ML20211N405
| ML20211N405 | |
| Person / Time | |
|---|---|
| Issue date: | 08/19/1999 |
| From: | Spector A NRC (Affiliation Not Assigned) |
| To: | NRC (Affiliation Not Assigned) |
| References | |
| NUDOCS 9909100185 | |
| Download: ML20211N405 (45) | |
Text
I August 19, 1999 MEMORANDUM TO: File FROM: August K. Spector, Communication Task Leader inspection Program Branch (Original signed by:)
Division of Inspection Program Management Office of Nuclear Reactor Regulation
SUBJECT:
PUBLIC MEETING FIRE PROTECTION ISSUES JUNE 28,1999 On June 28,1999, a public meeting was held between the NRC and the NEl. The meeting summary (attachment 1), a list of attendees (attachment 2), an industry review of FPFI inspection findings (attachment 3), and a copy of written information exchanged at the meeting 1
(attachment 4) are attached.
Attachments: As stated
Contact:
August K. Spector ;
301-415-2140 l
}
Distribution:
D (Y )
Central Files PUBLIC llPB R/F
[tgg 3-[(-b
<c r g'? 2, A
g q M - b M c]- h4 DOCUMENT NAME: a:\62899mtgsum
- See previous concurrence.
To rGceive a copy of this document, indicate in the box: "C" = Copy without enclosures "E" = Copy with enclosures "N" = No copy OFFICE llPB:DIPM & IIPB:DIPM .. o l l l NAME AKSpector I) V WMDeanlL@f DATE Oh /1( /99 '/ pf/ [9 /99 I
/ OFFICIAL RECORD COPY 9909100185 990819 PDR REVQP ERONUNRC 97-/gp 1
4
)
@ Kito y 4 UNITED STATES g ,j t
NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20$fWW1001 k ,o 9***** August 19, 1999 MEMORANDUM TO: File FROM: August K. Spector, Communication Task Leader Inspection Program Branch /2cM Division of Inspection Program Management Office of Nuclear Reactor Regulation
SUBJECT:
PUBLIC MEETING FIRE PROTECTION ISSUES JUNE 28,1999 On June 28,1999, a public meeting was held between the NRC and the NEl. The meeting summary (attachment 1), a list of attendees (attachment 2), an industry review of FPFI inspection findings (attachment 3), and a copy of written information exchanged at the meeting (attachment 4) are attached.
Attachments: As stated
Contact:
August K. Spector 301-415-2140 l
l
m Meeting Summary June 28,1999 The staff presented a current draft of the fire protection baseline procedure and a "second round" of responses to stakeholder comments on the draft fire protection baseline procedure.
The staff stated that it had deleted a passage in the current draft stating that "the SRA's report will not focus on the validity of the modeling assumptions of the IPEEEs." The staff also agreed to remove a passage in the fire protection baseline procedure which referred to IN 97-48,
" Inadequate or inappropriate Interim Fire Protection Compensatory Measures" as inspection guidance in the area of compensatory measures.-
The staff presented a document titled " Determining Potential Risk Significance of Fire Protection and Post-fire Safe Shutdown inspection Findings Evaluation Guidance" intended for inclusion within the NRC Oversight Programs " Significance Determination Process"(SDP).
This document is a simplified rewrite of major portions of the staff's " Fire Protection Risk Significance Screening Methodology (FPRSSM). The staff stated that another portion of the FPRSSM, which provides guidance for designating inspection findings as having "high,"
" medium," or " low" risk significance, was being revised for inclusion in the Fire Protection Functional inspection (FPFI) Procedure (IP), currently being developed from the FPFI pilot program temporary instruction. [This FPFI IP !s planned to be issued to support the fire protection baseline procedure, licensee self-assessments and reactive FPFI teams.]
Approximately two weeks before the meeting the staff had provided NEl with se!seted pilot FPFI inspection findings for trial application of the FPRSSM by industry. The intent was to obtain information regarding the reproducibility of CDF computations under the Fire Protection Risk Significance Screening Methodology. NEl presented two licensee trial applications for comparison with NRC results. One industry application was essentially identical to the NRC application of the FPRSSM. The other industry application differed significantly from the staff's.
However, the source of the difference was easily identified as well-known fundamental technical disagreements between the licensee which applied the methodology and the staff regarding the rating of a specific fire barrier and the ease with which fire brigade members could gain access to a certain reactor plant area. The consensus conclusion regarding the FPRSSM was that, in the presence of resolved or agreed upon technical issues, it would provide reproducible CDF results.
