ML20211F929
| ML20211F929 | |
| Person / Time | |
|---|---|
| Issue date: | 08/11/1999 |
| From: | NRC |
| To: | |
| Shared Package | |
| ML20211F885 | List: |
| References | |
| 71111-01, NUDOCS 9908310105 | |
| Download: ML20211F929 (16) | |
Text
s Inspection Procedure 71111, Attachment 5 f
h05 18 P
PDR i
9 Gob' 3 \\0103'
INSPECTABLE AREA:
Fire Protection CORNERSTONES:
Initiating Events (10). Mitigating Systems (90)
INSPECTION BASES: Fire is generally a significant contributor to reactor plant risk. In many cases, the risk posed by fires is comparable to or exceeds the risk from internal events. The fire protection program shall extend the concept of defense in depth (DID) to fire protection in plant areas important to safety by (1) preventing fires from starting, (2) rapidly detecting, controlling, and extinguishing those fires that do occur, and (3) providing protection for structures, systems, and components important to safety so that a fire that is not promptly extinguished by fire suppression activities will not prevent the safe shutdown of the reactor plant. If DID is not maintained by an adequately implemented fire protection program, overall plant risk can increase.
This inspectable area verifies aspects of the initiating Events and Mitigating Systems cornerstones for which there are no performance indicators to measure licensee performance.
-'~
LEVEL OF EFFORT: For one hour a month, the resident inspector will tour from two to four plant areas important to reactor safety to observe conditions related to: (1) licensee control of transient combustibles and ignition sources; (2) the material condition, operational status, and operational lineup of fire protection systems, equipment and features; and (3) the fire barriers used to prevent fire damage or fire propagation. Once a year the resident inspector will observe a plant fire drill.
In addition, for one week every 3 years, in from three to five selected plant areas, an inspection team consisting of a fire protection engineer, a reactor systems engineer, and an electrical engineer will conduct a risk-informed, onsite inspection of the DID eternents used to mitigate the consequences of a fire, with emphasis on the fire protection features provided for maintaining at least one safe shutdown success path free of fire damage.
~
~~
01 INSPECTION OBJECTIVE The inspection objective is to assess whether the licenses has implemented a fire protection program that adequately controls combustibles and ignition sources within the plant, provides adequate fire detection and suppression capability, and ensures that procedures, equipment, fire barriers, and systems exist so that the capability to safely shut down the plant is ensured.
02 INSPECTION REQUIREMENTS 02.01 Monthly Routine insoection. For one hour each month, the resident inspector will tour from two to four plant areas important to safety to assess the material condition of plant fire protection systems and features, their operational status, and the operational lineup of fire protection systems or equipment. The tour should concentrate on the material condition of fire detection and suppression systems and equipment, and on passive fire protection features.
For the areas selected, as applicable to the area of concern, conduct the following lines of inspection inquiry:
a.
Control of Transient Combustibles and lanition Sources issue Date: 8/11/1999 DRAFT 71111.05
o 1.
Observe if any transient combustible materials are located in the area. If
~
transient combustible materials are observed, verify that they are being controlled in accordance with the licensee's administrative control procedures.
2.
Observe if any welding or cutting (hot work) is being performed in the area. Verify that hot work is being done in accordance with the licensee's administrative control procedures.
b.
Fire Detection Systems: Verify that the fire detectors installed in the room are located near or on the ceiling. Observe the physical condition of the fire detection devices and note any that show physical damage. Determine from licensee administrative systems the known operational status of the system, and j
verify that any observed conditions do not affect the operational capability of the system.
c.
Fire Suooression Systems:
1.
Sorinkler Fire Suooression Systems: Observe that sprinkler heads are located near the ceiling and under major overhead equipment obstructions (e.g., ventilation ducts); Observe and verify that the water supply control valves to the system are open and that the fire water supply and pumping capability is operable and capable of supplying the water supply demand of the system. Observe and note any material conditions that may affect performance of the system, such as mechanical damage, painted sprink!er heads, or corrosion, etc.
2.
