ML20211J378
| ML20211J378 | |
| Person / Time | |
|---|---|
| Issue date: | 03/12/1986 |
| From: | Chilk S NRC OFFICE OF THE SECRETARY (SECY) |
| To: | Asselstine NRC COMMISSION (OCM) |
| Shared Package | |
| ML20209D558 | List:
|
| References | |
| FOIA-86-274 COMJA-86-4, NUDOCS 8606260331 | |
| Download: ML20211J378 (1) | |
Text
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, g 'o UNITE 3 STATES
) ! , NUCLEAR REGULATORY COMMISSION .
g WASHINGTON. D.C. 20 Gee 3
1.,*..../ March 12, 1986 OFFICE OF THE COMJA-86-4 MEMORANDUM FOR: Commissioner Asselstine FROM:
SamuelJ.Chilk, Secret /
SUBJECT:
SECY-85-306, 306A AND 3061 - IMPLEMENTATION OF APPENDIX R i ,'
The attached SRM on the implementation of Appendix R (SECY-85-306 and 306B) has now been issued to the staff. In accordance with your wishes SECY is discontinuing action on '
COMJA-86-4.
a Copies: .
Chairman Palladino Commissioner Rober*.s Commissioner Bernthal Commissioner Zech OGC
' OPE f
8606260331 860619 PDH FOIA CARDE86-274 PDR
. 66 k.45
i
" M o UNITED STATES
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E n NUCLEAR REGULATORY COMMISSION rn E WASHINGTON, D. C. 20886 1., ,
AUG 21 1985 MEMORANDUM FOR: William J. Dircks Executive Director for Operations FROM: Victor Stello, Jr., Chairman Comittee to Review Generic Requirements
SUBJECT:
MINUTES OF CRGR MEETING NUMBER 79 The Comittee to h siew Generic Requirements (CRGR) met on Wednesday, July 24, 1985 from 12:30 -6 p.m. A list of attendees for this meeting is enclosed (Enclosure 1).
- 1. N. Randall (RES) presented for CRGR review the proposed Revision 2 of Regulatory Guide 1.99, " Radiation Damage to Reactor Vessel." Enclosure 2 sumarizes this matter (Category 2 item).
- 2. J. Funches (NRR) briefed the CRGR concerning the current request to OMB for approval to continue to impose the reporting and recordkeeping requirements of 10 CFR Part 50, Domestic Licensing of Production and Utilization Facilities.
The Part 50 reporting and recordkeeping burden on reactor pennittees/ licensees is currently estimated to be around 4-million hours
($240 million) per year. Approximately 1-million hourt of the annual burden involve reactor operating and maintenance staff, which is principally concerned with plant safety. The Part 50 reporting and recordkeeping burden on the NRC is currently estimated to be around 380 thousand hours ($23 million) per year. The current burden estimate reflects a 2-million-hour reduction from the 1982 estimate. (Enclosure 3, which was used to brief.the CRGR, provides sumary burden information.)
The CRGR strongly encourages NRC efforts to assure that only necessary reporting and recordkeeping requirements are imposed by NRC especially where reactor operating and maintenance staff burden is involved.
- 3. J. Knight (NRR) briefed the CRGR concerning pressure isolation valve (PIV) test requirements. Enclosure 4 sumarizes this matter (Category 2 item).
- 4. -J. Knight (NRR) presented for CRGR review the proposal for improving Fire Protection. Enclosure 5 sumarizes this matter (Category 2 item).
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, i 2 AUG 21 1985 Enclosures 2, 4, and 5 contain predecisional information and therefore will not be released to the Public Document Room until the NRC has considered (in a public forum) or decided the matters addressed by the enclosures, j Questions concerning these meeting minutes should be referred to Walt Schwink
- (492-8639),
f)Y) r .
~
MJ ctor Stello, r, hairman mittee to Revi w Generic Requirements
Enclosures:
As Stated ,
, cc: Comission (5) i SECY Office Directors Regional Administrators CRGR Members G. Cunningham N. Randall J. Funches J. Knight
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Enclosure 1 LIST OF ATTENDEES.
CRGR MEETING NO. 79 July 24, 1985 CRGR MEMBERS V. Stello R. Bernero S. Schwartz (for E. Jordan)
J. Scinto F. Hebdon (for J. Heltenes)
R. Cunningham D. Ross OTHERS J. Sniezek H. Taylor J. Conran W. Schwink .d V. Benaroya B. Johnston F. Rosa
, C. Serpan l R. Hernan W. Hazelton N. Randall H. Smith B. Pineles l J. Funches l G. Edison l W. Minners l J. P. Knight J. Philips l R. Bosnak l S. Scott i W. Hodges S. Diab l B. Milstead l G. Dick i 0. Rosenberg J. Page F. Cherny B. Shields F. Rowsome P. McKee '
J. Partlow R. Vollmer
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Enclosure 2 to the Minutes of Cl:GR Meeting No. 79 Proposed Draft of Revision 2 to Regulatory Guide 1.99
" Radiation Damage to Reactor Vessel Materials ,
C. Serpan and P. N. Randall (RES) presented for CRGR review a proposed draft of Revision 2 to Regulatory Guide 1.99 now entitled " Radiation Damage to Reactor Vessel Materials." CRGR was requested to recomend in favor of publication of this Regulatory Guide (RG) for pubile comment. (A copy of the viengraphs used to brief CRGR is attached.)
Basically, the proposed Revision 2 to RG 1.93 would update the existing staff guidance of RG 1.99 Revision 1, taking. into account the experience acquired since 1977 in this matter along with the accumulation of surveillance data from commercial power reactors. The proposed revisions reflects results of studies since 1977 as to the physical basis for neutron radle, tion damage and the correlations made for effects of the material chemical compositions and neutron fluence. The principal changes being made in RG 1.99 are the separate treatment of the radiation damage to welds and to the reactor vessel base metal. The nickel content of the material is being considered as a variable in the correlations and the phosphorus content because of its small effects is q removed. At high fluences, the fluence effects are being adjusted and guidance is given for determining the attenuation of damage through the depth of the reactor vessel wall. These changes in regulatory guidance have been brought about largely by advancements in data and in the science of predicting materf al damage largely as a result of work begun for the NRC in 1981. This was about the time that the requirements for pressurized thermal shock (PTS) were being developed and these advancements concerning radiation damage correlations have evolved with cognizance of the industry, EPRI, ANS, the ASTM Comittee E-10 and the Metal Properties Council on radiation damage. The objective of the proposed Revision 2 to RG 1.99 is to set forth these advancements and from these provide calculational procedures acceptable to the NRC for assuring that an acceptable level of reactor vessel toughness is maintained with margins through plant heat-up, cooldown and hydrotest operations. The package transmitted for CRGR review also includes confonning changes to the Standarti Review Plan (SRP) (NUREG-0800, Section 5.3.2). The proposed revisions to RG 1.99 and the SRP would be implemented on all plants (i.e., forward fit and backfit). Operating plants would be given up to 3 years to revise operating procedures and their technical specifications. The overall justification for the guidance of RG 1.99 is set forth by the requiratents of 10 CFR 50; Appendix A (General Design Criterion 31), Appendix G and Appendix H.
CRGR was advised that the proposed RG 1.99 Revisions would bring about greater restrictions on the pressure-temperature (PT) operating band for both the BWR and PWR plants. The BWR plants would, for example, be faced with difficulties in carrying out certain post-refueling hydrotest operations required by the ASME code. Although the full BWR implications were not available to CRGR or the staff, CRGR was advised that some of the older CWR plants may be forced into providing additional equipment for heatup, use of unusual system con-figurations or the use of the RHR pumps for heating, etc. so as to minimize the
)
chance of damage to the main recirculation pump seals. Additionally, there may also be BWR technical specifications requiring containment isolation for coolant temperatures greater than 200*F that would further complicate the hydrotest requirements - this might be rectifiable by changing the technical specifications.
The PWRs would also be affected by this narrowed pressure-temperature operating band, resulting in a somewhat lesser margin for operation in the low tempera-ture, low pressure region of operations. This could, for example, cause a somewhat more restrictive set point for PORVs used to provide low temperature overpressure protection. CRGR was also advised that RG 1.99 Revision 2 provides a new understanding on the profiles for the radiation damage progression as a function of the material chemistry versus fluence. This could possibly affect the previous understanding of pressurized thermal shock (PTS) risk depending on the particular PWR as it approaches the latter part of its vessel design life.
CRGR concluded that there was insufficient infomation provided in the RG package to permit a more complete exploration and understanding of this matter.
Of particular importance to the CRGR were the implications to the PTS issue.
CRGR commented that this new information should have been better integrated with the recent PTS rule and the ongoing PTS work. CRGR recomends that the EDO request NRR and RES to give a priority effort to the integration of these separate actions to the extent required by the new infomation at hand. ELD should also work closely with NRR and RES on this matter.
Subsequent to the meeting, RES requested that the proposed revision' to RG 1.99 be dropped from further CRGR consideration until the issue is fully reviewed by RES and NRR.
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j DRAFT REGULATORY GUIDE 1.99, REVISION 2 RADIATION DAMAGE TO REACTOR VESSEL MATERIALS PURPOSE: GET REVISION 2 OUT FOR PUBLIC COMMENT s
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- 1. SAFETY SIGNIFICANCE o NORMAL OPERATION o TRANSIENTS o FUNCTION OF R.G. 1.99 AND APPENDICES G & H IN REGULATING.
FRACTURE PREVENTION OF R.V.
II. TECHNICAL UPDATE, REV. 2 VS REY. 1 0 BETTER DATA BASE o BETTER ANALYSIS o ACCEPTANCE BY TECHNICAL COMMUNITY 111. VALUE/ IMPACT 0 WHAT PLANTS ARE AFFECTED AND HOW MUCH?
o PWRS-SAFETY IMPACT o TRANSIENTS o NORMAL OPERATION -- PNL ANALYSIS o COSTS -- HEATUP o LTOP o BWRS -- HYDROTEST IV. RELATIONSHIP To PTS RULE V. IMPLEMENTATION tg h
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SUMMARY
OF THE CHANGES IN PRESSURE-TEMPERATURE LIMITS EXPECTED TO RESULT FROM A CHANGE FROM REVISION 1 TO REVISION 2 0F REGULATORY. GUIDE 1.99 Effect of Change Operating Reactors Plants Undercoino Licensing from Rev. I to Rev. 2 PWR BWR Totcl PWR BWR Total Ratchet 50-100' 4* 4 8 Ratchet 20-50' 16 17 33 32 12 44 No Change (120*) 23 7 30 3 0 3 Benefit 20-50' 7 1 8 Benefit 50-100* 1 0 1 Benefit 100-150' 1 0 1 Totals 52 29 81 35 12 47
" Values in the table are number of plants.
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05/21/85 23 Reg Anal RG 1.99 Rev 2
/0 1
L
c HAZARDOUS f,[
TO VESSEL
/
INTEGRITY N
t 1 -
5 g 2 HEATUP/COOLDOWN PATHS 3
/
/
1 TEMPERATURE O INCREASE IN PROBABILITY OF VESSEL FAILURE + PERSON -
REM PUBLIc EXPOSURE O DELAY IN STARTUP+ COST OF REPLACEMENT POWER 0 OTHER COSTS 0 COSTS AVOIDED 0 PNL ESTIMATE: $3500-5600 PER PERSON - REM AVOIDED 0 STAFF ESTIMATES (CAG ETC.) $900-1400
//
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- /20' LTOP SET Porur (Usrus REV. 1)
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PUMP SEAL LIMIT TEMPERATURE POTENTIAL IMPACT OF REVISION 2 ON THE LTOP SET POINT FOR
' PRESSURIZED WATER REACTORS
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. POTENTIAL IMPACT OF REVISION 2 ON THE PRESSURE-IEMPERATURE LIMITS FOR HYDROTEST OF BOILING WATER REACTORS i
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POTENTIAL FUTURE IMPACT ON PTS RULE 1
j 0 DATE PLANT WOULD REACH SCREENING CRITERION IF RTPTS j WERE CALCULATED PER R.G. 1.99, REV. 2 I
FT. CALHOUN 1987 (USING UPPER-BOUND CHEMISTRY)
INDIAN POINT 2 1993 (COULD BE > E0L IF CHEMISTRY UPDATED)
PALISADES 1993 CALVERT CLIFFS 1993 INDIAN POINT 3 2001 POINT BEACH 1 2001 MAINE YANKEE 2002 COOK 1 2006 l ALL OTHERS E0L 9
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/V
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IMPLEMENTATION LETTER TO UTILITIES P-T LIMITS AND ANALYSIS OF TRANSIENTS
- 1. ALL SUBMITTALS (CP, OL OR OPERATING REACTORS) AFTER (EFFECTIVE DATE OF REY. 2) WILL BE REVIEWED PER REV. 2.
- 2. DON'T WAIT MORE THAN 3 YEARS TO SUBMIT REVIEW OF P-T LIMITS.
PTS SCREENING CRITERION
- 1. PTS RULE IS NOT BEING AMENDED AT THIS TIME, BUT
- 2. RECALCULATE RT PTS USING.REV. 2 FOR EARLY WARNING OF NEED FOR FURTHER FLUX REDUCTION OR OTHER ACTION.
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' REVISION OF UPPER-SHELF ENERGY (USE) TREND CURVES o P-T LIMITS NOT AFFECTED o TRANSIENT ANALYSIS NOT AFFECTED, ExCEPT ATWS o USED IN CP REVIEWS OF BELTLINE MATERIALS l 0 USED IN ANALYSIS OF 50 FT LB REQUIREMENT (APP. G) o CONTRACTOR'S EFFORT To UPDATE WAS INCONCLUSIVE 9
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C F.d R M Ecri e/& 79
( 7-24-s 59 unolovt" CRGR JtLY 24,1985 PESENTATION i
PART 50 - EQUEST FOR OPE APPRNAL JtLY 10, 1985
- - - - --- , ,-y
o e REPORTING /RECORiXEEPING REQUIREENTS EACH SECTI'ON OF @ B REQUEST HAS SPECIFIC JUSTIFICATION e POTENTIAL FUTURE IMPACTS PLANNED ISSUANCE OF GENERIC LETTER TO ELIMINATE IODINE SPIKING REPORTING REQUIREENTS FROM THE TECHNICAL SPECIFICATION RECOPtENDATIONS ANTICIPATED FROM TECWICAL SPECIFICATION REVIEW GPOUP AND TK TECif4ICAL SPECIFICATION IPPROVEENT PROJECT ARE EXPECTED TO RESULT IN ADDITIONAL REDUCTIONS RECORDKEEPING
- PRIMARILY, 2 TYPES OF RECORDS ARE REQUIRED:
- 1. SIPPLE MAINTENANCE -
INFORMATION OR WRITTEN DOCUENTATION PUST BE RETAINED BECAUSE OF REQUIREENTS ELSEWHERE IN THE REGULATIONS OR IN LICENSE CONDITIONS OR TECmICAL SPECIFICATIONS e RESULTS OF INSTRlPENT CALIBRATION / SURVEILLANCE e PLANT LOGS e OPERATIONAL RECORDS
-2 , ,
- 2. GENERATION AND STORAGE OF REPORTS BECAUSE THE INFORMATION IN THE REPORTS NEEDS TO BE ASSESSED OR EVALUATION AT A LATER DATE
- TECH SPECS
- REPORTS OF 50.59(B) CHANGES E0 e COMPARISON OF OVERALL BURDEN REDUCTION SINCE 1982.
1982 1985 BURDEN REDUCTION BURDEN REDUCTION 6 MILLION 14,500 4 MILLION 2 MILLION e PRIMARY REASONS FOR REDUCTIONS ELIMINATION OF FINANCIAL REQUIREENTS PREVIOUSLY SPECIFIED IN APPENDIX C FOR OL REVIEWS
- ND NEw CP OR OL APPLICATIONS PROJECTED FOR NEXT 3 YEARS, RESULTING IN:
FEWER DESIGN AND CONSTRUCTION DEFICIENCIES ANTICIPATED UNDER 50.55(E)
- LESS BURDEN IN Tm OLMLITY ASSI.RANCE (M) AREAS e SlM%RY OMRT (OF NOTEBOOK) - BtRDEN BY MAJOR PARTS
a .
-3 , .
e HOW MIH BURDEN AFFECTS OPERATIONAL AND MAINTENANCE AND HOW MJCH AFFECTS NON-OPEPATIONAL?
i i 1982 0FFICE OF ADMINISTRATION ESTIMATES:
l OPERATIONAL: RECORDKEEPING 25%
REPORTING 36%
TOTAL 61%
) CONSTRUCTION: RECORDKEEPING' 15%
REPORTING 5%
APPLICATIONS 18%
TOTAL 38%
I PRR ESTIMATES FROM TABLE 1
, % BY OPERATION BURDEN BY OPERATION PERCENT OF TOTAL BJRDEN, AND MAINTENANCE, AND MAINTENANCE TOTAL PART (SEE TABLE 1) HOURS PERSONNEL PERSONNEL, HRS. BURDEN 2 344K 60% 206K 3 1,81K 30% 489K 4 392K 60% 235K 10 IK 80% 0,8K 12 336K 20% 67K 14 23K 80% 18K TOTAL 1,016K 26%/1,016K 3
(3,878Kj
9 e S e 6 m
t%
N
{n+b C SD -+-
W e- 3 W f O EN l s<
Ll u 2 0 -
q #
w V J CD aC H
l l
6 TABLE 1 SupemRY OF SUF70RTING STATEMENTS 10 CFR 50 . ..
Annual pueber of Surden hours Annual Annual Pg 5dject Respondents Recordkeepl Total Annual Per Respondent Annually Reporting Total Cost to BurdenHours} Annual Burden Hours Annual Cost Federal 1 Applicottens 0 Surden Hours To Industry 0 0 Covernment 50.30, 50.30s. 0 0 50.33, 50.34, (now appilcations not expected for the next 3 years) 0 0 50.54(hb),
and 50.55(d) 50.55b, 200 23 Const. Per- 460 4,140 4,600 mit Est. $276,000 $138,000 Appendia K; O O O 50.33a and O Appendia t; O 0 Appendicles 0 N N, 0 and 0; 50.34(f),TMI 50.36 and 50.36a, Tech Specs (delineated in Part 2 er the Supporting statements) 50.59(c), 168 50.90, 95 1,600 14,400 16,000 50.91(a) and (b), 8960,000 $1,020,000 ticense Amend.
Appl.
stased on 15 of total borden, except in the areas of Technical SpeelficationSee su
- Burdens which, in part, affect operations and maintenance personnel .
s
Stpe#RY OF SUpp0RTING STAT [HENTS 10 CFR 50 . ,
Annual Number of Annual Annual Burden Hours Respondents Annuel' Total Total M Subject per Respondent Recordkeeping Reporting Annual Cost to Annually Burden Hours Annual cost Federal Burden Hours Burden Hours To Industry Appendices Government ASS, 50.55a.,
50.55(f)-QA (Delineated in Part 3 of the Supporting Statements)
Records 50.54(cc).
50.54(dd) and 50.74 (proposed) (Burden will be feposed when the rules become ffnal) 50.00(b) 0 0 0 0 0 0 0 50.82, Iftense 0 0 0 0 teruf* 0 0 $115,200 nation (for in-house appil-
- 2 50.36, 2047 catlons) 168 192.000 151,970 Tech 343,970 $20,638,200 $957,600 Specs
- 3 Appendices. 12.458 131 ASS, 50.55a 669.104 962,856 1,631,960 $97,917,600 $9,791,760 50.55(f)-QA Sup044RY OF SUPPORTING STATEMENTS 10 CFR 50 .
Annual Number of Annual Annual Total Annual Burden Hours Respondents Recordkeeping Total Cost to Part Subject Per Respondent Annually Reporting Annual Burden Hours Burden Hours Annual cost Federal 8urden Hours To Industry
- 4 50.71, Bul- 4,800 40 Government 39,200 352,800 letins and 392.000 $23,520,000 $%0,000 Generic Letters 5 50.48, 144 95 Appendix R. 1,368 12.312 13,680 $820,800 $28,500 Fire Pro-tection 6 50.54(p), 538 93 5,000 security 45,000 50,000 $3,000,000 $672,000 7 50.54(q, r. 4,442 168 74,623 and t) 671,625 746,250 $44,775,000 $326,400 1
Appendix E,
) Energ.
, Planning 8 50.71(e) 3,000 93 9.300 Updated 83,700 93,000 $5,580,000 $27,900 FSAR 9 50.54(f) 408 202 8,250 74,250 Oath or 82,500 $4,950,000 $580,800 Afftre
-Ill-E
St99WlY OF SUPPORTING STATEMENTS 10 CFR 50 . .
Annual leumber of Burden Hours Annual Annual' Part Subject Respondents Total Annual Per Respondent Annually Recordkeeping Reportfag Total Cost to Burden Hours Annual Burden Hours Annual cost Federal
- 10 50.72 10 Burden Hours To Industry 93 Covernment lootifiestion 93 837 930 of Events $55,800 $6,245,600 11 50.55(e) 500 34 Design and 1,700 15,300 ConsL. Deff- 17,003
$1,020,000 $294,000 clencies
- 12 50.59(b) 2,000 lleports 168 268,800 67,200 336,000
$20,160,000 $806.400 13 Appendicles 233 G and H; 127 2,962 26,658 29,620 50.60, 1,777,200 $86,400 Fracture Toughness
.$4 Appendta 248 J. Centain, 93 2,306 20,752 23,058 testage $1,383.480 $3,780 15 50.35(b) 0 0 Periodic 0 0 Reports 0 0 (See supportive discussion in the Statement regarding the negligible 0 estimates)
-Iv-
.m 7
~
SUPMARY OF SUPPORTING STATEMENTS 10 CFR 50 Annual Annual phaber of Annual Annual , Total Total Cost to Burden Hours Respondents Recordkeeping Reporting Annual Annual cost Federal M Subject Per Respondent Annually Burden Hours Burden Hours Burden Hours To Industry Government 16 50.71(b) 1 127 13 114 127 $7,620 $7,620 and Appendix C, Financial .
17 50.54(v)(4) 4 50 20 180 200 $12.000 $720 Property Damage Insur-ance 18 50.34(g) 0 0 0 0 0 0 0 Implemen- (see discussion in the statement with respect to neg11gible estimates) tion of SRP 19 50.44(c) 1,500 6 900 8,100 9,000 $540,000 $345,600 Hydrogen
+
Control 20 50.49, 622 127 5.060 73,940 79,020 $4,741,200 $152,880 Environmental (Includes one-time cost to Qualification industry and Federal Gov.
as discussed in Part 20) 21 50.62 52 127 660 5,944 6,604 $3%,240 $182,880 ATW5 (one-time cost to Industry and the Federal Government)
-v-
e SUMARY OF SUPPORTING STATEMENTS ,
Annual Annual Number of Annual Annual Total Total Cost to Burden Hours Respondents Recordkeeping Reporting Annual Annual cost Federal Part Subject Per Respondent Annually Burden Hours Burden Hours Burden Hours To Industry Government 22 50.61 . 35 66 233 2100 2,333 $139,900 $155,000 Pressurfred Thermal Shock 23 50.64 (pro- 0 0 0 0 0 0 o posed) Highly Enriched (Burden will be imposed when the rule becomes final)
Uranium Totals: 31,410 2,126 1,283,674 2,594,178 3,877,852 $232,671,120 $22,985,440
-vi-e
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Enclosure 4 to the Minutes of CRGR Meeting No. 79 Briefing on Leak Test Practices for Pressure Isolation Valves (PIVs)
Frank Cherney, Bill Milstead and Jim Knight briefed the CRGR concerning the current NRR practices for leak testing of valves that function as isolation barriers between the high pressure reactor coolant system and lower pressure systems (e.g.,ECCS). These lower pressure systems may be located either inside or outside of the containment. (A copy of the briefing slides is attached).
The matter of pressure isolation valve (PIV) testing had been raised in connection with a staff proposal of February 14,1985 for CRGR consideration of a proposed change in the standard technical specifications that would provide for a relaxation of the the previous PIV leak rate test acceptance criteria.
NRR had concluded that such previous leak rate acceptance criteria had been overly restrictive and represented an unnecessary burden on licensees. By memorandum dated February 25, 1985, the CRGR Chairman indicated that relaxation of the leak acceptance criteria was a step in the right direction, but that a larger and somewhat separable question concerned the safety rationale that was being pursued to decide which PIVs required these tests. It was further noted in these memoranda that a significant increase in the number and nature of PIV leak rate tests were being required of the NT0L plants relative to the operating reactors (ors). These NTOL requirements were also being backfit to the operating reactors under the 10-year In-Service Test (IST) program without a clear safety rationale evident to support these actions. By memorandum dated June 20, 1985, NRR requested discussion with CRGR primarily on the matter of the PIV leak rate acceptance criteria for the NTOLS since there existed an administrative urgency concerning the technical specifications for several plants about to the licensed fcr operation. The need for conduct of further intersystem LOCA analyses to better establish the safety rationale for the specific PIV test requirements was acknowledged by this June 20, 1985 memorandum.
The briefing by F. Cherney provided CRGR with the background / history on how the PIY test requirements evolved. With use of an example PIV configuration that postulated the occurrence of an intersystem LOCA inside containment, W. Milstead illustrated the potential for a risk reduction associated with PIV leak rate testing. On questioning by CRGR this example was, however, acknowledged to provide an optimistic estimate for the safety benefits to be expected from the PIV leak rate tests.
CRGR offered the following comments and suggestions on this matter:
- 1. There is a clear need to improve on the safety rationale being used to justify the full extent of the PIV testing now being required of NT0Ls and for retroactive applications to the ors via the 10-year IST program reviews. In regard to the ors, the staff should remain cognizant of the' backfit policy.
4
- 2. The NRR proposal to continue its PIV test practices for several NT0L plants was viewed by CRGR as an acceptable administrative approach to take at this time. This approach would, however, invoke the proposed generic relaxation on the PIV leak rate acceptance criteria. Should the ongoing staff analysis reveal that the staff has required considerably more PIV testing than is reasonably justifiable from the viewpoint of the overall safety benefits involved, the staff should then consider further actions to relax the extent of the PIV testing being required of the NT0Ls. As is appropriate to these PIV analyses, the staff should realistically take into account any unnecessary occupational exposures being caused; the negative safety effects of potential test and maintenance errors resulting from these PIV tests, as well as averted accident risks and plant downtimes involved.
- 3. CRGR acknowledged the existence of safety concerns about the interfacing system LOCAs - particularly those involving a potential for core damage in conjunction with containment bypass (such as the Event V Sequence identified in WASH-1400). Such PIV configurations have also been identified as risk contributors of importance in other NRC and industry sponsored PRAs. While noting that in large part the Event V safety concern for operating reactors has been dealt with by the NRC orders in 1981, CRGR expressed the view that it was prudent for the staff to continue to look for similar PIV vulnerabilities during the IST program reviews. With regard to requiring stringent leak rate criteria for the PIV tests, CRGR also noted that such leak rate tests would be unlikely to provide useful precursor information as to the PIV rupture failure mode.
Concerning the IST program, CRGR was advised that these OR reviews were
+
now ongoing at a rate of ten or so plants per year. Given that regulatory decisions on each of these IST programs will likely be needed in the near term, CRGR recommended staff consideration be given to the development of better focused PIV guidance for the IST reviewers. Even if such guidance was to be of an interim nature, this guidance could improve on the identification of more vulnerable PIV configurations of concern to risk and help to determine the benefits that may accrue from particular PIV test schemes. Until such time as NRR demonstrates an adequate generic basis for changing the PIV testing program at operating reactors, any such changes should be performed consistent with the NRC procedures for plant-specific backfit (MC-0514).
l
1 CRGR Me % 79 genwis'k (7-24-s5) !
t%L, A '
LEAK-RATE TESTING E
PRESSURE ISOLATION VALVES STANDARD TECH SPEC REVISION SUBMITTED TO CRGR (2/85)
INCREASE IN ALLOWABLE LEAK-RATE FROM 1 GPM TO 1/2 GPM PER INCH OF VALVE SIZE (UP TO 5 GPM MAX.)
DEFINITION EACH OF TWO VALVES IN SERIES WHIOi SEPARATES REACTOR C00UWT FROM LOWER DESIGN-PRESSURE SYSTEMS. (NORMALLY-REACTOR fl)0LANT PRESSURE BOUNDARY AT AN INTERFACE WITH AN ATTACHED LOW PRESSURE SYSTEM)
=
1 1/2" SIZE AND ABOVE I
1 l
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CURRENT AND PREVIOUS ORGANIZATIONS FOR PIV TESTING p DE- N B - CURREhTLY RESPONSIBLE FOR SPECIFYING LEAK TESTING OF PIV'S IN ALL PLAhTS, PRIOR TO TMI, E B WAS RESPONSIBLE FOR IST IN NEW PLANTS ONLY AND DID NOT SPECIFY ANY PIV TESTING.*
- DSI-RSB - SPECIFIED PIV TESTING IN NTOL PLANTS PRIOR TO TNI. CURRENT RSB SECTIONS IN SRP SPECIFY LEAK TESTING FOR Ef PIV'S, NRR -
4
- DST - SPEB - GEERIC ISSUE PRIORITIZATION
- DL - LICENSING AND IPPLEMNTATION OF IST AND TECH SPECS,
- DIVISION OF OPERATING REACTORS (DOR) WAS RESPONSIBLE FOR SPECIFYING PIV TESTING IN OR'S PRIOR TO TMI.
I A
i HISTORY o WASH IG IDENTIFIED EVENT V FAI'.URE OF RCPB AT LOW PESSURE INTERFACE AS A HIGH RISK EVENT (1975).
= PWR'S
= CHECK VALVES
=
VALVES WHICH LEAD TO LOCA OUTSIDE CONTAINTNT o TMI ACCIDENT,1979
= NRR REORGANIZATION, 1980 o DAVIS-BESSE, SEQUOYAH PIV FAILURES, 1980 o " EVENT V" ORDERS,1981
=
ADDRESSED WASH I E EVENT V AT 32 PWR'S AND,2 BWR'S o TESTING OF ALL PIV'S FOR LEAK TIGHTNESS FORMALLY APPROVED THROUGH DIVISION DIRECTOR LEVEL, 1981
=
ALL NT0L'S SINCE TMI ACCIDENT
=
ABOUT 10-15 OR'S HAVE HAD FULL LIST OF PIV'S IFFOSED DURING IST REVIEW. UPDATE OF TECH SPECS SPECIFIED o LEAK TEST REQUIREPENTS NOT INCLUDED IN SRP SECTION 3.9.6 DUE TO PEB RESOURCE SHORTAGES o FOR NT0L'S, TECHNICAL SPECIFICATIONS WERE USED TO Ilf0SE LEAK TEST EQUIRDelTS FOR PIV'S,
=
SECTION IN STANDARD BWR AND PWR TECH SPECS,
i CURRENT REQUIRE?ENTS o CATEGORIZE ALL PIV'S AS ASE CATEGORY A OR A/C.
1.E., LEAKAGE IS IPPORTANT.
o LIST ALL PIV'S IN TECHNICAL S KCIFICATIONS AS NOTED IN STANDARD TECH S RCS.
o TECH SKC STANDARD LEAK-RATE TEST REQUIREENTS
= EVERY 18 M)NTHS
= EVERY COLD SHUTDOWN LONGER THAN 72 HOURS, IF A
, TEST WAS NOT PERFORED IN PREVIOUS 9 P0NTHS
= AFTER MAINTENANCE
= AFTER VALVE ACTUATION OR FLOW THROUGH VALVE
= EVERY 18 K NTHS OR AFTER MAINTENANCE ONLY -
IF PLANT HAS H.P. ALARPG, CONTROL ROOM INDICATERS AND PRESSURE INTERLOCKS, (ACTUATION AND COLD SHUIDOWN TEST DROPPED) o ADD LCO'S TO TECH SECS PER STANDARD TECH SECS
! = LEAKAGE LIMIT i
= IF LEAKAGE LIMIT IS E:Onstal VALVE IS DECLARED INOPERABLE UNTIL REPAIRED AND Rtitsitv.
l 1
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JUSTIFICATION OF CURRENT PRACTICE o GDC 14, 15, 30 AND 32 ALONG WITli DEFINITION OF RCPB i IN 10 CFR 50.2 o SRP SECTIONS 5.4.6, 5.4.7 AND 6.3 FOR RCIC, RHR DISCHARGE AND ECCS, RESPECTIVELY
= YEARLY LEAK-RATE TESTING FOR TWO GECK VALVE C0fflGURATIONS INSIDE AND OUTSIDE CONTAlffEhT o RECEhT STUDIES
= GEERIC ISSUE B-63, #96 AND #105
=
RHR SUCTION GATE VALVES (NRR/SPEB)
= PIV'S INSIDE CONTAlffENT (NRR/SPEB)
O e
4
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ECOPMENDATIONS o CONTINUE CURENT PfGRAM
= DO NOT STOP LEAK-RATE TESTING o PERFORM DETAILED, CONFIGURATION SPECIFIC EGULATORY AND TECHNICAL ANALYSES TO VERIFY
. = VALVE LIST
= TEST FEQJENCY a
e i
l 1
- 1
//V 2dec) sr'rs Su A'.<st 0s PGst' skt 7) V7
,, 7- ? </- 6 {,
,in s. .< r
(
P. ISOL ATION OF LOW PRESSURE SYSTEMS C0Fr!FCTED TO REACTOR COOLANT PRESSUPE BOUNDAPY SPECIFIC CONFIGURATION -
- TWO CHECK VALVES IN SERIES OP CHECK VALVE AND MOV IN SERIEE t
- CONTAINMENT BYPASS RESOLVED - EVENT V.0RDER 8 IST REVIEW
- PROBABILITY OF EVENT TOO HIGH (9.5E-6/RY FOP TWO CHECK VALVES IN SERIES, NEVER INDIVIDUALLY TESTED -
INTERLOCKED WITH RCS PRESSURE .
NOT INDIVIDUALLY TESTED AT SOME PLANTS
- FOR INDIVIDUAL LEAK TEST z1R = 30 MR/ REACTOR CcST = S65K/ REACTOR S = 700 MR/$M PPIORITY RECOMMENDATION - MEDIUM
- 105 - INTERFACING SYSTEMS LOCA AT BWRS
- NUMEPOUS OVERPRFSSURE EVENTS AT BWRS
- PREDOMIPATELY FOR LOW PRESSURE SYSTEMS W!TH TESTABLE CHECK VALVES
- Ex - !MPPOVEMENTS IN Malt:TENANCE e TEr.T ds P = 1,150 NF /FFACTOP '
CnST = 175,000/REACTOP S = 15,000 MR/$M PR10 PITY - HIGH g -
-9 .-s _ -- , - - - - , -- -, - y, ,
1 c .
INDIVIDllAL LEAK TESTING OF PlVS
- 1. USE OCONFE
- PRA 8 RISK MODEL AVAILABLE ON IBM PC
- IST PEVIEW COMPLETE - PIVS IDENTIFIED
- 2. LEAST SIGNIFICANT PIV CONFIGURATION - LOCA INSIDE CONTAINMENT (N0 BYPASS) IF Hi P/ LO P BARPIER FAILS
- 3. EXAMINATION OF OCONEE PIVS REVEAL ONLY TWO CFT LINES WHICH SATISFY t,BOVE CRITERIA s 5, 4.c.4 -se 4. sq o .. .
.tseotsobsso w St e O fS t We l
a.- ( t.
p 1** P** N *
- s" b 4. CHECK valve FAILURE RATE DATA 8 CALULATION b ric faa = Ss sooffrr. Ys = 9.s no*'/4,. G aa n ,arre) b e4 a e 19xo'%e G = S.s n ae/4,waa . (e.,as
-m..-2.n.}Jh (paa,s.i)y
- 5. BARRIER FAILURE SCENARIO - SAME AS NUREG-0677 CHECK VALVE A FTC/ LEAK 8 B RUPTURES, CHECK VALVE B FTC/ LEAK'8 A PUPTURES, CHECK VALVES A & B RUPTURE 1
l I
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- 6. P ty, =P gp P gp3g ProvF " S1 In OCONEE N P - PROBAPILITY BOTH CHECK VALVE FAIL (OVER PRESS. EVE l:T S )
0F P - PROBABILITY OF LOW PRESS. SYST. RUPTURE (0.75)
LPSP P ggyp - PROBABILITY MOV CAN'T ISOLATE RUPTURE (0.3)
- 7. RESULTS - OCONEE (IWO CORE FLOOD TANKS)
INDIVIDUAL PlV LEAK TEST FREQUENCY PEFUELLING NEVER OUTAGF QUARTERLY 3.887x10-5/PY 5.63x10-6/RY F
LOCA 3.36v.10-4/RY F
CM 2.36x10-5/PY 2.71x10-6/RY 3.94x10-7/P.Y R(25 YRS) (680 MR 80 MR 11 MR x >c , 1 AF LOCA
= 3.0x10-4/RY gFLOCA = 3.3x10-5/RY AF CM
= 2.1x10-5/RY AF LOCA = 2.3x10-6/RY A R = 600 MR A R = 69 MP G
AVERTED ACCIDFMT SAVINGS $.25M $ 028M
_llCENSEE MAINT. F SURVEILLANCF MANPOWEP PFOUIREMEPTS FOR:
l lllGH PRIOPITY 348 MHRS/VALVF N/A ( R TOO SMALL) l (S2 3,000 PP/SM)
DEF NSIBLE RFOPPT. lill2 MHRS/ VALVE 8 MHRF/ VALVE (C1,000/MR) l l
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Enclosure 5 to the Minutes of CRGR Meeting No. 79 :
Fire Protection (
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J. Knight (NRR) and W. Johnston (NRR) presented for CRGR review a Fire Protection-related package that included (a) detailed interpretations and !
guidance relating to implementation of Appendix R requirements, (b) a proposed new Standard Fire Protection License Condition, (c) proposed Guidance for Enforcement Actions Concerning Fire Protection Requirements, and (d) a proposed Generic Letter for implementing (a), (b) and (c) preceding. Copies of the briefing slides used by NRR at this meeting are attached (see Attachment I to this Enclosure). The complete Fire Protection Package considered by the Committee at this meeting was transmitted to the EDO by memo dated June 24, 1985, Denton to Dircks; it included the following items:
- 1. Attachment A Commission paper entitled " Staff Reconnendations Regarding the Implementation of Appendix R to 10 CFR 50," and enclosures as follows:
- a. Enclosure 1 - memo dated 10/26/84, Fire Protection Steering Committee to Dircks, " Recommended Fire Protection Policy and Program Actions"
- b. Enclosure 2 - memo dated 5/3/85, Vollmer to Denton, " Updated Recommendations on Fire Prntection Policy and Program Actions"
- c. Enclosure 3 - (proposed) Generic Letter on Fire Protection 1
- d. Enclosure 4 - (proposed) Interpretation > of Appendix R
- e. Enclosure 5 - (proposed) Appendix R Questions and Answers
- f. Enclosure 6 - (proposed) Fire Protection License Condition
- g. Enclosure 7 - (proposed) Guidance for Enforcement Actions Concerning Fire Protection Requirements
- h. Enclosure 8 - memo dated 6/27/84, Olmstead to Vollmer, " Fire Protection - Response to Trubach memo on Appendix R Guidance"
- 2. Attachment 8 NRR Response to W. Dircks-12/10/84 memo, and enclosures as follows:
- a. Enclosure.1 " Resolution of Connents on the Recommendations of the Fire Protection Policy Steering Committee" (50 ))t 2056,1/15/85; GL 85-01)
- b. Enclosure 2 - memo dated 3/20/85, Speis to Knight, " Risk Perspective on Fires in Nuclear Power Plants," and attachments:
-,--n-.- , , . ~ . - - - , - - - , ,m-, - - - ~ ~ . - ,. ---.-~---v.-m,.-~---ca,,,,w-- .,------.-.,,-v,--,--,,,.--,,,,e-., , - - , - , ,-n. , - - - - ,,--n-~,,
I
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- " Risk Significance of the Current Status of Fire Protection Capability at Operating Plants," and
- Appendix to " Risk Significance of the Current Status..."
- c. Enclosure 3 - memo dated 3/6/85, Taylor to Knight, " Resource Estimates for Proposed Expedited Fire Protection Inspections" 4
- 3. Attachment C "NRR Comments on the Steering Comittee Report" In addition to the documents listed above, the Committee had the benefit of several other related documents provided by R0GR staff in connection with l, review of these Fire Protection matters, as indicated below:
j 1. Memo, dated 12/10/84, Dircks to Stello/Denton/DeYoung; " Fire Protection i Policy Steering Comittee Recomendations" (see Attachment 2 to this
] Enclosure) l 2. ROGR staff sumary of discussions at the preliminary briefing provided to i CRGR at Meeting No. 78, regarding the Fire Protection Package listed in j 1.a thru 1.h above (see Attachment 3 to this Enclosure) l 3. Excerpts from a U.S. Court of Appeals Decision, dated 3/16/82, regarding disposition of a Petition for Review of the NRC Order Imposing Appendix R (see Attachment 4 to this Enclosure)
The principal objectives of the staff in developing the proposed fire
- protection guidance and related implementing documents were to (a) facilitate understanding of the requirements of Appendix R for all licensees and
[ applicants, (b) to expedite compliance with Appendix R in older plants, and (c)
, to better assure consistent levels of fire protection safety in all plants.
The bulk of the detailed guidance developed by the staff, to facilitate mutual understanding among the utilities and the staff regarding acceptable ways of complying with the requirements of Appendix R, is contained in documents entitled " Interpretations of Appendix R" (Item 1.d above) and " Appendix R QuestionsandAnswers"(Item 1.eabove). The basic content of these proposed guidance documents has been known to and' agreed upon by the staff and the utilities, and fairly-well set, for more than a year now. The detailed contents of those documents were worked out on the basis of close coordination and interaction between the staff and utilities' representatives. The staff
- stated that this guidance does not involve any new technical requirements.
In addition to the two detailed interpretation / guidance documents noted above, the Fire Protection Package proposed by the staff also addressed several fire protection policy issues that were examined at the request of the EDO by a senior management review team (the Fire Protection Policy Steering Comittee).
The Steering Committee developed a number of recomendations aimed at expediting implementation of Appendix R and at assuring more consistent levels
,1 . of fire protection safety in all nuclear plants, including the older operating
- . - _ _ _r-. _ . y - - - - - - - - -
7 ,-m. _--.-
v -- ,---- ----
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plants as well as the more recently licensed ones. Most notably, the Steering Comittee's efforts resulted in the proposed new Standard Fire Protection License Condition, the proposed Fire Protection Enforcement Guidance, and a recommendation for no further schedular exemptions in completing implementation of Appendix R.