The staff informed the stakeholders that the pilot plants for the fire protection baseline procedure had been identified as Ft. Calhoun (early August,1999), Harris (mid-September, 1999), and Salem (November,1999).
The staff agreed to provide NEl with an electronic copy of the draft fire protection baseline procedure after it had been revised with respect to compensatory measures as discussed above.
Agreed that future fire protection issues would be discussed at bi-weekly public meetings on oversight process.
Attachment 1
ATTENDEES Public Meeting June 28,1999 ME! ,
l I
Fred Emerson l
l NRR l Steven Stein Cornelius Holden Morris Branch Leon Whitney Steve West Pat Madden J.S. Hysly See-Meng Wong Peter Koltay Other David Perkey, NUSIS Philip Otwnt, GAO ,
Mary AN Krustichy, GAO Mike Callahan, Self Denis Shumaker, PSE&G l
l l
Attachment 2 j I
INDUSTRY REVIEW OF FPFI INSPECTION FINDINGS USING DRAFT FIRE PROTECTION SDP IF = 2.15
~FB=0 SSD = -1 l
- AD/AS = 0.0 D/MS = -1.0 FE -4.15
-0 = Self Propagating, No Suppression
' IF = -2.09 IF = -2.09 FB = 0 FB = -2 SSD = -2 SSD = -2 ADIAS = 0.0 AD/AS = -0.0 D/MS = 1.0 D/MS = - 1.0
-5.09 -5.09 l
l Attachment 3
SELECTED PILOT FPFIINSPECTION FINDINGS FOR TRIAL APPLICATION
- 1. INTRODUCTION AND GENERAL APPROACE For the following fire initiation scenarios, industry is requested to apply the FPRSSM process using all relevant information from the specified pilot FPFI inspection report.
The FPRSSM process includes the following steps: (1) a fire scenario is postulated; (2) the inspection findings (fire protection deficiencies) are grouped according to fire area, and then grouped within each fire area according to the particular defense-in-depth element which they impact; (3) the degradation of each defense-in-depth element is characterized qualitatively as severity level high, medium, or low (the severity levels correspond to specific numerical failure probabilities); (4) the failure probabilities are integrated with the ignition frecuencies to determine the overall change in CDF for each fire area; (5) using threshold values, the CDF change values are assigned to a performance band (e.g. licensee response band, increased regulatory response band, required regulatory response band). It should be noted that, in this process, sets of related inspection findings are assessed collectively to determine their synergistic impact on risk. For example, if the plant fire brigade is deficient and the i:tomatic fire suppression system in a fire area is deficient, the FPRSSM considers the adverse impacts of both deficiencies in its assessment of the overall fire risk in the fire area.
- 2. ST. LUCIE flR 50 335/98-201 and IR 50-389/98-201) 2.1 Main Control Room (fire area 70) ;
i The Unit 1 main control room (fire area 70) is located on elevation 62'-0". The main control ,
room (MCR) is separated from other fire areas by fire barrier walls, floor and ceiling systems having a 3-hour fire resistive rating. j 1
It is assumed that a fire has occurred in the main control board and the burning cables have l sufficient energy to result in a hot gas layer. The fire initiation frequency (IF) for the main control room is 1.5.5X10E-2/yr.
l There are sufficient ignition and fuel sources in the MCR to have a fire which is capable
- f producing a hot gas layer in either a electrical cabinet or in the MCR itself.
l 1
2.2 "A" and "B" Cable Loft Area l The "A" cable loft (fire area 44A) is directly over the chemical count room and instrumentation calibration room and is adjacent to the "IT" cable loft (fire area 55W). The B cable loft area is directly over the radiological chemical hot laboratory (RAB elevation 19'-6"). The west and south walls of the "A" cable loft are constructed from Thermo-Lag. These walls (which includes j a door and cable penetrations) are rated for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and 48 minutes. Primary fire mitigation j capability in these areas is the combination of automatic detection (ionization spot type detectors) and manual suppression (hose or portable fire extinguishers). These two areas contain the cables (power and control) for most of the required trains of post-fire safe shutdown ,
capability and safety related accident mitigation systems. i Attachment 4 i
I-E The fire load in these areas are high. Most of the redundant control circuits associated with the plant's safety functions are located within these two fire areas. The fuel sources in the "A" cable loft have sufficient energy to result in a fire that is capable of developing a hot gas layer.
The fire initiation frequency for the "A" cable loft is 8.1X10E-3/yr.