Gaseous Suporession Systems: Observe that the gaseous suppression system (e.g. Halon or CO2) nozzles are located near the ceiling and are not obstructed or blocked by plant equipment. Observe and verify that the suppression agent charge pressure is within the normal band, extinguishing agent supply valves are open, and that the system is in the automatic mode. Observe and verify that the dampers / doors will close automatically (or their closure is otherwise assured) upon actuation of the gaseous system. Observe and verify that the room penetration seals are sealed and in good cnndition. Observe and note any material conditions that may affect performance of the system, such as mechanical damage, corrosion, damage to doors or dampers, open penetrations, or nozzles blocked by plant equipment.
d.
Manual Fire fiahtina Eouioment and Capabilitv.
1.
Fire Extinouishers: Ensure that adequate numbers and types of portable fire extinguishes are provided at designated places in or near the area being inspected, and that access to the fire extinguishers is unobstructed by plant equipment or other work related activities. Observe and verify that the general condition of fire extinguishes is satisfactory (e.g.,
pressure gauge reads in the acceptable range, nozzles are clear and unobstructed, charge test records indicate testing within the normal perodicity).
71111.05 Issue Date: 8/11/1999 DRAFT
l 1
4 O
I 2.
Hose Stations and Standoioes: Observe and verify that a hose station can provide coverage for the area being inspected (maximum hose length 100 feet and an electrically safe fog nozzle). ~ Observe and verify that the water supply control valves to the standpipe system are open and that the fire water supply and pumping capability is operable and capable
)
of supplying the water flow and pressure demand. Ensure that access to I
the hose stations is unobstructed by plant equipment or work-related activities. Observe and verify that the general condition of hose stations is satisfactory (e.g., no holes in or chafing of the hose, nozzle not mechanically damaged and not obstructed, ' alve hand wheels in place).
v e.
Passive Fire Protection 1.
Electrical Raceway Fire Barrier Systems: Observe the material condition of electrical raceway fire barrier systems (e.g. cable tray fire wraps) and I
determine if there are any cracks, gouges, or holes in the barrier material, that there are no gaps in the material at joints or seams, and that banding, wire tie, and other fastener pattem and spacing appears appropriate. Where the fire barrier is a wrap or blanket-type material, observe that the material has no tears, rips, or holes in any of the visible layered material, that there are no gaps in the material at joint or seam I
locations, and that banding spacing appears appropriate, if plant modifications have recently been conducted, establish that fire barriers removed as interference have been restored.
2.
Fire Doors: Observe the material condition of the fire door in the area being inspected. Verify that selected fire doors close without gapping, and that the door latching hardware functions securely.
3.
Ventilation System Fire Damoers: Observe the condition of the fire dampers in the areas being inspected. Ensure fusible link fire dampers
{
are not prematurely shut or obstructed.
4.
Structural Steel Fire Proofina: Observe the material condition of the structural steel fire-proofing (fibrous or concrete encapsulation) within the areas being inspected. Verify that this material is installed and that the structural steel is uniformly covered.
5.
Fire Barrier Electrical Penetration Seals: Tour plant areas being inspected and observe electrical and piping penetrations. Observe whether any seals are missing from locations in which they appear to be needed to complete a fire barrier, and determine that seals appear to be properly installed and in good condition. Verify that fire resistive material has been used to fill the opening / penetration.
f.
Comoensatorv Measures Verify that adequate compensatory measures are put in place by the licensee for degraded or inoperable fire protection equipment, systems or features (e.g.,
detection and suppression systems and equipment, passive fire barrier features, or safe shutdown functions or capabilities).
i Issue Date: 8/11/1999 DRAFT 71111.05 j
j
02.02 Annual Routine Inspection: During the annual observation of a fire brigade drill in a plant area important to safety, the resident inspector should observe that:
a.
Protective clothing /tumout gear is properly donned.
b.
Self-contained breather apparatus (SCBA) equipment is properly worn and used.
c.
Fire hose lines are capable of reaching all necessary fire hazard locations, that L
i the lines are layed out without flow constrictions, the hose is simulated being charged with water, and the nozzle is pattem (flow stream) tested prior to entering the fire area of concem.
d.
The fire area of concem is entered in a controlled manner (e.g., fire brigade members stay low to the floor and feel the door for heat prior to entry into the fire i
area of concem).
Sufficient fire fighting equipment is brought to the scene by the fire brigade to e.
properly perform their firefighting duties, f.
The fire brigade leader's fire fighting directions are thorough, clear, and effective.
g.
Radio communications with the plant operators and between fire brigade
- members are efficient and effective h.