Major points of discussion at this meeting regarding the proposals put fomard by the staff in tne Fire Protection Package were as follows:
- 1. Need for Appendix R and Proposed Measures for Expediting Its Implementation The staff focused on facilitating and expediting Appendix R implementation in developing the Fire Protection Package, and did not really attempt to i reexamine or reaffim at this point the safety need for the fire protection measures specified in Appendix R as suggested by several questions posed by the EDO in his December 10, 1984 memorandum to the program offices and DEDROGR (Attachment 2 to this enclosure; e.g.
- Questions 1, 5 and 7). The staff was assertive regarding this approach in discussions with CRGR at this meeting. The staff's view seemed to be that Appendix R is a "given," 1.e., it imposes Comission-approved requirements that are expected to be implemented expeditiously now, not further questioned and delayed. The staff emphasized that considerable (and, in some cases, repeated) delays have already been experienced in attempting to implement Appendix R, to the point that the Agency risks being severely criticized, or perhaps even sued, for failing to implement in timely fashion its own regulations, if it seriously contemplates and/or pemits further delays in implementing Appendix R at this point. Given that view, the staff felt that the Fire Protection Package that has been developed is appropriately responsive to the ED0's December 10, 1984 memorandum laying out and scoping the Commission paper intended to draw together all the separate elements and issues of the overall fire protection picture for Commission consideration and decision.
The Comittee acknowled'ed g the staff's concerns regarding such possible repercussions of further delay in implementing Appendix R, and felt that it was appropriate to bring those concerns to the attention of the Comission. Given CRGR's chartered function, however, the Committee considered it appropriate also to examine whether in the staff's view there is still seen a compelling safety need for the fire protection measures specified in Appendix R, or whether in concept and/or implementation to date Appendix R requirements go beyond what is actually prudently required for adequate fire protection safety. This seemed necessary, in fact, in order to better understand and judge the staff's current proposals, particularly those which appear to involve significant i new requirements, impose significant backfits, or otherwise suggest some significant impact (e.g., tb "no further schedular exception" recommendationandtheStanardLicenseConditionproposal).
j . . l l . ,
J.
I 1
1 2. Changes to Previously Approved Staff Positions i j In response to the Committee's request to identify any changes to r
- previously applicable staff positions involved in the proposed Fire ,
i Protection Policy, the staff indicated the following:
f a. The " Interpretations of Appendix R" (Item 1.d of the Fire Protection Package) reflect changes to previous staff positions in six l identified areas, the effect of which is to allow licensees greater
' flexibility in proposing acceptable ways of complying with Appendix R without the need for exemption (s).
I
- b. No new technical staff positions are imposed or implied by any of the extensive guidance material provided in the proposed " Appendix R Questions and Answers" document (Item 1.e of the Fire Protection Package). The intent of that document is to provide detailed
- clarification / guidance for licensees in areas where it was specifically requested and, in doing so, to reflect previously approved staff practice in the implementation of Appendix R to date.
- c. If imposed by NRC, the proposed Standard Fire Protection License i Condition (Item 1.f of the Fire Protection Package) would involve new i requirements, in the sense that for some licensees some comitments l to staff guidance would become enforceable as legal requirements.
However, the staff has only recommended that it be "made available" for voluntary subscription by licensees; as proposed, the'refore, the staff believes that the Standard License Condition imposes no new requirements or backfit.
- d. Schedules for completion of implementation of Appendix R by individual licensees are established by regulation under the i provisions of 10 CFR 50.48, as modified under the tolling provisions j
of 10 CFR 50.48 if requested and justified. The staff feels that '
ample relief has already been granted, where justified, from the schedules established basically by 50.48. The staff position, therefore, is that the "no further schedular exception" recomendation (see Item 1.c of the Fire Protection Package, at p.1)
, does not involve any new requirement or changed staff position, or impose any backfit as currently defined.
i With regard to the proposal to "make available" a Standard Fire Protection
! License Condition preferred by the staff, the Comittee wondered if the j staff seriously expected any licensee to voluntarily subscribe to a
- measure that would, in effect, make legal requirements of what were
! previously only comitments to staff guidance regarding their fire l protection program. The staff responded that the wording of the preferred Standard License Condition had been designed to actually facilitate
! changes to approved fire protection program features for some licensees j (e.g., in cases where some parts of a licensee's fire protection program l t i
1 e
1 l,
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are covered by comitments already documented in a license condition and' the licensee is therefore required arbitrarily to submit an amendment for changes), as well as to make binding licensee comitments that are not presently documented in a license condition or covered by 10 CFR 50.59.
More specifically, the staff explained that for licenses issued since about 1982 the Comission has directred that a license condition be imposed requiring compliance with the licensees fire protection program.
For these cases, the new license condition is intended to pennit licensees to make changes in their fire protection programs by a process similar to FSAR changes under 50.59, but still comply with the Comission guidance that there be a license ccndition. For older licenses there is a broad range of license conditions, some requiring compliance with certain (but not necessarily all) fire protection features. For these cases, the proposed license condition is intended to cover most aspects of some licensees fire protection programs than the current license condition; on the other hand, the license condition would permit, for some items, changes under procedures similar to 50.59 rather than by amendment. (For most plants, the fire protection program was not submitted as part of the FSAR and so would not be covered by 50.59.)
The Comittee suggested, with respect to NT0Ls, that the staff re-examine whether the 1982 Comission directive actually required use of a licensee condition rather than other methods for assuring enforceability. If so, the Comittee felt that the staff should explain the problem to the Comission and ask whether the Commission might reconsider that instruction initially developed in 1982 when Appendix R was published.
?
After considerable discussion on these points, the Comittee recommended that the staff consider having all licensees and applicants submit their fire protection program as part W the FSAR .in which case 50.59 would ap;,1y directly without need for the new license condition. Such a measure would still involve a new requirement for some licensees; but it is less intrusive as an imposed regulatory measure and has the added advantage of not appearing to elevate fire protection systems / features to a level of safety prominence exceeding that of other, safety-related plant systems / features (such as ECCS or protection systems) that typically are described in the FSAR but are not covered explicitly by a license .
condition. The Committee indicated that they could support such a measure
, as satisfying reasonably the apparently legitimate concerns and objectives of the staff in this area.
~
With regard to the recomendation for "no further schedular exemptions" in completing implementation of Appendix R, the Committee expressed serious reservations on the basis that the staff's proposal seemed to deny even '
the availability of the exemption process specified under 10 CFR 50.12 (except in a context requiring subscription to "living schedule"), and to l prejudge adversely the merit of any argument that might be offered by a l licensee or other interested party as justification for delaying the l 1
1
t schedule for full implementation. This seemed questionable in the context of an existing, explicit Comission policy that encourages continuing reassessment of the need/ justification for existing regulatory requirements, and recognizes the appropriateness of balancing considerations of safety importance/ priority vs availability (.of resources in determining schedules for implementing NRC requirements .. and not Note was also taken b just in a living schedule context.)in this context seeof a 19824U.S. Cour Attachment to this Enclosure) in which disposition favorable to NRC of a challenge to the order which imposed Appendix R seemed to be premised on assurances offered the Court regarding the availability to licensees of the exemption process with respect to any aspect of Appendix R in the implementation of that controversial rule. For these reasons, the Comittee felt that a very compelling safety rationale would have to be offered to justify anything like the stringent "no further schedular exemption" recomendation put forward by the staff in this package. Since that was lacking, the Comittee indicated
- that they could not support the staff's proposal in that regard.
- 3. Appendix R or Proposed Requirements That Go Beyond Safety In response to a request by the Comittee to identify areas in which Appendix R requirements and/or provisions of the proposed Fire Protection Package go beyond what would be required reasonably for safety, the staff stated that they were simply not in a position to detemine what parts of Appendix R are absolutely necessary for safety. The staff stated that Appendix R requirements (in fact, fire protection safety features i generally) are deterministic type involving judgment and considerations of L defense in depth to mitigate the many uncertainties involved (e.g.,
initiating fire frequency, size, spread, etc). The staff feels i comfortable that, collectively, all of the staff's fire protection requirements / positions provide at least the degree of fire protection safety sought; but individually any single element of Appendix R or a licensee's overall fire protection program might be difficult to justify either on the basis of safety need or cost effectiveness. In this context, it was noted that NRC fire protection requirements were drawn initially in an environment in which the guiding philosophy or approach was simply " prevent fires to prevent fire damage." The question posed by the CRGR here, however, seemed to reflect a different perspective; specifically the Comittee seemed to be asking "What degree of fire damage will result in an unacceptable degree of safety degradation?" The Comittee agreed that these were much different perspectives, and acknowledged the difficulty in sorting out "to what degree" Appendix R and the currently proposed Fire Protection Package go beyond what is required minimally for adequate fire protection safety. Nevertheless, the question posed seemed to some a valid one, in view of incipient concerns that have been noted within both the industry and the staff regarding the possible adverse safety impacts that could result from implementing unnecessary modifications to facilities to achieve levels of protection against postulated fire hazards that are not actually needed.
t l l
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4 7-I t
) In this context, the Comittee considered briefly, possible alternatives j to going forward with the Fire Protection Package and completing expeditiously the implementation of Appendix R. Basically, the alternatives seemed to be (a) starting over again with development of a new Fire Protection rule based on well defined fire protection safety 1 needs and objectives derived from consideration of the risk / safety l importance of the safety equipment to be protected from fire hazard, and
! (b) deferring completion of implementation of Appendix R to consider integration of its safety objectives with other closely-related pending safety issues (e.g., USI A-45 Decay Heat Removal). Both alternatives appeared to involve significant delay in closure of the fire protection
. issue; and it was noted that up to 70-80 percent of the total resources l required to complete Appendix R were probably already expended. On
- balance, in view of all these considerations, the Comittee agreed that
- the best cour
- e of action was to complete as expeditiously as possible the
} implementation of Appendix R.
- 4. Lack of Clarity in the Wording of Proposed Guidance The Comittee expressed concern that literal application of some staff j positions (as presently worded) contained in the proposed " Appendix R ,
- Questions and Answers" document was impossible, and that attempting to
- apply them literally could lead to degradation of safety. An example j focused on was a provision in the response to Question 5.3.10(c), which specifies that licensees must assure that " safe shutdown capability should
! - not be adversely affected by a fire in any plant area which results in l simultaneous spurious actuation of all valves in high-low pressure j interface lines." (see Item-1.e of T e Fire Protection Package, at
, p.26). Possible specific applications of that position in licensing reviews that were explored by the Committee reinforced the conclusion that literal implementation of this position and guidance was impossible. The most serious concern on the part of the Comittee was that in actually applying this guidance, as written, in licensing reviews to date, individual reviewers may have caused licensees to implement administrative
! controls (e.g., locking out circuit breakers or valve controls) which cumulatively could result in serious interference with prescribed operator
{
j actions and/or safety systems operation in response to severe transients i or accidents.
\
l The staff indicated that, in practice, the position was not applied by i
staff reviewers literally as written i.e., considering possible j simultaneous spurious actuation of all high/ low pressure interface valves ;
j in all lines / functions involving such interfaces. Instead, the staff i appTTes this position only to those valves or components whose control / power cables could be affected simultaneously by a postulated fire in one fire area. Typically a licensee may have to rack out the breaker supplying power to a motor-operated valve or lock out the controls for j, such a valve, in order to assure that at least one valve, in a line ,
j containingtwoorthreeisolationvalves,remainsopen/ closed (as '
3 required) when short circuits due to fire damage in control cables could '
! spuriously actuate valves if such administrative controls were not l implemented.
- i sw, v- w v.we,-,m +y ,,-ww--,-eng.ww~-pwcw .mn.n->y-- .c-. v,,r-._ --.-n4,,aye, _ .+,..,<mavn-4,,
, w y-v,.-,
I A similar question was raised regarding the wording and intent of
" Interpretation" #1 (see Item 1.d of the Fire Protection Package, at p.1),
which seemed to indicate that an exemption would be required if a licensee proposed anything except process monitoring instrumentation capable of providing a direct reading of reactivity in connection with the reactivity control function of a reactor. In application, the staff has accepted a source range monitor as providing the capability for a direct reading of reactivity, but rejected a proposal to use boron concentration readings in conjunction with rod position indication to provide equivalent reactivity monitoring capability. Some thought that (a) neither of those schemes provided a direct indication of reactivity; but (b) properly designed and implemented, both schemes provided equally acceptable indication of reactivity. It appeared that both schemes would require an exemption, however, under a literal reading of the language of the rule involved. Confusion resulted in the discussions of this matter, because the current staff position (and the proposed " Interpretations" document) guidance is that intended both schemes areby the staff in the acceptable without exemption.
As a generalization of the specific concerns noted above regarding the wording and intent of the proposed guidance documents, the Committee noted that there are a number of areas in which similar questions could be raised. The staff took note of the Comittee's concerns in this regard but cited a nunber of indications that, despite such problems or awkwardnesses in the specific wording of the guidance documents in question, sufficient mutual understanding exists between the staff and licensees regarding the meaning and intended application of the proposed guidance that it could be usefully applied in facilitating and expediting the implementation of Appendix R. One important indication noted in this context was significantly improved fire protection inspection results over the last year. The staff agreed to spot check on current and past staff practice in the two specific areas identified; but exprested confidence that application of the guidance in question by staff reviewers in the past has not resulted in degradation of safety at any operating reactor.
~
Conclusions and Recomendations As a result of the discussions of these matters with the staff, at this meeting and in the preliminary briefing provided by the staff at Meeting No. 78., the Comittee concluded the following:
On balance, it appears that the best course of action for the agency at this point is to complete the implementation of Appendix R. The Comittee believes that the detailed guidance proposed by the staff in the Fire .
Protection Package can be usefully applied in facilitating that process j and recomends that the Fire Protection Package be forwarded for 4 Comission consideration, subject to the following caveats:
l
9 t
- 1. .The Comittee does not support the recommendation for "no further schedular exemptions" for reasons indicated in the preceding (chiefly lack of a clear and defensible safety need). The Committee believes, however, that the staff's concerns regarding possible repercussions of failure to complete expeditiously implementation of Appendix R at this point as indicated in the preceding, and the related view that an amendment to Appendix R may be required if further schedular relief is to be granted, should be more clearly articulated to the Commission as the overriding decision factor if that is the staff's view.
- 2. The staff's proposal to make available a Standard License Condition for voluntary subscription by licensees should be modified as indicated in the preceding to more effectively achieve the staff's legitimate objectives as discussed in the preceding.
- 3. Explicit wording should be added to the implementing Generic letter that will be issued to licensees and applicants to make clear that the staff positions contained in this Fire Protection Package package (particularly in the document entitled " Interpretations of Appendix R") do not have a stature beyond that of regulatory guidance (i.e.,
the positions involved identify one, but not the only, acceptable way of conplying with the Commission's Fire Protection regulations).
l l
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l k
i ~
Attachment I to Enclosum 5 a IMPLEMENTATION, 0F APPENDIX R (FIRE PROTECTION)
PURPOSE: -
TO FACILITATE UNDERSTANDING OF THE REQUIREMENTS OF APPENDIX R. ,
)
EXPEDITE COMPLIANCE WITH THE REQUIREMENTS OF APPENDIX R IN OLDER PLANTS. I l
BETTER ASSURANCE OF CONSISTENT LEVELS OF FIRE PROTECTION AT ALL PLANTS.
DESCRIPTION: -
COMMISSION PAPER e .
INTERPRETATIONS OF APPENDIX R APPENDIX R QUESTIONS AND ANSWERS STEERING COMMITTEE ON FIRE PROTECTION POLICY
. GENERIC LETTER ON FIRE PROTECTION FIRE PROTECTION LICENSE CONDITION GUIDANCE FOR ENFORCEMENT ACTIONS 1
o .
] 6 RECOMMENDATIONS: THAT THE COMMISSION DIRECT THE STAFF TO:
- l. ISSUE THE GENERIC LETTER WITH ATTACHMENTS.
1
- 2. CONDUCT FIRE PROTECTION INSPECTIONS IN ACCORDANCE WITH CURRENTLY ALLOCATED FIRE PROTECTION RESOURCES AND AS DESCRIBED IN SECTION B 0F THE GENERIC LETTER.
- 3. UTILIZE THE GUIDANCE IN ENCLOSURE 7 AS ,
THE CRITERIA FOR ENFORCEMENT OF APPENDIX R REQUIREMENTS. < .
- 4. ENCOURAGE LICENSEES TO ADOPT THE STANDARD FIRE PROTECTION LICENSE CONDITION SET OUT IN ENCLOSURE 6.
- 5. PROCEED WITH MODIFICATIONS OF FIRE PROTEC-TION TECHNICAL SPECIFICATIONS IN CONJUNCTION i
WITH THE ONG0ING EFFORT ON TECHNICAL SPECI-FICATION IMPROVEMENTS.
1 l
i i
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- - _ . _ . ,.. _._._=___ _ - _ - _ . _
- Attachment 2 to
- / g.\ UNITED STATES Enclosure 5 i
[ NUCLEAR REGULATORY COMMQ!ON s me . oro . o. c. sem
(
..... DEC 10 984 l
MEMORANDUM FOR: Victor Stello, Jr., DEDROGR Harold R. Denton, Director, NRR Richard C. DeYoung. Director. IE FROM: William J. Dircks Executive Director for Operati,ons
SUBJECT:
FIRE PROTECTION POLICY STEERING ColmITTEE REC 0pmEN0tTIONS In a memorandum dated October 26, 1984, the Fire protection policy Steering L Committee provided me with their recessended actions on the fire protection !
policy and program. Comments on these recommendations have been received from the appropriate program and regional offices. The individual consents are enclosed.
These causents, although generally supportive of the Steering Committee's work, ,
raias a number of serious questions W11ch need to be answered before we can !
proceed to the Commission on this matter. They are:
- 1. Are all th: recoseendations 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? l
- 4. Considering the current status of fire protection capability at, operating plants, does the current risk dictate the reprogramming of inspection resources for fire protection inspection?
l
- 5. Is the magnitude of the safety problem cessensurate with the proposed actions; e.g., no further schedular exemptions?
- 6. Should the revised interpretations and guestions and answers be issued and what impact will they have on the overall program?
- 7. Do the recessendations go beyond what the Commission 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 Committee to the pDR and invite comment by interested parties. Comments should be V analyzed by NRR with assistry.e from IE and ELD as needed. This analysis should be provided as part o" a Commission paper.
\
l
! g
- lpp.
t
~ ~
i
- 2. The Director, NRR, should provide a quantitative estimate of the public risk associated with fire from operating plants based on their current status; 1.e., incomplete compliance with Appendix R. This p
estimate should be based on your review of pertinent existing PRAs that
' have been reviewed by NRC. The R0GR staff should be kept informed of i progress in this area. This estimate and associated basis should be :
i 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 reprogra m ed shall be identified and a basis provided.
l This report shall be provided to NRR for the Commission paper and shall be I 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
,1 provides specific recomendations for Commission approval. That paper i
should address the specific questions identified above. Target date for providing the paper to the CRGR for review is February 1,1985. ,
. hshould review the proposed Commission paper, address each of the above questions, and make specific recospendations to me not later than j 30 days after receipt from NRR.
I ex'pect appropriate management representatives from NRR, IE and the Steering Committee to attend the CRGR meetings on this issue to respond to CRGR questions.
AgnefEERan:18:rsks .
William J. Dircks -
Executive Director l for Operations !
l
Enclosures:
As stated
! cc: R. Minogue i G. Cunningham i Regional Administrators l Distribution ,
! Jconran JRoe )
WKane TRehm l
- J$nierek '
VStello i W0ircks l
- E00 rf '
DEDR0GR cf Central File -
0F0 :DEDROGR :DE R :DEDROGR :EDO f : : :
l
.....:............:.] .....:............:.. o ..:............:............:........... .
i NAME :WKane :JS k :VStello :WD rc s .: :
l DATE :12/3/84 :12/ /84 :12/ /84 :12//#/84 : :
I' -
! Attachment 3 to l ,
Enclosure 5
? (- ,
i l
) CRGR Briefing on Fire Protection
- l l
i The Committee was briefed by NRR (W. Johnston) on matters addressed in the proposed Fire Protection Guidance Package now scheduled for full review by CRGR l at Meeting No. 79 on July 24, 1985. The package being discussed was that submitted by MRR to the EDO by memorandum dated June 24, 1985 Denton to Dircks: that material was in turn distributed to CRGR mem6ers by memorandum dated F.fy 25, 1985, Stello to Bernero, et al. No additional briefing material was provided to the Comittee in connection with this briefing.
j The issues involved in completing implementation of the Appendix R rule regarding Fire Protection programs at operating reactors are long standing; and the Fire Protection Guidance Package that has been submitted for EDO
]
office-level consideration now ref'ects a complex chronology of evolution over j
l several years. This briefing was scheduled, therefore, in advance of final review by CRGR, to clarify any points or details identified by the Comunittee in I
its review of that seterial to date, and hopefully to better focus the presentations and discussions regarding the pmposed Fire Protection guidance package at Meeting No. 79.
I ~
The principal points developed in the discussions at this briefing were as 7
> follows:
. 1. The staff's position is that the new Fire Protection Guidance Package i addresses procedural changes and clarifications of interpretations of a
existing requirements that do not result in taposition of new requirements on licensees. Accordingly, NRR believes that the package would not -
necessarily require CRGR review. It was noted in this context, that the ,
ED0 has indicated (in a mano dated 12/10/84, Dircks to t j
5tello/Denton/DeYoung) that the Ceuunission Paper involved should be reviewed by the Ceuunittee; but it was also recognized that, with the l
i passage of time and the turn of events since then (including extensive consideration by a senior management review team appointed by ED0), review by CRGR may no longer be considered necessary.
j 2. The staff emphasized that the proposed Fire Protection Tech Specs, which were considered by the Fire Protection Steering Group in their review of l
the new Fire Protection Guidance documents included in this package, are 1 not now included in the package being considered by CRGR. The proposed Tech Specs involved are being further reviewed / developed in conjunction with the broader Tech spec review and improvement efforts now underway separately within NRR. They will be submitted for CRGR review later, as l-appropriate.
- 3. NRR has not prepared a cost-benefit analysis in connection with this Fire Protection Guidance Package, because no new requirements are-proposed / imposed or need justification. The NRR view is that this l
J
}
}
L_____ _,__ _ _ _______
l t
guidance package only reflects an attempt to expedite implementation of actions already specified or agreed to by the Comission.
- 4. Much discussion focused on the proposed Standard (Fire Protection) License l Condition. The staff believes that it is necessary to put existing Fire Protection Program comitments into a more binding form for some licensees, as part of an overall effort to better control / monitor changes made to previously approved Fire Protection system features or configurations. The staff also believes that it is appropriate to have all licensees on an equal footing with regard to documentation of plant-specific Fire Protection connitments (i.e., in the license condition fonnat already specified by the Comission for the more recently licensed plants).
The CRGR view was that the proposed Standard License Condition would, in effect, make legal requirements out of what have previously been recognized as comitments to guidance (in effect elevating guidance to the stature of a regulation or other such legal requirement). The proposed license condition does, therefore, involve new requirements (although, as proposed by the staff, the new legal requirements involved would not be imposed, but would be accepted voluntarily in response to " encouragement" ,
by the Comnission). The Comittee felt, therefore, that the proposed license condition was inconsistent with the suggestion that CRGR review was not really required. Alternative ways of achievin objectives in proposing the Standard (Fire Protection)g the staff's License stated Condition
. for all licensees were discussed. One alternative mentioned was for staff to identify the Fire Protection Program features over which the staff thought it necessary to exert improved control / monitoring, and to make Tech Spec items of those features. The discussions on this point at this
.. briefing were inconclusive; but this topic area was identified as a '
principal area for further treatment in CRGR Meeting No. 79 scheduled for July 24, 1985.
t
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the brief for respondent. Neresy /. Shahsian and G. Pisa! '
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. .E l '3euwerk. NI. also es,tered appearammar for agapendaat.
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! :).g an oil coHection system could sufBelently protect the cool- 3.T': . F~
t p% ant pump lubricant ihan Art. The anal rule, therefore, yfVgr, j stipulates only one anothod for protecting the lubrication M e
%:e. oll: an oil soDeetion system.10 C.F.R. I 50, App. R, -
'* b.: . III.0 (1980). :7,,g ,, * ,
This rule-making feBowed an eatensive presses of plant p f. .s l
. [g,::4d by plant evaluations that had enhainated in NRC staf ,9N 7 pir$4 approval of entire Are protection programs at usamty'du- '
3 clear power plants and of important portions et such JUd' h*
programs at others. Even so,'the original acties of pro- :M ' ~ ., ,
M.J posed r6% sentained no indication of whether 9 r g*$
l S plants would be seguired to alter approved features to .,y 4; l JAF
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comply with the new tions. The Anal rule spectaed .
g,g. >
] ' ,., that most of the requirements would not be in- ? ~.
](. M.M g posed upon plants that had received staf approval af 1
t features before the efective date of the new rela.10 f.K$5. M-M
- mmaa C.F.R. I 50.48(b) (1980). Three particular seguire-ments, however, were to be applied to aH suelear plants
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operating hafore January 1,1979, regardless of whether ! , '.9M . '"J3'-
.- 1 they had reesived staf approval of these aspects of their .'
i i Bre protection program. N. These include the portions /~. .. f. !. fli, .p? .*
%.5 of the Are protection program shaDenged here: the stand-ards for protecting duplicate and alternative asfa shut-
'T '.f.p@-y .
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down capacity and the method for protecting the reactor ,
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- An esample is the Robinson 2 unit, owned by Carolina di .v'
. 4 .
, Power & Usht Company. Carolina Power and Ught is an ,, .ht g
- j interrenor la this lawsalt. Its brief suplains in avant datan how the Are protection program as AnaHy adopted by the NRC
- 4. .. 4 @* d-s& l
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shsUensed here.10 C.F.R. I 50.48(b)yApp. R, IIIJ (1980). ,;
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F '. t " sonform to the new rules. E 150.4B(e)(4). - !' '
3.S.;F tation of the new rules is *N r =- Baal g=--5 _
W.8 acnon en me s wson 'E Exemptions are to ! t .3 Wgreiteirey the f = =t= upon a abowing by the' i f '
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7 requests were Aled within the thne provided and are now -
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in l< 7 IJght's most serious complaint about the nation of pro-posed rule-making here is that it isDed to ladicate or - ,
explain the technical basis en which the Coennission had .
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y i relied.in selecting the proposed rules. ; f .'
. .- The purpose.,ef the esament period is to aBow inter- -
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=ame process. If the notice of proposed ruleenaking ;
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%, UNITED STATES NUCLEAR REGULATORY COMMISSION i[
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APR 121985
)
MEMORANDUM FOR: Richard H. Vollmer, Chairman Fire Protection Policy Steering Comittee FROM: Faust Rosa, Chaiman Fire Protection Policy Working Group
SUBJECT:
FIRE PROTECTION POLICY STEERING COMMITTEE REPORT, INCORPORATION OF PUBLIC, REGION AND OFFICES COMMENTS; PROPOSED FIRE PROTECTION TECHNICAL SPECIFICATIONS I
The following enclosu.res are transmitted herewith. Enclosures 2 through 6 are typed in comparative - text format to identify the changes made in response to public, Region and Office coments (Reference 50FR2056 Jan.15,1985, G.L. 85-01).
pEnclosure 1: Proposed Technical Specifications For Fire Protection (with three attachments providing W.G. coments and recomendations) b Enclosure 2: Proposed Generic Letter on Fire Protection Mclosure3: Interpretations of Appendix R
? Enclosure 4: Guidance For Enforcement Actions Concerning Fire Protection Requirements c
c Enclosure 5: Fire Protection License Condition -
Enclosure 6: Appendix R Questions and Answers g Enclosure 7: Resolution of Coments on the Recomendations of the l
Fire Protection Steering Comittee j Advance copies of these enclosures were previously transmitted by my note to you dated April 4, 1985. The present transmittal differs from the previous in that the three attachments have been added to Enclosure 1, Section D of Enclosure 2 has been revised, Enclosure 6 has been revised to correct a few responses and Enclosure 7 has been completed.
The disposition of each coment is described in Enclosure 7. It should be noted that some of these comments cannot, in our view, be resolved without further Steering Committee and/or ISE action or consideration. This is i so indicated in,the resolutforysectipn'of jtbe folloying coniients:C1.2.a. l A;1.12, t 1.7, t2(1.2,42<2.6, Gf3.4, E.4.1,g2.4.3, Ac6.2.c2.6.6,@;7.~1, and'-2.7.3.
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R. Vollmer It should also be noted that the coments from three utilities (GPU Nuclear, Wisconsin Electric, and Southern California Edison) were received over a month after the expiration of the coment period. These coments were not addressed in Enclosure 7 because of resource and time constraints. It appears, from a cursory review of the coments, that they duplicate coments that have been addressed. A supplement to Enclosure 7 will be provided if deerred necessary after a more thorough review of the coments.
This transmittal fulfills all of the Working Group assignments to date on the fire protection policy review effort.
fgp Faust Rosa, Chaiman Fire Protection Policy Working Group
Enclosures:
As stated cc w/
Enclosures:
J. N. Grace T. T. Martin (RI)
J.A.Olshinski(RII)
R. L. Spessard (RIII)
C. J. Anderson (RI)
V. Benaroya T.E.Conlon(RII)
C. I. Grimes i W. V. Johnston W.S.Little(RIII)
S. D. Richardson W. M. Shields J. H. Conran G. Edison cc w/o
Enclosures:
V. Stello H. R. Denton J. M. Taylor l D. G. Eisenhut R. Bernero .
J. P. Knight R. W. Houston s
l 1
p,. pp -- ; =--= : = - . : -- - --- -
- - = :--- : -- - - --- . . -- : : . .. . -
EllCLOSURE 1 With Attichriisats21F20& 3);
4/12/85 It:STRUMENTATIOy FIRE DETECTI'ON INSTRUMENTATION
_ LIMITING CONDITION.FOR OPERATION 3.3.3.8 As a minimum, the fire detection instrumentation for each fire-detection zone shown-in Table 3.3-11 shall be OPERABLE.
APPLICABILITY: Whenever equipment protected by the fire detection instrument is required to be OPERABLE.
ACTION:
- a. With any, but not more than one-half the total in any fire zone, Function A fire detection instruments shown in Table 3.3-11 inoperable,,
restore the inoperable instrument (s) to OPERABLE status within 14 days or within the next 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> establish a fire watch patrol to inspect the zone (s) with the inoferable instrument (s) at leas't once per hour, unless the instrument (s) is located inside the containment, then inspect that containment zone at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> (or monitor the containment air temperature at leart once per hour at the locations listed in Specification 4.6.1.6;'-
b.
With more than one-half of the Function A fire detection instruments
" in any fire zone shown in Table 3.3-11 inoperable, or with any Function B fire detection instruments shown in Table 3.3-11 inoperable,
- r it h
- ny it:: :: ,
- r; ;dj;;;nt fir; d;;;;ti;n in;tr.;;nt; ;hean in '
Taile 2.2 11 inep; rabic, aithin I h;.7 restore the inoperable instrument (s) within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> so that more than one-half of the Function A and all of the Function B instru-ments are OPERABIE, or within the next i 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 contain-ment, then inspect that containment zone at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> (orthe at monitor t containment air temperature at least once per hour locati.he ons listed in Specification 4.6.1.6).
- c. The provisions of Specifications 3.0.3 and 3.0.4 are not applicable.
NOTE: Changes made by the Working Group are designated by a double bar in the right margit
- O SURVEILLANCE REOUIREMENTS 4.3.3.8.1 Each of the above required fire detection instruments which are accessible during plant operation shall be demonstrated OPERABLE at least once per 6 months by performance of a TRIP ACTUATING DEVICE OPERATIONAL TEST. Fire detectors which are not accessible during plant operation shall be demonstrated OPERABLE by the performance of a TRIP ACTUATING OEVICE OPERATIONAL TEST during each COLD SHUTDOWN exceeding 2" h;ir unless performed in the previous 6 months.
72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> The supervisory system for the NFPA Standard 720 4.3.3.8.2 The NITA Otandard 72 gsupervised circuits :;;;r. i:i:n associated with the detector alarms of each of the above required fire detection instrumer.:s snali ce camenstrated OPERAB.LE at least once per 6 months.
4.3.3.S.3 The nonsupervised circuits, associated with detector alarms, between the instrument and the control room shall be demonstrated OPERAELE at least once per 31 days.
W-STS 3/4 3-68 -
l I
l
- o TABLE 3.3-11 .
i FIRE DECTECTION INSTRUMENTATION '
TOTAL NUMBER INSTRUMENT. LOCATION OF INSTRUMENTS *
(Illustrative) ' HEAT F LAME SMOKE '
(x/y) (x/y) (x/y)
- 1. Containment #
- a. Zone 1 Elevation
- b. Zon'e 2 Elevation
- 2. Control Room
- 3. Cable Spreading
- a. Zone 1 Elevation
- b. Zone 2 Elevation
- 4. Computer Room
- 5. Switchgear Room
- 6. Remote Shutdown Panels ,,
- 7. Station Battery Rooms 8; Turbine
- a. Zone 1 Elevation
- b. Zone 2 Elevation 0 9. Diesel' Generator
- a. 2cne 1 Elevation
- b. Zone 2 Elevation
- 10. Safety Related Pumps
- a. Zone 1 Elevation '
- b. Zone 2 Elevation
- 11. Fuel Storage
- a. Zone 1 Elevation
- b. Zone 2 Elevation .
(List all detectors in areas required to ensure the OPERABILITY of safety-related equipment).
- (x/y): x is number of Function A (early warning fire detection and notification only) instruments.
y is number of Function B (actuation of Fire Suppression ,
Systems and early warning and notification)~ instruments.
- The fire detection instruments located within the containment are not required to be OPERABLE during the performance of Type A containment leakage rate tests.
i l
W-STS 3/4 3-69
ptART SYSTEM 5 3/4.7.11 FIRE SUPPRESSION SYSTEMS FIRE SUPPRESSION WATE'R SYSTEM E
LIMITING CONDITION FOR OPERATION 3.7.11.1 The Fire Suppression Water System shall be OPERABLE with:
- a. At least (two) fire suppression pumps, each with a capacity of (2500) gpm, at(125)psig and(rated)rpmfordiesel-drivenpumps with their discharge aligned to the fire suppression header,
'b. Separate water supplies, each'with a minimum contained volume of gillons, and
- c. An OPERABLE flow path capable of taking suction from the tank and the . tank and transferring the water through distribution piping with OPERABLE sectionalizing control or isolation valves to the yard hydrant curb valves, the last valve ahead of the water flow alarm device on each s:-inkler or hose standpipe, and the last valve ahead of the deluge va~ ve on each Deluge or Spray System req.uired to be OPERABLE per Specifications 3.7.11.2, 3.7.11.5, and 3.7.11.6.
APPLICABILITY: At all times.
ACTION:
- a. With one pump and/or one water supply ni' operable, restore the inoper-able equipment to OPERABLE status within 7 days.or p'rovide an alter-nate backup pump or supply. The provisions of Specifications 3.0.3 and 3.0.4 are not applicable.
- b. With the Fire Suppression Water System otherwise inoperab]e establish a backup Fire Suppression Water System within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
E-575 3/4 7-30
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. - . - i PLANT SYSTEMS SURVEILLANCE REOUIREMENTS 4.7.11.1.p. The Fire Suppression Water System shall be demonstrated OPERABLE: l
- a. At least once per 7 days by verifying the contained water supply l vol ume ,
- b. At least once per 31 days on a STAGGERED TEST BASIS by starting each electric motor-driven pump and operating it for at least 15 minutes on recirculation flow. -
- c. At least once per 31 days by verifying that each valve (manual, power operated, or automatic) in the flow path is in its correct position,
- d. .(At icest :n : p;r 5 months by performance of a (yetes fi 3t.,)
e: At least once per 12 months by cycling each testable valve in the flow path through at least one complete cycle of full travel.
-f . At least once per 18 months by performing a system functional test which includes simulated automatic actuation of the system throughout its operating sequence, and:
- 1) Verifying that each automatic valve in the flow path actuates to its correct position,
- 2) Verifying th;t ;;;h pump deni;ps at 1;nt (2500) spa at a
- yst;; had cf (250) feet, ,
Verifying that each fire pump starts (sequentially) through automatic operation and delivers 150 percent of rated capacity at not less than 65 percent of the total rated head and that the shutoff head does not exceed 120 percent of rated head for the split-case pumps or 140 percent for end-section pumps at rated speed (rpm).
~
- 3) Cycling each valve in the flow path that is not testable during plant operation through at least one complete cycle of full travel -end-
- 4) Verifyin; th;t G;h fire aup;ra;i;n pump starts (se_qwentielli) t: :: int:i- th: "' : hppr ::':r '!:t;r Sj;tc; prias . gr eter' then ;; ;;ni t: .p;ig.
- g. At least once per 3 years by performing a flow test of the system in accordance with Chapter 5, Section 11 of the Fire Protection Handbook, 15th Mt+r Edition, published by the National Fire Protection Association.
and at least once per (6 months - 3 years) by performing a system flush.
The interval for the system fluch should be selected on a plant-specific basis, based on the quality of the water source (e.g. ,
tank, pond, river,etc.).
h'-STS 3/4 7 . .
7 .
PLANT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued) c.7.11.1.2 The fire pump diesel engine shall be demonstrated OPERABLE:
- a. At least once per 31 days by verifying:
- 1) The fuel storage tank contains at least gallons of fuel, and
. continuously
- 2) The diesel starts from ambient conditions and operates for at' least 30 minutes on recirculation flow.
- b. At least once per 92 days by verifying that a sample of diesel fuel from the fuel storage tank, obtained in accordance with ASTM-D270-1975
-is within the acceptable limits specified in Table 1 of ASTM D975-1977 when checked for viscosity, water, and sediment; and
- c. At least once per 18 months, during shutdown, by subjecting the diesel to an inspection in accordance with procedures prepared in conjunction with its manufacture,r's recommendations for the , class of service.
4.7.11.1.3 The fire pump diese; starting 24-volt battery bank and charger shall be demonstrated OPERABLE:
- a. At least once -per 7 days by verifying that:
- 1) The electrolyte level of each battery is above the plates, and
- 2) The overall battery voltage is greater than or equal to 24 volts.
- b. At least once per 92 days by verifying that the specific gravity is appropriate for continued. service of the battery, and
__ c. At least once per 18 months by verifying that:
' 1) The batteries, cell plates, and battery racks show no visual indication of physical damage or abnormal deterioration, and
- 2) The battery-to-battery and terminal connections are c' lean, tight, free of corrosion, and coated with anti-corrosion material..
y-STS 3/4 7-32
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7 '
PLANT SYSTEMS -
SPRAY AND/OR SPRINKLER SYSTEMS l
LIMITING C0i!DITION FOR OPERATION i
- 3. 7.'11. 2- The following Spray and/or Sprinkler Systems shall be OPERABLE:
~
- a. (P1 ant depen' dent - to be listed by name and lo' cation.)
b.
c.
APPLICABILITY: Whenever equipment protected by the Spray / Sprinkler System is required to be OPERABLE.
ACTION:
equivalent manual
- a. With one o more of the above required Spray and/or Sprinkler Systems inoperab , within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> establish a continuous fire watch with b :hu;; ire suppress-ion equipment for those areas in which redundant systems or components could be damaged; for other areas, estsblish a .h hourly fire watch patrol.
- b. The provisions of Specifications 3.0.3 and 3.0.4 are not applicable.
SURVEILLANCE REOUIREMENTS -
4.7.11.2 Each of the.above required Spray and/or Sprinkler Systems shall be demonstrated OPERABLE:
_ a. At least once per 31 days by verifying that each valve (manual, power operated, or automatic) in the flow path is in its correct position,
- t. At least once per- 12 months by cycling each testable valve in the flow path through at least one complete cycle of full travel,
- c. At least once per 18 months:
- 1) By performing a system functional test which includes simulated automatic actuation of the system, and:
a) Verifying that the automatic valves in the flow path actuate to their correct positions on a test signal, and b) Cycling each valve in the flow path that is not testable during plant operation through at least one complete cycle of full travel.
, W-STS 3/4 7-33 1
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o' N SYSTEl'S l
SURVEILLANCE3 REQUIREMENTS (Continued) c) Opening a drain valve sufficient to verify that water l's available to the system.
- r0 0 7
- 2) By a visual inspection of the dr3 ;';; :Pr:) tid h a d.r:
system piping, hangers and appurtenances
. to verify their integrity; and .
- 3) By a visual inspection of each nozzle's spray a~rea to verify the spray pattern is not obstructed.
- d. ' At least once per 3 yeaYs by performing an air flow' test through each open head spray / sprinkler header and verifying each open head spray / sprinkler nozzle is unobstructed.
1 l
h'- ST5 3/4 7-34
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PL ANT SYSTE!'.S CO SYSTEMS 2
LIMITING CDNDITION FOR OPERATION 3.7.11.3- The f511owing High Pressure and Low Pres.sure CO -Systems shall- be 2
OPERABLE:
. a. (Plant dependent - to be listed by name and location.)
b.
c.
APPLICABILITY: Whenever equipment protected by the CO Systems is required to be OPERABLE. 2 ACTION:
- a. With one or more of the above required CO2 Systems inoperable,. ,
within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> estab.lish a continuous fire watch with backup fire suppression equipment for those areas in which redundant systems or components could be damaged; for other areas, establish an hourly fire watch patrol. .
- b. The provisions of Specifications 3.0.3 and 3.0.4 are not applicable.
SURVEILLANCE REOUIREMENTS 4.7.11.3.1 Each of the above required CO, Systems shall be demonstrated OPERABLE at least onc4 per 31 days by verTfying that each valve (manual, power
__ operated, or automatic) in the flow path is in its correct position.
4.7.11.3.2 Each of, the above required L: "n::= CO Systems shall be demonstrated OPERABLE: 2 '
For low-pressure systems,
- a. gat least once per 7 days by verifying the CO., storage tank level to be greater than and pressure to be greater .than psig, and for high-pressure systems, at least once per 6 months by verifying that the CO,stora6e
' tank weight is at least 90% of full-charge wei6ht, and
- l W-STS 3/4 7-35 ,
. - - - . - . , _ _ n - - - ,
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PLANT SYSTEI45 i )
SURVEILLANCE REOUIREMENTS (Continued)
- b. At least once per 18 months by verifying: time delays and alarm interlocks
- 1) The system including valves, associated tilation System fire dampers, and fire door release mechanis actuate manually and automatically, upon receipt of a simulated actuation signal, and
- 2) Flow frc : each nozzle during a " Puff Test."