3.0 PRAIRIE ISLAND UNITS 1 AND 2 flR 50-282. 306/98-016)
The auxiliary feedwater (AFW) pump rooms (fire areas 31 and 32) are located on auxiliary building elevation 695'-0", center section. The Unit 1 turbine driven AFW and the Unit 2 motor driven AFW pumps are located in Fire Area 32 and Unit 2 turbine driven AFW and the Unit 1 motor driven AFW pumps are located in Fire Area 31. The boundaries of the two fire areas are fire rated for 3-hours with all fire barrier openings protected with 3-hour rated assemblies (e.g.,
! doors dampers). These fire areas share a common fire barrier wall. The common wall has a door opening that is protected by a tin-clad sliding fire door that is held open and is closed by a fusible link counterweight door closer. Both pump rooms are protected by automatic sprinklers and are provided with spot type ionization detection. The pump rooms contain motor control centers, cables, lube oil, air compressors, and various electrical panels. Therefore, these rooms have enough potential ignition and fuel sources available to produce a hot gas layer.
l It is assumed that, if the critical post fire safe shutdown functions are exposed to a fire environment, they will be susceptible to fire damage and loss of function.
The fire initiation frequency (IF) for AFW pump rooms is 4.5xE-3/yr. j l
l 1
l l
l
)
L - 1
l l
\n Pre-decielons!- Draft - Work In I Proaress Revision: Draft 2 (June 27,1999) J Determining Potential Risk Significance of Fire Protection and Post-fire Safe Shutdown inspection Findings Evaluation Guidance Fire Protection Engineering Section (FPES)
Plant Systems Branch (SPLB) and Safety Programs Section Probabilistic Risk Assessment Branch (SPSB)
Division of Systems Analysis (DSA)
Office of Nuclear Reactor Regulation (NRR) 1.0 Introduction The fire protection defense-in-depth (DlD) elements are:
- 1) Prevent fires from starting;
- 2) Rapidly detecting and suppressing those fires that do occur; and
- 3) Provide protection for structures, systems, and components important to safety so that a fire that is not promptly extinguished by fire suppression activities that it will not prevent the safe shutdown of the plant'.
A fire protection program finding can generally be classified as a weakness associated with meeting the objectives of one of these DID elements. As a result, the Fire Protection Risk Significance Screening Methodology (FPRSSM), a two phase screening methodology, was developed to evaluate the potential fire risk significance of a fire protection DID weakness (es) within a plant fire area that is important to post-fire safe shutdown.
Phase 1 of the FPRSSM is a screening method that is used by the resident or regional inspector to screen out fire protection finding (s) (e.g, impairment (s) to one or more fire protection features) that are not related to fire protection systems and features used to protect safe shutdown capability. The Phase 1 is used as an oversight process to monitor operational ,
I conditions affecting fire protection systems and features This monitoring process identifies conditions could have a potential impact on the capable to maintaining one SSD success pathe
' Fire protection features sufficient to protect against the fire hazards in the area, zone or room under j consideration shall be capable of assuring that necessary structures, systems, and components need to achieve and maintain safe shutdown are free of fire damage (see Section Ill.G.2a, b, and c of Appendix R to 10 CFR Part 50),
that is, the structure, system, or component under consideration is capable of performing its intended function during and after the postulated fire, as needed.
2 include SSD performance goals from Appendix R l 1
1 I
_s
h' Pre-decisional- Draft - Work in I Proaress free of fire damage.
Findings that do not screen out as result of the Phase 1 review are candidates which should be subjected to the more detailed Phase 2 analysis. The Phase 2 analysis evaluates the l synergistic impact that these findings may have on risk by treating them collectively to arrive at j . an overall quantification of the relative importance these findings may have on fire risk for the l affected fire area of concern Because of the integrated approach taken by the Phase 2
( analysis, this analysis is generally performed, with technical support from NRC fire protection l engineers and risk analysts, to get a better understanding of the potential fire risk significance posed by the identified fire protection DID Phase 1 finding (s).
.2.0. Purpose l
The purpose of this two phase screening methodology is to 1) focus resources on monitoring the performance and effectiveness of those fire protection mitigation features that are important
! to protecting post fire safe shutdown capability; 2) establish a threshold method (Phase 1 method is described in Section 4.0) which will assist in recognizing which fire protection mitigation finding (s) may have the potential to affect post-fire safe shutdown capability; and 3)
! - determine the relative significance of potential fire risk of observed finding (s) associated with i fire protection mitigation features and systems used to protect SSD capability by performing screening assessment (Phase 2 described in Section 5.0) of the as-found condition (s). The Phase 2 screening analysis portion evaluates the "as-found" conditions associated with each fire protection mitigating element of the fire protection DID philosophy (e.g., detection,
. suppression, and passive protection separating post-fire safe shutdown (SSD) functions) within each of the DID elements. The potential fire risk significance of as-found condition (s)is
! determined by performing an integrated assessment of the fire protection mitigation finding (s) and the potential impact they may have on SSD capability.