Members of the fire brigade check for fire victims and propagation into other i
plant areas 1.
Effective smoke removal operations were simulated.
J.
The fire fighting pre-plan strategies were utilized.
k.
The licensee pre-planned the drill scenario was followed, and that the drill objectives acceptance criteria were met.
02.03 Triennial Insoection. Every three years in from three to five selected plant areas an inspection team will conduct a one-week inspection of the licensee's fire protection program with emphasis on post-fire safe shutdown capability and'the fire protection features provided for ensuring that at least one post-fire safe shutdown success path is maintained free of fire damage.
- a.
Insoection Preoaration:
1.
Prior to the inspection information gathering trip, the regional senior reactor analyst (SRA) will provide the team leader with a summary of plant specific fire risk insights (e.g., fire risk ranking of the rooms / plant fire areas, conditional core damage probabilities (CCDPs) for those rooms and areas, and transient sequences for these rooms).
71111.05 Issue Date: 8/11/1999 DRAFT i
e
e o
e 2.
The inspection team leader will manage and coordinate a two or three day information gathering site visit accompanied by the team members and the SRA designated to support the team.
3.
The team leader will use the fire risk insights, and input from the other team members, to develop an inspection plan which assesses post-fire safe shutdown capability and the fire protection provided for maintaining one success path train of this capability fr.ee of fire damage for from three to five selected plant areas, rooms, or zones.
b.
Insoection Conduct: For the plant areas selected for review, conduct the following inspection efforts:
1.
Systems Reauired to Achieve and Maintain Post-fire Safe Shutdown Verify that the licensee's shutdown methodology has properly identified the components and systems necessary to achieve and maintain safe shutdown conditions. This requires verifying the following:
(a)
The reactivity control function is capable of achieving and maintaining cold shutdown reactivity conditions.
(b)
The reactor coolant makeup function is capable of maintaining the i
reactor coolant level above the top of the core for boiling water
{
reactors (BWRs) or within the level indication in the pressurizer (or solid plant) for pressurized water reactors (PWRs).
I (c)
The reactor heat removal function is capable of achieving and maintaining decay heat removal.
(d)
The process monitoring equipment provides direct readings of the process variables for reactivity control, coolant makeup, and decay heat removal functions [ note: source range neutron indication is not necessarily required, and an attemative method of reactivity measurement can be provided).
(e)
The support system functions are capable of providing the process cooling, lubrication, and other services necessary to permit extended operation of the equipment used to accomplish safe shutdown functions.
2.
Eke Protection of Safe Shutdown Caoability For the plant areas selected, evaluate the separation of systems necessary to achieve safe shutdown, and verify that fire protection features are in place to satisfy the separation and design requirements of Section Ill.G of Appendix R (or, for reactor plants reviewed under the Standard Review Plan, license specific requirements).
Verify that the fire detectors and automatic fire suppression systems, associated with 1-hour fire barriers required by Section Ill.G.2 of issue Date: 8/11/1999 DRAFT 71111.05 l
4 e
Appendix R (or, for reactor plarits reviewed under the Standard Review Plan, license specific requirements), have been adequately installed.
Review licensee evaluations which confirm that the installed automatic suppression systems would adequately suppress fires associated with the hazards of each selected area.
For the plant areas selected, verify that redundant trains of systems required for hot shutdown located in the same fire area are not subject to damage from fire suppression activities or from the rupture or inadvertent operation of fire suppression systems. Determine each of the following:
(a)
Whether a fire in a single location could, indirectly, through the production of smoke, heat, or hot gases, cause activation of potentially damaging fire suppression for all redundant trains, (b)
Whether a fire in a single location (or inadvertent actuation or rupture of a fire suppression system) could, through local fire suppression actnnty, indirectly cause damage to all redundant trains (e.g., sprinkler-caused flooding of other than the locally affected train), and (c)
Whether, in response to a fire in a single location, the utilization of manually controlled fire suppression systems could cause damage to all redundant trains.
For the plant areas selected, verify the adequacy of the design of fire area boundaries (i.e., able to contain the fire hazards of the area),
raceway fire barriers, equipment fire barriers, and fixed fire detection and suppression systems Address operator recovery actons (e.g., smoke removal, dowatering of
, spaces, controlled re-energization, and retum to service of equipment in fire-affected areas) for fires in each plant area.
