sore attendees expressed concern over approved BWR ADS /LPCI post-fire safe shutdown :onfigurations. Attendees were assured that fuel rod tests had been performed to assess the potential for core damage arising from short term partial core uncovery. DI contacted RES and developed the following information:
Dr. Robert Van Houten of the Fuel Systems Research Branch of the Division of Accident Evaluation, Office of Nuclear RegulatoryResearch(427-4463) is an authority in this area.
He states that fuel rod testing has been conducted for many years at the National Reactor Universal at the Chalk River (U.S.) National Laboratory in Chalk River, Canada. Up to 32 bundled light water reactor fuel rods have been tested for
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short time periods in partial steam cooling mode with simulated 100% power history decay heat. The cladding partially oxidized but no fuel damage resulted.
Various NUREGs (piiL, TH or MT series, Mohr or Freshly as authors) are available on this topic, as well as NUREG 0516 on dryout.
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During the meeting DI indicated that TI-2515/62 was to be revised to incorpora.te information from SECY-85-306. Additionally, DI will address whether a separate instruction or inspection procedure is needed to cover the inspection of facilities which have not received their full-power i
operating license.
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