The Phase 2 methodology can also be used by a NRR fire protection reviewer or a regional inspector as an aid for determining the potential risk / safety significance of: 1) a fire protection design condition which deviates from the intent of the facilities licensing / design basis; or 2) a Generic Letter 86-10 or 10 CFR 50.59 engineering waluation documenting a change in the a licensee's fire protection program.
For the purpose of this guidance, weaknesses or findings will be defined as conclusions or factual observations of those "in plant" conditions which do not meet regulatory requirements, do not conform to the facilities operating license fire protection condition, or are considered to have risk implications due to a inherent fire protection / post-fire safe shutdown system design
- weakness.
3.0 Scope
. The scope of Phase 1 is to provide a process which can assists inspectors with making a l
determination as to whether a particular fire protection finding (s) is important to the protection of safe shutdown capability and has the potential of being risk significant.
2 1
mn -we-- + =
b i
Pre 4ecisional-Draft WarirInIProaress Fire protection DlD finding (s) that have been determined to have potential risk implications by j
the Phase 1 screening method are subjected to a Phase 2 review. The scope of Phase 2 is to
. provide a process for regional and headquarters fire protection engineers and risk analysts to further evaluate how a particular fire protection DID finding or set of findings affects SSD capability. In order to evaluate the potential risk significance, Phase 2 integrates the "as-found" degradation (s) or finding (s) and evaluates their potential affects on fire mitigation effectiveness and SSD capability. Phase 2 is focused on these specific areas of fire mitigation:
fire barrier effectiveness fire detection / automatic suppression systems effectiveness a manual suppression effectiveness a safe shutdown capability 4.0 Fire Protection Risk Significance Screening Methodology - Phase 1 l Not all plant fire protection systems and features are considered to be important to the l protection of post-fire SSD capability. The results of the fire IPEEE can provide a relative l- ranking of the plant areas that are the major contributors to fire risk. The top 10 areas identified I
by this IPEEE/PRA ranking are generally important to post-fire SSD. These plant areas also present the greatest challenges with respect separation of redundant trains of post-fire SSD
- capability, protection of this capability, and the ability to perform the operator actions necessary to achieve and maintain post-fire SSD conditions.
l Phase 1 consists of two steps. Step 1 is a screening evaluation of a fire protection finding or a 3
- set of findings and is intended to screen out a finding or findings that do not affect the !
- effectiveness of a fire protection DID element. For those findings that affect the effectiveness of one or more of the DID elements, Step 2 is performed. Step 2 integrates the findings SSD capability provided for a given fire area and then provides insights with respect to the potential importance that these fire protection findings have on maintaining one success path of SSD capability free from of fire damage The following steps describes the general process for implementing Phase 1. (See figure 4-1,
" Phase 1 Process Diagram")
Sten 1 Screenina of Fire Protection Findinas The Step 1 screening process is described by Figure 4-1. This process idwtifies those fire protection findings that affect the mitigation effectiveness of one fire protection DID element.
Generally, findings that affect the effectiveness of one or more of the fire protection DID elements have risk implications8 . Once identified, findings affecting one or more of the DID elements, require further screening in order to determine if they are potentially important to i
l l .
- Allowed outage times with the use of compensatory measures do not provide an equivalent level of fire safety to that of a fully operable fire protection system or feature. Long term use (greater than 30 days) of compensatory measures for degraded or inoperable fire protection features used to protect safe shutdown capability is an indication of inappropriate attention and resources being given to managing fire risk vulnerabilities.
3 l
.r.
Pre-deelslanal - DraR - Work In I Proaress maintaining one success path of SSD capability free of fire damage. This screening is performed by Step 2 below.