The observation of a fire brigade drill for a simulated fire in a plant area important to risk may be necessary to assess the effectiveness of manual fire fighting capability.
Verify that adequate compensatory measures are put in place by the licensee for degraded or inoperable fire protection equipment, systems or features (e.g., detection and suppression systems and equipment, passive fire barrier features, or safe shutdown functions or capabilities) 3.
Post-fire Safe Shutdown Circuit Analvsis Verify that safety-related and non-safety related cables for equipment in selected fire areas have been identified by the licensee and analyzed to show that they would not prevent safe shutdown because of hot shorts, open circuits, or shorts to ground. Inspect the licensee's electrical systems and electrical circuit analyses with respect to the following:
)
71111.05 Issue Date: 8/11/1999 DRAFT
E
]
(a)
Common Power Suoolv/ Bus Concern: On a sample basis, review the electrical distribution system and verify protective device coordination and that the licensee has analyzed the systerns for j
high impedance fault conditions.
j (b)
Common Enclosure Concem: On a sample basis, review electrical fault ptotection from nonessential circuits routed in common enclosures (e.g. fire wrapped electrical raceways) with required safe shutdown circuits.
(c)
Sourious Sianal Concem: On a sample basis review fire-induced hot shorts, shorts to ground, and open circuits and their potential effects on post-fire safe shutdown capability.
(d)
Fuse / Breaker Coordination: On a sample basis, verify that circuit breaker coordination and fuse protection have been analyzed and provided.
4.
Altemative Shutdown Capability Verify the adequacy of the design and implementation of the licensee's attemative shutdown capability for selected plant areas by reviewing the licensee's altemative shutdown methodology and determining the identified components and systems necessary to achieve and maintain safe shutdown conditions. Establish that these components and systems can meet the following functional requirements:
(a)
The reactivity control function is capable of achieving, monitoring, and maintaining cold shutdown reactivity conditions.
(b)
The reactor coolant makeup function is capable of maintaining the reactor coolant level above the top of the core for BWRs, or is within the level indication in the pressurizer (or solid plant) for PWRs.
(c)
The reactor heat removal function is capable of achieving and maintaining decay heat removal.
(d)
The process monitoring equipment provide direct readings of the process variables for reactivity control, coolant makeup and decay j
heat removal functions [ note: source range neutron indication is i
not necessarily required, and an alternative method of reactivity measurement can be provided], and (e)
The support system functions are capable of providing the process cooling, lubrication, and other services necessary to permit extended operation of the equipment used to provide safe shutdown functions.
Verify that hot and cold shutdown from outside the control room can be achieved and maintained with off-site power available or not available.
Issue Date: 6/11/1999 DRAFT 71111.05 i
l Verify that the transfer of control from the control room to the attemative location has.been demonstrated to not be affected by fire-induced circuit faults (e.g. by the provision of separate fuses and power supplies for attemative shutdown control circuits).
- 5. '
Operationalimolementation of Attemative Shutdown Capability Verify that the training program for licensed and non-licensed personnel has been expanded to include attemative or dedicated safe shutdown capability.
Verify that personnel required to achieve and maintain the plant in hot shutdown following a fire using the attemative shutdown system can be provided from normal onsite staff, exclusive of the the fire brigade.
Verify that adequate procedures for use of the attemative shutdown system exist. Verify that the operators can reasonably be expected to perform the procedures within applicable shutdown time requirements.
Ensure that adequate communications are available for the personnel performing attemative or dedicated safe shutdown. Verify the implementation and human factors adequacy of the attemative shutdown procedures by " walking through" of the procedural steps.
Verify that the licensee has incorporated the operability of attemative shutdown transfer and control functions into the plant technical specifications.
Verify that the licensee periodically performs operability testing of the attemative shutdown instrumentation and transfer and control functions.
In addition, verify that if the licensee imposes the appropriate compensatory measures during periods in which altamative shutdown capability may be declared inoperable.
6.
Communications Verify through observation of licensee conducted communication tests that portable radio communications and/or fixed emergency communications systsms are available, operable, and adequate for the peformance of attemative safe shutdown functions. Assess the ability of the communication systems to support the operators in the conduct and coordination of their required actions (e.g., consider ambient noise levels, clarity of reception, reliability, coverage patterns).
7.