- 3) The integrity of the system piping, hangers and appurtenances by visual inspect' ion.
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. PLART SYSTEMS '
HALON SYSTEMS LIMITING CONDITION FOR OPERATION 3.7.11.4 The following Halon Systems shall be OPERABLE:
- a. (Plant dependent - to be listed by name'and location'.)
b.
c.
APPLICASILITY: Whenever equipment protected by the Halon System is required to be OPERABLE.
ACTION:
- a. With one or more of the above required Halon Systems inoperable, within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> establish a continuous fire watch with backup fire suppression equipment for those areas in which redundant systems or components could be damaged; for other areas, establish an hourly fire watch patrol. ,,
- b. The provisions of Specifications 3.0.3 and 3.0.4 are not applicable.
SURVEILLANCE REOUIREMENTS 4.7.11.4 Each of the above required Halon Systems shall be demonstrated OPERABLE:
- a. At least once per 31 days by verifying that each valve (manual, power operated, or automatic) in the flow path is in its correct-position,
- b. At least once per 6 months by verifying Halon storage tank weight (or level) .
4 to be at least 95% of full charge weight (or. level) and pressure to be at least 90% of full charge pressure, and verifying 1.
Atleastonceper18monthsbyq T
1)' V;rif ing 3 2he system, including associated Ventilation System fire dampers and fire door release mechanisms, actuates manually and automatically, upon receipt of a simulated actuation signal, and F
- 2) fe. fer.T.;c.;e cf a flow teet through headers and nozzles toduring a test assure no blockage. g
- 1) The integrity of the system piping, hangers and appurtenances by visual inspection i
l W-STS 3/4 7-37
,,, , --,-m, - ~ " ' ' ' ' '
PLANT SYSTEMS FIRE HOSE STATIONS LIMITING CONDITION FOR OPERATION .
3.7.11.5 Yhe fire hose stations shown in Table 3.7-5 shall be OPERABLE.
APPLICABILITY:, Whenever equipment in the areas protected ~ by the fire isose stations is reqdired to be OPERABLE.
ACTION:
- a. With one or more of the fire hose stations shown in Table 3.7-5 inoperable, pr:vid: ::t;d Wy;(;) en the nea. e;t O'C'ASLE hv==
- t:ti:n(:).
On: Outlet :f th: yy: chzi' b; ::nnt:t;d t; th;
- t:nd:rd 1:ngth :f h::: ;r;;id:d f:r th; h;;; ;t;t";n. The ;e;;nd.
- .tict ;f th; wy
- :h:11 b; ;;nac;t;d t: ; i;nsth ;f h;;; ;uffici;nt t; pr;;id: :: :r:;: f:r th: :r:: 1:ft anpr;t::t;d 53 th: inep;rabia-h;;; :t:ti:r. "h:r: it :;r 5: d;;:n:tr:t:d th:t th; phy:i;;t 7;; tin; ;f th: 'ir: 5::: .::;id r;; ult in : r;;;;ni;;bi; h;;;rd t;'
- p;r
- ti ; t::5-i:itn ,#-pi: nt :quipr:nt, :r th: 5::: it :if, th; fir; rel' :t_th: :Uti t f th: CP:Pf0L h;;e 5::: ch:1' be ste ed t:ti:r. Sign: :h:1' t: :: nt:d ;b:c; th; ;;t;d w3;(;) t; ide..tify th; pr;;;r h::: t: u:- Tn; ;b;;; ACT!ON' r;;;ir;;;nt ; hell be e;;;;pli;h;d ithi ,15;ur if th; insp;rabi; fi.; hee; i; the prim:ry :::n: :f " r: : p;r;;;ien, :th;rwi ; r;;t; th; ;ddition;i h;;; with'. 29 h:ur .
restore the inoperable station (s) to an OPERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, or within the next i hour provide equivalent suppression capability in the affected area (s); after 7 days, establish a continuous fire watch in the affected area (s),
g
- b. The provisions of Specifications 3.0.3 and 3.0.4 are not app 1icable. ,
SURVEILLANCE REOUIREMENTS 4.7.11.5 Each of the fire hose stations shown in Table 3.7-5 shall be demonstrated OPERABLE:
- a. At least once per 31 days, by a visual inspection of the fire hose stations accessible during plant operations to assure all required equipment is at the station.
- b. At least once per 18 months, by:
- 1) Visual inspection.of the stations not accessible during plant operations to assure all required equipnent is at the station,
- 2) Removing the hose for inspection and re-racking, and
- c. At least once per 3 years, by:
- 1) Partially opening each hose station valve to verify valve OPERABILITY and no flow blockage, and
- 2) Conducting a-hose hydrostatic test at a pressure of 150 psig or at least 50 psig above maximum fire main operating pressure, whichever is greater. .
lt W- STS
- 3/4 7-38 l 1
- - ~ -
TABLE 3.7-5
- FIRE HOSE STATIONS LOCATION
- ELEVATION HOSE RACK # -
)
" equipment.
List all Fire Hose Stations required to ensure the OPERABILITY of safety-related W-STS 3/4 7-39
PLANT SYSTEMS YARD FIRE HYDRANTS AND HYDRANT. HOSE' HOUSES LIMITING CONDITION FO'R' OPERATION 3.7.11.6 The yard fire hydrants and associated hydrant he'se houses shown in Table 3.7-6 shall be OPERABLE.
APPLICABILITY: Whenever equipment in the areas protected by the yard fire hydrants is required to be OFERABLE. ,
ACTION:
- a. With one or more of the yard fire hydrants or associated hydrant hose houses shown it Table 3.7-6 inoperable, withi- 15:;r hn:
'ficist dditi:=1 .WAe-ef-C 1/:' inh di; ,;tu h:n kut;d ir, n cdj:: nt OPEP*. ELE hydr:nt hn: 5:;n t: pr:;id: nrvi t; th; crpretected : ::( ) th: # :p:r:5h fh.c hydr:nt r n::i:ted hydr:nt hn: 5=n i: th: pr' :r; :n n; cf r: =;;rn:icn;
- th:r i n , preside th: 2dditier:1 5:n 'th'- 21 50;r:.
restore the inoperable hydrant (s) and/or hose house (s) to an OPERABLE status within 2f+ hours, or within the next i hour provide equivalent slippression capability in the affected area (s); after 7 days, establish a continuous fire watch in the affected area (s).
- b. The provisions of Specifications 3.0.3 and 3.0.4 are not applicable. !
SURVEILLANCE REOUIREMENTS 4.7.11.6 Each of the yard fire hydrants and associated ~ hydrant hose houses shown in Table 3.7-6 shall be demonstrated OPERABLE:
- a. At least once per 31 days, by visual inspection of the hydrant hose-house to assure all required equipment is at the hose house,
- b. At least once per 6 months (once during March, April, or May and once during September, October, or November), by visually inspecting each yard fire h drant and veri.fying that the hydrant b' a rrel is dry and that the hydrant is not damaged, and
- c. At least once per 12 months by:
- 1) Conducting a hose hydrostatic test at a pressure of 150 psig or at least 50 psig above maximum fire main operating pressure, whichever is greater,
_ in the couplings, and
- 3) Performing a flow check of each hydrant to verify its !
W
_-STS 3/4 7-40 l l
l
~
TABLE 3.7-6 YARD FIRE HYC RM;TS AND ASSOCIATED HYDRANT HOSE. HOUSES r
LOCATION
- HYDRANT NUMBER 4
" List all Yard Fire Hydrants and Hydrant Hose Houses required to ensure the OPERASILITY of safety rela ed equipment or facilities housing safety-related equipment.
Ll-STS 3/4 7-41
PLANT SYSTEMS 3/4.7.12 FIRE RATED ASSEMBLIES LIMITING CONDITION FOR OPERATION s
3.7.12 All fire rated assemblies (walls, floor / ceilings, cable tray enclosures and other fire barriers) separating safety related fire areas or separating portions of redundant systems important to safe shutdown within a fire area and all sealing device windows; fire dampers;g in fire rated assembly penetrations (fire doors; fire shall be OPERABLE.
cable, piping, and ventilation duct penetration seals) and APPLICABILITY: f,t d' ti ::. Whenever the equipment protected by the fire-rated assembly (ies) must be OPERABLE.
ACTION: ,
- a. With one or more of the above required fire rated assemblies and/or sealing devices inoperable, within one hour either establish a continuous fire watch on at least one side of the affected assembly, or verify the OPERABILITY of fire detectors on at least one side of the inoperable assembly and establish an hourly fire watch patrol. !
b.
The provisions of Sper'fications 3.0.3 and 3.0.4 are not applicable.
SURVEILLANCE REOUIREMENTS 4.7.12.1 f,t l = t On;; p;r 12 u nth; the above required fire rated assemblies .
andn penetration vi i in:p;;ti:nsealing Of: devices shall.be verified OPERABLE 3,7 p;rf;rr.'n;; a
- a. At least once per 18 months by perfoming visual inspections of:
_ i. A. The exposed surfaces of each fire rated assembly,
- 2. A. Each fire window /fira damper and associated hardware, and
- 3. A At least 10% percent of each type of sealed penetration. If apparent changes in appearance or abnormal degradations are found, a visual inspection of an additional 10% of each type of sealed penetration shall be made. This inspection process shall continue until a 10%
sample with no apparent changes in appearance or abnormal degradation is found. Samples shall be selected such that each penetration will be inspected every 15 years.
- b. At least once per 18 months by performin6 a functional test of at l l_ east 1QC of the accessible fire dampers.. If any non-confo m ing dampers are found, an additional 10% will be functionally tested.
This process will continue until an acceptable sample is found.
Samples shall be selected such that all accessible dampers are tested every 15 years.
f'-STS 3/4 7-42
PLANT SYSTEMS SURVEILLANCE REOUIREMENTS (Continued) 4.7.12.2
> _ . Edch of..___.:_
the above required __,_.__ fire doors shall 'be ver'ified OPERABLE by:
- __ _e.
.u_,a_....
ine s..ng r,___. ____
.o. . . . . . - . . . ~ . . r.., . . - . . . . .
__s
.. .:__..3
___e._:._
__s
,__e.._,_
... ,-. ... r -_. e. _ _ . u. . . . . . . . ,
...,a. u,m. .. _. . ..7. _ __
. . 3 e m, .....t.....t rv .,.< .+u- ...< -.......::-.
..r....... . . , .. . . . .. <_
..u. 2-
- m. .
. . _... . ... . _..u.
-eh.., ...:... ,. .
- 7. i. ..,. ..._.:,.....
.r J << ...
- .J.-_
. .. L..
m,,.-- - . . . . ~ , , _. ,
. 7 r ._._.<.._._......w*.*m*T.Pi . a e n-..wn- . . a .. .v u. e u m. w an. won. -.r,. .sa,. __ - __- ,, >_ ._
.. . m6 __ 6 wo c js. u w o,y , ,
- u. -6..,.. ...u ,
.s <: 2.._ . _,___;
.2.. .s . 3.
,ums ___
ys.
'I~6tYt s
- u. .. . 2._- ... ...:. u..._,.2._.__._._.
..:.u.. ..... ...
r
..s _.s.._
.. ......___. .u.__o .___ . m ,. ___ . . ,___
. t ,. ..
_u. _._.:... + ... v u.... ..> .
..s
. . . . . . . n. ... _-. .__ <..__.r.__,
_,,+.. ., .. .. .. . ..._r,--
- 4. . ,-_,-
_ . .. 3. . ._
7.. . .e ....u.,.,
u..
2
.. .. . . . .u ...,-a...-.4 <<.-. s ,. . ._. : . u. . . ..
.. .. ._ .... . . . . .3.
.+_ _.,
. ...... .. . .y....
.....,....,____,,u_..__ . ..... . . . . . r.. . . . . .
- a. At least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, by verifying that doors with automatic hold-open and release mechanisms are free of obstructions and that unlocked fire doors without electrical supervision are closed; '
- b. At least once per 7 days, by verifying that each locked closed fire -
door is locked and closed;
- c. At least once per 31 days, by performing a TRIP ACTUATING DEVICE OPERATIONAL TEST for each electrically-supervised fire door;
- d. At least once per 6 months, by visually inspecting the autematic hold-open, release and closing mechanisms and latches; and
__. e. At least once per 18 months, by perfoming a functional test of all hold-open and release mechanisms.
W-STS 3/4 7-43
j
)
PLANT SYSTEMS 3/4.7.13 ALTERNATIVE / DEDICATED SHUTDOWN SYSTEM LIMITING GONDITION FOR OPERATION 3 7.13 The Alternative / Dedicated Shutdown System (ASS / DSS) equipment, shown on Table 3 3-X, shall be OPERABLE.
APPLICABILITY: MOIES 1, 2, and 3 ACTION:
- a. With less than the mininum ASS / DSS equipment in Table 3 3-X OPERABLE, restore the inoperable equipment to OPERABLE within 7 days, or provide equivalent shutdown capability and restore the inoperable equipment to OPERABLE within 60 days, or be in HOT STANDBY within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and HOT SHUTDOWN within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
- b. The provisions of Specifications 3 0.3 and 3 0.4 are not applicable.
SURVEILLANCE REQUIREMENTS 4.7.13 1 EachmonitoringinstSmentationcht.nnelshallbedemonstrated OPERABLE by performing the CHANNEL CHECK and CHANNEL CALIBRATION operations at the frequencies shown on Table 4.3--X.
4.7.13 2 Each transfer switch, power supply and control circuit shall be demonstrated OPERABLE at least once per 18 months by operating each actuated component from the ASS / DSS stations.
4.7.13.3 The ASS / DSS diesel 6enerator shall be demonstrated OPERABLE:
- a. At least once per 31 days by verifyinE8
- 1) The fuel level in the fuel stora6e tank is greater than or equal to ( ) inches,and
- 2) The diesel starts from ambient conditions and operates for at least 30 mir.utes at greater than or equal to ( )kW.
- b. At 1. east once per 92 days by verifying that a sample of diesel fuel fron the fuel storage tank, obtained in accordance with ASTM-I270-1975, is within the ceceptance limits specified in Table 1 of ASTM-L975-1977 when checked for viscosity, water and sedinents and
- c. At least once per 18 months, during shutdown, by subjecting the diesel to an inspection in accordance with procedures prepared in conjunction with the manufacturer's recenmendations for the applicable class of service.
~
4
SURVEILLANCE REQUIREENTS (continued) 4.7.13.4, The ASS /IES battery bank and charger shall be demonstrated OPERABLE:
- a. At least once per 7 days by verifying that:
- 1) .The electrolyte level of each battery is above the plates, and
- 2) The overall battery volta 6e is greater than or equal to ( ) volts' .
- b. At least once per 92 days by verifyin6 that the specific gravity is appropriate for continued service of the battery; and ,
c, At least once per 18 months by verifying that:
- 1) The batteries, cell plates, and battery racks show no vicual indication of physical damage or abnomal deterioration, and
- 2) The battery-to-battery and terminal connections are clean,
. tight, and free of corrosion.
i NOTE: ADD OPERA 31LITY, ACTION REQUIREMENTS AND SURVEILLANCE REQUIREMENTS FOR ANY OTHER ASS / DSS PLANT-SFECIFIC EQUIIEENT, AS APPROPRIATE 4
e f
a m
4 h
r - ,
I (ILLUSTRATIONAL OrlLY)
ASS / DSS MINIMIN EQUIH4ENT 8
INSTRUMENT READ 0tTP IOCATION MININUM CHANNELS TRANSI'TR SWITCHES SWITCH IDCATIGi
_QONTROL CIRCUITS SWTTCH IDCATION 6
NOTE: , IDENTIFY OTHER MINIMUM EQUIPMENT REQUIRED TO OPERATE ASS /IES, AS APPROPRIATE
- 0 4
PLANT SYSTEMS l 3/4.7.14 PORTABLE FIRE EXTINGUISHERS l LIMITING CONDITION FOR OPERATION 3 7 14 All portable: fire extinguishers protecting areas containing safety-related equipment, as described in the Fire Hazards Analysis, shall be OPERABLE.
APPLICABILITY: At all times.
ACTION:
- a. With one or more of the required portable fire extinguishers inoperable, within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> replace the inoperable extinguisher with an OPERABLE extin6uisher having the same classification j and at least equal rating,
- b. The provisions of Specifications 3 0 3 and 3.0.4 are not applicable.
SURVEILLANCE REQUIREMENTS 4.7.14 Each required portable fire extinguisher shall be verified to be OPERABLE by performing surveillance and maintence in accordance with procedures prepared in conjunction with the manufacturer's recommendations and verifying that each extinguisher is located as designated in the Fire Hazards Analysis.
s e
h e
M
l TABLE le,3-X (ILLUSTRATIONAL ONLY)
ASS / DSS INSTRUMENTATION SURVEILLANCE REQi!IRENENTS INSTRklMENT CilANNEL CIIANNEL CHECK _ CALIBRATION e
h e
e 4
W
. . l FIRiT SYSTEMS 1
3/4.7.15 EMERCENCY LICHTING UNITS ;
LIMITING CONDITION FOR OPERATION 3.7.15 All required self-contained, battery-powered emer6ency lighting units, as described in the Fire Hazards Analysis, shall be OPERABLE.
APPLICABILITY At all times.
ACTION:
- a. With one or more of the required emer6ency lighting units inoperable, within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> replace the inoperable lighting unit with an OPERABLE lighting unit.
- b. The provisions of Specifications 3 0 3 and 3.0.4 are not applicable.
SURVEILLANCE REQUIREMENTS 4.7.15 Each of the required emergency lighting units shall be verified to be OPERABLE by performing surveillance and maintence in accordance with proceditres prepared in conjunction with the manufacturer's recommendations.
.l m
e O
M
INSTRUMENTATION s
BASES 3/4.3.3.2 MOVABLE INCORE DETECTORS The OPERABILITY of the movable incore detectors with the specified minim complement of equipment ensures that the measurements obtained from use of this system accurately represent the spatial neutron flux distribution of he core. The OPERABILITY of this system is demonstrated by irradiating a detector used1and determining the acceptability of its voltage curve Forthepurposeofmeasuring'F(Z)orFhafullincorefl q map is used. .
Quarter-core flux maps, as defined in WCAP-8648, June 1976, y be used in -
recalibration of the Excore Neutron Flux Detection System and full incore -
flux maps or symmetric incore thimblet may be used for nitoring the QUADRANT POWER TILT RATIO when one Power , Range channel is ino able.
3/4.3.3.3 SEISMIC INSTRUMENTATION m
a The OPERABILITt capability is available toofpromptly the seismic det instr entation ensures that sufficient E ine the magnitude of a seismic event and evaluate the response of those-fe ures important to safety. This capa- $
c.
bility is required to permit compar on of the measured response to that used- %
in the design basis for the faci pursuant to Appendix A of 10 C y to determine if plant shutdown is required s with the recommendations of gulatory100. Part The instrumentation is consistent Guide 1.12. " Instrumentation for Earth-E quakes," April 1974. =
y 8
m 3~/4.3.3.4 METEOROL CAL INSTRUMENTATION The CPE ITY of the meteorological instrumentation ensures that sufficient m eorological data are available for estimating potential radiation doses to public as a result of routine or accidental release of radioactive materia to the atmosphere. This capability is required to evaluate the need for i pu tiating protective measures to protect the health and safety of the c and is consistent with the reconnendations of Regulatory Guide 1.23,
" nsite Meteorological Programs," February 1972.
3/4.3-3.5 ' REMOTE 4HUTDOW.3YSTEM
~
The OPERABILITY of the Remote Shutdown System ensures that sufficient capability is available to permit safe shutdown of the facility from locations outside of the control room. This capability is required in the event control room habitat >ility is lost and is consistent with General Design Criterion 19 of 10 CFR Part 50.-
The OPERABILITY of the Remote Shutdown System ensures that a fire will not preclude achieving safe shutdown. The Remote Shutdown System instrumentation, W-STS B 3/4 3-4 r y-v. - , -- , . . , , - , _ , - , - - . , . , , . - - - $ -- -.,,--.4 - - , - - . - - , - .,,7 - n----. , c,
, INSTRU:4ENTATION BASES -
.RDO1F3)tuTD%WSY57,EM ( C o n t i n u e'd) control and' poser circuits and transfer . switches necessary to eliminate effects of the fire and allow operation of instrumentation,' control and power circuits required to achieve and maintain a safe shutdown condition are independent of areas where a fire could damage systems normally used to shutdown the reactor.
This capability is consistent with General Design Criterion 3 and Appendix R to 10 CFR 50.
3/4.3.3.6 ACCIDENT MONITORING INSTRUMENTATION <
The .0PERABILITY of the accident monitoring instrumentation ensures t suf ficient information is available on selected plant parameters to . tor and assess these variables following an accident. This capabili is consis-tent with the recommendations of Regulatory Guide 1.97, "In m Light-Water-Cooled Nuclear Power tlants to Assess Plant nditions mentation for g During and $
~ Following an Accident," Decembef*.975 and NUREG 072
- Action Plan Requirements," November.1980.
' Clarification of TMI .
3
.i c
._ 3/4.3.3.7 CHLORINE DETECTION SYC S
,- The OPERABILITY of 5
~ capability is avail e Chlorine Detection System ensures that sufficient e to promptly detect and initiate protective action in 6
, the event of a .cidental chlorine release. This capability is required to M e protect co
.o1 room personnel and is consistent with the recommendations of Regul
+
- y Guide 1.95, " Pro.tection of Nuclear Power Plant Control Room Oper-
.s Against an Accidental Chlorine Release," February 1975.
3/4. 3. 3. 7:'"TI RE'D ETECTI ON I N$TRDMENTATI ON OPERABILITY of the detection instrumentation ensures that both adequate warning capability is available for prompt detection of fires anc that Fire Suppression Systems, that are. actuated by fire detectors, will discharge extinguishing agent in a timely manner. Prompt detection and suppression of fires will reduce the potential for damage to safety related equipment and is an integral element in the overall facility Fire Protection Program.
When instrumentation is inoperable, frequent fire patrols are required in the affected area until OPERABILITY can be restored.
Fire detectors that are used to actuate Fire Suppression Systems represent a more critically 'mp;rt;nt component of a plant's Fire Protection Program than tion. detectors that are installed solely for early fire warning and notifica-Consfquently, t.'.;
mini;.; n ;ber ef CT: ' OLE fi. d;t;;ter: ;; L;
- rt;t r.
'5: 10::
Of d:t:cti:r ;;;;bility f;r Tir; Luppr;;;ica 3;;; ;, ;;;;;;;d by f' r; d;t;;t;r;, r;pri;;nte e ;ignificec.; Js;cedeti .. ef fic; r.vir...co fe.
t U-STS B 3/4 3-5
~
INSTRUMENTATION BASES 9
FIRETDETECTION -INSTRUMENTATION (Continued)
'ny
- :ren. A: : rc: ult, th: :: :bli;5 :nt f a fire watch patrol must be initiated at an earlier stage than would be warranted for the loss of detectors that provide only early fire warning. The ::t bli:F::nt :f 'r:q :nt " re p;tr:1; in th Of f::t:d rt:: i: r;quir:d t; prr.id; d; tecti:n ::p;bility unti' the ' :p;r:ble # 9 trur:nt:ti r i: rc:t:r:d t:. CIEnfa!LITY.
3/4.3.3.9 LOOSE-PART DETECTION INSTRUMENTATION The OPERABAILITY of the loose part detection instrumentation ensures th sufficient capability is available to detect loose metallic parts in the Reactor System and avoid or mitigate damage to Reactor System components The allowable out-of-service times and surveillance requirements are 'consi ent with the recommendations of Regy)atory Guide 1.133, " Loose-Part Det ion Program for the Primary System of Light-Water-Cooled Reactofs," M 1981.
3/4.3.3.10 RADIOACTIVE LIQUID EFFLUENT MONITORING INSTRUME 4ATION .
- The radioa'ctive liquid ef fluent instrumentation i provided to monitor and control, ,as applicable, the releases of radioact' e. materials in 1.iquid-effluents during actual or potential releases of l' uid effluents. The Alarm / Trip Setpoints for these instruments shall e calculated and adjusted in w accordance with the methodology and parameters n the ODCM to ' ensure that the -f alarm / trip will occur prior to exceeding th imits of 10 CFR Part 20. The 5 OPERASILITY and use of this'instrumentati is consistent with the requirements 3 of General Design Criteria 60, 63 and 6 of Appendix A to.10 CFR Part 50. The &
purpose of tank level indicating devi s is to assure the detection _and control [
g of leaks that if not controlled cou potentially result in the transport of radioactive materials to UNRESTRI ED AREAS. m 2
. Ui W
3/4.3.3:11 RADIOACTIVE GA 005 EFFLUENT MONITORING INSTRUMENTATION
)
The radioactive eous effluent instrumentation is provided to monitor and control, as appl ~ cable, the releases of radioactive materials in gaseous effluents during tual or potential releases of gaseous ef fluents. The Alarm / Trip Setp nts for these instruments shall be calculated and adjusted in accordance wi+ the methodology and parameters in the ODCM to ensure that the This l
alarm / trip 11 o'ccur prior to exceeding the limits of 10 CFR Part 20.
instrumen o ion also includes provisions for monitoring (and controlling) the concen ations of potentially explosive gas mixtures in the WASTE GAS HOLDUP '
SYST .. The OPERABILITY and use of this instrumentation is consistent with th requirements of General Design Criteria 60, 63 and 64 of . Appendix A to CFR Part 50.
I
! U-STS .B 3/4 3-6
=
l
o _ i\ ,
1 1
P.LANT SYSTEMS
. t 3ASES '
r SNUBBERS (Continued) .
The service l'ife of a snubber is established via manufacturer input )
information~ through consideration of the snubber service conditions an l i
associated installation' and maintenance records (newly installed sn er, seal replaced, spring replaced, in high radiation area, in high tempe- ure area,.
etc. . .). The requirement to moniter the snubber service li is included to ensure that the snubbers periodically undergo a performanc valuation in view of, their age and operating conditions. These records w' p.rovide statistical S b'a'ses for future consideration of snubber service li . The requirements E for the maintenance of records and the snubber se ice life review are not -
M intended to af fect plant operation. y c
3/4.7.10 ' SEALED SOURCE CONTAMINATION
- g
- ==
The limitations on removable ntamination for ' sources requiring leak testing, including alpha emitt .. is based on 10 CFR 70.39(c) limits for 5 plutonium. This limitation ~
C:
. and Special Huclear Mate .1 &nsure that leakage from Byproduct, Source, S al sources will not exceed allowable intake values. "
Sealed source are classified into three groups according tc their use,.
. with Surveillan Requirements . commensurate with the probability of damage to a source in th- group.
Those scurces which are frequently handled are required to be tes+ d more often than those which are not. Sealed sources which are
- . contin usly enclosed within a shielded mechanism (i.e., sealed sources':within
~
ra ion monitoring or baron measurin'g devices) are considere,d to be stored d need not be tested unless they are removed fron, the shielded mechanism.
3/4.7.11 FIRE SUPPRESSION SYSTEMS The OPERABILITY *of the Fire Suppression Systems ensures that adequate
~ fire suppression capability is available to confine and extinguish fires
- occurring located.
in any portion of- the f acility where safety' related equipment is.
The Fire Suppression System consists of the water system, , spray, '
and/or sprinklers, CD , Halon, fire hose stations, and yard fire hydrants.
Thecollectivecapabi$ityoftheFireSuppressionSystemsisadequateto < .
~
minimize potential damage to safety related equipment and is a major element in the facility Fire Protection Program. '
capability" i >
In the event that portions of the ' ~
Suppression Systems'arl' inoperabfe, 11:rn:t; backup fire-fighting ;quipa+nt is ' required tc .b: ::d; ;vf.'.iti; in .
the affected areas until the inoperable equipment is restored to service.
ULm. it.i in; fir:bi; fir - fightin; quip :nt i: 'nt;nd:d f;r .;; :: : 5:chup
~
sc;n; cf f'r; ;;;; :::icn, : .':ng:r p:ri:d Of ti:: i; :1' ::d t; prc'. 'd :n
- lt;rn;:: :::n; cf " r: " ;5t n; t th: ' p;r:bi pr' ry ::n: Of r : ;;r:::.ee. ::;.i :nt i: '5 '
i i
W-STS E-3/4 7-6
\
PLANT SYSTEMS BASES FIRE 25UPPRESSION SYSTEMS (Continued)
Backup fire fighting equipment, provided when the primary suppression systems are inoperable, must be able to provide an equivalent capability; in this context, equivalent capability means a reasonably similar fire suppression function, consistent with the primary system's design objective in the Fire Hazards Analysis. Backup equipment should not compromise plant safety when used.
Th; Curitillen;; 2:quir ent; pr vid ; ; ; u re.n : th:t,_th.,; minimum 0? A !LITY 7:quir:m r:t; cf th; T'r Suppr;;;i:n Sy:t m; cr ::t. An ;11 wence i; ;;d f:r :n:ur#ng : iuf#icient colum: Of M;1:c ' th: Mel:n ;t:r;;; tenh:
by ceri fy' 9; cither th: >:ight er the level of th: t:nk . L:v:1 :::;ur;m:nt:
- r; ar.d; by either
- 'J . L . ;r r M Oppr;;;d ::th;d.
In the event the Fire Suppression Water System becomes inoperable, prompt
/ :: dict: corrective measures must be taken since this system provides the major fire suppression capability of the plant.
3/47?l2 VIRE RATED ASSEMBL3ES The functional integrity of the fire rated assemblies and b,arrier penetra-tions ensures that fires will be confined or adequately retarded from spreading to adjacent portions of the facility. These design features minimize the
~
pessibility of a single fire rapidly involving several areas of the facility B prio'r to detection.and extinguishing of the fire. .The fire barrier penetrations areperiodic to' a passive element in the facility fire protection program and are subject inspections.
Fire barrier penetrations, including cable penetration barriers, fire doors and dampers are considered functional when the visually observed condition i:, the same as the as-designed condition. Ici these fi.. be. ie. pon i.ot;;n; th t r n:t i- th: ::-d::ign:d ::nditi:n, = ;;;'u .ti:n :hr,l'. b; p;rf;r;;d t -
' ;h;i thit th: ::dific: tion 5 ; .:t d:gr:d:d th: fir re. tin; ef th; fir; berri;r p;nctr. tier. .
The active assemblies (e.g., doors and dampers) are periodically tested to demonstrate their operability.
During periods of time when a barrief is not functional, either: (1) a continuous fire watcr) is required to be maintained in the vicinity.of the affected barrier, or (2) the fire detectors on at least one side of the affected barrier must be verified OPERABLE and an hourly fire watch patrol established, until the barrier is restored to functional status.
3/4.7.13 AREA TEMPERATURE MONITORING $ 1 ca The area temperature limitations ensure that safet - utpment 5 l will not be subjected to temperatures in eir environmental quali )
I fication temperatures. Ex
- xcessive temperatures may- degrade equipment <,
and can caus . its OPERABILITY. The temperature limits include an f lu.once for instrument error of ( )*F.
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= l W-STS B 3/4 7-7 U w l M
PLANT SYSTEMS BASES 3/4.7.13 ALTERNATIVE / DEDICATED SHUTDOWN SYSTEM The OPERABILITY of the ASS / DSS ensures that a fire will not preclude achieving safe shutdown. The ASS / DSS equipment are independent of areas where a fire could damage systems normally used to shutdown the reactor. This capability is consistent with GDC 3 and 10CFR50, Appendix R.
The equivalent shutdown capability provided when the ASS / DSS is inoperable depends on the specific equipment involved and, therefore, should be sufficient to assure that the intended shutdown actions can be accomplished, i or that fires can be reasonably precluded during that time for which ASS / DSS equipment would otherwise be required, consistent with the ASS / DSS design i
basis. Any temporary procedures or special fire watch patrols established to provide this equivalent capability should be reviewed by the (PORC) and approved by the (station superintendent) prior to implementation.
3/4.7.14 PORTABLE FIRE EXTINGUISHERS The portable fire extinguishers are the first line of fire defense and are most effective when fires are in their early stages of development. 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 promptly repaired or replaced.
3/4.7.15 EMERGENCY LIGHTING UNITS The 8-hour emergency lighting units are provided in areas needed for
- operation of safe shutdown equipment and in access and egress routes 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.
m
ADMINISTRATIVE CONTROLS
- d. The performance of activities required by the Operational Quality i
{
Assurance Program to meet the criteria of Appendix "B",10 CFR 50, ;
at least once per 24 months.
- i e.
i The Emergency Plan and implementing procedures at least once per 12 months. '
f.
Th'e Security Plan and implementing procedures at least once per
. 12 months.
- g. Any other area of unit operation considered appropriate by the (CNRAG) or the (Vice President Operations).
- h. The Fire Protection programmatic controls including the implementing procedures at least once per 24 months by qualified licensee QA personnel)
- 1. The fire protecti6n equipment and program implementation at least once per 12 months utilizing either qualified offsite licensee fire protection engineer or an outside independent fire protection consultant. An outside independent fire protection consultant shall be used at least every third year; 4 AUTHORITY 6.5.2.9 i
on those areas of responsibility specified in Sections 6.5.2 RECORDS 6.5.2.10
__ tributed as indicated below: Records of (CNRAG) activities shall be prepared, ap
~
a.
Minutes of each (CNRAG) meeting shall be prepared, approved and forwarded each to meeting. the (Vice President-Operations) within 14 days following b.
Reports of reviews. encompassed by Section 6.5.2.7 above, shall be l within 14 days following completion of the review. prepared)
I c.
Audit reports encompassed by Section 6.5.2.8 above,'shall be forwarded to the (Vice President-Operations) and to the management positions responsible for the areas audited within 30 days after completion of
- the audit by the auditing organization.
i ALL 575 6-13
~~
,7 Attachment 1 PROPOSED ACTION STATEMENTS FOR SECTIONS 3.7.11.2-4 AUTOMATIC FIRE SUPPRESSION SYSTEMS
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- a. With the [ system] inoperable such that one train of a safety system is not protected by automatic fire suppression, varify the functional capability of the redundant safety system train (s) which would accomplish the intended function and its associated fire suppression system, and restore the [ system] to OPERABLE within 7 days or establish hourly fire watch patrols in the affected area (s).
- b. With the [ system] inoperable such that a safety function (i.e., both or all trains of the safety system) is not protected by automatic fire suppression or a fire area is not p.rotected such that a fire could not be contained within the fire barriers which establish the area, within one hour establish a continuous fire watch with equivalent manual fire suppression equipment in the affected area (s),
- c. The provisions of Specifications 3.0.3 and 3.0.4 are not applicable.
BASES The OPERABILITY of the fire suppression systems does not include the actuating instrumentation (detectors) because they are covered under 3/4.3.3.8. When a fire suppression system is found to be inoperable, the action statement recognizes the importance of the safety functions being protected, consistent with the design approach for fire damage limits. When one train of a safety system becomes vulnerable to fires, the functional capability of the redundant train must be verified. This requirement is intended to provide assurance that a fire in the affected area will not result in a complete loss of the l
i
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_g.
safety function of the systems involved. The term verify the functional l
I capability, as used in this context, means to administratively check by l i
examining logs or other information to determine if necessary components are out-of-service for maintenance or other reasons; it does not mean to perform the surveillance required to demonstrate OPERABILITY of the system because such testing could reduce the system's reliability.
When an entire safety function (both or all trains) becomes vulnerable to fires, prompt action must be taken to ensure adequate manual fire fighting capability, until the automatic fire suppression systems are restored.
Similarly, when a fire area is unprotected such that a fire in that area would not be automatically contained and, therefore, could spread beyond its boundaries, prompt action must be taken to monitor the area with preparations for any manual fire fighting necessary to ensurc such fires will be contained.
l
- ,- - ,, -n , .-r -
._ . .. 1
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_ Attachment 2 SIGNIFICANT FIRE PROTECTION TECHNICAL SPECIFICATION ISSUES I
- 1. Detection Instrumentation The Working Group (WG) initially tried to remove the Function B (actuation) instrumentation from Technical Specification (TS) 3.3.3.8. Our objective was to simplify the complex action statement associated with Function A, Function B and detectors inside containment.
However, in doing so, the resulting action statement associated with the suppression system, as it would apply to the Function B detectors, would be overly restrictive. Moreover, there is an STS objective to keep such instrumentation separate and a precedent in the Reactor Protection System for distinguishing the LCO for actuating instrumentation (sensors) from the actuated system LCO.
e Ideally, there should be a action matrix which is a function of the number of inoperable detectors in any zone and the number of unprotected fire areas served by those detectors. However, such a requirement would be overly complex and confusing. Conversely, we believe that action within one hour whenever any detector is inoperable is wholly unwarranted.
Therefore, we have left the original construction of the action statement and modified the restoration periods to be appropriately comparable with l those which would be required with one or both trains of a safety system inoperable. In our judgment these changes are still conservative.
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- 2. Definition of Terms There were several comments that relate to the definition or explanation ,
of terms; e.g., fire watch patrol, backup equipment, TRIP ACTUATING DEVICE OPERATIONAL TEST, and puff test. Terms which are used consistently throughout the STS and have a precise meaning are defined in the introduction and are capitalized in the text (e.g., OPERABLE).
In some cases, there seems to be a wide range of views regarding terms commonly understood by fire protection engineers. Many of the clarifications proposed are so detailed that they more appropriately belong in the plant's procedures implementing the technical specifications.
In such cases, the inspector must be able to judge whether the procedures achieve the objective of the TS and, if they do not, then we would expect that the licensee has a broader problem which requires appropriate enforcement action.
Where reasonably simple and constructive clarifications can be made, we' have augmented the associated " bases" section in accordance with STS practice.
- 3. Reporting Requirements There were existing and recommended reporting requirements in action statements which would otherwise allow an indeterminant period of equivalent manual fire detection (Fire watch patrol) or suppression.
1 r
These reporting requirements appear to principally serve as a punitive:
measure to prevent licensees from operating under such conditions for extended periods of time.
We believe that such reporting requirements are unnecessary and only serve to shift the responsibility for action from the licensee to the NRC. The personnel time (i.e., fire watch patrols) required to provide the equivalent protection should be sufficient incentive for the licensee to repair inoperable equipment.
The Regions may not completely agree with this judgment.
- 4. Surveillance Requirements In several cases, recommended changes to the surveillance requirements were so detailed that they constituted implementing procedures or they appeared to verify design capability. We believe such changes go beyond the objective of surveillance requirements, which is to simply describe the inspections and tests necessary to assure that the LCO is satisfied.
In those cases where specific procedures or testing requirements are necessary to accomplish the surveillance, then specific references should be cited; e.g., ASTM-0975-1977 for diesel fuel chemistry. Otherwise, procedures for conducting s'urveillance should be prepared in accordance with TS 6.8.1 and, where appropriate, reference is made to procedures l
" prepared in conjunction with manufacturer's recommendations."
C
- 5. Fire Suppression Systems - Action Requirement Based on comments received, the WG attempted to prepare a new set of action statements which would be applied. consistently to all fire suppression systems. These action statem.ents would recognize that the fire suppression systems serve to protect safety systems and, therefore, if a redundant safety system train is still protected, a longer restoration time could be allowed than if an entire safety function is unprotected. Even then, manual fire suppression could serve for some reasonable time until the fire suppression system is again operable.
These action statements would also recognize that fire suppression systems prevent fires from spreading from one fire area to another or from growing to an unmanagable size.
8 A draft of these action statements is prdsented in Enclosure 3. While we believe that the approach is correct, we have not had time to assure that the proposed actions are appropriate for all possible system failures. We suggest that the Steering Committee consider this approach and, if agreeable, we will continue to refine this proposal.
1
- 6. Alternate / Dedicated Shutdown Systems Based on a variety of existing and recommended LCOs and surveillance requirements for Alternate and Dedicated Shutdown Systems (ASS / DSS), ,
l the WG has endeavored to construct a composite STS. We received consnents
~
regarding ASS / DSS inoperability for 60 days and the completeness of the TS.
l 1
4
Thew 5selectedaso-dayrestorationperiodbecause(1)weincludeda provision for " equivalent shutdown capability" in the event for inoperable equipment cannot be restored in 7 days, and (2) we considered the time that would be required to evaluate and process a TS change, should a situation arise requiring a temporary modification tc e ASS / DSS. We believe that, in most cases, any necessary repairs could be made in 60 days and the system inoperability could be reasonably compensated during that time.
l With regard to completeness, we attempted to identify LCOs and l surveillance requirements for all of the major system components. A clarifying note is included which explains that additional (plant-spevific) components should be similarly added.
- 7. Equivalent Capability There are several actions which require the licensee to establish
" equivalent" fire protection capability when a system is inoperable. We used the term " equivalent" to be consistent with its use throughout the !
STS. However, we believe this term will be misconstrued in many cases; I it does not mean identical, it is intended to be more like " comparable."
In order to ensure this understanding, we have added clarifications to the appropriate' bases sections.
i
t As a generic matter, we recommend that the Technical Specification Review Group (TSRG.) consider an alternate tem for use throughout the STS which will not be const' rued to mean " identical" where it is not so intended; e.g., comparable, compensatory, or appropriate.
- 8. Refueling Outage Surveillance The STS specify "at least once per 18 nonths" for surveillance that are intended during refueling outages. The WG noted that such a period can create schedular problems for plants with long power runs and, therefore,'
recomended changes to "at each refueling outage."
This is a policy issue beyond fire protection. The STS practice is to specify time periods. In either case, there are potential problems I
(e.g., rep 1' acing one fuel element is a refueling outage). Therefore, we have withdrawn our recommendation in favor o'f consistency. However, as a generic matter, we suggest the TSRG consider extending the 18-month per'od or specify "at least at each scheduled refueling outage but not less often than once each 24 months."
- 9. Emergency / Security Plans A question was raised regarding a change in the schedules from 24 months to 12 months for Emergency and Security Plans (6.5.2.8). These changes were made by the TSRG, not the WG, to make these schedules consistent with the requirement for annual updates required in the regulations.
l
Attachment 3 r
WORKING GROUP COMMENTS ON PROPOSED FIRE PROTECTION .'
TECHNICAL SPECIFICATIONS The Working Group reviewed the Standard Technical Specifications (STS) taking into account comments from Regions I, II and III. The CRGR package version of the Westinghouse STS was used as the basis document. The Working Group attempted to simplify and clarify the STS and added specifications for alterna-tive and dedicated shutdown systems, portable fire extinguishers and emergency lighting. The rationale for these additions is that these features are explicitly included in Appendix R.