Making judgements regarding how effective a fire t,rigade can be in extinguishing a challenging plant fire requires an evaluator to have comprehensive understanding of manual fire fighting techniques and operations. It is not the intent of Step 1 to expect resident inspectors to have the expertise _to make fire brigade effectiveness and performance evaluations. In most cases, fire brigade performance can be important to mitigating a fire and reducing its potential risk and
- should be considered when performing a Phase 2 evaluation. Reliance on fire brigade performance and its effectiveness as a sole means of maintaining one success path of SSD capability free of fire damage is not viewed as an acceptable practice. In those cases where manual fire fighting (i.e., fire brigade) is used as the sole means to control and extinguish a fire, one success path of SSD capability is generally maintained free of fire damage by a passive fire barrier having a fire resistive rating of 3-hours.- In Step 2, where fire barriers or fire barriers in combination with an automatic fire suppression system are used as the primary protection j scheme for maintaining a SSD success path free of fire damage, manual fire fighting i performance or effectiveness is not a dominate protection element of the primary protection scheme. For those protection schemes that use passive fire barriers as primary protection, findings related to only manual firefighting or fire brigade effectiveness do not warrant the ;
pelformance of a Phase 2 evaluation. l l
Screenina Process Phase 1 (Sten 1) Floure 4-1 i
For a given Mre area, zone, or room under consideration No Clearty stated Degradation orimpairment of u No impairment or degradation DID element notlonger than the fire protection r of fire protection feature or DID N allowed outage time without the findings appropriate compensatory measure.
Yeslf I Screen Degradation or impairment of DID element existed for less 4 than 30 days with the appropriate compensatory 3I Yeslf Affects one of the following g, fire mitigation DID elements:
- 1. Detection and manual suppression capability A ygg
- 2. Automatic suppression Go to step 2 of Phase 1 capability
> No Screen 4
r Pre-decIslons!- Draft - Work in i Proaress Steo 2 SafetvImoortance Determination When findings affect one or more of the fire protection DID elements in a given fire area, zono, or room it is necessary to perform an additional screening, in order to implement this screening step and determine if the findings are potentially risk significance, the post fire SSD capability for the fire area, zone or room of concern and the fire protection schemes used to maintain one SSD success path free of fire damage will have to be determined. For those findings that do not screen a Phase 2 evaluation will be performed.
The SSD determination can be made by reviewing the plant's Fire Safe Shutdown Analysis
- (FSSA). Using the FSSA information, the method and equipment being used to achieve and maintain post-fire SSD for each fire area, zone, or room under consideration can be determined. In addition, the FSSA willidentify fire protection schemes used to protect the l analyzed SSD success path. Depending on the degree of physical and electrical separation provided for the various SSD success paths, different fire protection schemes are used to !
ensure that one SSD success path is free of fire damage. Figures 4-2 through 4-5 below, provides additional screening guidance for determining if the fire protection DID findings are potentially significant. If a question is not asked in one of the following figures about a DID
. principle along a specific screening path which screens, the assumption is that the degradations associated with the DID elements not being question are low. l l
l
< SSD system with redundancy (e.g., all high pressure reactor inventory control functions)is located in i
the area, zone, or room of concern. Remaining mitigation capability none. No additional recovery r capability exists for performing the essentIsl SSD functions external to the aren, zone, or room of concern.
MRE AREA BOUNDARY i Fire area. zone, or room of
! concem l
SSO Train A Function l
SSD Train B Function No remaining recovery capability exists for performing essential ssD functions external to the area, zone or room of concem.
Figure 4-2 For the SSD interaction as noted in Figure 4-2 above, there are three basic equivalent fire ,
protection schemes used outside of primary containment to protect and maintain one train of SSD capability free from fire damage. These fire protection schemes are:
l 5
g_u ._ . , _ _
_ _ _ _ __._ . a
L Pre-decisione!- Draft - Work in I Proareas Scheme 1 Provide a 3-hour fire barrier separation which either encloses one SSD train or provides wall to wall and floor to floor separation between the redundant trains,
! or; Scheme 2 Provide a 1-hour fire barrier enclosing one of the SSD trains. The area shall be protected by automatic fire detection and suppression systems or:
Scheme 3 Provide greater than 20 feet of horizontal separation between the redundant i SSD trains. The spacial separation between the ~ redundant SSD trains shall be free of intervening combustibles. The area shall be protected by automatic fire detection and suppression systems.
Determine which scheme is used.
Screenino Criteria for Flaure 4-2 l Yes- !
l is Protection Scheme 1 is 3-hour fire barrier separating m j r' redundant SSD functions affected 7 4
by finding Yes i perform Phase 2 i
No y <
Screen Yes No No screen '
is Protection A is 1-hour fire barrier that is the automatic fire Scheme 2 used encloses one SSD function N suppression system 4 affected by finding affected by the finding.
l Yes V V pedorm Phase 2 Yes perform Phase 2 Yes No is Protection Are combustibles is the automatic fire Scheme 3 used
+ located in the A suppression system combustible free zone affected by the finding No V
, is detection or fire brigade Yes ,
effectiveness affected by perform Phase 2 finding t
No Screen 6
F l
Pre-decisions!- Draft - Work In I Proaress l
l SSD system with redundancy is locatedin the stes, zone, or room of concern. Remaining :
mitigation capability Is recovery of one fire stfected SSD train (e.g. attemative shutdown method \
for the controlroom).