Emeroency Liahtina Review emergency lighting provided for alternative safe shutdown along access routes and egress routes, and at control stations, plant parameter monitoring locations, and manual operating stations:
(a)
If emergency lights are powered from a central battery or batteries, verify that the distribution system contains protective 71111.05 Issue Date: 8/11/1999 DRAFT
7 4
cr devices so that a fire in the area will not cause loss of emergency lighting in any unaffected area needed for safe shutdown operations.
(b)
Review the manufacturer's information to verify that battery power supplies are rated with at least an 8-hour capacity.
(c)
Determine if the operability testing and maintenance of the lighting units follow the manufacturer's recommendations.
(d)
By asking the licensee to perform an emergency lighting test for selected plant areas, verify that the lamps are properly aimed.
(e)
Verify that emergency lighting unit batteries are being properly maintained (observe the unit's charge rate indication (lamp or meter) and specific gravity indication).
(f)
Verify that sufficient illumination is provided to permit access for the monitoring of safe shutdown indications and/or the proper operation of safe shutdown equipment. In coordination with the-licensee, observe a normal station lighting blackout condition test in selected plant locations (e.g., remote shutdown panel, switchgear room, diesel generator area). Determine if illumination is adequate to perform required shutdown actions.
(g)
Review the prever)tive maintenance surveillance procedure used.
for periodic checks of the emergency lights and verify that the maintenance frequencies and procedures are as specified by the manufacturer. Verify that the lighting units are routinely tested, and the testing criteria includes a "as-found" manufacturers recommended discharge test.
8.
Cold Shutdown Repairs Verify that the licensee has dedicated repair procedures, equipment, and materials to accomplish repairs of damaged components required for cold shutdown, that these components can be made operable, and that cold shutdown can be achieved within time frames specified by Appendix R to 10 CFR Part 50 (or, for reactor plants reviewed under the Standard Review Plan, license specific requirements). Verify that the repair i
equipment, components, tools, and matprials (e.g., pre-cut cable connectors with prepared attachment lugs) are available on site.
t 03 INSPECTION GUIDANCE:
General Guidance Routine inspection: The main focus of the resident inspector's activities is on the material conditions and operational status of fire detection and suppression systems and equipment and fire barriers used to prevent fire damage or fire propagation. The two to four plant areas to be inspected will be selected on the basis of the plant specific risk information matrix, or the lasue Date: 8/11/1999 DRAFT -
e generic RIM 2 document for the subject reactor plant. The resident inspector's assessment of the licensee's control of transient combustibles and ignition sources is addressed more frequently in the Plant Status inspection procedure.
TnennialInspection:
Obiective: The one week, onsite, triennial inspection is primarily a risk-informed look at the mitigation elements of fire protection defense in depth (DID) (i.e., detection, suppression, and
' confinement of fires through passive barriers, and the fire protection features and procedures which establish the licensee's ability to achieve and maintain post-fire safe shutdown conditions during and after a fire). The triennialinspection is uniquely that portion of the baseline inspection program that focuses on the design of reactor plant fire protection and post-fire cafe shutdown systems, features, and procedures. The inspection team leader will manage and coordinate the conduct of an inspection emphasizing post-fire safe shutdown. The team will use plant-specific risk, event, and technical information (including the results of licensee self-assessments) to confirm that at least one train of safe shutdown capability (e.g., reactivity control, reactor coolant makeup, reactor heat removal, process monitoring, and support systems)is free of fire damage.
Post-fire Safe ShtMawn naa=N!hv Inspection Tooics: The confirmation of reactor plant post -
fire safe shutdown capability includes (1) the identification of safe shutdown systems required to achieve the performance goals for the reactor plant's necessary shutdown functions; (2) identification and design adequacy of physmal separation (e.g., Fire Barriers) and suppression schemes used by the licenses to protect redundant cables or components (e.g.,3-hour bamers,1-hour barrier / detection / suppression combinations, distance, exemption approved unique separation and suppression configurations); (3) review of the rating and physical condition of fire area boundaries to ensure their adequacy to contain the fire hazards within each fire area; (4) analysis of potential fire damage to power, control and indication cables for required systems so as to establish their continued ability to perform their intended functions (5) review of electncal control transfer mechanisms for altamative safe shutdown capabilities at remote shutdown panels and/or emergency control stations (typmally for postulated main contros room and cable spreading room fires); ( 6) review of altemative or dedicated post-fire safe shutdown procedures, equipment access, communications and manual actions; (7) review of licensee circuit analyses for required and associated circuits of concem that could interfere with post-fire safe shutdown; and (8) review of cold shutdown equipment repair procedures, tools, and materials.