Obviously, the Working Group has had to exercise a collective judgment to develop these recommended changes to the technical specifications. We did not al. ways include recommended changes to the technical specifications; because of the wide range of opinions, we perceive that there may never be universal agreement on the details of these requirements. Nevertheless, there were comments which raised issues broader than fire protection or involved conflicting objectives; e.g., simplicity of action statements, definition of {
terms, reporting requirements, procedural details, action objectives and
r consistency, use of " equivalent" capabilities, and surveillance during refueling outages. To ensure that the bases for our recommended changes are clearly understood, we have responded to the more significant comments and explained some of our judgments in Attachment 2. We have also recommended generic improvements to the STS which should be considered when a final action is taken to upgrade the fire protection technical specifications.
The Working Group is not entirely satisfied with its revisions to the STS.
Although we believe the surveillance and LCOs concerning fire protection enhance safety, we are concerned that the way they are presented elevates fire protection almost to the stature of ECCS. However, given the safety signifi-cance of fire protection and the present format of the STS, the Working Group could not come up with an acceptable alternative.
We believe that the technical specification format included in the proposed rulemaking offers a more appropriate way of regulating fire protection sur-veillance and compensatory measures for inoperative equipment. The rule-making (47FR13369, 3/30/82) calls for only the most important features to be included in the body of the technical specifications. The LCOs, compensatory measures, surveillance requirements, and administrative requirements of lesser importance but still important to safety removed from the technical specifica-tions are to be placed in a companion document (supplemental specifications).
The supplemental specification may be revised by the licensee upon approval l I
,- , - - n e-y-
l E
of its safety committee. The supplemental specifications and the documentation of surveillance and tests conducted in accordance with the supplemental speci-fications are subject to NRC inspection.
We recommend that the "new" Technical Specifications include an administrative requirement for the licensee to maintain a procedure for surveillance and compensatory measures for inoperative equipr.ent. This procedure would not be a part of the Technical Specifications but would be included in and therefore could be revised by the licensee on approval of the licensee's safety committee without NRC approval. However, the procedure and the records of surveillances and compensatory measures could be inspected by the region.
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ENCLOSURE 3 APR 121985 INTERPRETATIONS OF APPENDIX R
- 1. Process Monitoring Instrumentation Section III.L.2.d of Appendix R to 10 CFR Part 50 ' states that "the process monitoring function shall be capable of providing direct readings of the process variables necessary to perform and control" the reactivity control function. In I&E Information Notice 84-09, the staff provides a listing of instrumentation acceptable to and preferred by the staff to demonstrate com-pliance with this provision. While this guidance provides an acceptable method for compliance with the regulation, it does not exclude other alternative methods of compliance. Accordingly, a licensee may propose to the staff alternative instrumentation to comply with the regulation. While such a sub-mittal is not an exemption request, it must be justified based on a technical evaluation. The licensee may also propose alternatives to actual compliance with the regulation (e.g., instrumentation which does not provide a direct reading of the process variable) by filing an exemption request with adequate justification.
- 2. Repair of Cold Shutdown Equipment Section III.L.5 of Appendix R states.that when in the alternative or dedicated shutdown mode, " equipment and systems comprising the means to achieve and main-tain cold shutdown conditions shall not be damaged by fire; or the fire damage to such equipment and systems shall be limited so that the systems can be made operable and cold shutdown can be achieved within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />." This is not to be confused with the requirements in Section III.G.I.b of Appendix R.
Section III.G.I.b contains the requirements for normal shutdown modes utilizing the control room or emergency control station (s) capabilities. The fire areas falling under the requirements of III.G.I.b are those for which an alternative or dedicated shutdown capability is not being provided. For these fire areas,Section III.G.1.b requires only the capability to repair the systems necessary to achieve and maintain cold shutdown from either the control room or emergency control station (s) within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, not the capability to repair and achieve cold shutdown within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> as required for the alternative or dedicated shutdown modes by Section III.L (noted above).
! With regard to areas involving normal shutdown, however,Section I of i
Appendix R states that repairs must be made using only onsite capabilities.
After repairs are made, cold shutdown can be achieved on a reasonable schedule using any available power source.
i l _ _ _. _
. ?, ,
1 l
- 3. Fire Damage Appendix R to 10 CFR Part 50 utilizes the term " free of fire damage." .In pro-mulgating Appendix R, the Commission has provided methods acceptable for assur-ing that necessary structures, systems and components are free of fire damage (see Section III.G.2a, b and c), that is, the structure, system or component under consideration is capable of performing its intended function during and after the postulated fire, as needed. Licensees seeking exemptions from Section III.G.2 must show that the alternative proposed provides reasonable assurance that this criterion is met. (Note also that Section III.G.2 applies only to equipment needed for hot shutdown. Thdrefore, an exemption from III.G.2 for cold shutdown equipment is not needed.)
- 4. Fire Area Boundaries The term " fire area" as used in Appendix R means an area sufficiently bounded to withstand the hazards associated with the area and, as necessary, to protect important equipment within the area from a fire outside the area. In order to meet the regulation, fire area boundaries need not be completely.
sealed floor-to-ceiling, wall-to-wall boundaries. However, all unsealed openings should be identified and [evaluatedr] considered in evaluating the '
effectiveness of the overall barrier. Where fire area boundaries were not ,
approved under the BTP process, or where such boundaries are not wall-to-wall, floor-to-ceiling boundaries with all penetrations sealed to the fire rating-required of the boundaries, licensees must perform an evaluation to assess the adequacy of fire boundaries in their plants to determine if the boundaries will withstand the hazards associated with the area and protect important p equipment within the area from a fire outside the area. This analysis must -
be performed by at least a fire protection engineer and, if required, a systems engineer. Although not required, licensees may submit their '
evaluations for staff review and concurrence. In any event, these analyses ;
must be retained by the licensees for subsequent NRC audits.
- 5. Automatic Detection and Suppression Sections III.G.2.b and III.G.2.c of Appendix R state that "In addition, fire detectors and an automatic fire suppression system shall be installed in the 4 fi re a rea . . . " Other provisions of Appendix R also. use the phrase " fire detectors and an automatic fire suppression system in the fire area..." ,
(see e.g.,Section III.G.2.e).
In order to comply with these provisions, suppression and detection sufficient to protect against the hazards of the area must be installed. In this regard, detection and suppression providing less than full area coverage may be adequate to comply with the regulation. Where full area suppression and detection is not installed, licensees must perform an evaluaticn to assess the adequacy of partial suppression and detection to protect against the hazards in-the area. The evaluation must be performed by a fire protection engineer and, if required, a systems engineer. Although not required, e
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licensees may submit their evaluations to the staff for review and concur-rence. In ahy event, the evaluations must be retained for subsequent NRC audits. Where a licensee is providing no suppression or detection, an ex-emption must be requested.
- 6. Alternative or Dedicated Shutdown
'Section III.G.3 of Appendix R provides for " alternative or dedicated shutdown capability and its associated circuits, independent of cables, systems or compcnents in the area, room, or zone under consideration." While "in-dependence" is clearly achieved where alternative shutdown equipment is out-side the fire area under consideration, this is not intended to imply that alternative shutdown equipment in the same fire area but independent of the room or the zone cannot result in compliance with the regulation. The " room" concept must be justified by submission of a detailed fire hazards analysis that demonstrates a single fire will not disable both normal shutdown equip-ment and the alternative shutdown capability.
0 e
ENCLOSURE 4 APR 121985 i
GUIDANCE FOR ENFORCEMENT ACTIONS CONCERNING FIRE PROTECTION REQUIREMENTS
- 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 License Conditions, facility technical specifications and other legally binding requirements, as applicable. A Notice of Violation will be issued for violation of requirements. How-ever, failure to meet fire protection commitments will be desig-nated as deviations. %g '
.3T B. Failures to meet regulatory requirements for protecting Usins of equipment required for achieving and maintaining safe hot or cold shutdown are serious violations. The specific violations should be reviewed individually and as a group to determine their rootcause(s). This guidance gives examples of violations at various severity levels and should be used to detennine the appropriate enforcement action. For purposes of this guidance, required structures, systems, and components are those which are necessary to achieve and maintain hot and/or cold shutdown and which require the application of fire protection features as described in the *icensee's fire hazards analysis report and At ME safety evaluation report. -
C. Fire protection violations 1iiay involve incperable or inadequgt fire barriers, separatic'n, suppression or detection systemsJYe- g
[*) -
pair parts, proceduresVor other conditions or items required to g'[g)/'
pr6tect safe shutdown equipment from fire and/or permit the opera-M Dn of safe shutdown equipment during a fire or to restore safe @,MfM p
- shutdown equipment to service following an actual fire.
D. Numerous violations of fire protection requirements which in-
, dividually may be classified at lower severity levels may cumulatively be classified at a higher severity level due to
~
inadequate implementation of the fire protection program.
==
,- -,- .- - -e --, -
"P M
.i , UNITED STATES -
is a -
t NUCLEAR REGULATORY COMMISSION WASHING TON, D. C. 20555
%,,,,,# MAY 0 31985 8
i MEMORANDUM FOR: Harold R. Denton, Director Division of Nuclear Reactor Regulation FROM: Richard H. Vollmer, Chairman Fire Prorection Policy Steering Committee
SUBJECT:
UPDATED RECOMMENDATIONS ON FIRE PROTECTION POLICY AND PROGRAM ACTIONS
Background:
In a memorandum to Mr. Dircks dated October 26, 1984, the Fire Protection Policy Steering Committee (SC) provided recommendations designed to resolve a number of issues associated with fire protection policy and imple- ,
mentation of fire protection features for nuclear power plants. In response to 1 the Committee's recommendations, Mr. Dircks directed certain actions by memo- l randum to you and Messrs. Stello and DeYoung dated December 10, 1984, including release of the SC's work for public comment. The purpose of this memorandum is to provide you the SC's recommendations and guidance documents for your action in completing items one and four of the memorandum of December 10. The SC's recommendations and guidance documents on fire protection have, to some extent, :
been altered by the actions directed and the current status of the issues ;
involved. -
Discussion:
- 1. The report of the SC was released to the public, and as of April 15, 1985, 13 letters of public comment had been submitted. The individual public comments, except for four that were received very late, and their reso-lution have been reviewed by the Steering Committee and are included in Enclosure 1. As a result of these comments, those received from NRC
- Offices and Regions, and in consideration of the current status of some of .
the issues, a number of changes to individual SC recommendations have been made.
The SC has carefully evaluated its previous recommendation regarding an expedited inspection program for reviewing firo protection compliance.
Although we still believe that an expedited fire protection inspection would be beneficial, because of resource constraints tha SC has modified its recommendation to place more emphasis on the priority. selection of plants to be visited within current resources allocated for fire protec-tion. The SC recommends that, while continuing the present program of inspection of plants completing their Appendix R modifications and. those plants close to receiving an operating license, the regions be given flexibility to inspect plants where implementation problems are believed j to exist. In addition, the staff should support a licensee's request for 1 an inspection which may avoid costly design and implementation decisions 1 with which the staff may disagree. This is particularly important since the Interpretations of Appendix R gives the licensee more implementation.
flexibility without prior. staff review.- c ~ . qS n em y77 e ~yNVN v J fpbuq gb-974 ,
- El4 _ff8 II~'l
'/
Harold R. Denton 2 MAY 0 31985
- 2. The proposed Generic Letter on Fire Protection to be issued as a generic letter to all licensees and operating license applicants has teen revised in several areas:
(a) The inspection program discussion reflects the recommendations indicated above.
(b) Documentation necessary to show compliance with fire protection requirements has been clarified.
(c) The application of quality assurance to fire protection has been clarified. Although the SC believes that the QA requirements of GDC-1 are applicable to fire protection features, the QA provisions in most fire protection programs, in addition to the recent proposed rulemaking on important to safety, provide sufficient near and long term assurance in this area.
(d) Section F has been added to provide rationale for a standard license condition and to request licensees to submit this standard fire protection condition as a license amendment.
The revised Generic Letter is included as Enclosure 2.
- 3. Very minor changes have been made to the Interpretations of Appendix R and the Guidance for Enforcement Action concerning fire protection require-ments. These revised documents are included as Enclosures 3 and 4.
- 4. A number of changes to the question and answer package have been made e a result of public coments and comments from other NRC offices. The revised guidance document is included as Enclosure 5.
- 5. The SC has reviewed and approved a proposed standard license condition and several proposed technical specification changes based on fire protection requirements. These changes were developed in order to promote consistency of fire protection requirements at all operating reactors whether they are covered under Appendix R or not. These documents are included as Enclosures 6 and 7.
Recommendations:
1
- a. Promptly issue the enclosed Generic Letter (Enclosure 2) with the l Interpretations of Appendix R, Responses to Industry's Questions, l and the Fire Protection License Condition as enclosures. Note that the Commission wishes to review this guidance before it is issued to industry. -
- b. Conduct fire protection inspections in accordance with currently allocated fire protection resources. Regional workshops should be conducted in order to provide latest information to inspection teams. A referee' team should be established to promptly settle disagreements between the licensee and inspection teams.
o y Harold P. Denton 3 N 01 pri
- c. Endorse a standard fire protection license condition in accordance with Enclosure 5 to all future operating licenses and encourage licensees to review their licenses to conform.
- d. Utilize the proposed technical specifications where appropriate in future operating licenses and as guidance to the NRR tech spec Improve-ment Project for inclusion in their current effort.
- e. Adopt the guidance in Enclosure 4 as the agency criteria for enforce-ment of fire protection requirements. Following adoption of this guidance, pending fire protection enforcement cases should promptly be processed by IE.
To keep you informed of status on approved recomendations and other fire protection matters, the Steering Comittee will make periodic reports to you on this matter.
For the Fire Protection Policy Steering Comittee:
i
- /87+ ^ -y R chard H. Vollmer, Chairman
Enclosures:
- 1. Resolution of Coments on Recomendations of the Fire Protection Steering Comittee
- 2. Revised Generic Letter 84-01
- 3. Revised Interpretations of Appendix R
- 4. Revised Enforcement Guidance on Fire Protection Requirements
- 5. Proposed Standard License Condition Regarding Fire Protection Requirements
- 6. Proposed Revised Technical Specifications Regarding Fire Protection 7 Revised Questions and Answers Regarding Fire Protection cc w/ enclosures:
F. Rosa, NRR N. Grace, RII d . Shields, ELD T. Martin, RI T. Wambach, NRR W. Olmstead, ELD W. Johnston, NRR J. Olshinski, RII V. Benaroya, NRR L. Spessard, RIII S. Richardson, IE cc w/o enclosures:
V. Stello, DEDR0GR I
r ENCLOSURE l' RESOLUTION OF COMMENTS ON THE RECOMMENDATIONS
' OF THE FIRE PROTECTION POLICY STEERING COMMITTEE
, (50FR2056 JAN. 15, 1985; G.L. 85-01) 1.0 PUBLIC COMMENTS: .
1.1 Nuclear Utility Fire Protection Group: Letter from J. M. McGarry t
to H. R. Denton dated February 14, 1985.
1.1.1 Comment (A.1): Schedular Relief "The discussion at pages 1-2 of the draft Generic Letter indicates that schedular relief under 10 C.F.R. 9 50.48 can no longer be obtained. The Group is concerned that this discussion could be read as precluding the filing of schedular exemption requests under 10 C.F.R. 6 50.12. It is the Group's understanding from discussions with the Staff that schedular exemptions under 10 C.F.R. 6 50.12 continue to be available despite the expiration of the Section 50.48 deadlines. To avoid any misunderstanding, the Group would recommend that the l Staff's Generic Letter state explicitly that the filing of a schedular exemption request under Section 50.12 is not precluded by the expiration of the Section 50.48 deadlines."
Resolution:
The NUFPG comment indicates a misunderstanding of the Steering Committee recommendation on schedular exemptions, which have always been issued under 10 CFR 50.12. The Steering Canuittee recommended that no further schedular exemptions be granted, and that schedules (for licensees whose 50.48 deadlines have passed) will be set in the enforcement context. Therefore, their understanding that schedule exemptions would still be available if this recommendation is adopted is not correct. However, this does not preclude the filing of 1 schedular exemption request under 10 CFR 50.12 based on a justified "living schedule" which has been a The proposed Generic Letter has been revised (pprovedfootnote,byPg.
the2) NRC. to clarify this point.
1.1.2 Comment (A.2): Inspection Process a) This comment addresses the Steering Committee recommendation for an accelerated fire protection inspection program and presents reasons why such inspections should be postponed until the new guidance package has been reviewed and approved by the Commission. The conclusion of this comment states:
"For these reasons, we believe that the most efficient use of Staff and licensee resources would result from postponing the inspections (absent a safety concern or an indication of readiness on the part of the licensee) until the new interpretations and guidlnce have been reviewed and approved by the Commission. 2/"
b) The above cited footnote states: !
"2/ In connection with the discussion of the inspection process, the Group strcngly supports the Steering Committee's recommendation regarding the establishment of a referee team, headed by senior NRR management, to resolve significant differences between inspection personnel and the licensee. The Group understands that the resolution of such differences will be accomplished expeditiously by the referee team, with a decision issued generally within one week, but in any event before the inspection report would be released."
Resolution:
' a) The inspection program will be conducted as expeditiously as present resources allow with priority given to utilities not yet inspected and those requesting early inspections.
b) The understanding of the NUFPG regarding the composition and expected performance of the " referee" team is correct. If the recommendation for formation of a referee team is approved by the Commission, the substance of this comment will be in-cluded in its Charter.
1.1.3 Comment (A.3): Documentation Required to Demonstrate Compliance
---The proposed Generic Letter states (at page 3):
Failure to have such an evaluation available for an area where compliance with Appendix R is not readily demonstrated will be taken as prima facie evidence that the area does not comply with NRC requirements, and may result in enforcement action. 3/ (Emphasis added.)
It is the Group's understanding from our discussions with the staff that the term "readily demonstrated" is intended to include situations where compliance is apparent by observation. Thus, if compliance with Appendix R is apparent
.by observation of the features in question, failure to have an evaluation available will not be considered evidence of noncompliance. With this understanding expressly incorporated i into the Generic Letter, the Group has no objection to this part of the proposed Generic Letter." l'
Resolution:
The understanding is correct. The proposed Generic Letter and the Guidance for Enforcement. Actions have been revised to incorporate the NUFPG understanding.
1.1.4 Comment (A.4): Quality Assurance Requirements This comment takes exception to the introductory sentence to section D of the proposed Generic Letter which states: " Fire protection systems must meet the requirements of General Design Criterion 1 of Appendix A to 10 CFR Part 50." Specifically, the objection is to the citation to GDC 1 because this impacts the current rulemaking regarding the safety classification issue, i.e.,
the important-to-safety vs. safety-related controversy. It further states that the QA guidance provided in BTP CMEB 9.5-1 (also cited in the proposed Generic letter) is adequate for this purpose and has generally been followed in the industry. Therefore, it recom-mends deletion of the citation to GDC-1.
Resolution:
This comment is considered valid. The references to GDC-1 can be deleted without loss of the point being made regarding adequate QA for fire protection equipment. The rulemaking now in progress on the safety classification issue will clarify that licensees are expected to carry out QA commitments already present im the FSAR and other licensing documents. The proposed Generic Le+.ter has been revised to delete reference to GDC 1 and to more completely describe the appropriate QA guidance.
1.1.5 Comment (B.1): Size of the Fire This comment recommends that the Interpretations of Appendix R be revised to include guidance concerning the size of an assumed initiating fire. Specifically, it is recommended that the following footnote be added to Section 3, Fire Damage:
"For purposes of the fire protection program, Staff practice has been to assume a relatively small amount of combustible material as the initiation source, i.e., absent special considerations indicating high or low potential combustible initiators, typically in the range of 5 gallons of flammable liquid."
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l Resolution:
I We do not concur in this recommendation. Guidance concerning the size of an assumed initiating fire could be helpful in evaluating the fire severity within a fire area in a mechanistic way. How-ever, the proposed guidance is not representative of expected transient combustibles in most plant areas, does not specify the configuration of the transient fuel and incorrectly states the staff practice.
The expected transient combustibles vary throughout the plant.
For example, in some areas, the expected transient combustible may be oil; however, the amount and configuration of the oil would be dependent on the reason for it to be there. In the control room, paper (drawings and computer runs) and plastic scrap is the expected transient. In cable spreading rooms, cables and cable drums have been the most prevalent transient combustibles identified. On the .
refueling deck, wood and polyethylene sheets would be expected. In other areas, drums of plastic (protective clothing) are present.
Each configuration of these transient combustibles poses a different threat because of the differing characteristics of fire growth, fire duration and heat release rate.
The present guidelines recommend that the appropriate transient com-bustible for the particular area be considered. The Fire Hazard Analyses are based on this assumption. Therefore, the proposed addition was not incorporated.
1.1.6 Comment (B.2): Fire Area Boundaries This comment questioned whether each individual unsealed opening in a fire barrier must be evaluated, and stated that it was their understanding ".... that the staff would permit an evaluation of openings by groups, e.g., according to size of the openings and distance from combustible material."
. Resolution:
The stated understanding is not correct. Unsealed openings should be grouped by the fire barrier which they penetrate. The evaluation of the overall effectiveness of the barrier should then consider the size and distribution of these openings, the combustible loading,
, and the proximity of such loading on both sides of the barrier.
A clarifying revision to the Interpretations has been made.
1.1.7 Comment (C.1): General Guidance The comment stated the understanding that Section IB of the Guidance for Enforcement Actions Concerning Fire Protection Requirements does not require a separate list of safe shutdown equipment; that "the necessary equipment need only be identifiable from the fire hazards analysis and SERs."
Resolution:
ThIsunderstandingiscorrect. No revision is considered necessary.
1.1.8 Coment (C.2): Severity Categories The comment stated the understanding that the word " dedicated" used in Sections 2.A. 2.8 and 2.C of the Guidance for Enforcement Actions Concerning Fire Protection Requirements "is meant to refer to the equipment identified in the fire hazards analysis for safe hot or cold shutdown."
Resolution:
This understanding is correct. A clarifying revision to that-effect has been made.
1.1.9 Comment (D.1): Current Reca.irements The comment states that the proposed license condition is unnecessary for plants licensed prior to January 1,1979 because license condi-tions were issued upon completion of the staff's review of con-formance to the positions in Appendix A to BTP APCSB 9.5-1; that for i
plants licensed after January 1, 1979, a license condition has been imposed; that all modifications must be reviewed and reported pur-suant to 10 CFR 50.59; and that 10 CFR 50.72 and 50.73 provide relevant reporting requirements. Therefore, adequate enforceability e
is already present without additional actions.
The comment also recommended that the response to Question 8.3 (which inquired whether an exemption is required from Appendix R sections other than III.G III.J and III.0 for future modifications that do not comply with such sections) be changed from "yes" to "no." This was based on the interpretation of Appendix R as not requiring exemptions for modifications that were made to features which were approved by the staff under Appendix A of BTP APCSB 9.5-1. The Statement of Considerations to Appendix R (45FR76602, Nov.19,1980) was cited to support this.
Resolution:
A standard license condition is considered necessary for the following reasons. The license conditions which were imposed on plants licensed prior to January 1,1979 only addressed the modifications that were required. Those parts of a plant's fire protection program including the fire hazards analysis, found acceptable by the staff in the Fire Protection Safety Evaluation Report with no ,
modifications necessary were not addressed by the license condition. '
9
The NRC has found during inspections that some licensees do not con-sider the Appendix A to BTP APCSB 9.5-1 items of their fire pro-tection programs as binding and have either changed them or ignored them. For plants licensed after January 1,1979, while all such plants have a license condition regarding fire protection, the scope of what is covered by the condition and the wording of the condition varies widely. This results in varying degrees of compliance and uneven enforcement. Therefore, we believe that a " standard license condition" is necessary .for consistent and fair regulation. How-ever, the license condition has been revised to include specific identification of the documents providing the basis for the license condition.
Regarding the applicability of 10 CFR 50.59, in many cases, includ-ing all plants licensed prior to January 1,1979, the fire protection program and the fire hazards analysis are not described in the FSAR.
Therefore, the provisions of 10 CFR 50.59 are not directly appli-cable. Accordingly, the license condition has been revised to specify the applicabilit cess and 10 CFR 50.71(e)y of 10 (2) for CFR the 50.59 for reporting the evaluation process. Addi- pro-tional 1.1.11.
revisions are described in coment resolutions 1.1.10 and Regarding the comment on Question 8.3, this comment is not con-sidered valid. The cited Statement of Considerations does not address the applicability of Appendix R in regard to modifica-tions made to features previously approved by the staff. The staff 50.48(position in thistoregard b). A revision is clearly the response to supported Question 8.3by 10 hasCFR been made to clarify this point.
1.1.10 Comment (D.2): Hearing Requirements Under the proposed license condition, any change to the program must be analyzed for its effect on overall fire protection safety.
Even minor modifications such as adding one cable to a room or a change in the location of a fire extinguisher would have to be analyzed, and, if found to lower the level of fire protection, no matter how minor, would require a license amendment with full notice and hearing rights, an expensive and time-consuming process with-out a commensurate benefit to safety. Therefore, the proposed license condition should not be adopted.
Resolution:
The proposed license condition has been revised to make it clear that only those changes to the fire protection program that l
"significantly" decrease the level of fire protection would require l prior Commission approval and a license amendment; changes which do i
not "significantly" decrease the level of fire protection may be
n-t ',
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made in accordance with 10 CFR 50.59 and reported annually with FSAl '
revisions as required by' to CFR 50.71(e).
1.1.11 Comment (D.3): Section 50.59 's g '
In regard to paragraph 3 of the proposedslicense condition the, coment states: '
a) ---that the requirement to submit the supporting analyses would impose an undue paperwork burden on both the licensees -
and the Staff. Significantly, Section 50.59 does not require actual submittal of the analyses performed in accordance with that section. Instead, licensees re pursuant to 10 C.F.R. 9 50.71(e) (2) port to the NRC annually changes have been made.
on what Section 50.59 We would recommend that a similar procedure be used for fire prt.tection changes, and therefore would recomend not imposing a requirement for actual subenitta1f
, of the analyses." ,
b) ---there is no safety reason to require that "All changes to 1 the approved program" be reported to the NRC annually. For example, changing the location of a fire extinguisher or adding one cable to a room may have no practical bearing on safety.
Yet, pursuant to the license condition as postured it may need to be reported. We maintain that such a requirement is unjusti-fied and unwarranted."
Resolution: t
- a) The proposed license condition has been revised to remove the requirement for submittal of the analyses and to specify the applicability of 10 CFR 50.59 and 10 CFR 50.71(e),
b) It is not intended that changes that "---have no practical bear-ing on safety" be reported; it is expected that licensees would exercise reasonable judgment in this regard. A revision was made '
to indicate this intent. -
s 1.1.12 Coment (E): Standard Technical Specifications The comment supports the Steering Committee effort to revise thie fire '
protection Technical Specifications to the extent that it is directed toward simplifying and generalizing them to be more workable. It recomends that any proposed TS changes be reviewed as part of the overall staff consideration of Technical Specifications in general, and. requests an opportunity to coment on propoiod changes.
e 4
1' ,
I
Resolution:
The course of action to be followed should be defined by the Steering Comittee. The options available are:
(1) Include the revised fire protection Technical Specifications -
in the package being submitted for CRGR review and subsequently for Comission approval.
This option would provide a complete package for " resolution" of the fire protection issue; the "Comission approved" fire protection TS could then be incorporated in the STS without delay, and implementation in OLs and ors could proceed imediately.
(2) Handle the fire protection Technical Specifications separately (from the CRGR/Comission package), i.e., sutunit the proposed revision to the Technical Specification Review Group (TSRG)
(E. Butcher) for eventual inclusion in the STS.
It is our understanding that the TSRG is presently revising the STS to include all clarifying changes which reflect present practice and which will not require CRGR review. The TSRG intends to make substantive type changes, which will then be submitted to the CRGR on a single issue basis, at a later date.
The proposed fire protection TS changes are in this second category. Therefore, CRGR approval and subsequent implementa-c tion of the TS on OLs and ors would be delayed significantl Also, the direct Commission approval afforded by option (1)y.
would not be available to support backfitting the revised TS on ors.
(3) Defer action on fire protection TS until some action is taken by NRR on the recomendations of the Technical Specification !
Improvement Project (TSIP) (S. Bryan [formerly under !
D. Beckham]) which are scheduled for September 1985. ;
This option has the same detrimental aspects in regard to implementation of the TS as option (2) except that the delay involved would probably be greater.
It is recomended that option (1) be selected. It is also recom-mended that the TS not be issued for public comment, unless so directed by the Comission. Substantive changes to Technical 3
Specifications normally only require CRGR review.
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1.1.13 Comment
- (F.1): Question 3.2.3 (Fire Door Modifications)
The comment notes that according to UL and FM any modification of a fire door will invalidate its label. Therefore, the following portion of the response to Q3.2.3, "An exemption is required if fire doors installed in a fire barrier ured to satisfy Section III.G.2 are modified such that the labeled rating no longer applies," could be interpreted to require an exemption for modifi-cations to incorporate security hardware or flooding protection.
It is recomended that the response be revised to state that an exemption is required only after a boundary analysis which considers the fire loading on both sides of the boundary shows that adequate margin no longer exists.
Resolution:
The comment is valid. To be consistent with Section #4 of the
" Interpretations," the response to Q3.2.3 has been revised to in-dicate that evaluation of fire door alterations is part of a fire boundary analysis not requiring an exemption.
1.1.14 Coment (F.2): Question 3.6.2(InterveningCombustibles)
The comment notes that the response to Q3.6.2 classifies cables in covered cable trays as " intervening combustibles" while the response to Q3.6.3 vening states that cables in conduit are not considered inter-combustibles. It is recommended that the response to Q3.6.2
- be revised to state that "--cable in fully enclosed cable trays does not constitute an intervening combustible for Appendix R purposes."
Resolution:
The response to Q3.6.2 has been revised to state that cables in cable trays which do not have solid sheet metal bottom sides and top are considered intervening combustibles. The response to Q3.6.3 has been revised to state that cables in metal conduits or in cable trays or raceways which have solid sheet metal bottom, sides and top are not considered intervening combustibles.
1.1.15 Comment (F.3): Question 3.6.3(UnexposedCombustibles)
"The response to this question states that oil in closed containers that conform to NFPA Standard 30 is not considered an intervening combustible, while oil in sumps is so considered. The Group believes that oil in closed sumps should be treated as equivalent to oil in NFPA Standard 30 containers,
-and therefore should not be classified as an intervening i combustible. The Group does not object, however, to classifying oil in open sumps as an intervening combustible."
Resolution:
r The coment is valid. The requested revision has been made.
1.1.16 Coment .(F.4): Question 5.3.8 (High Impedance Faults)
The comment questioned the need for including multiple high impedance faults in associated circuits subject to fire damage in short circuit coordination studies;Section III.G.2 of Appendix R was cited as expressly "not" requiring consideration of multiple high impedance faults.
Resolution:
The comment is not valid. Section III.G.2 does require considera-tion of ' hot shorts" and " shorts to ground," and these tenns encom-pass high impedance faults. Given a major cable fire, multiple high impedance faults will probably occur. However, the response to QS.3.8 was revised to clarify staff practice in regard to when short circuit coordination studies need or need not be performed. The revision also corrected the typographical error identified in the comment.
1.1.17 Comment (F.5): Question 8.11 (Plants Licensed After January 1,1979)
"The respense to Question 8.11 states that plants licensed after January 1,1979 are subject to, inter alia, BTP CMEB
?
9.5-1. Some plants in this category, however, were licensed to the APCSB version of BTP 9.5-1 rather than the CMEB version.
There are some material differences between the two versions, and if a plant that was licensed to the APCSB version were required to follow the CMEB version, exemption requests and modifications could be necessary. We expect the response was merely an oversight on the Staff's part. We would recommend modifying the response to Question 8.11 to read: 'BTP CMEB 9.5-1 or BTP APCSB 9.5-1, if so provided as part of a license condi-tion or licensing commitment, which includes....'"
Resolution:
l The point.
comment is valid. A revision has been made to clarify this 1.'1.18 Comment (F.6): Question 8.19(a) (Exemption Requests)
"There appears to be an oversight in the response to
._ Question 8.19(a). That response contains a cross-reference to the responses to Question 8.21.1 through 8.21.6, but'the responses referred to do not appear in the document. He understand that the Staff will add the promised responses. The Group reserves the right to comment when these responses are provided." i l
Resolution:
The cited cross-reference has been corrected to read "--response to Questions 8.19.1 through 8.19.4."
1.2 Duke Power Company: Letter from H. B. Tucker to the Secretary of the Commission dated February 14, 1985. (Endorses the NUFPG comments and provides the following specific comments) 1.2.1 Comment (1): Quality Assurance Requirements The coment states that reference to GDC 1 of Appendix A to 10 CFR 50 in Section D of the proposed Generic Letter is clearly inappropriate, and that "The QA program for fire protection should be reviewed to requirements of the GDC 3, BTP or SRP as applicable."
Resolution:
This is included in the resolution of comment 1.1.4 above.
1.2.2 Coment (2):Criteria Acceptance Question 3.2.1 (Fire Barrier Qualification -
" Staff Position is that maximum heat transfer (sic) across a penetration seal, subjected to ASTM-E119 Fire Endurance test, is 325'F.
" Comment frequently- is
- 1) greater ASTM-#119 thancriteria 75*F. is2) 250*F above ambient which Appendix R,Section III.M. states acceptance criteria for temperature as
' ..sufficiently below the cable insulation ignition temper-ature...'.
This interpretation (the staff's position [added])
is clearly contrary to the intent and verbage of Appendix R."
Resolution:
- 1) The response to Q3.2.1 clearly states that 75'F is generally recognized as an acceptable norm. No revision is warranted.
- 2) Question 3.2.1 addresses criteria for qualification of cable 1 tray fire wrap material while Section III.M.2 of Appendix R addresses criteria for qualification of cable penetration l seals. While Section III.M.2 is not explicitly applicable to l cable wrap material, applicability is implied. Therefore, we have revised the response to Q3.2.1 to clarify that a qualifi-cation criterion less than 325'F may be justified by an analysis l
-demonstrating that the maximum recorded temperature is sufficiently below the cable insulation ignition temperature. '
Also see resolution 1.3.1. -
1.2.3 Comment (3): Question 3.3.4 (Cable Tray Support Protection)
" Staff Position is that '... cable tra protected regardless (emphasis added)yofsupports whethershould therebe is a sprinkler system. . . ' .
There is no technical basis for this arbitrary position. If a sprinkler system is provided and functions (as it is apparently given credit in rtducing fire barrier rating from 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> to I hour), the environment will be cooled below the temperature at which cable tray supports will be affected by heat fatigue.
In addition, each area should be reviewed individually to assess combustible loadings and other factors to determine if a potential fire could generate sufficient heat to affect cable tray supports."
Resolution:
The comment is not entirely justified in that the quoted portion of the staff position is preceded by "In general," and is followed by two conditions (one based on qualification tests perfonned and the other on structural analysis performed) under which cable tray supports need not be protected. However, the staff agrees that a clarification regarding the analysis to be performed is desirable.
The response to Q3.3.4 has been revised accordingly.
1.2.4 Comment (4): Question 3.8.4 (Control Room Fire Considerations)
The staff position in the response to Q3.8.4 does not reflect staff practice during Apper. dix R inspections.
"The Staff Position is '...that the only manual action usually credited in the control room by this analysis is the reactor trip. Any additional control room actions deemed necessary would have to be justified under the exemption process.'
Comment - During a recent Appendix R inspection we demonstrated the control room abandonment portion of our Hot' Standby Opera- '
tions procedure to Region II, ONRR and BNL representatives.
We demonstrated reactor trip, turbine trip and main feedwater manual trips (in case automatic signals did not function properly). This is reasonable since the control room does not instantly become uninhabitable. There was no question during the inspection about the capability to trip all of the subject systems therefore the new interpretation should be changed to agree with actions which have been reviewed and accepted."
Resolution:
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The comment is valid. The response to Q3.8.4 has been revised accordingly including removal of."Any additional control room actions deemed necessary would have to be justified under the exenption process."
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1.2.5 Coment (5): Question 5.1.3 (III.L Backfit)
"The question is Why do Staff Interpretation memoranda (emphasis added) regarding the criteria for satisfaction of Section III.L. form the auditable basis for determining com-pliance to Appendix R...?
Comment - The response fails to address the rationale for considering Staff interpretative memoranda as part of the Rule.
If necessary, the Rule should be so amended."
Resolution:
The response does provide the basis for the applicability of Section III.L.of Appendix R. Because the bases cited in the response are deemed sufficient, there is no need for a rule change. Addition-ally, it should be noted that the explicit portions of " interpretive memoranda" describe methods acceptable to the staff for demonstra-ting conformance to Appendix R. This does not preclude licensees from proposing and justifying other methods, e.g., see Section 1, Process Monitoring Instrumentation, of the Interpretations of Appendix R.
1.2.6 Comment (6): Question 5.2.4 (Post Fire Procedures Guidance Documents)
"The question pertains to Staff guidance documents of post fire operating procedures. The response is that there is no guidance other than criteria of Section III.L.
Comment - Licensees need to know the criteria used for evaluating post fire shutdown procedures. In addition, without criteria how do various inspection teams plan to conduct consistent reviews?"
Resolution:
It is our judgement that the responses to Questions 5.2.1, 5.2.2, and 5.2.3 are appropriata and that the criteria for operating procedures in III.L are sufficient. As indicated in the aforementioned responses the methods for meeting these criteria are the option of each licensee. The inspection process will be flexible in this regard as long as the licensee can show compliance wich the criteria of Section III.L. The preceeding sentence has been added to the re-sponse to QS.2.4.
1.2.7 Comment (7): Question 9.3 (NT0L Inspections)
" Response states that NT0L's will be subject to Appendix R inspections.
Comment - This is inappropriate for stations reviewed to technical requirements of Standard Review Plan 9.5.1 which differ significantly from requirements of Appendix R, Sections III.G and III.L." l
Resolution:
The staff is aware of only one significant difference between Sections III.G and III.L of Appendix R and the corresponding posi-tions in BTP CMEB 9.5-1 which is part of Standard Review Plan 9.5.1.
See response to Question 8.11 in " Appendix R Questions and Answers."
1.2.8 Comment (8): General Question "For stations previously inspected, will inspection results be modified to meet -these new interpretations (i.e., will addf-tional findings evolve based on new published interpretations)?"
Resolution:
For plants previously inspected and which have no remaining open fire protection items in an Inspection Report already issued, the answer is no. For previously inspected plants where open items remain in an issued Inspection Report, the new interpretations will be used in subsequent inspections performed to close out the open items. In plants where an inspection has been made but the Inspection Report has not yet been issued, the new interpretations will be used as a basis for any findings. It is reconenended that the Steering Committee include the preceeding resolution in its report.
1.3 Toledo Edison Company: Letter (#1127) from R. P. Crouse to H. R. Denton dated February 14, 1985. (Endorses the NUFF'S consnents and provides the following specific comments) e 1.3.1 Comment (1): Question 3.2.1 (Acceptance Criteria)
"The discussion in response to Question 3.2.1 of the draft Generic Letter 85-01 states as follows (page 14):
' Conduit and cable tray enclosure materials accepted by the NRC as I hour barrier prior to Appendix R (e.g.,
some Kaowool and 3M materials) and already installed by the licensee need not be replaced even though they may not have met the 325*F criteria. However, new material should meet the 325*F criterion. Justification of temperatures which exceed 325*F is required.'
It is Toledo Edison's determination that the final quoted sentences should be modified to read, 'However, newly identified conduit and cable trays requiring such wrapping should use new material which meets the 325 F criterion or justification should be provided of temperatures ex-ceeding the 325 F criterion.'
Utilizing the different wording would prevent situations occurring, such as one conduit undergoing repair being partially wrapped by two differing materials."
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Resolution:
s The coment is valid. The proposed revision,'ith w an editorial
- change, has been made. Also see resolution 1.2.2.
1.3.2 Coment (2): Question 5.3.8 (Short Circuit Coordination Studies)
"The response to Question 5.3.8, concerning Short Circuit Coordination Studies, states:
' Clearing such faults on non-essential circuits may be accomplished by manual breaker trips governed by written procedures.'
The word non-essential may allow misinterpretation with regard to essential vs non-essential circuits, Class IE vs. Non-Class 1E circuits, etc. It is Toledo Edison's understanding that all loads not required to achieve and maintain safe shutdown, which may fault and cause high impedance ground fault tripping of the supply breaker may be opened allowing reenergizing of the bus supply power. Toledo Edison, therefore, recommends that the words 'non-essential circuits' be removed and replaced by
' associated circuits which may effect safe shutdown'."
Resolution:
The recomended revision has been made. Also see resolution 1.1.16.
1.4 Boston Edison Company: Letter (BEco 85-037) from W. D. Harrington to H. L. Thompson, Jr. dated February 22, 1985. (Requests a 30-day extension of the coment period and provides the following specific coments) 1.4.1 Coment (1): Schedular Relief The comment points out that a "living schedule" including fire pro-tection modifications beyond the 10 CFR 50.48 deadlines has' been approved by the NRC. And that, therefore, ,
i "The Steering Comittee recommendation to follow the schedule dictated by 10 CFR 50.48 without granting the extensions already filed with the NRC will make the fire protection modifications the highest priority. This will preclude the evaluation of other safety issues which could be equal or higher in safety i
priority than fire protection."
Resolution:
The coment is valid. Section A of the proposed Generic Letter h'as been revised to clarify that schedular exemptions based on NRC approved "living schedules" are available and would be issued under 10 CFR 50.12. Also see resolution 1.1'.1.
1.4.2 Comment (2): Question 3.6.2 (Intervening Combustibles)
Same as comment 1.1.14.
Resolutio' n:
Same as resolution 1.1.14.
1.4.3 Comment (3): Question 4.1 (Illumination Levels)
"Section 4.1, "I1'lumination Levels", the clarification states
'where a licensee has provided emergency lighting per Section III.J of Appendix R, we would expect that the licensee verify by field testing that this lighting is adequate to perform the intended tasks'. The term ' adequate lighting' could be inter-preted differently by the licensee and the NRC inspection staff."
Resolution:
It is expected that the licensee and NRC inspection staff would use reasonable engineering judgement to arrive at a mutually acceptable assessment of " adequate lighting." No revision to the Q4.1 response was deemed necessary.