FIRE AREA BOUNDARY SSD TRAIN A l SSO TRAIN B Fire Area, zone, or room of concem l l
RECOVERY of ONE SSD Recovery actions taken outside TRAIN Figure 4-3 For the post-fire SSD interaction noted in Figure 4-3 above, there is generally one basic type of fire protection scheme used.
Scheme This scheme minimizes fire damage to the preferred SSD trains by providing automatic detection and fixed suppression in the fire area, zone, or room of concern (control room is an exception, no fixed fire suppression is provided). In addition, this scheme provides an alternative shutdown system that is electrically and physically independent of the fire area, zone, or room of concern.
Screenina Criteria for Floure 4-3 No No No Screen is fixed fire suppression Does fire barrier forming the is detection or fica system affected by A fire area boundaries interface 4 brigade effectiveness 4 finding with recovery areas. Are any affected by finding of these fire barriers affected by the finding y Yes V Yes . perform Phase 2 perform Phase 2 Yes y
perform Phase 2 7
Pre-decirlonal- Drstt - Work in I Proaress SSO system with redundancy is located in the area, zone, or room of concern. Remaining mitigation capability is a system with redundancy which is physicallyindependent of the fire stes, zone, or room of concern and is manually actuated under time constraints.
MRE AREA BOUNDARY l
SSD TRAIN A FUNCTION SSD TRAIN B FUNCTION Fire area, zone or room of concern Recovery system with redundancy which is physically independent of the fire area, zone, orroom of concem andis manuallyactuated under time constraints Figure 4 4 For the post-fire SSD interaction noted in Figure 4-4 above, there is three basic types of fire protection schemes used to protect one train of SSD from fire damage within the area of concern. These fire protection schemes consist of the following fire protection features and/or systems:
Scheme 1 Provide a 3-hour fire barrier separation which either encloses one SSD train or provides wall to wall and floor to floor separation between the redundant trains; or Scheme 2 Provide a 1-hour fire barrier enclosing one of the SSD trains. The area shall be protected by automatic fire detection and suppression; or Scheme 3 Provide greater than 20 feet of horizontal separation between the redundant SSD trains. The spacial separation between the two trains shall be free of intervening combustibles. The area shall be protected by automatic fire detection and suppression.
Determine which protection scheme is used.
8
I i
. i Pre-decIslons!- Draft - Work In I Proaress Screenina Criterle for Floure 4-4 Yes is 3-hour fire barrier is Protection Scheme 1 used
+ separating redundant SSD 4 No Screen functions affected by finding Yes lf is recovery system physically independent (separated by a 3-hour fire barrier) of the No fire area, zone, or room of concem and capable of being manually actuated under 4 perform Phase 2 !
the time constraints.'
)
Yes Y Screen Yes No m
is 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> fire barrier is the automatic fire No i is Protection Scheme 2 used + that encloses one Y suppression system Screen SSD function affected affected by the by finding finding.
Yes Yes 3g is recovery system physically independent (separated by a 3-hour fire barrier) of the fire area, zone, or room of concem and capable of being manually actuated under the time constraints.
II No Yes perform Phase 2 Screen s
s 9
Pre-decielonal- Oraft - Work In I Proaress Yes No No is Protection Are combustibles Scheme 3 used 4 located in the is the automatic fire
-A suppression system affected combustible free by the finding zone i I
l s
ifYes !
Yes Yes is detection or fire brigade effect eness affected by is recovery system physically independent (separated by a 3-hour fire barrier) of the fire area, Nolf zone, or room of concem and capable of being Screen manually actuated under the time constraints.
No II . Yes perform Phase 2 Screen l I
l SSD system with redundancy is located in the area, zone, or room of concern. Remaining i' mitigation capability is a system with redundancy which is unaffected by the fire and immediately available (automatic initiation or no time constraints).
MRE AREA BOUNDARY SSD TRAIN A FUNCTION SSD TRAIN B FUNCTION Fire area, zone , or room of concern Recovery system with redundancy remains unaffected by the fire and immediately available (automatic initiation or no time constraints).