Inapection Aporoach: The inspection of post-fire safe shutdown capability and its assocated fire protection features can be either plant area-based or safe shutdown system-based, depending on the structure of the licensee's analysis.
In=aar* ion Team "daua and Resoonsibilities: The team assihned to conduct disciplinary triennial fire protection inspection will be comprised of a fire protection engineer, an electrical engineer, and a reactor systems engineer.
1.
,Reardar Systems Enoineer (SE). The reactor systems engineer will assess the capability of reactor and balance-of-plant systems, equipment, operating personnel, and procedures to achieve and maintain post fire safe shutdown and minimize the release of radioactivity to the environment in the event of fire. He will be knowledgable regarding integrated plant operations, maintenance, testing, surveillance and quality assurance, reactor normal and off-normal operating 71111.05 Issue Date: 8/11/1999 DRAFT
n
,4 V
procedures, an'd BWR and/or PWR nuclear and balance-of-plant systems design.
2.
Electrical Enaineer (EE). The EE will identify electrical separation requirements for redundant train power, control, and instrumentation cables. He will verify that the licensee has adequately demonstrated that fire-induced circuit failures (hot shorts, shorts to ground, and open circuits) will not prevent safe shutdown operation. He will review altomative shutdown panel electrical isolation design to establish the panels' electrical independence from postulated fire areas. He will also review required and associated circuits of concem for the elimination of fire-induced faults that can cause spurious signals which could interfere with post-fire safe shutdown, and in regard to common enclosure concems and common power supply concems. He will be knowledgeable regarding reactor plant electrical and instrumentation and control (l&C) design and will be familiar with industry ampacity derating standards 3.
Fire Protection Enaineer (FPE). The FPE will review fire protection systems, features and procedures. The FPE will work with other team members in determining the effectiveness of the fire barriers and systems that establish the reactor plant's post-fire safe shutdown configuration and maintain it free of fire damage. He will determine whether suitable fire protection features (suppression, separation distance, fire barriers, etc.) are provided for the separation of equipment and cables required to ensure plant safety. He will possess a fire protection degree or equivalent experience, and will be knowledgeable regarding reactor plant fire protection systems and features.
Regulatorv Requirements and Lice'nsing Bases: The regulatory requirements and licensing bases against which post-fire safe shutdown capability is assessed are as follows:
1.
Plants licensed before January 1.1979: Effective February 17,1981, the NRC amended its regulations by adding Section 50.48 and Appendix R to 10 CFR Part 50 to require certain provisions for fire protection in nuclear power plants licensed to operate before January 1,1979. This action was taken to resolve certain contested generic issues in fire protection safety evaluation reports (SERs) and to require all applicable licensees to upgrade their plants to a level of fire protection equivalent to the technical requirements in Sections Ill.G, J, L, and O of 10 CFR Part 50, Appendix R. Licensees were required to meet the separation requirements of Section lil.G.2, the attemative or dedicated shutdown capabiiity requirements of Sections lil.G.3 and Ill.L, or to request an exemption in accordance with 10 CFR 50.48. Alternative or dedicated safe shutdown capabilities were required to be submitted to the Office of Nuclear Reactor Regulation (NRR) for review. NRR approvals are documented in SERs.
2.
Plants licensed after January 1.1979: These plants are subject to requirements similar to those in 10 CFR part 50, Appendix R, as specified in the conditions of their facility operating license, commitments made to the NRC, or deviations granted by the NRC. These reactor plants licensed after January 1,1979, are subject to 10 CFR 50.48 (a) and (e) only.