1.4.4 Conrnent (4): Question 7.1 (Fire Protection and Seismic Events)
" Item 7.1 of Enclosure 5 clariffes the guidelines for the e
seismic design of fire protection systems in relation to the reactor coolant pump lube oil system, and those situa-tions where seismic events are assumed to be initiators of a fire. The NRC response does not address the intent of the question but establishes guidelines for the seismic design of fire protection systems. Boston Edison takes exception to this clarification and states that a seismic event is not considered concurrent with a fire and the fire protection systems are not seismically designed."
Resolution:
It is agreed that all or parts of fire suppression systems are not seismically designed. The BTP positions cited indicate what con-siderations should be given to seismic design of these systems (Also, see response to Q7.2). Certain items, such as the RCP lube oil system and the hydrogen lines, were addressed specifically with regard to seismically induced fire. In both these cases, the fire protection measures specified do not . involve a fire suppression system. The BTP CMEB 9.5-1 cited in the response does not apply to plants reviewed and approved prior to the issuance of that BTP.
The responses to 07.1 and 7.2 have been revised to make this clear.
1 1.5 Northeast Utilities: Letter (A04606) from W. G. Counsil to H tR. Denton dated March 1, 1985. (Endorses the NUFPG comments and provides the following specific comments) 1.5.1 Coment (1): Proposed License Condition a) This coment quotes the following excerpt from Section II.
Regulatory Philosophy of NUREG-0885 Issue 4, U. S. Nuclear Regulatory Commission Policy and Planning Guidance 1985:
"The Commission intends to shift its regulatory emphasis away from detailed, prescriptive requirements toward general design and performance criteria."
and states that "While much of the fire protection policy steering committee report runs contrary to the above quoted Comission policy, the proposed license condition is the most
, significant one."
b) Section 2 of the proposed license condition would require a license amendment for minor changes to the fire protection program having no safety significance (Essentially the same as comment 1.1.10).
c) Section 3 of the proposed license condition would impose '
reporting and review requirements for fire protection greater than those associated with other elements of operating a nuclear facility (Essentially the same as comment 1.1.11).
Resolution:
a) The staff acknowledges the merit of the cited Comission policy guidance in general. However, it should be recognized that in the case of fire protection GDC-3 has provided " general design and performance criteria", and that the regulation of fire protection requirements solely on that basis has proven in-effective.
As a result, the Commission determined, after analyzing the re-sults of the Browns Ferry fire, that the more prescriptive re-quirements embodied in the BTP and subsequently in Appendix R to 10 CFR 50 were necessary, and established the present regulatory requirements. The proposed license condition adds no new requirements. It only identifies in the license the fire protection program committed to by the licensee and ac-cepted by the staff in previous reviews. It also includes an
_ allowance for changes to be made to that program by the licensee
without Commission approval, and a method for keeping record of a such changes.
b) See resolution 1.1.10.
c) See resolution 1.1.11.
1.5.2 Comment (2)/ Resolution: Schedular Relief Same as comment 1.1.1., and same resolution.
1.5.3 Comment (3)/ Resolution: Quality Assurance Requirements Same as comment 1.1.4, and same resolution.
1.5.4 Comment (4)/ Resolution: Documentation Required to Demonstrate Compliance Same as comment 1.1.3, and same resolution.
1.5.5 Comment (Sa)/ Resolution: Question 3.2.3 (Fire Door Modifications)
Same as comment 1.1.13, and same resolution.
1.5.6 Comment (5b): Question 3.1.1 (Fire Area Definition)
"The response to this question, referring to 10CFR50 Appendix R Section III.G.3.b, indicates that, for safety-related equipment
- and associated cabling the licensee must '(p)rovide the design criteria for protection of such equipment against inadvertent operation, careless operation or rupture of extinguishing systems.' In contrast the regulation itself addresses
' rupture or inadvertent operation of fire suppression systems.'
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Reference (3) quoting 10CFR50 Appendix A General Design Criterion 3 (GDC) states '(f)f re fighting systems shall be designed to ensure that their rupture or inadvertent operation does not significantly impair the safety capability' of safe.ty-related equipment. We believe that the inclusion of the additional criterion of ' careless operation,' is inappropri-ate.
It is not clear what additional concern the NRC intends for licensees to address by inclusion of this term."
Resolution:
The comment is valid. The words " careless operation" have been deleted.
1.6 KMC, Inc.: Letter from P. F. Riehm to H. R. Denton dated February 14, 1985. ~
, Comment / Resolution:
Same as comment 1.1.4, and same resolution.
1.7 Virginia Power: Letter (85-113) from W. L. Stewart to H. R. Denton dated Febrtary 14, 1985.
Comment:
The comment focused on the approach the Commission should take in achieving its fire protection goals rather than on specific mech-anisms for doing so. It states, based on experience, that fire protection "---is a living evolving issue that does not Tend itself to definitive guidance nor swift compliance."
Favorable views on the Steering Committee recommendations are expressed as follows:
"We are encouraged by such recommendations as: establishing referees to resolve significant differences that arise during inspections, inspection team workshops, expediting inspections to obtain a clearer understanding of the status of industry in achieving compliance, and designating a central point of con-tact within NRC to resolve internal conflict. We believe that recommendations such as these reflect not only our experience with fire protection, but indicate that NRC also recognizes that guidance must continue to evolve, that interpretations will change, and that exceptions to the regulations will arise and need to be addressed."
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However, the following reservations in regard to the recommendations ars cited:
"On the other hand, we are concerned by such recomendations as: . elimination of schedular exemptions, more aggressive and expedited enforcement actions, and more regulation (i.e.
standard license conditions) and apparent new requirements (e.g. meeting GDC-1). We believe that recommendations such as these fail to recognize the nature of the fire protection issue.
It is not reasonable to expect that fire protection issues will be resolved and'c~ompliance will be achieved solely through mandate. The history of fire protection in the nuclear industry provides ample evidence to support this. Rather, they will be resolved and achieved through better understanding and continued active comunication between NRC and industry. The issuance of the Steering Comittee's policy recommendations for coment is a positive step in that direction and we encourage the NRC to continue in this manner."
In sumary, the coment states:
---and we encourage the NRC to adopt the Steering Committee's policy recommendations that support resolution of fire protection issues through understanding and communications."
Resolution:
The coment is acknowledged. The approach being taken by the Steering Committee is, we believe, in accord with the thrust of this comment and is consistent with the overall fire protection objectives of the Commission.
1.8 New York Power Authority: Letter (IPN-85-08, JPN-85-15) from C. A. NcNeill to H. R. Denton dated February 23, 1985. (Endorses ,
the NUFPG comments and provides the following specific coments).
Comment / Resolution:
The coments are essentially the same as comments 1.1.1 and 1.1.2 (and 1.2.8), and 1.1.3, and the same resolution.
1.9 Georgia Power Company: Letter (NED-85-088) from L. T. Gucwa to H. R. Denton dated February 14, 1984. (Endorses the NUFPG coments and provides the following specific coment).
Comment / Resolution:
Same as coment 1.1.2, and the same resolution.
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h.
ENCLOSURE 2 i GENERIC LETTER ON FIRE PROTECTION TO ALL LICENSEES AND APPLICANTS FOR OPERATING LICENSES Gentlemen:'
SUBJECT:
IMPLEMENTATION OF FIRE PROTECTION REQUIREMENTS In the Spring of 1984, the Commission held a series of Regional Workshops on the implementation of NRC fire protection requirements at nuclear power plants.
At those workshops, a package of recently-developed NRC guidance was dis-tributed to each attendee which included NRC staff responses to industry questions and a document titled " Interpretations of Appendix R." The cover memo for the package explained that it was a draft package which would be issued in final form via Generic Letter following the workshops.
The guidance approved by the Commission is appended to this letter, and is in the same format as the draft package, i.e., " Interpretations of Appendix R" and responses have been modified from the draft package, and a number of in-dustry questions raised at or subsequent to the workshops have been added and answered. This package represents the official agency position on all issues covered, and where this guidance differs from previously issued guidance (in-cluding Generic Letter 83-33) on this subject, this guidance takes precedence.
In the lettered sections below, some additional topics are covered which also bear on the interpretation and implementation of NRC fire protection require-ments. The topics are: (A) schedular exemptions, (B) revised ins
' program, (C) documentation required to demonstrate compliance, (D)pection assurance requirements applicable to fire protection systems, and (qualityE) notifi-cation of the NRC when deficiencies are discovered.
A. Schedular Exemptions The Appendix R implementation schedule was established by the Commission in 10 CFR 50.48(c), promulgated together with Appendix R in November of 1980.
Allowing time to evaluate the need for alternative or dedicated shutdown systems, which require prior NRC approval before installation, and time for design of and NRC review of such systems, the Commission envisioned that implementation of Appendix R would be complete in four to five years, or approximately by the end of 1985. Many schedule extensions were granted by.
the staff under the " tolling provision," 50.48(c)(6), and under 10 CFR 50.12, the longest of which now extends into 1987. Some licensees have proceeded expeditiously to implement Appendix R and are now finished or nearly finished with that effort. Others have engaged in lengthy negotiations with the staff while continuing to file reque:;ts for schedule extensions, and thereby have barely begun Appendix R modifications needed to comply with Sections III.G l
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and III.L. Schedule extension requests have been received seeking implementa-tion dates of 1990 or beyond.
As the 50.48(c) schedule was intended to be a one-time' schedule commencing in the 1980-1982 time frame and ending in the 1985 time frame, extensions well.
beyond this schedule (particularly where major modifications remain to be completed) undermine the purpose of the schedule, which was to achieve ex-peditious compliance with NRC fire protection requirements. The NRC will therefore grant no further extensions to the 50.48(c) schedules. When a licensee's schedule expires, compliance is expected and appropriate enforce-ment action will be taken. If compliance cannot be achieved by that date, the licensee will be required to submit and justify a minimum schedule for comple-tion of fire protection modifications, and to supply interim measures to compensate for the lack of compliance. In submitting a schedule which goes beyond the current 50.48 deadline the licensee will be required to demon-strate that it has endeavored in good faith to complete modifications on schedule. A showing of good faith attempt to complete implementation on schedule may mitigate enforcement action for noncompliance with NRC requirements. Licensees submitting "living schedules" for NRC approval should be aware that existing 50.48 schedules continue to apply. Licensees intending i to include fire protection modifications within a "living schedule" are ex-pected to assign within such schedules the relative safety priorities of remain-ing fire protection modifications. If the NRC accepts a delayed implementa-tion date in the context of a living schedule, this would provide the basis for a schedular exemption which would then be issued under 10 CFR 50.12.
The NRC is currently reviewing all dockets of plants covered by the 50.48 schedule to determine schedule deadlines. When this review is completed, each licensee will be informed of the deadlines.
B. RevisedInspectionProgram[To he regged' [y [f [)
In 1982, the NRC developed an inspection program to verify compliance with the requirements of 10 CFR 50, Appendix R. This program was primarily oriented towards reviewing safe shutdown features of those pre-1979 licensees that had completed Appendix R modifications and selected NT0L plants. From 1982 to the present, approximately seven Appendix R compliance inspections have -
been performed. In a number of cases, these inspections. have discovered that licensees had made significant errors in implementing a number of Appendix R requirements.
i In order to expedite compliance verification and to provide the NRC staff with earlier indication of problems associated with implementation of fire pro-tection features, the NRC will conduct fire protection inspections of cpera-ting plants and plants currently undergoing operating license review during
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1985 to include at least one site from each licensee who has not been subject to a previous NRC fire protection inspection. This inspection will review completed modifications and, in the case of incomplete modifications, review licensee plans and schedules for completing such modifications.
C. Occumentation Required to Demonstrate Compliance The " Interpretations" document attached to this letter states that, where the licenee chooses not to seek prior NRC review and approval of, for example, a fire area boundary, an evaluation innst be performed by a fire protection engineer (assisted by others iis needed) and retained for future NRC audit.
Evaluations of this type must be written and organized to facilitate review by a person not involved in the evaluation. Guidelines for what such an evaluation should contain may be found in: (1) Section B of Appendix R and (2) Section C.1.b of Branch Technical Position (BTP) CMEB 9.5-1 Rev. 2 dated July 1981. All calculations supporting the evaluation should be available and all assumptions clearly stated at the outset. The NRC intends to initiate enforcement action where, for a given fire area, compliance with Appendix R is not readily demonstrable and the licensee does not have available a written fire hazard analysis for the area. The term "readily demonstrable" includes situations where compliance is apparent by observation of the potential fire hazard and the existing protective features.
D. Quality Assurance Requirements Applicable For fire protection systems the licensee should have and maintain a quality assurance program that provides assurance that the fire protection systems a will be designed, fabricated, erected, tested, maintained and operated so that they will function as intended. Fire protection systems are not " safety-re-lated" and are therefore not within the scope of Appendix B tg 10 CFR Part 50, unless the licensee has committed to include these systems under the Appendix B program for the plant. NRC guidance for an acceptable quality assurance pro-gram for fire protection systems, given in Section C.4 of Branch Technical Position CMEB 9.5-1 Rev. 2 dated July 1981, has generally been used in the re-view and acceptance of approved fire protection programs for plants licensed after January 1, 1979. For plants licensed prior to January 1,1979, similar guidance was referenced in footnotes 3 and 4 to 10 CFR 50.48. They are contair.ed in BTP APCSB 9.5-1 and Appendix A thereto and in " Nuclear Plant Fire Protection Functional Responsibilities, Administrative Control and Quality i Assurance" dated June 14, 1977. !
l E. Notification of the NRC When Deficiencies are Discovered l Licensees are reminded of their obligation to notify the NRC of fire protection deficiencies which meet the criteria of 10 CFR 50.72 or 10 CFR 50.73 as -
applicable.
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l F. Standard License Conditi.on All licenses contain a section on fire protection. License conditions for plants licensed prior to January 1,1979, contain a condition requiring imple-mentation of modifications committed to by the licensee as a result of the BTP review. These license conditions were added by amendments issued between 1977 and February 17, 1981, the effective date of 10 CFR 50.48 and Appendix R. Two points should be noted in regard to these conditions: (1) they did not expli-citly cover required fire protection features where modifications to the exist-ing plant configuration or procedures were not required, and (2) some of the provisions in these conditions could have been superseded by Sections III.G.,
J, 0, and L of Appendix R.
License conditions for plants licensed after January 1, 1979, vary widely in scope and content. Some only list open items that must be resolved by a spe-cified date or event, such as exceeding five per cent power or the first re-fueling outage. Some reference a comitment to meet Appendix R; some reference the FSAR and/or the NRC staff's SER. These variations'have created problems for licensees and for NRC inspectors in identifying the operative and enforce-able fire protection requirements at each facility.
These license conditions also create difficulties because they do not specify when a licensee may make changes to the approved program without requesting a license amendment. If the fire protection program comitted to by the licensee is required by a specific license condition or is not part of the FSAR for the facility, the provisions of 10 CFR 50.59 may not be applied to make changes
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without prior NRC approval. Thus licensees may be required to submit amendment requests even for relatively minor changes to the fire protection program.
A standard fire protection license condition is enclosed for your considera-tion. Its purpose is twofold: (1) to identify clearly the approved fire pro-tection program for the facility, against which compliance with be measured, and (2) to specify when prior NRC approval is or is not required when changes to the approved program are contemplated. The condition also contains record retention and reporting requirements paralleling those of 10 CFR 50.71 for changes to the FSAR. Note that this standard condition does not impose any new substantive requirements, but only documents existing licensee commitments approved by the NRC.
[0ptional paragraph:
We request that each licensee submit, within 120 days of the date of this '
letter, a license amendment request proposing a license condition for its l facility using the enclosed standard condition as guidance.] -
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ENCLOSURE 3 l
l r INTERPRETATIONS OF APPENDIX R
- 1. Process Monitoring Instrumentation Section III.L.2.d of Appendix R to 10 CFR Part 50 states that "the process monitoring function shall be capable of providing direct readings of the process variables necessary to perform.and control" the reactivity control function. In I&E Information Notice 84-09., the staff provides a listing of instrumentation acceptable to and preferred by the staff to demonstrate com-pliance with this provision. While this guidance provides an acceptable method for compliance with the regulation, it does not exclude other alternative methods of compliance. Accordingly, a licensee may propose to the staff alternative instrumentation to comply with the regulation. While such a sub-mittal is not an exemption request, it must be justified based on a technical evaluation. The licensee may also propose alternatives to actual compliance with the regulation (e.g., instrumentation which does not provide a direct reading of the process variable) by filing an exemption request with adequate justification.
- 2. Repair of Cold Shutdown Equipment Section III.L.5 of Appendix R states that when in the alternative or dedicated shutdown mode, " equipment and systems comprising the means to achieve and main-tain cold shutdown conditions shall not be damaged by fire; or the fire damage to such equipment and systems shall be limited so that the systems can be made operable and cold shutdown can be achieved within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />." This is not to :
be confused with the requirements in Section III.G.1.b of Appendix R.
Section III.G.I.b contains the requirements for normal shutdown modes utilizing the control room or emergency control station (s) capabilities. The fire areas falling under the requirements of III.G.I.b are those for which an alternative or dedicated shutdown capability is not being provided. For these fire areas,Section III.G.I.b requires only the capability to repair the systems necessary i to achieve and maintain cold shutdown from either the control room or emergency control station (s) within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, not the capability to repair and achieve cold shutdown within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> as required for the alternative or dedicated shutdown modes by Section III.L (noted above).
With regard to areas involving normal shutdown, however,Section I of Appendix R states that repairs must be made using only onsite capabilities.
After repairs are made, cold shutdown can be achieved on a reasonable schedule using any available power source.
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- 3. Fire Damage Appendix R to 10 CFR Part 50 utilizes the term " free of fire damage." In pro-mulgating Appendix R, the Comission has provided methods acceptable for assur-ing that necessary structures, systems and components are free of fire damage (see Section III.G.2a, b and c), that is, the structure, system or component under consideration is capable of performing its intended function during and after the postulated fire, as needed. Licensees seeking exemptions from Section III.G.2 must show that the alternative proposed provides reasonable assurance that this criterion is met. (Note also that Section III.G.2 applies only to equipment needed for hot shutdown. Therefore, an exemption from III.G.2 for cold shutdown equipment is not needed.)
- 4. Fire Area Boundaries The term " fire area" as used in Appendix R means an area sufficiently bounded to withstand the hazards associated with the area and, as necessary, to protect important equipment within the area from a fire outside the area. In order to meet the regulation, fire area boundaries need not be completely sealed floor-to-ceiling, wall-to-wall boundaries. However, all unsealed openings should be identified and considered in evaluating the effectiveness of the overall barrier. Where fire area boundaries were not approved under the BTP process, or where such boundaries are not wall-to-wall, floor-to-ceil-ing boundaries with all penetrations sealed to the fire rating required of the boundaries, licensees must perform an evaluaticn to assess the adequacy of fire boundaries in their plants to determine if the boundaries will withstand the hazards associated with the area and protect important equipment within the area from a fire otitside the area. This analysis must be performed by at least a fire protection engineer and, if required, a systems engineer. Al-though not required, licensees may submit their evaluations for staff review and concurrence. In any event, these analyses must be retained by the licen-sees for subsequent NRC audits.
- 5. Automatic Detection and Suppression Sections III.G.2.b and III.G.2.c of AppencMx R state that "In addition, fire detectors and an automatic fire suppression system shall be installed in the fire area..." Other provisions of Appendix R also use the phrase " fire detectors and an automatic fire suppression system in the fire area..."
(see e.g.,Section III.G.2.e).
In order to comply with these provisions, suppression and detection sufficient to protect against the hazards of the area must be installed. In this regard, de'tection and suppression providing less than full area coverage may be adequate to comply with the regulation. Where full area suppression and -
detection is not installed, licensees must perform an evaluation to assess the adequacy of partial suppression and detection to protect against the hazards in the area. The evaluation must be performed by a fire protection engineer and, if required, a' systems engineer. Although not requided,
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-3 licensees may submit their evaluations to the staff for review and concur-rence. In any event, the evaluations must be retained for subsequent NRC audits. Where a licensee is providing no suppression or detection,'an' ex-emption must be requested.
- 6. Alternative or Dedicated Shutdown Section III.G.3 of Appendix R provides for " alternative or dedicated shutdown capability and its associated circuits independent of cables, systems or components in the area, room, or zone u,nder consideration." While "in-dependence" is clearly achieved where alternative shutdown equipment is out-side the fire area under consideration, this is not intended to imply that alternative shutdown equipment in the same fire area but independent of the room or the zone cannot result in compliance with the regulation. The " room" concept must be justified by submission of a detailed fire hazards analysis that demonstrates a single fire will not disable both normal shutdown equip-ment and the alternative shutdown capability.
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,<.'*, A ENCLOSURE 4 8
GUIDANCE FOR ENF' ORCEMENT ACTIONS CONCERNING~
FIRE PRDTECTION REQUIREMENTS
- 1. General _ Guidance A7 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 License Conditions, facility technical specification.S and other legally binding requirements, as applicable. A Notice of Violation will be issued for violation of requirements. How-ever, failure to meet fire protection c6nnitments other than re-quirements will be designated as deviations.
B. Failures to meet regulatory requirements for protecting trains of equipment required for achieving and maintaining safe hot or cold shutdown are serious violations. The specific violations should be reviewed individually and as a group to deterniine their rootcause(s). This guidance gives examples of violations at various severity levels and should be used to determine the appropriate enforcement action. For purposes of this guidance, required structures, systems, and components are those'which are necessary to achieve and maintain hot and/or cold shutdown and which require the application of fire protection features as described in the licensee's fire hazards analysis report and NRC's safety evaluation report.
C. Fire protection violations may involve inoperable or inadequate:
fire barriers, separation, suppression 6r detection systems, re-pair parts, procedures or other conditions or items required to :
prevent fires, protect safe shutdown equipment from fire and/or permit the operation of safe shutdown equipment during a fire or to restore safe shutdown equipment to service following an actual fire.
D. Numerous violations of fire protection requirements which in-dividually may be classified at lower severity levels may cumulatively be classified at a higher severity level due to inadequate implementation of the fire protection program.
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- 2. Severity Categories A. Severity I. Violations of fire protection requirements estab-listed to protect or enable operation of safe bot shutdown equip-ment concurrent with an actual fire which damages that equipment such that safe hot shutdown could not be achieved or maintained using the equipment identified in the fire hazards analyses for this purpose, l
B. Severity II. Violations of fire protection requirements established I
to protect or enable operation of safe cold shutdown equipment concurrent with an actual fire which damages that equipment such that safe cold shutdown could not have been achieved and maintained using the equipment identified in the fire hazards analyses for this purpose in accordance with the applicable requirements.
C. Severity III. Violations of fire protection requirements established to protect or enable operation of safe shutdown equipment such that a fire in the area could damage that equipment to the extent that safe hot or cold shutdown could not have been achieved and maintained using the equipment identified in the fire hazards analyses for this purpose in accordance with applicable requirements. The NRC intends to initiate enforcement action where, for a given area, compliance with Appendix R is not readily demonstrable and the licensee poes not have available a written evaluation for the area. The tenn "readilj demonstrable" includes situations where compliance is apparent by observation of the potential fire hazard and existing protective features.
D. Severity IV. Violations of one or 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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ENCLOSURE 5 g
FIRE PROTECTION LICENSE CONDITION
- 1. The licensee shall implement and maintain in effect all provisions of the approved fire protection program as described in the Final Safety Analysis Report for the facility (or as described in submittals dated--------) and as approved in the SER dated--------(and Supplements dated--------) subject to provisions 2 and 3 be1ow.
- 2. The licensee may make no change to the approved fire protection program which would significantly decrease the level of fire protection in the plant without prior approval of the Commission. To make such a change the licensee must submit an application for license amendment pursuant to 10 CFR 50.90.
- 3. The licensee may make changes to features of the approved fire pro-tection program which do not significantly decrease the level of fire protection without prior Commission approval provided (a) such changes do not otherwise involve a change in a license condition or technical specification or result in an unreviewed safety question (see 10 CFR 50.59), and (b) such changes do not result in failure to complete the fire protection program approved by the Commission prior to license issu-ance. The licensee shall maintain, in an auditable form, a current record of all such changes, including an analysis of the effects of the change on the fire protection program, and shall make such records avail-able to NRC inspectors upon request. All changes to the approved program shall be reported annually to the Director of the Office of Nuclear Reactor Regulation, along with the FSAR revisions required by 10 CFR 50.71(e).
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ENCLOSURE 6 J
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APPENDIX R QUESTIONS AND ANSWERS t
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APPENDIX R QUESTIONS AND ANSWERS
- 1. INTRODUCTION
- 2. OVERVIEW
- 3. III G, FIRE PROTECTION OF SAFE SHUTDOWN CAPABILITY 3.1 Fire Area Boundaries 3.1.1 Fire Area Definition 3.1.2 Previously Accepted Fire Area Boundaries 3.1.3 Exterior Walls 3.1.4 Exterior Yards 3.1.5 Fire Zones 3.1.6 Documentation 3.2 Fire Barrier Qualifications 3.2.1 Acceptance Criteria 3.2.2 Deviations from Tested Configurations 3.2.3 Fire Door Modifications 3.3 Structural Steel 3.3.1 NFPA Approaches 3.3.2 Previously Accepted Structural Steel 3.3.3 Seismic Supports 3.3.4 '
- E;.: Tr2y S. pcrt Pio:cc; ion 3.4 Automatic S;ppression System 3.4.1 Water Density 3.4.2 NRC Consultation 3;4.3 Sprinkler Location 3.4.4 Fixed Suppression System In Fire Area 3.4.5 Sprinkler Head Location -
. 3.4.6 Previously Approved Suppression Systems 3.5 Separation of Redundant Circuits 3.5.1 Twenty-Foot Separation Criteria 3.5.2 Floor-to-Floor Separation 3.6 Intervening Combustibles 3.6.1 Negligible Quantities.of Intervening Combustibles 3.6.2 In Situ Exposed Combustibles 3.6.3 Unexposed Combustibles APPENDIX R QUESTIONS & ANSWERS 1 l
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3.7 Radiant Energy Shields 3.7.1 Fire Rating 3.8 Besign-Bases 3.8.1 '
3.8.2 Fire Protection Features NFPA Conformance Design Basis Fire 3.8.3 Redundant Trains / Alt'rnate e Shutdown 3.8.4 Control Room Fire Considerations
- 4. III J, EMERGENCY LIGHTING 4.1 Illumination Levels 5.
III L, ALTERNATIVE AND DEDICATED SHUTDOWN CAPABILITY 5.1 Safe and Alternative Shutdown 5.1.1 5.1.2 Previously Accepted Alternative Shutdown Capability 5.1. 3 Pre-Existing Alternative Shutdown Capability III L Backfit 5.2 Procedures 5.2.1 Shutdown and Repair Basis 5.2.2 Post Fire Operating Procedures 5.2.3 Alternative Shutdown Capability 5.2.4 Post Fire Procedures Guidance Documents 5.3 Safe Shutdown and Fire Damage 5.3.1 Circuit Failure Modes 5.3.2 " Hot Short" Duration 5.^.3 H:'. E ;tdc.. C r::i:n 5.3.4 Cooldown Equipment 5.3.5 Pressurizer Heaters 5.3.6 Dr.-Site Power 5.3.7 Torus Level Indication 5.3.8 5.3.9 Short Circuit Coordination Studies Diagnostic Instrumentation
-5.3.10 Design Basis Plant Transients 5.3.11 Alternate / Dedicated Shutdown vs. Remote Shutdown Systems 6.
III 0, OIL COLLECTION SYSTEMS FOR REACTOR COOLANT PUMP 6.1 Lube Oil System Seismic Design 6.2 Container ,
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BRANCH _ TECHNICAL POSITION CMEB 9.5-1 7.1 Fire Protection and Seismic Events 7.2 Random Fire and Seismic Events APPENDIX R QUESTIONS & ANSWERS 2
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- 8. LICENSING POLICY 8.1
- 8. 2 Fire Hazards Analysis / Fire Protection Plan Updating
- 8. 3 Fire Protection License Condition IJI G. J and 0 Exemptions for Future Modifications 8.4 Future Changes
- 8. 5 Schedular and Blanket Exemptions
- 8. 6 Trivial. Deviations
- 8. 7 Revised Modifica'tions E.8 Smallest Opening in a Fire Barrier
- 6. 9 NFPA Code Deviations 8.10 " ASTM E-119" Design Basis Fire E.11 Plants Licensed After January 1, 1979 8.12 Cold Shutdown Equipment Availability 8.13 Guidance Documents 8.14 Deviations from Guidonce Documents 8.15 Staff Interpretations of Appendix R 8.16 Dissemination 8.17 Equivalent of New Staff Positions Al'ternatives 8.18 Coordination Study Updates 8.19 Exemption Request Threshold 8.19.1 Penetration Designs Not Laboratory Approved 8.19.2 Individual vs. Package Exemptions 8.19.3 Exemption Request Supporting. Detail 8.19.4 50.12 vs. 50.48 Exemption Requests 8.20 Post January 1, 1979 Plants and Exemption Requests E.21 NRC Approval for BTP CMEB 9.5-1 Deviations
- 9. INSPECTION POLICY 9.1 Safety Implications 9.
- ' 2 Uniform Enforcement
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Future TI 2515/62 Revisions E.E tocumentation Supplied by Licensee L5 Suoseguent Inspections 9.7 WRC List of Conforming Items
- 9. 6 Inspection Re review 9.9 List of Shutdown Equipment L
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APPENDIX R QUESTIONS & ANSWERS 3'
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- 1. INTRODyCTION .
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- e" A major fire damaging safe shutdown equipment occurred at' the Brcwns' Ferry I Nuclear Station in. March 1975. The fire damaged over 1600 electrical cables and caused the temporary unavailability of some core cooling systems. Because this fire did substantial damage, the NRC established a Special Review Group which initiated grams at all nucluiran etaluation of the need for improving the fire protection pro-power plants.
regarding fire protection at Browns Fer;ry, and its rept t,The group found serio "Recocmendations Related to Browns Ferry Cire" (NUREG-0050, February 1976), contained over fifty recommendations ing facilities. regarding improvements in fire prevention and control in exist-The report also called for the' development.of specific guidance
-for implementing fire protection regulatiocs, and for. a comparison of that guid-ance with the fire protection program at each operating plant.
NRC developed technical gUidanceJfrom the technical recommendations in the Special Group's report;'and issued those guide' lines as Branch Technical Position Auxiliady Power Conversion Systems Branch 9.5-l'(BTP APCSB 9.5-1),!/ " Guidelines for Fireoperating plants Protection for Nuclear.
it that' time. Power Plants." This' guidance cid not apply to Guidance to operating plants was provided later in Appendix BTP APCSB 9.5-1. A 2/ to'B7P APCSB 9.5-1 which, to the extent practicable, relies on The gui~ dance in these documents was also published for public comment (June 1976). as Regulatory Guide 1.120, " Fire Protection for Nuclear Power Plants" revised 1 version of Regulatory Guide 1.120 for f urther public co R In May 1976, the NRC asked licensees to compare operating reactors with BTP APCSB 9.5-1, and in September 1976, those licensees were informed that the guidelines in each plant in area.
Appendix A would be used to analyze the consequences of a fire Inf$eptember 1976 the licensees, were.also requested to t evide anc
^
snowatnat:
fire hazards Enslysis that. divided the plaat into distinct fire ? ea<
are adeouately protected against damage by a fire. redundant systems tequire Early in 1977 each licensee resp:rded Analysis. with a Fica Orotection Program E.aluation which i.. iudad a Fire Hazard These evaluations and analyses identified aspects of licensees' fire protection programs that did not conform to the NRC guidelines.
1/Ratherthan[ehvingasinflexible,.legalrequirementsthatmustbefollowed by licensees, issuances such as r'egulatory guides and branch technical posi-tions are n.eant to give guidance to licensees concerning those methods-the NRC's rules. staff finds acceptable for impl.ementing the' general criteria embodied in the 7 NRC 400, 406 (1978);See, e.g., Petition for Emergency & Remedial Action, CLI-Units 1 and 2) ALAB:444, 6 NRC"760, 772 (1977). Gulf States Utilities Com 2/July Guidelines 1, 1976. for Fire Protection for Nuclear Powere Plants r or to Docket d P i
'APPEEDIX R QUESTIONS & ANSWERS 1-
~ w % ~ w
. '. s . .,
'at a Thereafter,'the staff initiated discussions with all licensees aimed'at achieving implementation of fire protection guidelines by October 1980. The staff held many meetings with licensees, visited every operating reactor. conducted extensive correspondence with them, and As a result, many fire protection items were resolved, Reports and-agreements issued by the NRC. were included in Fire Protection' Safety Evaluation with a number of licensees. Several fire protection issues remained unresolved.
By early A.
Appendix 1980, most operating plants had implemented most of the guidelines in However, as the Commission noted in its Order of May 23, 1980, the tion. fire protection program has had some significant problems with implementa-disagreement with, and refused to adopt recommendations rel generic issues, including the requirements for fire brigade size and training, water supplies for fire suppression systems, alternate and dedicated shutdown capability, emergency lighting, qualifications of seals used to enclose places where cables penetrated pump lubrication system fires.fire barriers, and the prevention of reactor coolant To establish a definitive resolution of these dix A to the BTP and to assure timely compliance by licensee issued a proposed fire protection rule and its Appendix R, which was described as setting out minimum fire protection requirements for the unresolved issues (45 Fed. Reg. 36082 May 29, 1980).3/ The fire protection features addressed included protection of safe shutdown capability, emergency lighting, fire bar-riers, associated nate shutdown circuits, reactor coolant pump lubrication system, and alter-systems.
The Commission stated that it expected all modifications (except for November alternate 1, 1980 1/ and dedicated shutdown capability) to be implemented by -
As originally proposed (Federal Register Vol. 45 No. 1&5, May 22, 1980),
Appendix R would have applied to all plants including those for which the staff had previously accepted other fire protection modifications. After analyzing comments on the rule, the Commission determined that only three of the fifteen items s'1 in Appendix R were of such safety significance ths.t they should apply to
+ts.
been approved inc1 Ming tHse by previously forthe which staff.alternative fire p etecticn acticos hcd These items are protection of safe shutdc.:r.
r" t t cacability (including alternate shutdown systems), emergency lighting, reactor cociar.t pump lubrication system. Accordingly, the final rule required all reactors licensed to operate before January 1, 1979, to comply with these three items even if the NRC had previously approved alternative fire protection features in these areas (45 Fed. Reg. 76602 Nov.~19, 1980).
the final rule is more flexible than the proposed rule because Item III.G nowHowever, provides three alternative fire protection features which do not require anal-ysis to demonstrate the protection of redundant safe shutdown equipment, and reduces fifty feetthe acceptable to twenty feet.distance in the physical separation alternative from tion procedure which can be initiated by a licensee's assertion tha required fire prot.ection feature will not enhance fire protection safety in the facility or that such modifications may be detrimental to overall safety (10 CFR 50.48(c)(6)). If the Director, Nuclear Reactor Regulation determines 3/11NRC707,718(1980) j/Id. at 719 APPENDIX R QUESTIONS & ANSWERS 2
'. s 4
4 *
- that a licensee has made a prima facie showing of a sound technical basis for such an assertion, then the implementation dates of the rule are tolled until
, final Commission action on the exemption request.
Most licensees requested and were granted additional time to perform their reanalysis, propose modifications to improve post fire shutdown capability and to identify exemptions for certain fire protection configurations. In reviewing some exemption requests, the staff noted that some licensees had made signifi-cantly different interpretations of certain requirements. These differences were identified in the staff's draft SER's. These differences were also dis-cussed on several occasions with the cognizant licensee as well as the Nuclear Utility Fire Protection Group.
of generic letter 83-33. These discussions culminated in the issuance
- 2. OVERVIEW Section 50.48 Fire Protection of 10 CFR Part 50 requires that each operating nuclear power Criterion plant have 3 of Appendix A toa10 fire protection CFR 50. It plan that satisfies General Design specifies what should be contained in such a plan and lists the basic fire protection guidelines for this plan.
It requires that the Fire Protection Safety Evaluation Report which has been issuedfacility.
each for each operating plant state how these guidelines were applied to Section 50.48 also requires that all plants with operating licenses prior to January 1, 1979 satisfy the requirements of Section III.G, III.J and III.0, and other Sections of Appendix R where approval of similar features had not been obtained prior to the effective date of Appendix R. By a separate action, the Commission approved the staff's requirement that all plants to receive their operating license after January 1,1979 also satisfy the requirements of S Sections established.III.G, III.J and 111.0 and that a fire protection license condition be Deviations from Appendix R requirements for pre-1979 plants are processed under the exemption process. Deviation from other guidelines are identified and evaluated in the Safety Evaluation Report.
A standard fire protection license condition has been developed and will be included in each new operating license. Present operating licenses will be a erded tc include the standard license ccadition.
The R.egions initiated inspections of operating plants and identified several significant items of non-compliance. The Nuclear Utility Fire Protection Group requested interpretations of certain Appendix R requirements and provided a list of questions that they thought should be discussed with the industry.
The NRC held workshops in each Region to assist the industry in understanding the NRC's requirements and to improve the Staff's understanding of the industry's concerns.
This document presents the NRC's response to the questions posed by the industry and supplemented of interest _to the with additional industry or thequestions staff. identified at the workshops as being ance for design, review and inspection activities.These responses The questionsmay havebe used as guid-been reformatted according to their applicability to Sections of. Appendix R, BTP CMEB 9.5-1, licensing policy or inspection policy.
I l
APPENDIX R QUESTIONS & ANSWERS 3
. '. s 3.
SECTION-III.G, FIRE PROTECTION OF SAFE SHUTOOWN CAPABILITY 3.1 Fire Area Boundaries 3.1.1 Fire Area Definition i
OUESTION Section III.G states the fire protection features required for cables and equipment or redundant trains of systems required to achieve and maintain hot shutdcen that are located within the same fire area. Is the fire area of Section III.G, the same fire area referred to in BTP APCSB 9.5-1, Appendix A; and the supplementary guidance of September 1976?
RESPONSE
The definition of a fire area given in the BTP is somewhat more restrictive than that given in Section #4 of the " Interpretations of Appendix R."
where a licensee has reviewed its facility using the BTP criteria, this wouldClearly, meet Appendix R requirements.
The BTP criteria may continue to be used as guidance, but the minimum requirements for fire area boundaries are set out in Section #4 of the " Interpretations."
3.1.2 Previously Accepted Fire Area Boundaries-OUESTION If a fire area boundary was described as a rated barrier in t.he 1977 fire hazards analysis, no open items existed in this area in the Appendix A SER, and the barriers have not been altered, then need those barriers be reviewed by licensees or the Staff under Appendix R?
(
RESPONSE
If a fire area
..a..:.., boundary was described as a rated barrier in the 1977 fire hazards sac was eva^.oatea ano accepted in a pubiisned SER, tne fire area boun-dary tic, III.G ofnot need be reviewed Appendix R. as part of the re analysis for compliance with Sec-Openings in the fire barriert, if any, should have been specifically identified formed in the Appendix A process. and justified in the fire hazards analysis per-If openings in the fire area boundaries were not previously evaluated, such an evaluation should be performed as a basis for asses' sing compliance with Appendix R.
tions of Appendix R," and the response to question 3.1.1.See Items #4 and #6 of the "I In BTP APCSB 9.5-1, Fire Barrier is defined as:
" Fire Barrier - those components of construction (walls , floors, and roofs) that prevent are the rated by approving spread of fire. laboratories in hours-for resistance to fire to i
The term " fire area" as used in Appendix R means an area sufficiently bounded to withstand the hazards associated with the fire area and, as necessary, to protect important equipment within the fire area from a fire outside the area.
In order to meet the regulation, fire area boundaries need not be completely APPENDIX R QUESTIONS & ANSWERS 4
.. s, sealed with floor to ceiling and/or wall-to wall boundaries.
Where fire area boundaries were not approved under the Appendix A process, or where such bound-aries are not wall-to-wall or floor-to-ceiling boundaries with all penetrations sealed to the fire rating required of the boundaries, licensees must perform an evaluation,to assess the adequacy of fire area boundaries in their plants to determine if the boundaries will withstand the hazards as.sociated with th and protect important equipment'within the area from a fire outside the area.
This analysis required, must engineer.
a systems be performed by at least a fire protection engineer and, if Although not re evaluations for Staff review and concurrence. quired, licensees may submit their In any event, these analyses must be retained by tne licensees for subsequent NRC audits.
3.1. 3 Exterior Walls OUESTION Mest exterior walls to buildings and their p,enetrations be qualified as rated barriers?
RESPONSE
Exterior walls and their penetrations should be qualified as rated barriers when (1) they are required to separate a shutdown related division (s) inside the plant from its redundant (alternate) counterpart outside the plant in the immediate vicinity of the exterior wall, (2) they separate safety related areas from non-safety related areas that present a significant fire threat to the safety FSAR or FHA.related areas, or (3) they are designated as a fire barrier in the 3
Usually are exterior evaluated by thewalls are designated guidelines of AppendixasA.a fire area boundary; therefore, they A FHA should be performed to determine the rating of exterior walls, if required by the above criteria .
3.1.4 Exterior Yards OuESTION yards? SPccid a utility define the boundaries of fire areas ccmprising exterior
RESPONSE
An area. exterior yard area without fire barriers should be considered as one fire The area may consist of several fire zones.
zones should be determined by a FHA. The boundaries of the fire The protection for redundant / alternate shutdown systems within a yard area would be determined on the bases of the largest " design basis fire" (see response to question 3.8.2) that is likely to occur and the resulting damage. The boundaries of such damage would have to be justified with a fire hazards analysis. The analysis should consider the' degree of spatial separation between divisions; the presence of in-situ and transient combustibles, including vehicular traffic; and criticality of the shutdown related systems. grading; available fire See Sections #3, #4 and #6 of the " Interpretations of Appendix R."
APPENDIX R QUESTIONS & ANSWERS 5
3.1.5 Fire lones QUESTION Appendix R,Section III.G.3 states " alternative or dedicate'd shutdown capability and its associated circuits, independent of cables, systems or components in the area room or zone under consideration...." What is the implied utilization of a room or zone concept under Section III.G of Appendix R? The use of the phraseology " area, room or zone under consideration" is used again at the end of the Section III.G.3. Does the requirement for detection and fixed suppres-sion indicate that the requirement can be limited to a fire zone rather than throughout a fire area? Under what conditions and with what caveats can the fire zone concept be utilized in demonstrating conformance to Appendix R?