Figure 4-S 10
p f- ,
l*
Ett-gtecisional- Draft - Work In I Proaress For the post fire SSD interaction noted in Figure 4-5 above, there is three basic types of fire protection schemes used to protect one train of SSD from fire damage within the area of concern. These fire protection schemes consist of the following fire protection features and/or systems:
Scheme 1 Provide a 3-hour fire barrier separation which either encloses one SSD train or provides wall to wall and floor to floor separation between the redundant trains; or.
Scheme 2 Provide a 1-hour fire barrier enclosing one of the SSD trains. The area shall be protected by automatic fire detection and suppression; or 1
Scheme 3 Provide greater than 20 feet of horizontal separation between the redundant l SSD trains. The spacial separation between the two trains shall be free of i intervening combustibles. The area shall be protected by automatic fire '
detection and suppression.
Determine which protection scheme is used.
I Screenina Criteria for Floure 4-4 l
Yes i No is Protection is 3-hour fire barrier Screen Scheme 1 used 4 separating redundant 4 l SSD functions affected by finding )
)
if Yes is recovery system physically independent (separated by a 3-hour fire barrier) of the fire area, zone, or room > No I of concem and capable of being automatically initiated perform Phase 2 or manually actuated under no time constraints.
1f Yes Screen I 1
l l
11 l
l l
y,_.-.-.-_-,_._._____ _ _ _ _ _ _ . , . __
l . ,
1 \
l I l Pre-decisional- Draft - Work In i Proaress Yes No la Protection is 1-hour fire barrier is the automatic fire No Screen Scheme 2 used that encloses one Y suppression system A SSD function affected affected by the finding by finding Yes Yes lf 1I is recovery system physically independent (separated by a 3-hour fire barrier) of the fire area, zone, or room of concem and capable of being automatically initiated or manually actuated under no time constraints.
Yes lf No Screen perform Phase 2 Yes No is Protection Are combustibles is the automatic fire No Scheme 3 used located in the 4 suppression system affected by +
combustible free zone the finding Yes Yes is detection or fire brigade Yes effectiveness affected by finding 1f is recovery system physically independent (separated No by a 3-hour fire barrier) of the fire area, zone, or room Screen of concern and capable of being automatically initiated or manually actuated under no time constraints.
Yes II perform Phese 2 12
Predecisional-DraN IVorkInIProaress 5.0 Fire Protection Risk Significance Screening Methodology- Phase 2 -
The FPRSSM is an integrated process that can be used to assess the relative risk significance of identified --
weaknesses in the fire protection DID principles in a given fire area, zone, or room under cortsideration. The following steps describe the general process that should be followed when implementing this methodology (see Figure 51. Fire Protection Risk Significance Screening Methodology- Process Diagram). In the case that a the Phase 2 method determines that the assessed findings have potential risk significance, Phase 3, which is a more refined analysis can be performed.
Rlng.1 Groucina of Fire Protection and Post-Ifre Sek Shutdown Findinas The specific fire protection inspection findings affecting the fire protection mitigation DlD features are grouped together for each specific fire area, zone or room under consideration. Then a area specific fire scenario needs to be considered and postulated to occur. Step 2 provides guidance for defining fire scenarios. Step 1 and Step 2 should be performed during an inspection in an integrated manner (i.e., observations of a fire protection degradation and the related fire hazards in the area of concem).
Sten 2 DeWne the Fire Scenerlo in order to properly support the FPRSSM risk estimates, the inspector or the reviewer will need to develop a postulated fire damage scenario which describes the fire and its potential for propagation (see inspection Procedure (IP) XXX, Fire Protection Functional inspection (FPFI), Appendix H for further guidance) within the fire area, zone or room under consideration. Under this postulated scenario, the inspector or reviewer will need to J make deterministic / qualitative judgements regarding the effectiveness of various degraded fire protection mitigation feature or systems and their ability to protect a post-fire safe shutdown path and maintain it free from fire damage.
Postulated fires involving fuel sources in an area under consideration are deemed meaningful if they are capable of developing a plume and/or a hot gas layer that has the potential to directly affect components of equipment that are important to safety, Sten 3 Qualitative Evaluation of Findinas Once the fire area, zone, or room affiliation for the various inspection DID findings and a meaningful fire scenario have been established, the individual findings have to be evaluated with respect to their ability to satisfy the performance objective established by the applicable DID principle. Upon making the determination of which DlD principles have been affected by the specific fire protection finding, a qualitative evaluation of each finding and its effects on accomplishing the DID objective is performed. It should be noted that many inspection findings can contribute to a degradation in a DID principles. For example, poor training, poor fire brigade / operational drill performance, improperty installed detection, and inadequate hose coverage of a fire area can all contribute to the degradation rating assigned to manual suppression. Therefore, in order to perform this step, the existing plant conditions noted by the inspection finding are evaluated against the deterministic / qualitative evaluation guidance and
, degradatiors categorization criteria established in IP XXX, Appendix H.