The fire hazards analysis (FHA) (" Fire Protection Review, Fire Protection Evaluation") document of the reactor plants licensed after January 1,1979, may issue Date: 8/11/1999 DRAFT 71111.05
I 1
have been reviewed under Appendix A to Branch Technical Position APCSB 9.5-1 " Guidelines for Fire Protection for Nuclear power Plants Docketed Prior to July 1,1976," of August 23,1976 (in which case, the licensee conducted an Appendix R comparison and justified final safety analysis report (FSAR) or FHA differences from the specific provisions of Appendix R). It is possible also that licensee submittals for plants licensed after January 1,1979, were reviewed under the Standard Review Plant, NUREG-0800, and Branch Technical Position (BTP) CMEB 9.5-1 (formerly BTP ASB 9.5-1), " Guidelines for Fire Protection for Nuclear Power Plants," Rev. 2 (July 1981) (in which case, licensee submittals were reviewed according to requirements that closely paralleled the provisions of Appendix R).
The actual fire protection requirements applicable to a given reactor plant licensed after January 1,1979, arise from the specific license conditions in the facility operating license. These license conditions possibly refer to SERs and their supplements. Section 9.5 of such an SER delineates which licensee submittals were reviewed (e.g., a fire hazards analysis would be such a submittal). The plant configurations and procedures described in these submittals are " requirements of the license."
Inspection Process:
1.
Licensee Notification Letter: The licensee should be notified of the triennial inspection in writing at least three months in advance of the onsite week. The letter should discuss the scope of the inspecion, request an information-gathering visit to the licensee reactor site / engineering offices, discuss documentation and licensee personnel availability needs during the onsite inspection week, and request a pre-inspection conference call to discuss administrative matters and finalize plans for inspection activities and schedules.
2.
Inform #-r,-aatherina Site Visit: The inspection team leader will manage and coordinate a two to three day information-gathering site visit, accompanied by'the team members. The purposes of the information gathering site visit are to gather the site-specific information important to inspection planning. In advance of the information-gathering site visit, and in order for the onsite information exchange to be as effective as possible, the team leader should give the licensee a list of information and documents that will be needed to prepare for the inspection, and the inspection team should already have reviewed previous inspection results and other docketed information about the licensee's fire protection program.
3.
Information Reauired: The team members should gather sufficient information to become familiar with the following:
(a)
The reactor plant's design, layout, and equipment configuration.
(b)
The reactor plant's current post-fire safe shutdown licensing basis through review of 10 CFR 50.48,10 CFR Part 50 Appendix R (if applicable), NRC safety evaluation reports (SERs) on fire protection, the plant's operating license, updated final safety analysis report (UFSAR),
and approved exemptions or deviations.
71111.05 Issue Date: 8/11/1999 DRAFT
o w
(c)
The licensee's strategy and methodology, and derivative procedures, for accomplishing post-fire safe shutdown conditions. Among the~ sources of information are the updated final safety analysis report (UFSAR), the latest version of the fire hazards analysis (FHA), the latest version of the post-fire safe shutdown analysis (SSA), fire protection / post-fire safe-shutdown related 10 CFR 50.59 documentation and modification packages, plant drawings, and emergency / abnormal operating procedures.
(d)
The historical record of plant-specific fire protection issues through review of the following plant-specific documents: previous NRC inspection results, intemal audits performed by the reactor licensee (e g., self-assessments and quality assurance audits), corrective action system records, event notifications submitted in accordance with 10 CFR 50.72, and licensee event reports (LERs) submitted in accordance with 10 CFR 50.73.
(e)
The safe shutdown systems and support systems credited by the licensee's analysis for each fire area, room, or zone for accomplishing of the required shutdown functions (e.g., reactivity control, reactor coolant makeup, reactor heat removal, process monitoring, supporting functions),
as necessary to comply with the safe shutdown requirements of 10 CFR 50.48(a) and plant-specific licensing requirements. The shutdown logic for each area, room, or zone to be inspected must be thoroughly understood by the team members.
(f)
The licensee's analytical approach for electrical circuits separation analyses, and the licensee's methodology for identification and resolution of associated circuits of concem. The team's electrical review should include addressal of the assumptions and boundary conditions used in the performance of the licensee's analyses.
4.
Sianificance Determination Process (SDP): The inspection team may identify a finding or set of findings that callinto question one or more elements of defense in depth (DID) at the reactor plant. In order to make a determination of the significance of the finding (s), it may be necessary to evaluate them within the significance determination process in the referenced supplemental fire protection functionalinspection procedure (the Fire Protection Risk Significance Screening Methodology of IP XXXXX). The results of such significance evaluations can be used to help the team leader to (1) develop the in-process information necessary to prioritize and focus further onsite inspection activities, and (2) characterize the significance of triennial team inspection findings both during and after the site exit meeting with the licensee.