RESPONSE
Section III.G was written after NRC's multi-discipline review teams had visited all operating power plants. From these audits, the NRC recognized that it is not practical and may be impossible to subdivide some portions of an operating plant into fire areas. In addition, the NRC recognized that in some cases where fire areas are designated, it may not be possible to provide alternate shutdown capability independent of the fire area and, therefore, would have to be evaluated on the basis of fire zones within the fire area. The NRC also recognized that because some licensees had not yet performed a safe shutdown analysis, these analyses may identify new unique configurations.
To cover the large variation of possible configurations, the requirements of Section III.G were presented in three parts:
Section III.G.1 requires one train of hot shutdown systems be free of fire damage and damage to cold shutdown systems be limited.
Section III.G.2 provides certain separation, suppression and detection requirements within fire areas; where sJch requirements are met, analysis is ont necessary.
Section III.G.3 requires alternative dedicated shutdown capability for configurations that do not satisfy the requirements of III.G.2 or where fire suppressants released as a result of fire fighting, rupture of the system or inadvertent operation of the system may damage redundant equip-ment.
If alternate shutdown is provided on the basis of rooms or zones, the provision of fire detection and fixed suppression is only required in the room or zone under consideration.
Section III.G recognizes that the need for alternate or dedicated shutdown capability may have to be considered on the basis of a fire area, a room or a fire zone. The alternative or dedicated capability should be independent of the fire area wher,e it is possible to do so (See Supplementary Information for the final rule Section III.G). When fire areas are not designated or where it is not possible to have the alternative or dedicated capability independent of the fire area, careful consideration must be given to the selection and location of the alternative or dedicated shutdown capability to assure that the performance
~
requirement set forth in Section III.G.1 is met. Where alternate or dedicated shutdown is provided for a room or zone, the capability must Le physically and APPENDIX R QUESTIONS & ANSWERS 6
electrically independent of that room or zone.
The vulnerability of the equip-ment and personnel required at the location of the alta'rnative or dedicated shutdown capability to the environments produced at that location as a result -
of the fire or fire suppressant's m.ust be evaluated. These environments may be due to ther hot layer, smoke, drifting suppressants, common ventilation systems, common drain systems or flooding. In addition, other interactions between the locations may be possible in unique configurations. '
If alternate shutdown is provided on the basis of rooms or zones, the provision' of fire detection and fixed suppression is only required in the room or zone under consideration. Compliance with Section III.G.2 cannot be based on rooms or zones.
See also Sections #5 and #6 of the " Interpretations of Appendix R." ;
3.1.6 Documentation QUESTION In Generic Letter 83-33 at pg. 2, the NRC Staff referred to the guidance in Appendix A to BTP 9.5-1 to establish the rating of the barrier. What level of documentation ments of Appendixmust R? be provided to verify that the fire area meets the require-
RESPONSE
The documentation required to verify the rating of a fire barrier should in-clude its firethe design description of the barrier and the test reports that ve'rify rating. Reference can be made to UL listed designs.
3.2 Fire Barrier Qualification 3.2.1 Acceptance Criteria
- 9. 'E S TI0':
Recently ce ni the Staff has applied a 325 F cold side temperature criterion to its tray wraps. of the acceptability of one-hour and three-hour fire barrier cable vation Appendix A as an acceptance criterion for fire barrier cable tray not contained in Appendix R.
It appears to represent post-Appendix R guidance.
What is the origin of this criterion and why is it applicable to electrical cables where insulation degradation does not begin until jacket temperatures reach 450 F to 650 F?
RESPONSE
Fire barriers relied upon to protect shutdown related systems to meet the re-quirements of III.G.2 need to have a fire rating of either one or three hours.
S 50.48 references BTP APCSB 9.5-1, where the fire protection definitions are found. Fire rating is defined:
" Fire Rating - the endurance period of a fire barrier or structure; it defines i i
the period of resistance to a standard fire exposure before the first critical point in behavior is observe.d (see NFPA 251)."
APPENDIX R QUESTIONS & ANSWERS "7 e
- o. . '.. ..
The acceptance criteria contained in Chapter 7 of NFPA 251, " Standard Methods of fireFire Tests of Building Construction and Materials," pertains to non-bearing barriers. These criteria stipulate that transmission of heat through the barrier "shall not have been such as to raise the temperature on its unexposed surface mone than 250 F above its initial temperature." The ambient air tem-perature at the beginning of a fire test usually is between 50 F and 90*F. It is generally recognized that 75 F represents an acceptable norm. The resulting 325 F cold side temperature criterion is used for cable tray wraps because they perform the fire barrier function to preserve the cables fr:e of fire damage.
It is at 325clear F. that cable that begins to degrade at 450*F is free of fire damage During the Appendix A review, licensees began to propose fire barriers to enclose cable trays, conduit, fuel lines, coolant lines, etc. Industry did notbus or have standard duct rating tests for such components or for electrical, piping penetrations. The NRC issued a staff position giving acceptance criteria for electrical penetration tests. These criteria require an analysis of any temperature on the unexposed side of the barrier in excess of 325 F.
In the past, manufacturers designed their own qualification tests. Nuclear Insurers, and the Institute of Electrical and Electronic Engineers have issued tests for some of these components. These tests usually exposed the component to the ASTM E-119 time temperature curve, but all had different acceptance criteria.
Conduit and cable tray enclosure materials accepted by the NRC as 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> barrier prior to Appendix R (e.g. some Kaowool and 3M materials) and already installed by the licensee need not be replaced even though they may not have met the 325*F criteria. However, for newly identified conduit and cable trays requiring such wrapping new material which meets the 325 F crite-rion should be used, or justification should be provided for use of material which does not meet the 325 F criterion. This may be based on an analysis demonstrating that the maximum recorded temperature is sufficiently below the 4 cable insulation ignition temperature.
3.2.2 Deviations from Tested Configurations m e-~y Due to cbstructions and supports, it is often impossible to achieve exact dupli-c...:,:.;,f the specific tested configuration of the one-hour fire barriers whicn are to be placed around either conduits or cable trays. For each specific in-stance where exact replication of a previously tested configuration is not and cannot a be achieved, is an exemption necessary in order to avoid a citation for violation?
RESPONSE '
No.
Where exact replication of a tested configuration cannot be achieved, the field installation should meet all.of the following criteria:
- 1. The continuity of the fire barrier material is maintained.
2.
The thi~ckness of the barrier is maintained.
3.
The nature of the support assembly is unchanged from the tested configuration.
APPENDIX R QUESTIONS & ANSWERS 8
4.
The application or "end use" of the fire barrier is unchanged from the tested configuration. For example,-the use of a cable tray barrier to protect a cable tray which differs in configuration from those that were tested would be acceptable. However, the use of structural steel fire proofigg to protect a cable tray assembly may not be acceptabls.
5.
The configuration has been reviewed by a qualified f' ire protection engineer and found to provide an equivalent level of protection.
3.2.3 Fire Door Modifications QUESTION Where labeled and rated fire doors have been modified to incorporate security hardware or for flooding protection, is an exemption from Appendix R required?
RESPONSE
Where a door is part of a fire area boundary, and the modification does not effect the fire rating (for example, installation of security " contacts"), no further analysis need be performed.
If the modifications could reduce the ;
fire rating (for example, installation a vision panel), the fire rating of the door should be reassessed to ensure that it continues to provide adequate mar-gin considering the fire loading on both sides. Since this reassessment per-tains required.to the establishment of a valid fire area boundary, an exemption is not See Section #4 of the " Interpretations of Appendix R." i 3.3 Structural Steel i
3.3.1 NFPA Approaches l QUESTION Does the NRC's definition of structural steel supporting fire barriers com-c'eteb i
secommodate arrecaches desc*ibed in NFPA gu dance d:ct e-t3 i
and st ndarcs? ;
RESPONSE l The NRC d-5s not define the structural steel supporting fire barriers. This steel is identified by the licensee. Our position regarding the need to protect the s,tructural steel, which forms a part of or supports fire barriers, is con-sistent with sound fire protection engineering principles as delineated in both NFPA codes and standards, and The Fire Protection Handbook.
3.3.2 Previously Accepted Structural Steel QUESTION Is it necessary to protect structural steel in exisitng fire barriers where those barriers were approved in an Appendix A SER?
l
RESPONSE
No.
APPENDIX R QUESTIONS & ANSWERS 9
3.3.3 Seism'ic Supports QUESTION Doesstruc}uralsteelwhosesolepurposeistocarrydynamicloadsfromaseismic event require protection in accordance with Section III.G.2a of Appendix R?
RESPONSE
No, unless the failure of any structural steel member due to a fire could result in significant degradation of the fire barrier. Then it must be protected.
3.3.4 Cable Tray Support Protection QUESTION Should cable tray supports be protected if there is a sprinkler system in the fire area? Under what conditions may cable tray supports be unprotected? Do unprotected supports require an exemption?
RESPONSE
In is ageneral, cable sprinkler tray supports should be protected, regardless of whether there system.
However, they need not be protected if (1) the qualifi-cation tests were performed on wrapped cable trays with unprotected supports, and the supports are shown to be adequate, or (2) an analysis is performed, which takes into account the fire loading and automatic suppression available in the area, and which demon-strates that the unprotected support (s) will not fail and cause a loss of the cable tray fire barrier required for the postulated fire.
An exemption is not required; however, the qualification tests and applicability or the structural evaluation should be documented and available for audit.
o: ; *- :t c i o-- -c;:ic, svetg-3.4.1 Water Density QUESTION Staff guidance provided in Generic Letter 83-33 concerning automatic suppression coverage of fire areas interprets the phrase "in the fire area" in Section III.G as meaning "throughout the fire area."
What delivered wat,er density or occupancy
. standard as specified in NFP/-STD-13 must be achieved to meet this guidance?
RESPONSE
Individual plant areas are diverse in nature. The designer should determine the particular water density or occupancy classification. Those areas which contain a limited quantity of in-situ and anticipated transient combustibles and which feature contents such as tanks and piping, may be considered as
" Ordinary Hazard (Group 1)," as defined by NFPA Standard No.13. For those areas containing large amounts of cables or flammable. liquids, an occupancy classification of " Extra Hazard" may be warranted.
The decision as to which APPENDIX R QUESTIONS & ANSWERS 10
~ . .
a, s classification should be applied should be made by a qualified fire protection engineer.
Once the o'ccupancy classification is determined, the minimum water density should be based on the Density Curves in table 2.2.1(8) of NFPA 13. Any den-sity equal to or in excess of the curves would be in conformance with our guidelines as delineated in Section C.6.c of BTP CMEB 9.5-1.
3.4.2 NRC Consultation QUESTION Section 4.1.2 of NFPA-STD-13 allcws for " partial installations" or partial coverage. The standard states that "the authority having jurisdiction shall be consulted in each case." With the NRC as authority in this instance, must consultation occur only through the exemption process?
RESPONSE
No.
The staff is always available to consult with utility representatives and provide guidance as to the acceptability of a particular fire protection con-figuration in individual plant areas. See also Section #5 of the "Interpreta-tions of Appendix R."
3.4.3 Sprinkler Location QUESTION How does a suppression system designer know whether the term "throughout the area" means that sprinkler heads must be above or below cable trays when, in his judgment, the hazard of concern is a floor based fire?
RESPONSE
f....cr. C.S.c(3) cf E!? "EE 9.5-1 states:
"(3) Fixed water extinguishing systems should conform to requirements of appropriate standards such as NFPA-13, " Standard for the Installation of Sprinkler Systems," and NFPA-15, " Standard for Water Spray Fixed Systems"."
This question pertains to those sprinkler systems covered by NFPA-13. Chapter 4 of NFPA-13 provides guidance as to the location of sprinkler heads in relation to common obstructions. In general, to achieve complete area-wide coverage, sprinklers should be located at the ceiling, with additional sprinklers provided below significant obstructions such as wide HVAC ducts and " shielded" or solid bottom stacked cable trays. To the extent that an existing or proposed sprin-kler system design deviates from this concept, the design would have to be justified by a fire hazards analysis. See also Section #5 of the "Interpreta-tions of Appendix R."
APPENDIX R QUESTIONS & ANSWERS- 11
. - . . .. .= . - - . _ _ _ - . - . - - - - - . -
i 3.4.4 Fixed Suppr[ssion System In Fire Area i
s QUESTION Are fixed guppression systems required by Section III G.3 to be throughout the fire area, room or zone under consideration?
- RESPONSE No, but partial coverage must be properly justified and documented.
- See Item #5 of the " Interpretations of Appendix R."
i the suppression regulation. less than full area coverage may be adequate to comply with i Where full area suppression and detection is not installed, licensees must perform an evaluation to assess the adequacy and necessity of partial suppression and detection in an area. The evaluation must be performed
! by a fire protection engineer and, if required, a systems engineer. Although not required, licensees may submit their evaluations to the staff for review and ' concurrence.
NRC audits..." In any event, the evaluations must be retained for subsequent s
i 3.4.5 Sprinkler Head Location QUESTION If stacks of horizontal or vertical cable trays extend from ceiling to floor, i are sprinkler heads required (1) under the lowest horizontal trays, near the floor for vertical trays; (2) at some intermediate level between the floor and J
ceiling, and (3) at the ceiling? ,
j RESPONSE i Sprinkler heads should be located at the ceiling. Sprinkler heads at other locations may be necessary depending upon the hazard and the cumulative effect or tne costructions to the discharge of water from the sprinkler head. The sprinkler system design should meet NFPA 13.
- 3.4.6 Previously Approved Suppression Systems QUESTION Must suppression systems approved and installed under BTP APCSB 9.5-1, Appen-
. dix A be extended or altered to meet the total area requir'ements of Secticn III.G (as interpreted by the Staff) or does this " requirement" only apply to new installations?
RESPONSE
4 Suppression systems installed in connection with-Appendix A may or.may not have 4
to be extended as a result of III.G. The licensee must analyze each area where j suppression is required by III.G, and where only partial suppression has been.
j provided, determine if the coverage is adequate for the fire hazard in the area.
e The licensee may consult with the staff during this review. In any event, the i
APPENDIX R QUESTIONS & ANSWERS 12 I
- s. %
Appendix R analysis showing that the suppression provided is adequate must be retained and available for NRC audit. See also Section #5 of the "Interpreta-tions of Appendix R."
3.5 Separation of Redundant Circuits 3.5.1 Twenty-Foot Separation Criteria '
QUESTION Assuming that a licensee is utilizing the 20-foot separation for circuit protec-tion, could an exemption request be granted for a portion of the circuit that did not maintain the 20-foot minimum separation if that portion was protected by one-hour barrier until 20-foot was achieved? This barrier would not be firewall-to-firewall, and the circuit protection would not be claimed under the one-hour barrier rule.
RESPONSE
With the erection of a partial qualified one-hour rated barrier for portions of the circuits with less than 20 ft. separation, if 20 feet of horizontal separation existed between the redundant unprotected portions of the circuits without intervening combustibles or fire hazards, and if the fire area was pro-tected by automatic fire detection and suppression, compliance with Section III.G.2.b would be achieved.
These the NRC.types of configuration have to be evaluated on a case-by case basis by 3.5.2 Floor-to-Floor Separation QUESTION Where redundant circuits are separated by floor elevation but are within the same fire area due to open hatchways, stairs with regard to separation criteria? If train A etc., what is the ?RC's positicn is located twenty feet from an open hatchway on the lower elevation and train B is located ten feet from the same cpening on the next elevation, would this be considered adequate separation?
RESPONSE
If a wall or floor / ceiling assembly contains major unprotected openings such as hatchways and stairways, then plant locations on either side of such a bar-rier must be considered as part of a single fire area. Refer to Section #4 of the " Interpretations of Appendix R."
As to the example provided, if train A was separated by a cumulative horizontal distance of 20 feet from train B, with no intervening combustible materials or fire hazards, and both elevations were provided with fire detection and suppres-sion, the area would be in compliance with Section III.G.2.b.
\
APPENDIX R QUESTIONS & ANSWERS 13
- s. '. .
3.6 Interve'ning Combustibles 3.6.1 Negligible Quantities of Intervening Combustibles t
QUESTION '
Twenty feet of separation with absolutely no intervening combustibles is a rare case in most nuclear plants. What is the most acceptable method of addressing intervening combustibles? How are various utilities addressing this subject, and what would be sufficient justification to support an exemption request?
RESPONSE
If more than negligible quantities of combustible materials (such as isolated cable shouldruns) exist between redundant shutdown divisions, an exemption request be filed. [ Negligible quantity" is an admittedly judgmental criterion, and this judgment should be made by a qualified fire protection engineer and documented for later NRC audit.] Justifications for such exemptions have been based on the following factors:
1.
A relatively large horizontal spatial separation between redundant divi-sions; all cables qualified to IEEE-383.
2.
The presence of an automatic fire suppression system over the intervening combustible (such as a cable tray fire suppression system);
3.
The presence cable trays; of fire stops to inhibit fire propagation in intervening 4.
The likely fire propagation direction of burning intervening combustibles in relation to the location of the vulnerable shutdown division; 5.
The availability of compensating active and passive fire protection.
cry 'c'. e cr.ar.;;es '
the celc cer. figuration due tv modifications could be handled under 50.59. See the provisions of the license condition in the response to question 8.2.
3.6.2 In-Situ Exposed Combustibles QUESTIONS Within Appendix R,Section III.G.2.b, the phrase " twenty f.eet with no interven-ing combustible or fire hazards" is utilized.
intervening combustible?" What is the definition of "no Is the regulation focused predominantly on the absence of fixed combustibles?
RESPONSE
There is no_ specific definition of "no intervening combustible." The regulation is focused on the absence of in-situ exposed combustibles. Non combustible materials would not be considered as intervening combustibles.
In BTP CMEB 9.5-1, noncombustible material is defined as:
APPENDIX R QUESTIONS & ANSWERS 14
i -
- s. %
" Noncombustible Material a.
A material which in the form in which it is used and under the conditions anticipated, will not ignite, burn, support combustion, or release flamma-ble v4pors when subjected to fire or heat.
- b. Material having' a structural base of noncombustible Inaterial, as defined in a. , above, with a surfacing not over 1/8-inch thick that has a- flame spread rating not higher than 50 when measured using ASTM E-84 Test
" Surface Burning Characteristics of Building Materials."
In Generic Letter 83-33, we state:
" Staff Position: Section III.G.2.b requires the " separation ...with no inter-vening combustibles ..." To meet this requirement, plastic jackets and insula-tion of grouped electrical cables, including those which are coated, should be considered as intervening combustibles."
For fire protection, "no intervening combustibles" means that there is no sig-nificant quantities of in-situ materials which will ignite and burn located between redundant shutdown systems.
significance is a judgmental decision.TheAs amount of such combustibles that has with other issues, if the licensees fire protection engineer is concerned that the quantity of combustibles between shutdown divisions may not be considered insignificant by an independent reviewer, an exemption could be requested, or the staff consulted.
Transient materials are not considered as an intervening combustible; however, they must be considered as part of the overall fire hazard within an area.
Cables that are in cable trays which do not have solid sheet metal bottom, sides y
and top should also be considered as intervening combustibles.
Coated cables with a fire retardant material are also considered as intervening combustibles.
3.6.3 Unexposed Combustibles CUESTION Are u.nexposed combustibles, such as oil in sumps, closed cans, or sealed drums, or electrical cable in conduits, considered as " intervening combustibles?"
RESPONSE
Only oil in closed containers which are in accordance with NFPA 30 or electrical cables in metal conduits (or in cable trays or raceways having solid sheet metal bottom, sides and top) are not considered as intervening combustibles. In situ oil in open sumps is considered to be an intervening combustible; in situ oil in closed sumps equivalent to NFPA Standard-30 containers is not considered to be an intervening combustible.
APPENDIX R QUESTIONS & ANSWERS 15
. - _ _ _ _ _ _ _ _ _ _ _ _ _ _ ___ - _ _ N
- i. .
- a. '.
3.7 Radiant Energy Shield 3.7.1 Fire Rating QUESTION Recently, the NRC Staff indicated that non combustible radiant energy shields should be tested.against ASTM-TD-E-119 based, apparently, on the requirements of BTP CMEB 9.5-1, Rev. 3, a document issued after Appendix R was promulgated.
This new requirement would not appear to be required by Appendix R or BTP APCSB 9.5-1 Appendix A. Could the Staff clarify the requirements in this area?
RESPONSE
During the Appendix A reviews, we observed that inside some containments, there were large concentrations of cables converging at electrical penetration areas.
In some cases, where the penetrations were grouped by division, shields were placed between the divisions so that radiant energy from a fire involving the cables of one division would not degrade or ignite cables of the other divisions.
These shields also directed the convective energy from the fire away from the surviving division. These shields were usually constructed of 1/2-inch marinite board in a metal frame. Appendix R,Section III.G.f refers to these shields as "a noncombustible radiant energy shield." The guidelines in BTP CMEB 9.5-1 Section C.7.a(1)b. indicate that these shields should have a fire ratir.g of 1/2 hour. In our opinion any material with a 1/2 hour fire rating should be capable of performing the required function.
The guidelines of BTP CMEB 9.5-1 relating to a firerated radiant energy shield are being considered in our current reviews of NT0L plants. However, to the g
extent that an applicant can justify that a proposed radiant energy shield car.
achieve an equivalent level of safety, we have been accepting shields that have not been tested against the acceptance criteria of ASTM E-119.
In our Appendix R reviews, we have accepted non-fire-rated radiant energy shieles that have been der.cnstrated by fire hazards analysis to crovide an acceptable level of protection against the anticipated hazard of a localized fire within the containment. We have also accepted fire-rated metal-sheathed
" ire al insulated cables, as a radiant energy shield in specific configurations.
3.8 Design Bases 3.8.1 Fire Protection Features NFPA Conformance QUESTION Sheuld the fire protection features required by Section III.G conform to the NFPA Codes?
RESPONSE
Yes. For e2 ample,Section III G.2 requires an automatic suppression system.
Our guidelines would recommend that the system be in accordance with an NFPA Code. If deviations are made from the Code, they should be identified in the FSAR or FHA.
APPENDIX R QUESTIONS & ANSWERS 16
. 1
i, .
3.8.2 Design Basis Fire QUESTION Why fire?
isn't }he industry allowed to design to protect against a design basis
RESPONSE
Neither the industry nor the Staff has been able to develop criteria for esta-blishing design basis fire conditions for a single " design basis fire" because the in situ and potential transient combustibles vary widely in different areas of the plant.
However, the establishment of a " design basis fire" for specific fire areas or zones is a prerequisite to performance of a valid fire hazards analysis (See Appendix R Section II.B(1) and BTP CMEB 9.5-1 Sections C.b(1) and (2)).
3.8.3 Redundant Trains / Alternate Shutdown QUESTION Confusion exists as to what will be classified as an alternate shutdown system and thus what systems might be required to be protected by suppression and detection under Section III.G.3.b. For example, while we are relying upon the turbine-building condensate system for a reactor building fire and the RHR sys-tem for s turbine building fire, would one system be considered the alternative to the other. If so, would suppression and detection be required for either or both systems under III.G.3.b? An explanation of alternative shutdown needs to be advanced for all licensees.
p RESPONSE If the system is being used to provide its design function, it generally is considered redundant. If the system is being used in lieu of the preferred system because the redundant components of the preferred system does not meet tne separation criteria of Section III.G.2, the system is considered an alter-native shutdown capability. Thus, for the example above, it appears that the condensate system is providing alternative shutdown capability in lieu of sepa-rating redundant components of the RHR System. Fire detection and a fixed fire suppression system would be required in the area where separation of redundant components of the RHR system is not provided. However, in the event of a tur-bine building fire, the RHR system would be used for safe shutdown and is not considered an alternative capability. However, one train of the RHR system must be separated from the turbine building. I 3.8.4 Control Room Fire Considerations QUESTION What considerations should be taken into account in a control room fire?What is the damage that is considered? What actions can the operators take before evacuating the CR? When can the control room be considered safe after-a fire for the operator to return?
APPENDIX R QUESTIONS & ANSWERS 17 l
., 6 ,
l s, .
RESPONSE
The control room fire area contains the controls and instrumental redundant shutdown system in close proximity (i.e. usually separation is a few inches).
Because itsis possible to provide shutdown capability that is physically and electrically independent of the fire area, it is our opinion that alternative or dedicated shutdown capability and its associated circuits for the control room be independent of the cables system and components in the control room fire area.
The damage to the system in the control room for a fire that causes evacuation of the control room cannot be predicted. A bounding analysis should be made to assure that safe conditions can be maintained from outside the control room.
This analysis is dependent to the specific design. The usual assumptions are:
- 1. The reactor is tripped in the control room.
2.
Offsite power is lost as well as automatic starting of the onsite a.c.
generators and the automatic function of valves and pumps whose control circuits could be affected by a control room fire.
The analysis should demonstrate that capability exists to manually achieve safe shutdown conditions from outside the control room by restoring a.c. power i to designated pumps, assuring that valve lineups are correct, and assuming that any malfunctions of valves that permit the loss of reactor coolant can be corrected before unrestorable conditions occur.
Note that the only manual action in the control room prior to-evacuation usually given credit for is the reactor trip. For any additional control room actions deemed necessary prior to evacuation, a demonstration of the capability of per-4 forming such actions would have to be provided. Additionally, assurance would have to be provided that such actions could not be negated by subsequent spur-ious actuation sinnals resulting from the postulated fire.
A'ter the fire, the operators could return to the control room when the follow-ing conditions have been met:
1.
The fire has been extinguished and so verified by appropriate fire protec-tion personnel.
2.
The control room has been deemed habitable by appropriate fire protect. ion personnel and the shift supervisor.
3.
- Damage has been assessed and, if necessary, correctiv'e action has been taken to assure necessary safety, control and information systems are functional (some operators may assist with these tasks) and the shift supervisor has authorized return of plant control to the control room.
4.
Turnover procedures which assure an orderly transfer of control from the alternate shutdown panel to the control room has been completed.
After returning to the control room, the operators can take any actions compa-tible with the condition of the control room.
where the fire occurred would not be available. Controls in any Smoke ant' firearea (cabinet) suppressant APPENDIX R QUESTIONS & ANSWERS 18
7 U I .
I i, .
damage in other areas (cabinets) must also be assessed and corrective action
[
taken before controls in such cabinets are deemed functional. Controls in i
undamaged area (cabinets) could be operated as required. Minor modifications inside the control room may be performed to reach cold shutdown.
i i
4 EMERGENCY LIGHTING 4.1 Illumination Levels QUESTION What is the requisite intensity level for emergency lighting for egress routes and areas where shutdown functions must be performed? What are the bases for determining these levels of lighting?
RESPONSE
The level of illumination provided by emergency lighting in access routes to and in areas where shutdown functions must be performed is a level that is sufficient to enable an operator to reach that area and perform the shutdown functions. At the remote shutdown panels the illumination levels should be sufficient for control panel operators.
The bases for estimating these levels of lighting are the guidelines contained in Section 9.5.3 of the Standard Review Plan, which are based on industry standards (i.e., Illuminating Engineering Society Handbook).
Where a licensee has provided emergency lighting per Section III.J Appendix R, we would expect is adequate that the to perform the intended licenseetasks.
verify by field testing that this lighting 5.
ALTERNATIVE AND DEDICATED SHUTDOWN CAPASILITY 5.1 Safe and Alternative Shutdown 5.1.1 Previously Accepted Alternative Shutdown Capability QUESTICN As part of the Appendix A review process, some plants had committed to an alter-native system.shutdown system in the form of a remote shutdown panel or remote shutdown Footnote 2 to Appendix R describes alternative shutdown capability as being associated with " Rerouting, relocating, or modifying of existing systems."
To the extent that an existing remote shutdown system previously reviewed and approved under Appendix A to BTP 9.5-1 does not require modifications, rerouting, or relocating Appendix of existing systems, are the requirements of Section III.L of R backfit?
RESPONSE
Yes.
Existing remote shutdown capabilities previously reviewed and approved under Appendix III.G.3 of Appendix A toR.
BTP APCSB 9.5-1 do not categorically comply with Section Licensees were requested to re-analyze their plants to determine compliance with Section III.G.
If the licensee chooses to use the APPENDIX R QUESTIONS & ANSWERS 19
, 4 l
)
option of II'I.G.3 for provision of safe shutdown capability for certain areas, the criteria of Section III.L are applicable to that capability for that area.
See also the response to 5.1.3.
5.1. 2 Pre , Existing Alternative Shutdown Capability QUESTIONS Some licensees defined safe shutdown capability for purposes of analysis to Section III.G criteria as being composed of both the normal safe shutdown capability and the pre-existing redundant or remote safe shutdown capability which was previously installed as part of the Appendix A process. This defini-tion often took the form of two " safe shutdown trains" comprising (1) one of the two normal safe shutdown trains, and (2) a second safe shutdown train cepa-bility which was being provided by the pre existing remote shutdown capability.
This definitional process, which was undertaken by a number of licensees, makes a significant difference in the implementation of Appendix R. Under such a definition, doesSection III.L criteria apply when the Commission did not call out Section III.L as a backfit?
RESPONSE
The definitional process mentioned considers an alternative shutdown capability provided under the Appendix A review as a redundant shutdown capability under the Appendix R review. This definitional process is incorrect.
For the pur-pose of analysis to Section III.G.2 criteria, the safe shutdown capability is defined as one of the two normal safe shutdown trains. If the criteria of Section III.G.2 are not met, an alternative shutdown capability is required.
The alternative shutdown capability may utilize existing remote shutdown capa-bilities and must meet the criteria of Sections III.G.3 and III.L of Appendix R.
See also the response to 5.1.3.
5.1. 3 III.L Backfit Ol'F M Why dc the Staff interpretive memoranda regarding the criteria for satisfaction of Sc:tien III.L form the auditable basis for determining compliance to Appen-dix R when the Commission failed to backfit this section to all plants?
RESPONSE
Although 10 CFR 50.48(b) does not specifically include Section III.L with
- Sections III.G, J, and 0 of Appendix R as a requirement ap'plicable to all power reactors licensed prior to January 1, 1979, the Appendix, read as a whole, and ,
the Court of Appeals decision on the Appendix, Connecticut Light and Power, '
et al. v. NRC, 673 F2d. 525 (D.C. Cir., 1982), demonstrate that Section III.L :
applies to the alternative safe shutdown option under Section III.G.if and where that option is chosen by'the licensee. This does not preclude licensees )
from proposing and justifying other methods, e.g. , see Section #1, Process Moni-toring Instrumentation, of the " Interpretations of Appendix R."
APPENDIX R QUESTIONS & ANSWERS 20
- s. +.
5.2 Procedures 5.2.1 Shutdown and Repair Basis OUESTION E
With regard to the term " post-fire procedures" the Commiss' ion states that it is impossible to predict the course and extent of a fire. Given this, how does one write post-fire shutdown and repair procedures that are both symptomatic and usable to an operator?
RESPONSE
Safe shutdown capabilities including alternative shutdown capabilities are all designed for some maximum level of fire-damage (system unavailabilities, spur-ious actuations). Since the extent of the fire cannot be predicted, it seems prudent to have the post-fire shutdown procedures guide the operator from full system availability to the minimum shutdown capability. As for repair procedure, similar conditions exist. A repair procedure can be written based on the maxi-mum level of damage that is expected. This procedure would then provide shut-down capability without accurately predicting likely fire damage.
5.2.2 Post Fire Operating Procedures QUESTION Does the NRC have any requirements regarding whether post-fire operating proce-dures should be based upon fire areas, systems, or be symptom-based?
RESPONSE
i The NRC does not have requirements, nor do we propose any requirements regard-ing whether tems post-fire operating procedures should be based upon fire areas, sys-or be symptom-based.
We suggest that the post-fire shutdown capabilities designs tneir input.
be reviewed with the plant operation staff and proced. Pes '.?itten with See also responses to 5.2.1 and 5.2.3.
5.2.3 Alternative Shutdown Capability QUESTION Is it acceptable to develop post-fire operating procedures only for those areas where alternative shutdown is required? (For other areas standard, emergency operating to a singleprocedures train.) would be utilized in the presence of potential fire damage
RESPONSE
Yes.
The only requirement for post-fire operating procedures is for those areas where alternative shutdown is required. For other areas of the plant, shutdown would be achieved utilizing one of the two normal trains of shutdown system.
Shutdown in degraded modes (one train unavailable) should be covered by present operator training and abnormal and emergency operating procedures.
If the degraded modes of operation are not presently covered, we would suggest APPENDIX R QUESTIONS & ANSWERS 21
that th'e ope' ration staff of the plant determine whether additional training or procedures are needed.
5.2.4 Post Fire Procedures Guidance Documents QUESTION ,
Do any NRC Staff guidance documents exist relative to the extent, form, nature, etc. of Appendix 'R post-fire operating procedures?
RESPONSE
No.
Other than the criteria of Section III.L, no specific post-fire shutdown procedure guidance has been developed. See also responses to 5.2.1, 5.2.2 and 5.2.3.
The inspection process will be flexible in this regard as long as the licensee can show compliance with the criteria of Section III.L.
5.3 Safe Shutdown and Fire Damage 5.3.1 Circuit Failure Modes QUESTION What circuitactuation?
by spurious failure modes must be considered in identifying circuits associated
RESPONSE
Sections III.G.2 and III.L.7 of Appendix R define the circuit failure modes as hot shorts, open circuits, and shorts to ground. For consideration of spurious i actuations, all possible functional failure states must be evtluated, that is, the component could be energized or de-energized by one or more of the above failure modes. Therefore, valves could fail open or closed; pumps could fail running or not running; electrical distribution breakers could fail open or closad.
For three phase AC circuits, the probability of getting a hot short on all three phases in the proper sequence to cause spurious operation of a motor is considered involving Hi/Losufficiently low as to not require evaluation except for any cases pressure interfaces. For ungrounded DC circuits, if it can be shown that only two hot shorts of the proper polarity without groundin,g could cause spurious operation, cases involving no further Hi/Lo pressure evaluation,is necessary except for any interfaces.
5.3.2 " Hot Short" Duration QUESTION If one mode of fire damage involves a " hot short" how long does that condition exist as a result.of fire damage prior to terminating in a ground or open circuit and stopping the spurious actuation?
RESPONSE
We would postulate that a " hot short" condition exists until action has been taken to isolate the given circuit from the fire area, or other actions as APPENDIX R QUESTIONS & ANSWERS 22
n, *.
s appropriate have been taken to negate the effects bf the spurious actuation.
We do not postulate that the fire would eventually clear the " hot short."
S.3.3 Hot Shutdown Duration
- QUESTION Since hot shutdown cannot be maintained indefinitely, hot shutdown equipment needs to be prot'ected for only a limited period of time. How long must a '
plant remain in that condition in order to meet the requirement for achieving hot shutdown with a single train of equip;nent?
RESPONSE
Section III.G.1 requires that the one tra*n of systems needed to achieve and maintain hot shutdown be free of fire Camage. Thus, the systems necded are to J be completely protected from the fire regardless of tima. If the intent of the question concerns how long these systems must operate, these systems must be capable of operating until tha systems needed to achieve and maintain cold shutdown are available.
5.3.4 Cooldown Equipment QUESTION Certain equipment is r.ecessary only in the cooldown phase when the plant is neither in hot nor cold shutdown condition as defined by technical specifica-tions. Is this equipment considered hot or cold shutdown in naturc?
RE3PONSE As stated in Section III.G.1, one train of systems needed to achieve and main-tain hot shutdown conditions must be free of fire damage. Systems necessary to achieve and maintain cold shutdown can be repaired within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Thus, if this certain ecuipment necessary only in the co0ldown phase, is used to achieve cold shutdown, it can be repaired within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. It' the certain equipment is maintaining hot shutdown while repairs are being made, one train must be free of fire damage. See also Section #2 of the " Interpretations of Appendix R."
5.3.5 Pressurizer Heaters QUESTION Most PWRs do not require pressurizer heaters to maintain stable conditions. In fact, the Commission does not consider heaters to be important to safety and they are not required to meet Class IE requirements. Are they required for hot
~
shutdown under Appendix R? If yes, then how does a plant meet the separation requirements of Section III.G.2.d.e. or f without major structural alterations to the pressurizer? -
APPENDIX R QUESTIONS & ANSWERS 23
l l
RESPONSE
One trein of systems necessary to achieve and maintain hot shutdown conditions must be free of fire damage. PWR licensees have demonstrated the capability to achieve,and maintain stable hot shutdown conditions without the use of pres-surizer heaters by utilizing the charging pump and a water solid pressurizer for reactor coolant pressure control.
5.3.6 On-site power QUESTION Appendix R.Section III.L.4 States in part, "If such equipment and systems will not be capable of being powered by both on site and of f-site electrical power systems because of fire damage, an independent on-site power system shall be provided." Again, in Appendix R,Section III.L.5, the stattment is made "If such equipment and systems used prior to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> after the fire will not be i capable of being powered by both onsite and offsite electrical power systems because of fire damage, an independent onsite power system shall be provided." ,
An interpretation is needed of the meaning and the applicability of these two '
quotes relative to alternative shutdown capabilities.
PESPONSE These statements are meant to indicate that the alternative shutdown capability should be powered from an onsite power system independent (both electrically and physically) from the area under consideration. Further, if the normal emergency onsite power supplies (diesel generators) are not available because of fire damage, then a separate and independent onsite power system shall be provided. .As an example, some plants are utilizing a dedicated onsite diesel g generator or gas turbine to power instrumentation and control panels which are a part of the alternative shutdown capability.
5.3.7 Torus Level Indication 00E5 TION For EWRs, IEE Information tiotice 84-09 suggests that licensees need to have torus level indication post-fire. If an analysis shows that a level does not change significantly during any operational modes or worse case conditions, is level indication still required? Is an analysis in file adequate or is an exemption request required?
RESPONSE
- It continues to be our position that torus (suppression pool) level indication is the preferred post-fire monitoring instrumentation in order to confirm the availability of the torus (suppression pool) as a heat sink. We recognize that existing analyses' indicate that suppression pool level is not significantly changed during emergency shutdown conditions. However, we believe the operator should be able to confirm that spurious operations or other unanticipated occur-rences have not affected the torus function.
by ittelf is not considered an acceptable basis.An analysis of torus level change APPENDIX R QUESTIONS & ANSWERS 24
1
. i i
I 5.3.8 Short Circuit Coordination Studies
. OUESTION Should circuit coordination studies consider high impedance faults?
RESPONSE
~
Yes, in those coordination studies performed to assess the vulnerability of safe shutdown capability due to fires involving associated circuits. To meet the separation criteria of Section III.G.2 and III.G.3 of Appendix R, high impedance faults should be considered for all associated circuits located in the fire area of concern. Thus, simultaneous high impedance faults (below the trip point for the breaker on each individual circuit) for all associated cir-cuits located incapability.
safe shutdown the fire area should be considered in the evaluation of the Clearing such faults on associated circuits which may effect safe shutdown may be accomplished by manual breaker trips governed by written procedures. Circuit coordination studies need not be performed if it is assumed that shutdown capability will be disabled by such high impedance faults and appropriate written procedures for clearing them are provided.
5.3.9 Diagnostic Instrumentation QUESTION What is diagnostic instrumentation?
RESPONSE
)
Diagnostic instrumentation is instrumentation, beyond that previously identified in Attachment 1 to I&E Information Notice 84-09, needed to assure proper actua-tion and functioning of safe shutdovn equipment and support equipment (e.g.,
flow rate, pump cischarge pressure). The diagnostic instrumentation needed deoends on the design of the alternative shutdown capability. Diagno: tic in-strumentation, if needed, will be evaluated during the staff's review of the licensee's proposal for the alternative shutdown capability.
5.3.10 Design Basis Plant Transients QUESTION What plant transients should be conside'ed r in the design of the alternative or dedicated shutdown systems?
t
RESPONSE
{
Per the criteria of Section III.L of Appendix R a loss of offsite power shall be assumed for a fire in any fire area concurrent with the following assumptions:
- a. !
The safe shutdown capability should not be adversely affected by any one l spurious actuation or signal resulting from a fire in any plant area; and l
l APPENDIX R QUESTIONS & ANSWERS 25
., .. l b.
The safe shutdown capability should not be adversely affected by a fire in any plant area which results in the loss of all automatic function (signals, logic) from the circuits located in the area in conjunction with and one worst case spurious actuation or signal resulting from the fire; c.
The safe shutdown capability should not be adversely affected by a fire in any plant area which results in simultaneous spurious actuation of all valves in high-low pressure interface lines.
5.3.11 Alternative / Dedicated Shutdown v. Remote Shutdown Systems QUESTION What is the difference between the alternate / dedicated shutdown systems required i for fire protection and the remote shutdown systems recommended under Chapter 7 of the SRP?
I
RESPONSE
The remote shutdown systems recommended under Chapter 7 of the SRP are needed to meet GDC 19.
These remote shutdown systems need to be redundant and physi-cally independent of the control room in order to meet GDC 19. For GDC 19, damage to the control room is not considered. Alternate shutdown systems for Appendix independent R need of thenot be redundant control room. but must be both physically and electrically 6.
OIL COLLECTION SYSTEMS FOR REACTOR COOLANT PUMP 6.1 Lube Oil System Seismic Desian QUESTION If the reactor coolant pump lube oil system and associated appurtenances are ss':-ic:11, desigr.ed, does the lube oil collection system aisc require seismic design? Is an exemption required?
P.ESPGNSE Where the RCP lube oil system is capable of withstanding the safe shutdown earthquake (SSE), the analysis should assume that only random oil leaks from the joints could occur during the lifetime of the plant. The oil collection system, therefore, should be designed to safely channel the quantity of oil
- from one pump to a vented closed container.
Under this set of circumstances.
the oil collection system would not have to be seismically designed.
An exemption is required for a non-seismically designed oil collection system.
The basis for this exemption would be that random leaks are not assumed to occur simultaneously with the seismic event, since the lube oil system is designed to withstand the seismic event. However, the Rule, as written, does not make this allowance.
APPENDIX R QUESTIONS & ANSWERS 26
6.2 Cor.tainer QUESTION It would appear that a literal reading of Section III.0 regarding the oil' col-lection sydtem for the reactor coolant pump could be met by a combination of seismically designed splash shields and a sump with sufficient capacity to con-tain the entire lube oil system inventory. If the reactor coolant pump is seismically cesigned and the nearby piping hot surfaces are protected by seis-mically designed splash shields such that any spilled lube oil would contact only rule?
celd surfaces, does this design concept conform to the requirements of the
RESPONSE
If the reactor coolant pump, including the oil system, is seismically designed and the nearby hot surfaces of piping are protected by seismically designed splash shields such that any spilled lube oil would contact only cold surfaces, and it could be demonstrated by engineering analysis that sump and splash shields would be capable of preventing a fire during normal and design basis accident conditions, the safety objective of Section III.0 would be achieved.
Such a design concept would have to be evaluated under the exemption process.
The justification for the exemption should provide reasonable assurance that oil from all potential pressurized and unpressurized leakage points would be safely collected and drained to the sump. The sump should be shown capable of safely containing all of the anticipated oil leakage. The analysis should verify that there are no electric sources of ignition.
7 BRANCH TECHNICAL POSITION CMEB 9.5-1 7.1 Fire Protection and Seismic Events QUESTION r
or which situations other than the reactor coolar.t cumo lute o cystem are seismic events assumed to be initiators of a fire?
CESP0"SE The guidelines for the seismic design of fire protection systems which cover other general situations is delineated in BTP CMEB 9.5-1 C.I.C(3) and (4):
"(3) As a minimum, the fire suppression system should be capable of delivering water to man'Jal hose stations located within hose reach of areas contain-ing equipment required for safe plant shutdown following the .afe shutdown earthquake (SSE). In areas of high seismic activity, the staff will con-sider on a case-by-case basis the need to design the fire detection and suppression systems to be functional following the SSE.
(4) The fire protection systems should retain their original design capability for (a)-natural phenomena of less severity and greater frequency than the most severe natural phenomena (approximately once in 10 years) such as tornadoes, hurricanes, f'oods, ice storms, or small-intensity earthquakes I APPENDIX R QUESTIONS & ANSWERS 27 I
l
., '. w that are characteristic of the geographic region, and (b) potential man-made site-related events such as oil barge collisions or aircraft crashes that have a reasonable probability of occurring at a specific plant site.
The effects of lightning strikes should be included in the overall plant fire protection program."
We have considered California as being a high seismic activity area.
For those plants reviewed under Appendix A, our position is (A.4):
" Postulated fires or fire protectior system failures need not be considered concurrent with other plant accidents or the most severe natural phenomena."
Our guidelines on the seismic design of fire protection systems installed in safety related areas are delineated in Regulatory Guide 1.29 " Seismic Design Classification," paragraph C.2. The failure of any system should not affect a system from performing its safety function.
Our guidelines on the seismic design of hydrogen lines is delineated in BTP CMEB 9.5-1 Section C.S.d(5):
(5) Hydrogen lines in safety related areas should be either designed to seismic Class I requirements, or seleved such that the outer pipe is directly vented to the outside, or should be equipped with excess flow valves so that in case of a line break, the hydrogen concentration in the affected areas will not exceed 2%.
All PWR's have a hydrogen line going to the Volume Control Tank (Make up Tank) that needs to be protected, g
To identify plant specific situations in which seismic events could initiate a fire in a specific plant area, the fire protection engineer and systems engineer performing the fire hazards analysis should be concerned with in situ combusti-ble materials which can be released in a manner such that they could contact
-: 't; ';n' tion ::;r:13 :y seismic event. An e c ple cf ti.is wcold be'the rupture of the RCP lube oil line directly above the hot reactor coolant piping.
The fire prctection engineer should also be concerned with seismic induced lgoition 3curces, electrical or mechanical, wnich could contact nearby in-situ combustible materials.
It should be noted that the guidelines cited abo've from BTP CMEB 9.5-1 are not applicable to plants reviewed and approved under BTP APCSB 9.5-1.
. 7. 2 Random Fire and Seismic Events OVESTION Is a random fire to be postulated concurrent with a seismic event?
RESPONSE _
Our position, as stated in Section C.1.6 of BTP'CMEB 9.5-1, is " Worst case fire need not be postulated to be simultaneous with nonfire-related failures in safety systems, plant accidents, or the most' severe natural phenomena."
APPENDIX R QUESTIONS & ANSWERS 28
Where plant systems are designed to prevent the release of combustible materials caused by a seismic event, such as a dike around a fuel oil tank transformer, or
. seismic supports for hydrogen lines, then.no fire need to be arbitrarily assumed to take place in the fire hazards analysis.
t .
Because it is impossible to completely preclude the occurrence of a seismically irduced fire, Section C.6.c(4) cf CMEB 9.5-1 states:
" Provisions should,be made to supply water at least to standpipes and hose connections for manual firefighting in areas containing equipment required for safe plant shutdown in the event of a safe shutdown earth-quake.
The piping system serving such hose stations should be analyzed for SSE loading and should be provided with supports to ensure system pressure integrity. The piping and valves for the portion of hose stand-pipe system affected by this functional requirement should, as a minimum, satisfy ANSI B31.1, ' Power Piping.' The water supply for this condition may be obtained by manual operator actuation of valves in a connection to the hose standpipe header from a normal seismic Category I water sys-tem such as the essential service water system. The cross connection should be (a) capable of providing flow to at least two hose stations (approximately 75 gpm per hose station), and (b) designed to the same standards as the seismic Category I water system; it should not degrade the performance of the seismic Category I water' system."
The post-seismic procedures should include a damage survey, and a determination of whether any fires were initiated as a result of the seismic event. See also the response to Question 7.1.
It should be noted that the guidelines cited above from BTP CME 8 9.5-1 are not applicable to plants reviewed and approved under BTP APCSB 9.5-1.
e 8. LICENSING POLICY 8.1 Fire Hazard Analysis / Fire Protection Plan Updating
-. r et t ~;
'that constitutes the fire protection plan required by 50.48(a)? Should licens-tes have prcgrams to maintain the fire hazards analysis and the fire protection plan current or updated periodically? How often should the plan be updated?
Must revisions be provided to the NRC?
RESPONSE
The basic elements required in the fire protection plan are described in 10 CFR 50.48(a). The fire protection program that implements that plan should include the details of the fire hazards analysis. The plan and program may be separate or combined documents and must be kept current with the fire hazards analysis updated prior to making modifications. We would expect that for most plants licensed after January 1, 1979, the fire protection plan and program
.would be patt of the FSAR and therefore, would be updated and sumitted to the NRC in conformance with the requirements of 10 CFR 50.71(e). For plants whose fire protection plans and programs are not part of the FSAR, we would expect that they would be updated pri.or to making modifications and kept at the site in an auditable form for NRC inspection.
APPENDIX R QUESTIONS & ANSWERS 29
. -. - -. = = - .- -. . . - - ._. .- -. . - -
8.2 Fire Protecti n License Condition
{
QUESTION l What is the ' significance of the fire protection license condition? :
RESPONSE !
l
+ For.those plants licensed prior to January 1,1979 (Appendix R plants), the >
license condition is the legally enforceable requirement for the fire protection features other than those required by III.G, III.J and III.0 that were accepted by the NRC staff as satisfying the provisions of Appendix A to Branch Technical j Position BTP APCSB 9.5-1.
For those plants licensed after January 1,1979, the license condition is the legally enforceable requirement for all fire protection features at the facility.
Appendix R is only enforceable on Post 1979 plants through the license condition.
10 CFR 50.48 makes Appendix R applicable only to plants licensed prior to January 1,1979. Refer to 10 CFR 50.48(e).
The NRC has drafted new language for this license condition'which delineates the circumstances under which the fire protection plan may be revised. We are now including this language in all new licenses and are considering amending present licenses. The revised language is as follows.
"9.5 Fire Protection Program (Section 9.5, SER) a.
The licensee shall implement and maintain in effect all provisions of the approved fire protection program as described in the Final Safety Analysis Report for the facility (or as described in submittals dated )
and as approved dated in the SER (and supplements dated subject to provisions b & c below. )
b.
The licensee ma make no change to the accroved fire protection oregrae anicn would cecrease the level of fire protection in the plant without prior approval of the Commission. To make such a change the' licensee l rust submit an application for license amendment pursuant to 10 CFR 50.90.
]
l c.
i The licensee may make changes te features of the approved fire protection 1
program which do not significantly decrease the level of! fire protection
- without prior Commission approval provided (a) such changes do not other-wise involve a change in a license condition or technical specification or result in an unreviewed safety question (see 10 CFR 50.59), and (b) such changes do not result in failure to complete the fire protection program approved by the Commission prior.to license issuance. The licensee shall i maintain, in an auditable form, a current record of all such. changes in-ciuding an analysis of the effects of the change on the fire protection program, request.
and 'shall make such records available to NRC inspectors upon All changes to the approved program shall be reported annually to the-Director of the Office of Nuclear Reactor Regulation, along with the FSAR revisions required by 10 CFR 50.71(e).
I l
APPENDIX R QUESTIONS & ANSWERS 30
l
=, .
8.3 III G, J and 0 Exemptions for Future Modifications
, QUESTION Is an exemation required from Appendix R Sections other than III.G, III.J and III.0 for future modifications that do not comply with such sections?
RESPONSE
Yes, for those modifications which deviate from the previously accepted fire protection configurations. The exclusion of the applicability of Sections of Appendix R other than III.G, III.J, and III.0 is limited to those features
" accepted by the NRC staff as satisfying the provisions of Appendix A to Branch Technical Po ition BTP APCSB 9.5-1 reflected in staff fire protection safety evaluation reports issued prior to the effective date of the rule." No re-analysis is required except for proposed modifications which would alter pre-viously approved features. This position is based directly on CFR 50.48(b).
Also see response to Question 8.2.
8.4 Future Changes QUESTION Will future changes (no matter how minor) to approved configurations be required to be reviewed by the Staff in an exemption request? At what point may the process of 10 CFR 50.59 be invoked?
RESPONSE
If a future modification involves a change to a license condition or technical specification, a license amendment request must be submitted. When a modifica-a tion not involving a technical specification or license condition is planned, the evaluation made in conformance with 10 CFR 50.59 to determine whether an unreviewed safety question is invcived must include an assessment of the modi-fication's impact on the existing fire hazards analysis for the area. This 7- ' c' t"e evaluation . rust be perferned by the persor. responsible for the fire safety program for the plant. The assessment must include the effect on com-bustible loading and distribution and the consideration of whether circuits or cc.;cnents, including asociated circuits, for a train of equipment needed for safe shutdown are being affected or a new element introduced in the area. If this evaluation concludes that there is no significant impact, this conclusion and its basis must be documented as part of the 50.59 evaluation and be avail-
. able for future inspection and reference. If the evaluation finds that there is an impact that could result in the area either not being in conformance with Appendix R, or some other aspect of the approved fire protection program, or being outside the basis for an exemption that was granted for the area involved, the licensee must either make modifications to achieve conformance or justify and request exemption (or, for the~ post 1979 plants, approval) from the NRC. See also responses to Questions 8.1 and 6.2.
G 4
APPENDIX R QUESTIONS & ANSWERS 31
I o, o. !
8.5 Schedurar and Blanke't Exemptions QUESTION If an exemption is warranted and at the same time the provisions of the rule indicate t6at the appropriate schedular deadlines have passed, should a sched-uler: exemption be filed at the same time as the technical exemption request?
If as part of the exemption request the utility is proposing to make modifica-tions to achieve a reasonable level of conformance with Appendix R, and if the associated " clock" has run out for that type of modification, should the tech-nical exemption request and the description of the modification be filed with a schedular exemption?
When filing a schedular exemption under $50.12, it is not always clear from what specific paragraphs of 550.48 an exemption should be sought. Is it ac-ceptable to request a blanket exemption from the schedular provisions of 10 CFR 550.48 without a specification by paragraph?
If an exemption request is submitted to meet newly published interpretations of Appendix R, when does the licensee need to be in compliance? Is the sched-ule presented in Appendix R still the guideline or must a new schedule be developed under a different criteria?
, RESPONSE We do not intend to issue any further extensions of the 50.48(c) schedules.
When a licensee priate NRC determines Region that a 50.48(c) schedule cannot be. met, the appro-must be notified. This policy is further explained in the generic letter transmitting this package.
8.6 Trivial Deviations QUESTION anat guicance can tne NRC Staff give the industry regarding when a deviation from the literal interpretation of Appendix R is sufficiently trivial as to not require a specific exemption?
RESPONSE
The significance of a deviation must be judged as part of a fire hazards anal-ysis.
inspector. The conclusion of this analysis is always subject to review by the NRC 8.7 Revised Modifications QUESTION What with is the process Appendix R SERs? for altering configurations not yet implemented for plants APPENDIX R QUESTIONS & ANSWERS 32-
RESPONSE
If licensees propose changes to their NRC approved modifications, they must sub-mit their new proposal and revised schedule for implementation for NRC approval.
t This change must be justified as to (1) the reason for th'e change, (2) the basis for the revised schedule, and (3) the interim measures that will be pro-vided to assure post fire shutdown capability until the final modifications are implemented.
Whether or not enforcement action will be taken based upon con-tlnued noncompliance with Appendix R will be decided by the NRC Regional Administrator in consultation with NRC Headquarters.
- 8. 8 Smallest Openino in a Fire Barrier QUESTION What is the smallest opening allowed in a fire area barrier for which an exemption request is not needed?
RESPONSE
Unsealed openings in the configuration for which approval was obtained by an approved laboratory or the NRC staff would be acceptable. '
Our position on openings is given in Section 5.a(3) of BTP CMEB 9.5-1:
"(3) Openings through fire barriers for pipe, conduit, and cable trays which separate fire areas should be sealed or closed to provide a fire resistance rating at least equal to that required of the barrier itself. Openings 2 inside conduit larger than 4 inches in diameter should be sealed at the fire barrier penetration. Openings inside conduit 4 inches or less in diameter should be sealed on each side of the fire barrier and sealed either at both ends or at the fire barrier with non-combustible material 10 pre.e..t the passage cf smoke and het gases. Fire barrier penetrations that must maintain environmental isolation or pressure differentials should be qualified by test to maintain the barrier integrity under such conditions."
The u,nsealed opening (s) allowed in a fire area boundary or a. barrier which separates redundant shutdown divisions should not permit flame, radiant energy, smoke and hot gases to pass through the barrier and cause damage to redundant shutdown divisions on the other side. The licensee should assess the adequacy of existing protection and should determine the minimum size based on a fire hazards analysis and conservative fire protection engineering judgment. If the significance of openings in fire barriers is marginal, a formal exemption request could be submitted or the staff consulted. The basis for the lack of signifi-cance should be available for review by NRC Inspectors.
Our acceptance of unprotected openings in fire barriers would depend upon the
. quantity _and nature of combustible materials on either side of the barrier; the location of the opening (s) in relation to the ceiling (for openings in walls);
the location, vulnerability and importance of shutdown systems on either side of the barrier; and compensating fire protection.
APPENDIX R QUESTIONS & ANSWERS 33 I
l SeealsoSec' tion #dofthe"InterpretationsofAppendixR."
8.9 NFPA Code Deviation 00ESTION ,
Is an exemption / deviation required for deviations from NFPA Codes?
RESFONSE Deviations from the codes should be identified and justified in the FSAR or FHA.
An exemption is nnt required for NFPA codes. NRC guidelines reference certain NFPA codes as guidelines to the systems acceptable to the staff, and therefore such codes may be accorded the same status as Regulatory Guides.
When the applicant / licensee states that its design " meets the NFPA codes" or,
" meets the Intent of the NFPA Ccdes" and does not identify any deviations from such codes, NRR and the Regions expect that the design conforms to the code and the design is subject to inspection against the NFPA codes.
8.10 " ASTM E-119" Design Basis QUESTION Is an exemption / deviation required, if components are designed to withstand an
" ASTM E-119" fire?
RESPONSE
2 Some cables are being developed for high temperature (e.g., 1700*F) applications.
An exemption would be required if such cable is used in lieu of the alternatives of III.G.2 or III.G.3 in a pre-1979 plant. A deviation from the guidelines vrould to recuired for sir.ilar applications in a post 1979 p' art.
8.11 Plants Licensed After January 1, 1979 QUESTION What fire protection after January guidelines and requirements apply to the plants licensed 1, 1979?
RESPONSE ~
Post-1979 plants are subject to:
i GDC 3 1
)
10 CFR 50.48(a) and (e)
The guidelines identified in the footnotes to 50.48(a)
Guidelines documents issued after January 1,1979.
APPENDIX R QUESTIONS & ANSWERS 34
8, *O Commitments made to meet the requirements of Appendix R1 or specific sec-tions such as III.G, III.J, III.0; or Appendix A to BTP APSCB 9.5-1; or BTP CMEB 9.5-1, which includes the requirements of Appendix R* and the previous guidance documents incorporated into the Branch Technical Position.
t The license for each plant licensed after January 1,1979,contains a license condition which identifies by reference the approved fire protection program for that plant.
- A deficiency in the BTP CMEB 9.5-1 has been noted in that a requirement in Appendix R Section III.G.3.b to provide alternative or dedicated shutdown cap-ability in an area where both redundant safe shutdown trains could be damaged by suppression activities or inadvertent operation or rupture of fire suppres-sion systems is not included. This requirement will be added in the next revi-sien of the BTP.
8.12 Cold Shutdown Equipment Availability QUESTION A.
Can a licensee achieve compliance with III.G.1(b) by demonstrating that one train of cold shutdown equipment will remain free of fire damage?
B. In demonstrating that one train of cold shutdown equipment will remain free of fire damage, is a licensee limited to the three alternatives in III.G.2?
RESPONSE
A. Yes.
B. No.
8.13 Guidance Documents QUESTION Please list all NRR guicance documents and position papers issued since Appendix R was promulgated.
RESPONSE
Fire Protection Guidance Issued Since January 1,1975:
IE Information Notices i
No. 83-41: Actuation of fire suppression systems causing inoperability of )
safety related equipment.
No. 83-69: _ Improperly installed fire dampers at nuclear power plants.
No. 83-83: Use of portable radio transmitters inside nuclear power plants.
APPENDIX R QUESTIONS & ANSWERS 35 l
1
~
g a.
- No. 84-09: ' Lessons Learned From NRC Inspections of Fire Protection Safe Shutdown Systems (10 CFR 50, Appendix R) l Standard Review Plan 9.5.1', Rev.' 1 Fire Protection System, dated 5/1/76 9.5.1, Rev. 2 Fire Protection Prooram, dated 03/78 9.5.1, Rev. 3 Fire Protection Program, July 1981.
Reaulations 10 CFR Part 50:
Proposed fire protection program for nuclear power plants operating prior to January 1,1979, dated May 29, 1980. Federal Register Vol. 45, No. 105, 36082.
10 CFR Part 50:
dated November 19,Fire protection program for operating nuclear power 1980. plants, Federal Register Vol. 45, No. 225, 76602.
10 CFR Part 50:
Fire protection rule corrections, dated September 8, 1981.
Federal Register Vol. 46, No. 173, 44734.
Generic Letters NOTE:
The following documents were obtained from the Palisades file Docket No. 50-255.
ities. Similar The dates maydocuments should be in the file for other operating facil-vary slightly.
1.
Letter dated 9/28/76 - Enclosing App. A to BTP APCSB 9.5-1 and supplementary guidance on information needed for fire protection program evaluation.
2.
Letter sheet.
errata dated 12/1/76 - Enclosing sample Technical Specifications and an 3.
Letter dated 8/19/77 - Enclosing " Nuclear Plant Fire Protection Functional Responsibilities, Administrative Controls and Quality Assurance."
- 4. Letter dated 6/8/78 - Re: Manpower requirements for operating reactors.
- 5. Letter dated 9/7/79 - R'e: Minimum fire brigade shift size.
6.
Letter dated 9/14/79 - Enclosing staff positions safe shutdown capability.
- 7. Letter dated 10/31/80 -
schedules for operating nuclear power plants. Enclosing new 10 CFR 50.48
- 8. Letter dated 11/24/80 ~ Enclosing a copy of revised 10 CFR 50.~48 and new App. R to 10 'CFR 50, and a summary of open items from the SER for the BTP APCSB 9.5-1 review.
'9.
Letter dated 2/20/81 - Generic Letter 81-12 identifying information needed for NRC review of modifications for alternative shutdown capability.
APPENDIX R QUESTIONS & ANSWERS 36 gs -- "
].
t *,
10.
Letter dated 4/7/82 - Provided clarification to Generic Lette'r 81-12 and guidance on information needed for NRC review of exemption requests.
11.
Letter dated 10/6/82 - Generic Letter 82-21; provided criteria for annual, biennfal, and triennial audits required by Technical Specifications.
- 12. Letter dated 10/19/83 - Generic Letter 83-33; NRC Positions on Certain Requirements of Appendix R to 10 CFR 50.
Staff Generic Positions
- 1. Letter, Denton to Bernsen, dated 4/20/82 - Control room fires.
^2. SECY 83-269, dated July 5, 1983 - Attachments B and C.
3.
Memo, Eisenhut to Olshinski, dated 12/30/83 - Physical independence of electrical systems.
4.
Memo, Eisenhut to Jordan, dated 10/24/83 - Bullet resistant fire doors.
" Staff positions regarding the need for certain exemptions delineated in this guidance document have been revised per the " Interpretations of Appendix R".
8.14 Deviation From Guidance Documents 00ESTION If a utility determines that a deviation from a guidance document exists, does an exemption request need to be filed? If so, what is the legal basis for this requirement?
4
RESPONSE
No.
5 . _' 5 Staff Interpretation of Appendix R 00ESTION How does the Staff initiate interpretations of Appendix R in a manner which ensures their technical adequacy and consistency with the rule's objectives ,
(e.g., presentation to ACRS, issue for comment as in draft regulatory guides, etc.)?.
RESPONSE
Staff positions are initiated when our experience shows that generic issues are identified that require clarification. These positions are reviewed for accuracy and consistency by the cognizant Division Directors. Usually, they are not issued for comment. However, Generic Letter 83-33 was commented on by i
the NUFPG since it was initiated, in part, at their request.
l i
APPENDIX R QUESTIONS & ANSWERS 37 1 i
. j
g a, 8.16 Disseminatio of New Staff Positions QUESTION Will they licensees be automatically sent a copy of new Staff position papers as are developed?
RESPONSE
The Staff positions on generic subjects are considered for issuance in Generic Letters from ONRR and Information Notices or Bulletins from OI&E. Staff positions issued for specific questions on specific plants are not given generic promulgation because they normally involve plant specific design considerations.
8.17 Eouivalent Alternatives QUESTION How does a licensee demonstrate that alternative measures are equivalent to the measures of Section III.G.2 in order to obtain an exemption lacking a formal definition of the term " free of fire damage"?
RESPONSE
See Item #3 of " Interpretations of Appendix R."
8.18 Coordination Study Update i QUESTION Circuit modifications are an ongoing process.
How recent must a coordination study source?
power be in order to be valid in protecting circuits associated by common
RESPONSE
would address the electrical protection required and the effects protection system. on the coordination of the protection for the power distribution This type of consideration should be included in the evaluation required by 10 CFR 50.59 CP.anges, Tests and Experiments. The design package and modification coordination evaluation could not be complete without consideration of the study.
would be current with the last circuit modification made.Therefore, we would 8.19 Exemption Request Threshold QUESTION (a) What is the threshold for exemption requests? (b) Is it necessary' to file a request for each and every possible deviation from Appendix R?
APPENDIX R QUESTIONS & ANSWERS 38 L
l
[ -
l RESPONSE '
Typical examples are discussed in the response to Questions 8.19.1 through 8.19.4.
t (a) The licensee must develop its criteria for an exemption request threshold.
(b) No.
8.19.1 Penetration Designs Not Laboratory Approved QUESTION Where penetration designs have been reviewed and approved by NRC but have not been classified by an approval laboratory, will it be necessary to submit an exemption request?
RESPONSE
No.
8.19.2 Individual vs. Package Exemptions QUESTION How do we submit future modification exemption requests, etc.? Would NRC prefer them individually, or developed and submitted in packages for review and approval?
RESPONSE
Future exemptions should be submitted individually, if they are independent of each other.
0._'E.2 East; tion RegoEst Supporting Detail CUESTION When an exemption request is filed, what criteria are used to determine the level.of detail needed to support the request?
RESPONSE
See Enclosure 2 of NRC's letter to all licensees dated April-May 1982.
8.19.4 50.12 vs. 50.48 Exemption Requests QUESTION With regard _to exemption requests for future: modifications, will they be submitted under 50.12 or 50.48?
APPENDIX R QUESTIONS & ANSWERS 39 L _
T
RESPONSE
18.20 Post Oanuary 1, 1979 Plants and Exemption Requests QUESTION Do plants licensed after January 1,1979 which have committed to meet the '
requirements of Section III.G, III.J and III.0 and are required to do so as a license condition, need to request exemptions for alternative configurations?
RESPCNSE No; however, deviations from the requirements of Section III.G, III.J and III.0 should be identified and justified in the FSAR or FHA and the deviation would probably require a license amendment to change the license condition.
See responses 8.1 and 8.2.
8.21 NRC Approval for BTP CMEB 9.5-1 Deviations QUESTION Do future deviations from BTP CMEB 9.5-1 guidelines require approval by the NRC?
Do such deviations constitute a violation of license conditions?
RESPONSE
Compliance with guidelines in the BTP is only required to the extent that they were incorporated in the approved Fire Protection Program as identified in the license condition.
When the new license condition is in place (See Response 8.2), future deviations may be made in accordance with the procedure stated therein. With present non-
~
- 'i (rie : rditicct, such deviat';7: may cr T.a3 .st requirc a lice.ce ame r.dme nt. In the absence of a license amendment, a violation may exist.
- 9. IMSPECTION FOLICY 9.1 Safety Implications QUESTION
' Since the Commission states that fire damage cannot be defined and fire spread cannot be predicted, how does the Commission determine which Appendix R viola- ;
tions have "important safety implications?" '
RESPONSE
i III.G.2 provides alternatives to ensure that one of the redundant trains is free of fire damage. Fire spread within one area cannot be predicted, but damage is limited to one fire area.
l APPENDIX R QUESTIONS & ANSWERS 40 '
I
! 'r ,
the same fire area that are needed for safe shutdown or can adversely affect safe shutdown, approved and are not protected by the features of III.G.2, III.G.3 or an alternative.
- 9. 2 Uniform Enforcement QUESTION '
How does between the' Commission ensure that violations of the rule are uniformly treated regions?
RESPONSE
Each 10 CFRRegion evaluates 2, Appendix C. violations in accordance with the NRC Enforcement Policy, The Policy provides guidance for the determination of appropriate enforcement sanctions for violations. The Office of Inspection and Enforcement provides guidance for and monitors Regional implementation of the Policy to ensure a uniform application. In addition, the policy requires that all escalated Inspection andenforcement Enforcement. actions be approved by the Director of the Office of 9.3 NTOL Inspections QUESTION Will NT0Ls be subject to an Appendix R audit now being performed on plants licensed to operate prior to January 1, 1979? Or, will the current review and analysis being performed by the Staff be satisfactory?
RESPONSE
Yes, NT0Ls will be subject to the Appendix R audit; the TI 2515/62 is being revised to reflect the appropriate requirements for NTOLs' and it is our intent to conduct such inspections prior to issuing the operating license.
10 CFR 50.48 requires each such plant to have a fire protection plan. Their operating license will contain a specific license condition to implement their approved fire protection program which must identify deviations from Appendix R.
The fire protection inspections will be against the particular license conditions.
- 9. 4 Future TI 2515/62 Revisions QUESTION Does the NRC plan to issue a new or revised version of Temporary Instruc-tion 2515/62 for future Appendix R audits? '
RESPONSE
Yes. _
APPENDIX R QUESTIONS & ANSWERS 41
['s
- 9. 5 Documen'tation Suoplied by Licensee QUESTION Temporary }nstruction 2515/62 needs to review as part of the audit process.provided a list of documentation that the N In past audits, the NRC has requested additional information other than that contained on the list. Will a new list of documentation be developed?
RESPONSE
The documentation listing Provided in TI-2515/62 does not restrict the inspection team from enhancing inspection efficiency by requesting a licensee to provide additional relevant documentation. A new listing of documentation for TI-2515/62 is not being developed.
9.6 Subsecuent Inspections QUESTION To what extent will Appendix R issues be raised at future Regional I&E Fire Protection Audits after a successful Appendix R audit? For example, if an area hasreview to later already andbeen reviewed andbynothe reinterpretation noncompliance Staff? found, will it be subject
RESPONSE
The Appendix R inspections are conducted on a sample basis. These inspections do notidentified.
been certify that all possible items of noncompliance with Appendix R have The inspection results do provide a basis for a determina-tion of the adequacy of a licensee's Appendix R reanalysis, modification and preparation.
When 24-'=ena noncompliance with Appendix R requirements is identified, a notice of will be issued to ensure adequete cc rective actier.. Ir. those cases in which the licensee believes that the staff has invoked a reinterpretation of adequacy in areas which appeal would be applicable. had previously been reviewed, NRC's procedures for
- 9. 7 NRC List of Conformino Items QUESTION At the end of the audit, will the NRC provide a list of it' ems that had been reviewed and found in conformance with Appendix R? To date,-only areas of nonconformance have been specifically identified in exit interviews. l
RESPONSE
Subsequent to an Appendix R inspection, the NRC will not provide a list of items reviewbd and found to be in conformance with Appendix R.
We do list the areas inspected and where non compliances were not found .
APPENDIX R QUESTIONS & ANSWERS 42
sqery ,
A x* = = .
B: y-t c
- 9. 8 Inspection Re-review OUESTION Where assurgptions are made and clearly stated within the analysis submitted to NRR for review, will such assumptions be subject to a second review by OI&E during the inspection process? '
Where assumptions are made in conjunction with the analysis, should exemption requests be filed just to provide protection for the licensee?
If NRR accepts a licensee's selection of equipment and shutdown paths as being sufficient to meet the Appendix R shutdown criteria, will OI&E review and have the right to challenge the approved shutdown paths and approved equipment selec-tion? Or will they only check the shutdown paths and equipment in question to see that they meet the Appendix R requirements, i.e., separation?
RESPONSE
To the extent that a licensee's submittal to NRR is comprehensive and suffi-ciently detailed, the basis for the OI&E Appendix R inspection will be the assumptions, shutdown paths and equipment selections approved by NRR. If the inspection results in new information that casts doubt upon the approved con-figuration, the Regional inspectors have the responsibility to resolve such doubts.
- 9. 9 List of Shutdown Equipment OUESTION What lists of shutdown equipment will be used by the Regional inspectors, if the shutdown analysis has not been reviewed and approved by NRR7
RESPONSE
Regional Inspectors will use the lists of shutdown equipment the licensee has icentified in his fire protection plan.
Generic Letter 81-12 and its clarification documents expect licensees to show how they will shutdown if a fire area is not provided with redundant train separation.
Inherent within this expectation is the assumption that the licen-see will identify the equipment to be used.
It is because the licensees have not had fire hazard analyses at all for non-alternative shutdown fire areas that the inspectors to date have resorted to using the only lists available (the alternative shutdown equipment list used by NRR in their reviews).
It is unlikely there would not be a list of at least those systems to be used for alternate shutdown, since 10 CFR 50.48 requires NRR review and approval of the means of alternate shutdown.
G APPENDIX R QUESTIONS & ANSWERS 43 y ~ _ - , _. _ _. __ ._ _,..
t s EllCLOSURE -
7 With- Attfchismtulf 20& 3): !
4/12/85
-I;:577.UMENTATION i
FIRE DETECTION INSTRUMENTATI N-LIMITING CONDITION.FOR OPERATION 3.3.3.8 - As a minimum, the fire detection instrumentation for each fire detection zone shown'in Table 3.3-11 shall be OPERABLE. -
APPLICABILITY:
Whenever equipment protected by the fire detection instrument is required to be OPERABLE.
ACTION:
a.
With any, but not more than one-half the total in any fire zone, Function A fire detection instruments shown in Table 3.3-11 inoperable, restore the inoperable instrument (s) to OPERABLE status within 14 days or within the next I hour establish a fire watch zone (s) with the inoferable instrument (s) at leas't once patrolper to inspect hour, unit. the the instrument (s) is located inside the containment, then inspect that containment zone at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> (or monitor the containment air temperature Speci at leart fication 4. 6.1. 6'- once per hour at the locations listed in
? b.
With more than one-half of the Function A fire detection instruments in any fire zone shown in Table 3.3-11 inoperable, or with any Function B fire tu: detection
- :r; instruments shown in Table 3.3-11 inoperable,
- r litt
- q Tm_l. 2.2 11 in:p; ;il;, dj;;;nt 'ir; d;t;;ti;n ir.;tr..i.;;..s sh;-n in ithin I h;;r -
restore the inoperable instrument (s) within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> so that more than one-half of the Function A and all of the Function B instru-ments are OPERA 31.E, or within the next i 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 contain-ment, then inspect that containment zone .at least once per B hours (or monitor the containment air temperature at least once per hour
~
at the locations listed in Specification 4.6.1.6).
c.
The provisions of Specifications 3.0.3 and 3.0.4 are not applicable.
NOTE: Changes made by the Working Group are designated by a double bar in the right margin.
t t SURVEILLANCE REOUIREMENTS s
4.3.3.8.1 Each cf the above recuired fire detection instruments which are accessible during plant cperation shall be demonstrated OPERABLE at least once per 6 months by performance of a TRIP ACTUATING DEVICE OPERATIONAL TEST. Fire detectors which are not accessible during plant operation shall be demonstrated OPERABLE by the performance of a TRIP ACTUATING DEVICE OPERATIONAL TEST during each COLD SHUTDOWN exceeding 2f hears unless performed in the previous ' months.
72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> The supervisory system for the NFPA Standard 72D 4.3.3.8.2 Thc N'TA Star.dcrd 7^ 4 supervised circuits : ;;r i:i:r associated with the detector alarms of each of the above required fire detection ir.stremer. s shall be camonstratec OPERABLE at least once per 6 mont.hs.
4.3.3.8.3 The nonsupervised circuits, associated with detector alarms, between the instrument once per 31 cays,and the control room shall be demonstrated OPERAELE a- least h'- ST S 3/4 3-68 '
e 6
1 .
. , 1
~
~ ^ TABLE 3.3-11 t
FIRE DECTECTION INSTRUMENTATION TOTAL NUMBER INSTRUMENT LOCATION OF INSTRUMENTS *
(li l ustrativ' e) HEAT FLAME SMOKE (x/y) (x/y) (x/y)
- 1. Containment'#
- a. Zone 1 Elevation
- b. Zone 2 Elevation
- 2. Control Room
- 3. Cable Spreading
- a. Zone 1 Elevation
- b. Zone 2 Elevation
- 4. Computer Room
- 5. Switchgear Room
- 6. Remote Shutdown Panels ,,
- 7. Station Battery Rooms 8; Turbine
- a. Zone 1 Elevation
- b. Zone 2 Elevation
- 9. Diesel' Generator a.' Zone 1 Elevation
- b. Zone 2 Elevation
- 10. Safety Related Pumps
- a. Zone 1 Elevation
- b. Zone 2 Elevation i t
- 11. Fuel Storage
- a. Zone 1 Elevation
- b. Zone 2 Elevation a (List allequipment).
related detectors in areas required to ensure the OPERABILITY of safety-
- (x/y):- x is number of Function A (early warning fire detection and notification only) instruments.
y is number of Function B (actuation of Fire Suppression ,
Systems and early warning and notification)' instruments. *
- The fire detection instruments located within the containment are not required to be OPERABLE during the performance of Type A containment leakage rate tests.
i y-STS 3/4 3-69
pl*NT SYSTEMS 3/4.7.11 FIRE SUPPRESSION SYSTEMS FIRE SUP.PRESSION WATER SYSTEM LIMITING CONDITION FOR OPERATION 3.7.11.1 The Fire Suppression Water System shall be OPERABLE with:
- a. At least (two) fire suppression pumps, each with a capacity of (2500) gpm, at (125)psig and (rated) rpm for diesel-driven pumps with their discharge aligned to the fire suppression
- t. Separate water supplies, each'with a minimum contained volume of gallons, and
- c. An OPERABLE flow path capable of taking suction >from the tank and the tank and transferring the water through distribution piping with OPERABLE sectionalizing control or isolation valves to the yard hydrant curb valves, the last valve ahead of the water flow alarm device on each s:-inkler or hose standpipe, ar.d the last valve ahead of the deluge v6 ve on each Deluge or Spray System required to '
be OPERABLE per Specifications 3. 7.11. 2, 3. 7.11. 5, and 3. 7.11. 6.
APPLICASILITY: At all times. .
ACTION:
- a. With one pump and/or one water supply inoperable, restore the inoper-able equipment to OPERABLE status within 7 days.or p'rovide an alter-nate backup pump or supply. The provisions of Specifications 3.0.3 and 3.0.4 are not applicable.
- b. With the Fire Suppression Water System otherwise inoperabJe establish a backup Fire Suppression Water System within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
W-575 3/4 7-30
l r
- e i
O 8 l PLANT SYSTEMS l SURVEILLANCE REOUIREMEh'TS 4.7.11.1.1 The Fire Suppres sion Water System shall bd demonstrated OPERABLE:
- a. At least once par 7 days by verifying the contained water supply vol ume , t
- b. At least once per 31 days on a STAGGERED TEST BASIS by starting each electric motor-driven pump and operating it for at least 15 minutes on recirculation flow,
- c. .At least once per 31 days by verifying that each valve (manual, power operated, or automatic) in the flow path is in its correct position,
- d. .(At 1;;;t :n;; p;r E m; nth; by perf;rmar,;; ;f e 3,etes fimeh,)
mm At least once per 12 months by cycling each testable valve in the flow path through at least one complete cycle of full travel, 1'. At least once per 18 months by performing a system functional test which includes simulated automatic actuation of the system throughcut its operating sequence, and:
- 1) Verifying that each automatic valve in the flow path actuates to its correct position,
- 2) V;cif3ng th;t ;;;h pump d;vil;p; at 1;;;; (2500) gpa et a-
- y;t;; h;;d of (250) feet, Verifying that each fire pup starts (sequentially) throu6h automatic operation and delivers 150 percent of rated capacity at not less than 65 percent of the total rated head and that the shutoff head does not exceed 120 percent of rated head for the split-case pumps or 140 percent for end-section pumps at rated speed (rpm).
- 3) Cycling each valve in the flow path that is not testable during plant operation through at least one complete cycle of. full travel -end-
?) V;rifying th;t ;;;h fir; ;uppr;;;ica pu;; ;t;rt; (;;qwenti;11y) -
t: :: int i- th: "'r; Sup;r;;;i n '!;t:r Cy;t;; pie;; . e gr;;;;ri then ;r ;;;;1 t; p;ig.
g.
At least once per 3 years by performing a flow test of the system in 15th accordance with Chapter 5, Section 11 of the Fire Protection Handbook,
&&He Edition, published by the National Fire Protection Association.
and at least once per (6 months - 3 years) by performing a system flush.
The interval for the system flush should be selected on a plant-specific basis, based on the quality of the water source (e.g.,
tank, pond, river,etc.).
W-STS 3/4 7-31 l
PLANT SYSTEMS SURVEILLANCE REOUIREMENTS (Continued)
E 4.7.11.1.2 The fire pump diesel engine shall be demonstrated OPERABLE:
- a. At least once per 31 days by verifying:
- 1) The fuel storage tank contains at least gallons of fuel, and continuously
- 2) The diesel starts from ambient conditions and operates 3 for at least 30 minutes on recirculation flow.
- b. At least once per 92 days by verifying that a sample of diesel fuel from the fuel storage tank, obtained in accordance with ASTM-D270-IS75 is within the acceptable limits specified in Table 1 of ASTM 0975-1977 when checked for viscosity, water, and sediment; and
- c. At least once per 18 months, during shutdown, by subjecting the diesel to an inspection in accordance with procedures prepared in conjunction with its manufacturer's recommendations for the , class of service.
4.7.11.1.3 The fire pump diese' starting 24-volt battery bank and charger shall be demonstrated OPERABLE:
- a. At least once -per 7 days by verifying that:
- 1) The electrolyte level of each battery is above the plates, and
- 2) The overall battery voltage is greater than or equal to 24 volts.
- b. At least once per 92 days by verifying that the specific gravity is appropriate for continued. service of thd battery, and
__ c. At least once per 18 months by verifying that:
- 1) The batteries, cell plates, and battery racks show no visual indication of physical damage or abnormal deterioration, and
- 2) The battery-to-battery and terminal connections are c' lean, tight, free of corrosion, and coated with anti-corrosion material..
1 W-STS 3/4 7-32
,=-- .
~
. i PLANT SYSTEMS SPRAY AND/OR SPRINKLER SYSTEMS LIMITING CONDITION FOR OPERATION 3.7.11.2' Th'e following Spray and/or Sprinkler Systems shall b.e OPERABLE: -
- a. (P1 ant depen' dent - to be liste'd by name and location.)
b.
C.
APPLICABILITY: Whenever equipment protected by the Spray / Sprinkler System is required to be OPERABLE.
ACTION:
equivalent manual
- a. With one o more of the above required Spray and/or Sprinkler Systems inoperab e, within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> establish a continuous fire watch with b:;h_p fire suppression equipment for those areas in which redundant systems or components could be damaged; for other areas, establish a l hourly fire watch patrol.
- b. The provisions of Specifications 3.0.3 and 3.0.4 are not applicable.
SURVEILLANCE REOUIREMENTS 4.7.11.2 Each of the,above required Spray and/or Sprinkler Systems shall be demonstrated OPERABLE:
__ a. At least once per 31 days by verifying that each valve (menual, power operated, or automatic) in the flow path is in its correct position,
- b. At least once per 12 months by cycling each testable valve in the flow path through at least one complete cycle of full travel,
- c. At least once per 18 months:
J
- 1) By performing a system functional test which includes simulated automatic actuation of the system, and:
a) Verifying that the automatic valves in the flow path actuate to their correct positions on a test signal, and l
i b) Cycling each valve in the flow path that is not testable during plant ~ operation through at least one complete cycle of full travel.
I W-STS 3/4 7-33 l
i -- - , . . . .- . - . .
o .
l p'_ f;- SYSTEP.S i SURVEILLANCE' RE00:REMENTS (Continued) c) Opening a drain valve sufficient to verify that water is available to the system.
- 2) By a visual inspection of the dre ;ip: :pr:a 2^d ;? '-9 07 h a d.r; system piping, hangers and appurtenances to verify their integrity; and
- 3) By a visual inspection of each nozzle's spray a'rea to verify the spray pattern is not obstructed.
- d. ' At least once per 3 yeaYs by perfoming an air flow' test through each open head spray / sprinkler header and verifying each open head spray / sprinkler nozzle is unobstructed.
h'-ST5 3/4 7-34
PLANT SYSTE!'.5 CO SYSTEMS 2
LIMITING CONDITION FOR OPERATION 3.7.11.3- The following High Pressure and Low Pressure CO 2 Systems shall be OPERABLE:
- a. (Plant dependent - to be listed by name and location.)
b.
c.