Specific Guidance 03.01 Inspection Reauirement 02.01: The resident inspector should not attempt to address all plant areas each month. The monthly plant tour should focus on from two to four plant areas important to risk, should note levels of transient combustible and ignition source control, and the material condition and operational status (rather than on the design) of fire detection and suppression systems, and fire barriers used to prevent fire damage or fire propagation. The issue Date: 8/11/1999 DRAFT 71111.05 i
inspector may identify a finding or set of findings which call into question one or more elements of defense-in-depth at the reactor plant. In order to assess the degree of degradation of the DID element (s), and make a determination of the significance of the finding (s), it may be necessary to evaluate them within the significance determination process of the referenced supplemental fire protection functional inspection procedure (the Fire Protection Risk, Significance Screening Methodology of IP XXXXX).
03.02 Insoection Reauirement 02.01a: Fire prevention measures, such as control of (typically maintenance-related) transient combustible materials and ignition sources (typically related to j
welding, cutting, and grinding operatione), can reduce the likelihood of plant fires and fire risk.
Consequently the prevention attribute is also addressed by the resident inspector in the more I
frequently performed baseline plant status inspection procedure.
l 03.03 Inspection Reauirement 02.01f: Short term compensatory measures should be adequate to compensate for the degraded function or feature until appropriate corrective action can be taken.
03.04 Insoection Reauirement 02.03a3: The inspection plan issued by the team leader for the triennial inspection should consider or contain the following:
1.
Recognition of the limitations imposed by the short (1 week) duration of the triennialinspection site visit; 2.
The adequacy of the time allocated for the conduct of inspection efforts to gather information required for the application of the Fire Protection Risk Significance Screening Methodology contained in the reference supplemental fire protection inspecten procedure (see section 03.01 above);
- 3. '
Follow-up on results of recent fire protection inspections, if it is determined that corrective actions for specific risk-important inspection findings from such inspections appear to be deficient or inadequate.
03.05 Inspecten Reauirement 02 03b2: Short term compensatory measures should be adequate to compensate for the degraded function or feature until appropriate corrective action l
can be taken.
RESOURCE ESTIMATE:
This procedure is estimated at 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br /> per year for routine inspection and 108 hours0.00125 days <br />0.03 hours <br />1.785714e-4 weeks <br />4.1094e-5 months <br /> every 3
{
years for the triennialinspection.
REFERENCES:
IP XXXXX, " Fire Protection Functional inspection" Month ##,1999.
l 71111.05 Issue Date: 8/11/1999 DRAFT
I 1
ATTACHMENT ROUTINE INSPECTION GUIDANCE TABLE CORNERSTONE RISK PRIORITY EXAMPLES INITIATING EVENTS (10)
Equipment or actions that could cause Transient combustibles (rags, wood, ion or contribute to initiation of fires in plant exchange resin, lubricating oil, or Anti-areas important to safety or near Cs) are not in areas where transient equipment required for safe shutdown.
combustibles are prohibited. Transient combustible amounts in other areas do not exceed administrative controls.
Ignition sources (welding, grinding, brazing, flame cutting) have a fire watch. Planning includes precautions and additional fire prevention measures where these activities are near
)
combustibles.
q MITIGATING SYSTEMS (90)
Functionality of fire barners in plant Doors and dampers that prevent the areas important to safety, spread of fires to/or between plant areas important to safety remain in place and Functionahty of detection systems in are functional.
plant area important to safety.
Electncal raceway fire barriers and Functionality of automatic suppression penetration seats that protect the post-systems in plant areas important to fire safe-shutdown train are not
- safety, damaged.
Fire brigade manual suppression Fire detection and alarm system is effectiveness.
functional for plant areas important to safety.
Compensatory measures for degraded fire detection systems, fire suppression Automatic suppression system features, and barriers to fire sprinklers are functional and their propagation.
sprinkler head pattems are not blocked by plant equipment.
Fire brigade pertormance indicates a 3
prompt response with proper fire fighting techniques for the type of fire encountered.
Manual fire suppression equipment is of the proper type and has been tested.
Degraded fire detection equipment, j
suppression features and fire propagation bamers are adequately compensated for on reasonably short.
term bases.
l issue Date: 8/11/1999 DRAFT 71111.05