APPLICABILITY: Whenever equipment protected by the CO Systems is required to be OPERABLE. 2 ACTION:
a.
With one or more of the above required CO2 Systems inoperable, .
within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> estab.lish a continuous fire watch with backup fire suppression equipment for those areas in which redundant systems or components could be damaged; for other areas, establish an hourly fire watch patrol. .
b.. The provisio.ns of Specifications 3.0.3 and 3.0.4 are not applicable.
SURVEILLANCE REQUIR MENTS 4.7.11.3.1 Each of the above required CO Systems shall be demonstrated OPERABLE at least once per 31 days by ver,fying T that each valve (manual, power operated, or automatic) in the flow path ~is in its correct position.
4.7.11.3.2 Each of. the above required ': 1 "r:::: : CO Systems shall be demonstrated OPERABLE: 2 For low-oressure systems,
- s. g At leas't once per 7 days by verifyir.g the CO, storage tank level to be greater than and pressure to be greater than psig, and 6
for hi h-pressure systems, at least once per 6 months by verifying i that ed the CO 2 storage tank weight is at least 90% of full-charge weight, W-STS 3/4.7-35
- l
PLANT SYSTEP.S I
SURV5ILLANCE REQUIREMENTS (Continued) b.
At least once per 18 months by verifying: time delays and alam interlocks
- 1) The system including valves, asso:iated tilation System fire dampers, and fire door release mechanis actuate manually and automatically, upon receipt of a simulated actuation signal, and
- 2) Flow frca each no::le during a " Puff Test."
- 3) The integrity of the system piping, hangers and appurtenances by visual inspection.
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h'- STS w 3/4 7-36 "
I
o e PLAC SYSTEMS i HALON SYSTEMS LIMITING C0FDITION FOR OPERATION 3.7.11.4 The following Halon Systems shall be OPERABLE:
- a. (Plant dependent - to be listed by name and location'.)
~
b.
c.
APPLICAEILITY: Whenever equipment protected by the Halon System is required to de 0?ERABLE.
ACTION:
- a. With one or more of the above required Halon Systems inoperable, within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> establish a continuous fire watch with backup fire suppression equipment for those areas in which redundant systems or components could be damaged; for other areas, establish an hourly fire watch patrol.
- b. The provisions.of Specifications 3.0.3 and 3.0.4 are not applicable.
SURVEILLANCE REOUIREMENTS 4.7.11.4 Each of the above required Halon Systems shall be demonstrated OPERABLE:
- a. At least once per 31 days by verifying that each valve (manual, power operated, or automatic) in the flow path is in its correct-position,
- b. (or level)
At least once per 6 months by verifying Halon storage tank weightg to be at least 95% of full charge weight (or level) and pressure to be at least 90% of full charge pressure, and verifying c.
Atleastonceper18monthsbyq T
1)' V;cif ing 3 2he system, including associated Ventilation System fire dampers and fire door release mechanisms, actuates manually and automatically, upon receipt of a simulated actuation signal, and F
- 2) f . fer.T.ance of ; flow test through headers and nozzles toduring a test assure no blockage.
- 3) The integrity of the system piping, hangers and appurtenances by visual inspection W-STS 3/4 7-37
PLANT SYSTEMS FIRE HOSE STATIONS LIMITING CONDITION FOR OPERATION _
r 3.7.11.5 The fire hose stations shown in Table 3.7-5 shall be OPERABLE.
APPLICABILITY:.. Whenever equipment in the areas protected by the fire ho'se stations is required to be OPERABLE.
ACTION:
- a. With one or more of the fire hose stations shown in Table 3.7-5 i inoperable, pr;vid; ;;t;d Wye (s) en the neere.L OPERASLE hv==
- t:ti:n(:). One retiet Of the 17: :h:l' i; ::rn;;t;d t; th;
- t;nd:rd 1:ngth Of 5::: pr;'.id:d f;r th; h;;; ;t;ti;n. The ae;;nd
- tict ;f th; ;y;
- h
- 11 b; ;;nn;;ted t: ; 1;ngth ;f h;s; aufficient t; pr:vid: ::v;r:g: f:r th; ;r;; 1;ft unpr;t;;t;d by the ir.;p;rebis h;;; :t:ti:r, "t:r: it ::r b; d;;;n:tr;t;d th:t th; phy;i;;i 7;; ting Of th; " r: 5::: ;;;ld r;;;it in ; 7;;;gni:f;1; h;;;rd t;-
- r tim; t
- b-ictin
- ,#-pi:nt :;ui;r:nt, ;r th: 5;;; it;;if, th; fir; 5::: chti' be st red : r:1' :t-th: : ti;t ;f th; OPERA 2LE h;;2 at; tier Sign: 05:1' L; ;;;nt;d ;b;;; th; g;t;d ag e(s) te iisntify ,
th; pr;;;r h::: t: ;;: 'h; ;b;;; ACTION r;;;ir;;;nt shell b;
- pli h;d ithin 1 n;;r if th; insp;;;bi; fire heee is the pri
- ry L
,~ ,.- - ..
- n: :f '. .# r: ::;;r;;;i:n, :th;rwi;; r;;t; th; ;dditi;ne
.26Lf.
- . A. L.... . .. ., .
restore the inoperable station (s) to an OPERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, or within the next i hour provide equivalent suppression capability in the affected area (s); after 7 days, establish a continuous fire watch in the affected area (s).
- b. The provisions of Specifications 3.0.3 and 3.0.4 are not applicable.
SURVEILLANCE REOUIREMENTS 4.7.11.5 Each of the fire hose stations shown in Table 3.7-5 shall be demonstrated OPERABLE:
~
- a. At least once per 31 days, by a visual inspection of the fire hose stations accessible during plant operations to assure all required equipment is at the station.
- b. At least once per 18 months, by:
- 1) Visual inspection of the stations not accessible during plant operations to assure all required equipment is at the station,
- 2) Removing the hose for inspection and re-racking, and
_ the couplings. l l
- c. At least once per 3 years, by: l
- 1) Partially opening each hose station valve to verify valve OPERABILITY and no flow blockage, and l 2) Conducting a hose hydrostatic test at a pressure of 150 psig or at least 50 psig above maximum fire main operating.pressur'e, I whichever is greater.
W-STS
- 3/4 7 . _ _ _
TABLE 3.7-5 8
FIRE HOSE STATIONS LOCATION" ELEVATION ~
HOSE RACK #
1 .
j l
I 4
" equipment.
List all b re Hose Stations required to ensure the OPERABILITY of safety-related i
l h'-STS , 3f4 7 39
., -- - - - - . , - , . . ,, , , . . , , , . _ , + - ,,,.,,.--,.,,,.a,,,, ,, e .e--r+ r. , - . , ,
PLANT SYSTEMS YARD FIRE HYDRANTS AND HYDRANT HOSE' HOUSES LIMITING, CONDITION FOR OPERATION 3.7.11.6 The yard fire hydrants and associated hydrant hose houses shown in Table 3.7-6 shall be OPERABLE.
APPLICASILITY:
Whenever equipment in the areas protected by the yard fire hydrants is required to be OPERABLE.
ACTION:
a.
With one or more of the yard fire hydrants or associated hydrant hose houses shown in Table 3.7-6 inoperable, with'- 1 5: n 5:n -
Mfi:::nt :dditi:=1 ingth; Of 21/2 in:h di=:t= h;n 1;;;;;d in r cdh::nt CPEE*3LE hydr =t hn: 5:=: t: pr;;id: nr;in t; th:-
c.;retected tre: N th: ' :perd 1: fir; hydr =t :r u n:i:,t:d hjdr=t 5:n 5:=: i: th: p r ' r; :n= Of"r; =;; n:i=;
eth:r in, pret d: the 2dd't'e-.:1 5::: 't- 2". he r;.
restore the inoperable hydrant (s) and/or hose house (s) to an OPERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, or within the next i hour provide equivalent suppression fire watch in the affected area (s); after 7 days, establish a continuous capability in the affected area (s).
- b. The provisions of Specifications 3.0.3 and 3.0.4 are not applicable. I i;URVEILLANCE REQUIREMENTS
- 4.7.11,5 Each of the yard fire hydrants and associated' hydrant hose houses shown in Table 3.7-6 shall be demonstrated OPERABLE:
- a. At least once per 31 days, by visual inspection of the hydrant hose house to assure all required equipment is at the hose house,
- b. At least once per 6 months (once during March, April, or May and .
once during September, October, or November), by visually inspecting each yard fire hydrant an'd veri.fying that the hydrant barrel is dry and that the hydrant is not damaged, and
- c. At least once per 12 months by:
- 1) Conducting a hose hydrostatic test at a pressure of 150 psig or at least 50 psig above maximum fire main operating pressure, whichever is greater,
- 3) Performing a flow check of each hydrant to verify its OPERABILITY.
}l-STS 3/4 7-40
. 1 TABLE 3.7-6 YARD FIRE HYC RA';TS AND ASSOCIATED HYDRANT HOSE. HOUSES 8
LOCATION" HYDRANT NUMBER
" List all Yard Fire Hydrants and Hydrant Hose Houses required to ensure the OPERA 5ILITY of safety-rela .ed equipment or facilities housing safety-related equipment.
W-STS 3/4 7-41
P L A':T SYSTEMS 3/4.7.12 FIRE RATED ASSEMBLIES LIMITING, CONDITION FOR OPERATION 3.7.12 All fire rated assemblies (walls, floor / ceilings, cable tray enclosures and other fire barriers) separating safety related fire areas or separating portions of redundant and all sealing devicesystems important to safe shutdown within a fire area windows; fire dampers;g in fire rated assembly penetrations (fire doors; fire shall be OPERABLE. andcable, piping, and ventilation duct penetration seals)
APPLICASILITY:
St :1' ti ::. Whenever the equipment protected by the fire-rated '
assembly (ies) must be OPERABLE.
ACTION:
a.
With one or more of the above required fire rated assemblies and/or sealing devices inoperable, within one hour either establish a continuous fire watch on at least one side of the affected assembly, or verify the OPERABILITY of fire detectors on at least one side of the inoperable assembly and establish an hourly fire watch patrol.
b.
The provisions of Spec -fications 3.0 3 and 3.0.4 are not applicable.
SURVEILLANCE REOUIREMENTS 4.7.12.1 at 1:::t ;n c p;r IS ;nths the above required fire rated assemblies and penetration vi;;;l in:p::ti:r :f:
sealing devices shall,be verified OPERABLE *L, p;r'; rain; c a.
At least once per 18 months by performing visual inspections of:
- 1. h, The exposed surfaces of each fire rated assembly, i
- 2. A.
Each fire window / fire damper and associated hardware, and 3- h, At least 10% percent of each type of sealed penetration. If apparent changes in appearance or abnormal degradations are found, a visual inspection of an additional 10% of each type of sealed penetration shall be made. This inspection process /.e.sil continue until a 10%
sample is found.withSamples no apparent changes in appearance or abnormal degradation shall be selected such that each penetration will be inspected every 15 years.
- b. At least cnce per 18 months by performing a functional test of at least 10% of the accessible fire dampers. If any non-conformin6 dampers are found, an additional 10% will be functionally tested.
This process will continue until an acceptable sample is found.
Samples shall be selected such that all accessible. dampers are tested every 15 years.
f*-STS 3/4 7-42
DLAUT SYSTEMS SURVEILLANCE REOUIREMENTS (Continued) 4.7.12.2
. m ,. m . . .
4
- ___a E'ach .__..:_
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At least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, by verifying that doors with automatic hold-open and release mechanisms are free of obstructicns and that unlocked fire doors without electrical supervision are closed; b.
At least once per 7 days, by verifying that each locked-closed fire door is locked and closed; c.
At least once per 31 days, ty perfoming a TRIP ACTUATING IEVICE OPERATIONAL TEST for each electrically-supervised fire door; d.
At least once per 6 months, by visually inspectin6 the automatic hold-open, release and closing mechanisms and latches; and
_ . e.
At least once per 18 months, by performing a functional nst of all
. hold-open and release mechanisms.
1 l
l W-STS l
3/4 7-43
PLANT SYSTEMS 3/4.7.13 ALTERNATIVE / DEDICATED SHUTDOWN SYSTEM LIMITING' CONDITION FOR OPERATION 3 7.13 The Alternative / Dedicated Shutdown System (ASS / DSS) equipment, shown on Table 3 3-X, shall be OPERABLE.
AFFLICA3ILITY: MODES 1, 2, and 3 ACTION:
- a. WithlessthantheminimumASS/DSSequipmentinTable33-XOPERABLI, restore the inoperable equipment to OPERABLE within 7 days, or provide equivalent shutdown capability and restore the inoperable equipment to OPERAELE within 60 days, or be in HOT STANDBY within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and HOT SHUTDOWN within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
- b. The provisions of Specifications 3.0 3 and 3.0.4 are not applicable.
SURVEILLANCE REQUIFIMENTS 4.7.13.1 Each monitoring instrumentation channel shall be demonstrated OPERAELE by performing the CHANNEL CHECK and CHANNEL CALIBRATION operations at the frequencies shown on Table 4.3-X.
4.7.13.2 Each transfer switch, power supply and control circuit shall be demonstrated OPERABLE at least once r 18 months by operating each actuated component from the ASS S stations.
4.7.13.3 The ASS / DSS diesel 6enerator shall be demonstrated OPERABLE:
- a. At least once per 31 days by verifying:
- 1) The fuel level in the fuel storage tank is Ereater than or equal to ( ) inches, and
- 2) The diesel starts from ambient conditions and operates for at least 30 minutes at greater than or equal to ( ) kW.
- b. At least once per 92 days,by verifying that a sample of diesel fuel from the fuel storage tank, obtained in accordance with ASTM-D270-1975, is within the acceptance limits specified in Table 1 of ASTM-D975-1977 when checked for viscosity, water and sediment; and l
- c. At least once Mr 18 months, during shutdown, by subjecting the diesel to an inspection in accordance with procedures prepared in conjunction with the manufacturer's recommendations for the
_ applicable class of service.
SURVEILLANCE EEQUIREMENTS (continued) 4.7.13.6 The ASS / DSS battery bank and charger shall be demonstrated OPERABLE:
- a. At least once per g days by verifying that:
1)~ The electrolyte level of each battery is above the plates, and
- 2) The overall battery volta 6e is greater than or equal to ( ) volts,
- b. At least once per 92 days by verifyin6 that the specific gravity is appropriate for continued service of the battery; and
- c. At least once per 18 months by verifying that:
- 1) The batteries, cell plates, and battery racks show no visual indication of physical damage or abnormal deterioration, and
- 2) The battery-to-battery and terninal connections are clean, ti6 ht, and free of corrosion.
NOTE: ADD OPERABILITY, ACTION REQUIRD!ENTS AND SURVEILLANCE REQUIRDENTS FOR ANY OTHER ASS / DSS PLANT-SPECIFld EQUIWINT, AS APPROPRIATE h
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3/!4.7.14 FORTABLE FIRE EXTINGUISHERS LIMIT.ING CONDITION FOR OPERATION 3.7.14 All portable fire e.xtin6uishers protecting areas containing safety-related equipnent, as described in the Fire Ha: anis Analysis, shall be OPERAELE.
AFFLICABILITY: At all times.
ACTION: -
- a. With one or more of the required portable fire extinguishers inoperable, within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> replace the inoperable extinguisher with an OPERABLE extinguisher having the same classification and at least equal rating.
- b. The provisions of Specifications 3 0 3 and 3.0.4 are not applicable.
SURVEILLANCE REQUIREMENTS t
4.7.14 Each required portable fire extin6uisher shall be verified to Ni OPERA 3LE by performing surveillance and maintence in accordance with procedures prepared in conjunction with the manufacturer's reconnendations and verifying that each extinguisher is located as designated in the Fire Hazards Analysis.
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PLANT SYSTEMS 3/4.7.15 EMERCENCY LIGHTING UNITS r
LIMITING CONDITION FOR OPERATION 3.7.15 A11' required self-contained, battery-powered emergency lighting units, as descrited in the Fire Hazards Analysis, shall be OPERA 3LE.
AFFLICABILITY: At all times.
ACTION:
- a. With one or more of the required emergency lightin6 units inoperable, within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> replace the inoperable lighting unit with an OPERA 3LE lighting unit.
- b. The provisions of Specifications 3.0 3 and 3.0.4 are not applicable.
SURVEILLANCE REQUIF.EMENTS 4.7.15 Each of the required emer6ency lighting units shall be verified to be OPERA 3LE by performing surveillance and maintence in accordance with procedures prepared in conjunction with the manufacturer's recommendations.
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INSTRUMENTATION t
BASES 3/4.3.3.2 MOVABLE INCORE DETECTORS The OPERABILITY of the movable incore detectors with the specified minim complement of equipment ensures that the measurements obtained from use of ,
t this system accurately represent the spatial neutron flux distribution of he core.
The OPERABILITY of this system is demonstrated by irradiating e detector used'and determining the acceptability of its voltage curve For the purpose of measuring'F q (Z) or Fh a full incore fl map is used. -
Quarter core flux maps, as defined in WCAP-8648, June 1976, y be used in recalibration of the Excore Neutron Flux Detection System and full incere flux maps or symmetric incore thimbles may be used for nitoring the QUADRANT POWER TILT RATIO when one Power Range channel is inop able.
l 3/4.3.3.3 SEISMIC INSTRUMENTATION a
The OPERABILITY of the seismic instr entation ensures that sufficient I capability is available to promptly det mine the magnitude of a seismic event S and evaluate the response of those-fe ures important to safety. This capa- d bility is required to permit compar' on of the measured response to that used- %
in the design pursuant basis A to Appendix forofthe faci ' y to determine if plant shutdown is required 10 C s Part 100.
with the recommendations of gulatory GuideThe instrumentation is consistent 1.12, " Instrumentation for Earth- E quakes," April 1974. z g
3~/4.3.3.4 METEOROL ICAL INSTRUMENTATION m The.0PE ITY of the meteorological instrumentation ensures that sufficient m eorological data are available for estimating potential radiation doses to public as materia to the atmosphere. a result of routine or accidental release of radioactive for .i This capability is required to evaluate the need pu tiating protective measures to protect the health and safety of the e and is consistent with the recommendations of Regulatory Guide 1.23,
" nsite Meteorological Programs," February 1972.
3/4.3 -3'S ~REMOTEh0WN'5YSTEM The OPERABILITY of the Remote Shutdown System ensures that sufficient capability is available to permit safe shutdown of the facility from locations outside of _the control room. This capability is required in the event control room habitability is lost and is consistent with General Design Criterion 19 of 10 CFR Part 50.-
The OPERABILITY of the Remote Shutdown System ensures that a fire will not preclude achieving safe shutdown.
The Remote Shutdown System instrumentation, W-STS B 3/4 3-4
,' XHSTRUMENTATION BASES -
. REMOMEMUTDDWN'5YSTE M ( C o n t i n ue~d) -
control and power circuits and transfer . switches necessary to eliminate effects of the fire a'nd allow operation of instrumentation,' control and power circuits required to achieve and maintain a safe shutdown condition are independent of areas where a fire could damage systems normally used to shutdown the reactor.
This to 10 capability CFR 50. is consistent with General Design Criterion 3 and Appendix R 3/4.3.3.6 ACCIDENT MONITORING INSTRUMENTATION -
The -OPERABILITY of the accident monitoring instrumentation ensures t sufficient information is available on selected plant parameters to tor
. and assess these variables following an accident. This capabili tent with the recommendations of *egulatory Guide 1.97, "In s consis- w Light-Water-Cooled Nuclear Power Clants to Assess Plant mentation for g.
' Following an Accident," Decembef'_S75 and NUREG 07 nditions During and 5:
Action Plan Requirements," November 1980. ,
' Clarification of TMI O-i;
. .c :
._ 3/4.3.3.7 CHLORINE DETECTION SYC' .S El
[
O The OPERABILITY of capability is avail Chlorine De~ection t System ensures that sufficient 2 e to promptly detect and initiate protective action in 6
, the event of a -
cidental chlorine release. This capabi3ity is required to M protect co Regul
- ol room personnel and is consistent with the recommendations of
- y Guide 1.95, " Pro.tection of Huclear Power Plant Control Room Oper- '
.s Against an Accidental Chlorine Release," February 1975.
3/4.3.3.7 MIRE DETECTION IN$TRDMENTATION OPERABILITY of the detection instrumentation ensures that both adequate warning capability is available for prompt detection of fires and that Fire Suppression extinguishing Systems, agent in a that aremanner.
timely actuated by fire detectors, will ~ discharge Prompt detection and suppression of fires will reduce the potential for damage to safety related equipment and is an integral element in the overall f acility Fire Protection Program.
When instrumentation is inoperable in the affected area until OPERABIf.,ITY can be restored. frequent fire patrols are required Fire detectors that are used to actuate Fire Suppression Systems represent a more critica113 'sp;rt:n; component of a plant's Fire Protection Program than detectors tion. that are installed solely for early fire warning and notifica-Consequently, t.t; nini;.... n..;t..
- r;;t
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4 h*-STS B 3/4 3-5
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INSTRUMENTATION BASES t FIRETDETECTION INSTRUMENTATION (Continued)
- ny :ren. 1: : :: ult, th: :t:bli:F :nt of a fire watch patrol must be initiated at an earlier stage than would be warranted for the loss of detectors that provide only early fire warning. Th; ::;;bli;ttent of 'r quent "re p;t.;;; in th: Off :ted crc : i: required t: pr:.id; d; tecti:n ::p;bility unti' th: ' :p;r:bi t 'n t :nt:ti:r i: r;;t:r:d tc.CFEF,fi!LITY.
3/4.3.3.9 LOOSE-PART DETECTION INSTRUMENTATION The OPERABAILITY of the loose part detection instrumentation ensures th sufficient capability is available to detect loose metallic parts in the Reactor System and avoid or mitigate damage to Reactor System components The allowable out-of-service times and surveillance requirements are 'consi ,ent with the recommendations of Regy)atory Guide 1.133, "Leose-Part Det ion Program for the Primary System of Light-Water-Cooled Reactors," M 1981.
3/4.3.3.10 RADI0 ACTIVE LIQUID EFFLUENT MONITORING INSTRUME iATION .
~
- The radicactive liquid effiuent instrumentation i provided to monitor and control, as applicable, the releases of radioact' e. materials in 1.iquid-effluents dur'ing actual or potential releases of 1 uid effluents. The
~ Alarm / Trip Setpoints for these instruments shall e calculated and adjusted in w accordance with the methodology and parameters n the ODCM to ' ensure that the g alarm / trip will occur prior to exceeding th imits of 10 CFR Part 20. The 5 OPERASILITY and use of this'instrumentati is consistent with the requirements 3 '
of General Design Criteria 60, 63 and 6 of Appendix A to 10 CFR Part 50. The i purpose of tank level indicating devi s is to assure the detection,and control [
of leaks that if not controlled cou potentially result in the transport of g
. radioactive materials to UNRESTRI ED AREAS. , ,
8 l 0
3/4.3.3'11 NADI 0 ACTIVE GA US EFFLUENT MONITORING INSTRUMENTATION M The radioactive ecus effluent instrumentation is provided to monitor and control, as appl
- cable, the releases of radioactive materials in gaseous effluents during tual or potential releases of gaseous ef fluents. The Alarm / Trip Setp nts for these instruments shall be calculated and adjusted in accordance wi the methodology and parameters in the ODCM to ensure that the alarm / trip 11 occur prior to exceeding the limits of 10 CFR Part 20. This instrumen otion also includes provisions for monitoring (and controlling) the l concen ations of potentially explosive gas mixtures in the WASTE GAS HOLOUP SYST .. The OPERASILITY and use of this instrumentation is consistent with th requirements of General Design Criteria 60, 63 and 64 of Appendix A to CFR Part 50.
" 'Tc B 3/4 3-6 - - - - ._
1
- s
'E PLANT SYSTEMS
. 1 BASES t
SNUSEERS (Continued)
The service life of a snubber is established via manufacturer input information through consideration of the snubber service conditions an associated installation and maintenance records (newly installed sn - er, seal replaced, spring replaced, in high radiation area, in high tempe ure area,.
etc. . .). The requirement to monitor the snubber service li is included to ensure that the snubbers periodically undergo a performanc valuation in view of, their age and operating conditions. These records w' p.rovide statistical
~
ba'ses for future consideration of snubber service li . The requirements 22 for the maintenance of records and the snubber se ice life review are not -
M intended to affect plant operation.
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3/4.7.10 SEALED SOURCE CONTAMINATION
- g x
The limitations on removable ntamination for sources requiring leak testing, including alpha emitt .. is based on 10 CFR 70.39(c) limits for 5 plutonium. This limitation p i snsure that leakage from Byproduct, Source, S and Special Nuclear Mate 'al sour:es will not exceed allowable intake values.
- Sealed source are classified into three groups according to their use,
. with Surveillane Requirements commensurate with the probability of damage to a source in th- group.
Those scurces which are frequently handled are required
- to be tes+ d more often than those which are not. Sealed sources which are contin usly enclosed within a shielded mechanism (i.e., sealed sources within ra # . ion monitoring or boren measurin'g devices) are considere.d to be stored d need not be tested unless they are removed from the shielded mechanism.
3/4.7.11 FIRE SUPPRESSION SYSTEMS ihe OPERABILITY 'of the Fire Suppression Systems ensures that adequate
~ fire suppression capability is available to confine and extinguish fires occurring in any portion of the facility where safety related eouipment is located. The Fire Suppression System consists of the water system,. spray, and/or sprinklers, CO , Halon, fire hose stations, and yard fire hydrants.
Thecollectivecapabi$ityoftheFireSuppressionSystemsisadequateto minimize potential damage to safety related equipment and is a major element in the facility Fire Protection Program.
capability In the event that portions of the
- Suppression Systems are inoperable, cit:rn:t: backup fire-fighting q.ir.- nt is required t; b: m;d: n:il: tic in -
the affected_ areas until the inoperable equipment is restored to service.
- . e c. J , e ~,;;;c b1
- f'rc 'ightin; q.ip :nt :: 'nt:nd: f:r -:: :: : r::h;;
- n: :f :;;; :-::i:n, ; ':n;:r ;;ri:d f ti : i: :'" ::d i prn ':: :r
- lt;rn:t: m :n: ef "r: " ;hti.; tE: th: ' :;er:b': ::;;r :nt : ' 5:
pr'- ry ::n: ef : : ;; :::i r.
' .'- ST S
- E 3/4 7-6
PLANT SYSTEMS BASES FIRE 25UPP,RESSION SYSTEMS (Continued)
Backup fire fighting equipment, provided when the primary suppression systems are inoperable, must be able to provide an equivalent capability; in this context, equivalent capability means a reasonably similar fire suppression function, censistent with the primary system's design objective in the Fire Hazards Analysis. Backup equipment should not compromise plant safety when used.
The Cur;;i'1:ne 9: qui :: nt: pr:;id: ::;ur:n;; th:t the OT:?,A::L:TY r :uir m; cit; cf th: F' r: Su;;r;;;i n Sy;t:m; 5?: ninimam:: t.
~
An cli;- nce--
i; ::d: f:r en;ur'n; : iuf'icient ; lum:
f 9:1:r '- th: 9:1:n ;t:r:g: t:nh by s r#fy'n; cither the acight er th: 1:v:1 Of th: t:nk:. Lev:1 :::;ure.::nt:-
cre ;;d ty cith r : t'. L . ; r
- 9 :ppr;ved meth:d.
In the event the Fire Suppression Water System becomes inoperable, prompt
/ 5: dict corrective measures must be taken since this system provides the major fire suppression capability of the plant.
3/A9r12 FIRE RATED ASSEMBlilES The functional integrity of the fire rated assemblies and b.arrier penetra-tions ensures that fires will be confined or adequately retarded from spreading to adjacent portions of the facility. These design features minimize the pessibility of a single fire rapidly involving several areas of the facility prio'r to detection.and extinguishing of the fire. The fire barrier penetrations are a passive to'periedic element in the f acility fire protection program and are subject inspections. -
Fire barrier penetrations, including cable penetration b6rriers, fire doors and dampers are considered functional when the visually observed condition is the same as the as-designed condition. -r:c these fi.. Le..iec gon L t;cas th:t cr; n:t '- th:
- h;u'th
- t th ::-d::';n:d ::nditi:n, er tv;iu;ti:n :hcli b; p;rf;rm;; t:
- dific ti
- n h:: .:t degr:d:d th fir 7 ting ;f th p;n tr: tier. fire b rrier The active assemblies (e.g., doors and dampers) are periodically tested to demonstrate their operability.
During periods of time when a barrier is not functional, either: (1) a continuous fire watch is required to be maintained in the vicinity of the affected barrier, or (2) the fire detectors on at least one side of the affected barrier must be verified OPERABLE and an hourly fire watch patrol established, until the barrier is restored to functional status.
i 3/4.7.13 AREA TEMPERATURE MONITORING d i m l The area temperature limitations ensure that safet - u1pment 5
- will not be subjected to temperatures in o etr environmental quali-3 i
fication temperatures. Ex cessive' temperatures may degrade equipment *,
g: i l and can caus . its OPERABILITY. The temperature limits include an
. e or instrument error of 1 (
)*F. *
=
y-STS S B 3/4 7-7 u M
E PLANT SYSTEMS BASES 3/4.7.13 ALTERNATIVE / DEDICATED SHUTDOWN SYSTEM The OPERABILITY of the ASS / DSS ensures that a fire will not preclude achieving safe shutdown. The ASS / DSS equipment are independent of areas where a fire could damage systems normally used to shutdown the reactor. This capability is consistent with GDC 3 and 10CFR50, Appendix R.
The equivalent shutdown capability provided when the ASS / DSS is inoperable depends on the specific equipment involved and, therefore, should be sufficient to assure that the intended shutdown actions can be accomplished, or that fires can be reasonably precluded >during that time for which ASS /OSS equipment would otherwise be required, consistent with the ASS / DSS design basis. Any temporary procedures or special fire watch patrols established to provide this equivalent capability should be reviewed by the (PORC) and approved by the (station superintendent) prior to implementation.
3/4.7.14 PORTABLE FIRE EXTINGUISHERS The portable fire extinguishers are the first line of fire defense and are most effective when fires are in their early stages of development. 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 promptly repaired or replaced.
3/4.7.15 EMERGENCY LIGHTING UNITS The 8-hour emergency lighting units are provided in areas needed for operation of safe shutdown equipment and in access and egress routes 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.
1 m
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i l
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l ADMINISTRATIVE CONTROLS d.
The. performance of activities required by the Operational Quality Assurance Program to meet the criteria of Appendix "B", 10 CFR 50, at least once per 24 months.
e.
The Emergency Plan and implementing procedures at least once per 12 months.
f.
The Security Plan and implementing procedures at least once per
. 12 months.
g.
Any other area of unit operation considered appropriate by the (CNRAG) or the (Vice President Operations).
h.
The Fire Protection programmatic controls including the implementing procedures at least once per 24 months by qualified licensee QA personnel!
l 1.
The fire protecti6n equipment and program implementation at least once per 12 months utilizing either qualified offsite licensee fire protection engineer or an outside independent fire protection consultant. An outside independent fire protection consultant shall be used at least every third year; ALITHORITY 2
6.5.2.9 The on those areas (CNRAG) shall report to and advise the (Vice President Op of responsibility specified in Sections 6.5.2.7 and 6.5.2.8.
RECORDS 6.5.2.10
_ tributed as-indicated below: Records of (CNRAG) a divities shall be prepared, a.
Minutes of each (CNRAG) meeting shall be prepared, approved and forwarded each meeting.to the.(Vice President-Operations) within 14 days follow b.
Reports of reviews. encompassed by Section 6.5.2.7 above, shall be within 14 days following completion of the. review. prepa c.
Audit reports encompassed by Section 6.5.2.8 above, shall be forwarde to the (Vice President-Operations) and to the management positions responsible for the areas audited within 30 days after completion of the audit by the auditi ing organization.
ALL STS.
6-13
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. o Attachment 1 PROPOSED ACTION STATEMENTS FOR SECTIONS 3.7.11.2-4 AUTOMATIC FIRE SUPPRESSION SYSTEMS E
- a. With the [ system] inoperable such that one train of a safety system is not protected by automatic fire suppression, verify the functional capability of the redundant safety system train (s) which would accomplish the intended function and its associated fire suppression system, and restore the [ system] to OPERABLE within 7 days or establish hourly fire watch patrols in the affected area (s).
- b. With the [ system] inoperable such that a safety function (i.e., both i
or all trains of the safety system) is not protected by automatic fire suppression or a fire area is not protected such that a fire could not be contained within the fire barriers which establish the area, within one hour establish a continuous fire watch with eouf valent manual fire suppression equipment in the affected area (s).
- c. The provisions of Specifications 3.0.3 and 3.0.4 are~ not applicable.
BASES The OPERABILITY of the fire suppression systems does not include the actuating instrumentation (detectors) because they are covered under 3/4.3.3.8. When a fire suppression system is found to be inoperable, the action statement recognizes the importance of the safety functions being protected, consist'nt e with the design approach for fire damage limits. When one train of a safety system becomes vulnerable to fires, the functional capability of the redundant train must be verified. This requirement is intended to provide assurance that a fire in the affected area will not result in a complete loss of the' i
. . . . . , l 2- '
safety function of the systems involved. The term verify the functional capability, as used in this context, means to administratively check: by examining logs or other information to determine if necessary components are out-of-service for maintenance or other reasons; it does not mean to perform the surveillance required to demonstrata OPERABILITY of the system because such testing could reduce the system's reliability.
When an entire safety function (both or all trains) becomes vulnerable to fires, prompt action must be taken to ensure adequate manual fire fighting capability, until the automatic fire suppression systems are restored.
Similarly, when a fire area is unprotected such that a fire in that area would not be automatically contained and, therefore, could spread beyond its boundaries, prompt action must be taken to monitor the area with preparations for any manual fire fighting necessary to ensure such fires will be contained.
e
Attachment 2 SIGNIFICANT FIRE PROTECTION I TECHNICAL SPECIFICATION ISSUES
- 1. Detection Instrumentation The Working Group (WG) initially tried to remove the Function 8 (actuation) instrumentation from Technical Specification (TS) 3.3.3.8. Our objective was to simplify the complex action statement associated with Function A, Function B and detectors inside containment.
However, in doing so, the resulting action statement associated with the suppression system, as it would apply to the Function 8 detectors, would be overly restrictive. Moreover, there is an STS ob,iective to keep such instrumentation separate and a precedent in the Reactor Protection System for distinguishing the LCO for actuating instrumentation (sensors) from the actuated system LCO.
2 Ideally, there should be a action matrix which is a function o# the number of inoperable detectors in any zone and the number of unprotected fire areas served by those detectors. However, such a requirement would be
. overly complex and confusing. Conversely, we believe that action within one hour whenever any detector is inoperable is wholly unwarranted.
Therefore, we have left the original construction of the action statement and modified the restoration periods to be appropriately comparable with those which would be required with one or both trains of a safety system inoperable. In our judgment these changes are still conservative.
-2 t
- 2. Definition of Terms There were- several comments that relate to the definition or explanation of terms; e.g., fire watch patrol, backup equipment, TRIP ACTUATING DEVICE OPERATIONAL TEST, and puff test. Terms which are used consistently throughout the STS and have a precise meaning are defined in the introduction and are capitalized in the text (e.g., OPERABLE).
In some ca'ses, there seems to be a wide, range of views regarding terms commonly understood by fire protection engineers. Many of the clarifications proposed are so detailed that they more appropriately belong in the plant's procedures implementing the technical specifications.
In such cases, the inspector must be able to judge whether the procedures achieve the objective of the TS and, if they do not, then we would expect that the licensee has a broader problem which requires appropriate enforcement action.
Where reasonably simple and constructive clarifications can be made, we have augmented the associated " bases" section in accordance with STS practice.
- 3. Reporting Requirements There were existing and recommended reporting requirements in action statements which would otherwise allow an indeterminant period of equivalent manual fire detection (fire watch patrol) or suppression.
-3 t
These reporting requirements appear to principally serve as a punitive measure to prevent licensees from operating under such conditions for extended periods of time.
We believe that such reporting requirements are unnecessary and only serve to shift the responsibility for action from the licensee to the NRC. The personnel time (i.e., fire watch patrols) required to provide the equivalent protection should be sufficient incentive for the licensee to repair inoperable equipment.
The Regions may not completely agree with this judgment.
4 Surveillance Requirements In several cases, recommended changes to the surveillance requirements were so detailed that they constituted implementing procedures or they appeared to verify design capability. We believe such changes go beycnd the objective of surveillance requirements, which is to simply describe the inspections and tests necessary to assure that the LCO is satisfied.
In those cases where specific procedures or testing requirements are necessary to accomplish the surveillance, then specific references should be cited; e.g., ASTM-D975-1977 for diesel fuel chemistry. Otherwise, procedures for conducting surveillance should be prepared in accordance with TS 6,8.1 and, where appropriate, reference is made to procedures
" prepared in conjunction with manufacturer's recommendations."
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- 5. Fire Suppression Systems - Action Requirement Based on comments received, the WG attempted to prepare a new set of action statements which would be' applied consistently to all fire suppression systems. These action statements would recognize that the fire suppression systems serve to protect safety systems and, therefore, if a redundant safety system train is still protected, a longer restoration time could be allowed than if an entire safety function is unprotected. Even then, manual fire suppression could serve for some reasonable time until the fire suppression system is again operable.
These action statements would also recognize that fire suppression systems prevent fires from spreading from one fire area to another or from growing to an unmanagable size.
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A draft of these action statements is presented in Enc';;- ~ /\ While we believe that the approach is correct, we have not had time to assure that the proposed actions are appropriate for all possible system failures. We suggest that the Steering Committee consider this approach and, if agreeable, we will continue to refine this proposal.
- 6. Alternate / Dedicated Shutdown Systems Based on a variety of existing and recommended LCOs and surveillance requirements for Alternate and Dedicated Shutdown Systems (ASS / DSS),
the WG has endeavored to construct a composite STS. We received comments regarding ASS / DSS inoperability for 60 days and the completeness of the TS.
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. o The WG selected a 60-day restoration period because (1) we included a provision .for " equivalent shutdown capability" in the event for inoperable, equipment cannot be restored in 7 days, and (2) we considered the time that would be required to evaluate and process a TS change, should a situation -arise requiring a temporary modification to the ASS / DSS. We believe that, in most cases, any necessary repairs could be made in 60 days and the system inoperability could be reasonably compensated during that time.
With regard to completeness, we attempted to identify LCOs ard surveillance requirements for all of the major system components. A clarifying note is included which explains that additional (plant-specific) components should be similarly added.
7 Equivalent Capobility There are several actions which require the licensee to establish I
" equivalent" fire protection capability when a system is inoperable. We used the term " equivalent" to be consistent with its use throughout the STS.
However, we believe this term will be misconstrued in many cases; it does not mean identical, it is intended to be more like " comparable."
In order to ensure this understanding, we have added clarifications to the appropriate bases sections.
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As a generic matter, we recommend that the Technical Specification Review Group (TSRG) consider an alternate term for use throughout the STS which -
will not be construed to mean " identical" where it is not so intended; e.g., comparable, compensatory, or appropriate.
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- 8. Refueling Outage Surveillance The STS specify "at least once per 18 months" for surveillance that are intended during refueling outages. The WG noted that such a period can create schedular problems for plants with long power runs and, therefore, reconnended changes to "at each refueling outage."
This is a policy issue beyond fire protection. The STS practice is to 4 specify time periods. In either case, there are potential problems (e.g., replacing one fuel element is a refueling outage). Therefore, we have withdrawn our recommendation in favor of consistency. However, as a generic matter, we suggest the TSRG consider extending the 18-month period or specify "at least at each scheduled refueling outage but not less often than once each 24 months." -
9,. Emergency / Security Plans A question was raised regarding a change in the schedules from 24 months to 12 months for Emergency and Security Plans (6.5.2.8). These changes were made by the TSRG, not the WG, to make these schedules consistent with the requirement for annual updates required in the regulations.
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Attachment 3 r
WORKING GROUP COMMENTS ON PROPOSED FIRE PROTECTION TECHNICAL SPECIFICATIONS l
The Working Group reviewed the Standard Technical Specifications (STS) taking into account comments from Regions I, II and III. The CRGR package version of the Westinghouse STS was used as the basis document. The Working Group attempted to simplify and clarify the STS and added specifications for alterna-tive and dedicated shutdown systems, portable fi~re extinguishers and emergency lighting. The rationale for these additions is that these features are explicitly included in Appendix R.
Obviously, the Working Group has had to exercise a collective judgment to develop these recommended changes to the technical specifications. We did not always include recommended changes to the technical specifications; because of the wide range of opinions, we perceive that there may never be universal agreement on the details of these requirements. Nevertheless, there were comments which raised issues broader than fire protection or involved conflicting objectives; e.g., simplicity of action statements, definition of
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terms, reporting requirements, procedural details, action objectives and 1
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consistency, use of " equivalent" capabilities, and surveillance during refueling outages. To ensure that the bases for our recommended changes are clearly undustood, we have responded to the more significant coments and explained some of our judgments in Attachment 2. We have also recommended generic improvements to the STS which should be considered when a final action is taken to upgrade the fire protection technical specifications.
The Working Group is not entirely satisfied with its revisions to the STS.
Although we believe the surveillance and LCOs concerning fire protection I enhance safety., we are concerned that the way they are presented elevates fire protection almost to the stature of ECCS. However, given the safety signifi-cance of fire protection and the present format of the STS, the Working Group 4 could not come up with an acceptable alternative.
We believe that the technical specification format included in the proposed rulemaking offers a mor,e appropriate way of regulating fire protection sur-veillance and compensatory measures for inoperative equipment. The rule-making (47FR13369,3/30/82) calls for only the most important features to be included in the body of the technical specifications. The LCOs, compensa1!ory i measures, surveillance requirements, and administrative requirements of lesser importance but still important to safety removed from the technical specifica-tions are to be placed in a companion document (supplemental specifications).
The supplemental specification may be revised.by the licensee upon approval
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r of its safety committee. The supplemental specifications and the documentation of surveillance and tests conducted in accordance with the supplemental speci-fications are subject to NRC inspection.
We recommend that the "new" Technical Specifications include an administrative requirement for the licensee to maintain a procedure for surveillance and compensatory measures for inoperative equipment. This procedure would not be a part of the Technical Specifications but would be included in and therefore could be revised by the licensee on approval of the licensee's safety committee without NRC approval. However, the procedure and the records of surveillances and compensatory measures could be inspected by the region.
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