The output from this deterministic / qualitative evaluation, results in a degradation rating (DR) (e.g., High, Medium, or Low) being assigned to each DID element.
Rtng.g Asslanment of Quentitative Values From the Step 3. "Ocalitative Evaluation of the Findings," a DR is assigned to each DID element. Once the DR for
- the findings have been determined, they are quantified by assigning a value from lookup Table 5.1 that corresponds to the DOR for each DID element. l 1
1 13 l
1 i
Pre-decisional- Draft - Work In I Proaress Table 5.1 Quantification of Degradation Ratings (DR) of the Individual DID Elements
- Automatic Fire AinnvalFire Fighting Levelof 3-Hour Fire 1. Hour Fire Suppression Effectiveness Degradetion marrier Barrier Ettectiveness (Fire Brigede)
Outsido inside Control Control Room Room High 0 0 0 -0.25 -0.5 Medium 1 -0.5 0.75 -0.5 -0.1 Low -2 (door) -1 1.25 -1 1.5 Dependencies exist between certain DID elements. Those dependencies and their values are exprecsed in Table 5.2 below.
Table 5.i. Quantification of Dependencies between DID Elements Automatic Fire Suppression AtenualFire Fighting Adjustment Due to Ettectiveness Degradation Effectiveness Degradation Dependency Medium High +0.75 Low High +0.5 The above dependency is based on the fact that automatic suppression merely controls the fire, and the fire brigade is needed to extinguish the fire. The resulting adjustment has the effect of providing partial credit for automatic suppression when it has a low degradation and is paired with high degradation of manual fire fighting capability. No credit is provided for automatic suppression when it has a medium degradation and is paired with a high degradation of manual fire fighting capability.
Table 5.3 Quantification of Common Cause Contribution Between Sprinkler Systems and Manual Fire Fighting Hose Stations Automatic Fire Suppression Atanual Fire Fighting Adjustment Due to Common Effectiveness Degradation Effectiveness Degradation Cause Low Low +0.25 The Table 5.3 adjustment is made since a common water delivery and supply system exists both automatic and manual water based systems.
SteD 5 Determination of Fire lanition freauency The next step is to determine the fire ignition frequency for the fire area, zone, or room of
- Each of these values in Tables 5.1,5.2, and 5.3 and in the criteria for determining the potential risk
(
significance are approximately exponents of 10, 14 l
l
[, . . . _ . . . _ _ _ _ _ - _ _ - _ . _ . .
l =
l Pre-declefonal- Oraft - Work in I Proaress concern. If an fire ignition frequency can be obtained for the specific fire area, zone, or room of I
from the plant specific IPEEE, it should be used. However, if the IPEEE does not provide it, then it may be selected for lookup Table 5.45 Note that the ignition frequencies for a building will be conservative when assigned to a fire area within the building since several fire areas can comprise a building.
Table 5.4 - Generic ignition Frequencies Plant Buildings or Rooms Building orRoom ignition Frequency (IF)
Control Room 7E 3 Cable Spreading Room SE-3 Diesel Generator euilding 6E-2 switchgear Room 1E-2 eattery Room 3E 3 to 1E-2 Reactor Building 3E 2 Auxiliary Building 6E-2 Turbine Building 6E 2 Containment 9E-3 Stoo 6 Lntearated Assessment of DIO Findinas (excludina SSO) and fire Ianftlon Freauency Once Steps 4 and 5 have been completed, then the respective DID findings for a given fire area, zone, or room are assessed collectively by summing, using the following formula, the fire ignition Frequency (IF) and the DR for each of the fire protection DID elements. This value is called the Fire Mitigation Frequency (FMF) and inputs into the SDP process to determine the change in risk.
FMF = IF+ FB + MS +AS+CC (when appropriate)
Where IF = Fire ignition Frequency FB = Fire Barrier MS = Manual Suppression / Detection l AS = Automatic Suppression / Detection CC = Dependencies / Common Cause Contribution Table 5.6 below provides the association between the FMF and the approximate frequency in Table 5.7 (Same as SDP Table 1 - Estimated Likelihood for loitiatin Event Occurrence During Degraded Period ).
5 Generic ignition frequencica for specific buildings or rooms are provided in lookup table Table 4.4a (taken from AEOD data base, NRC *Special Giudy: Fire Events O- Feedback of U.S. Operating Experience Final Report,."
June 19,1997). ,
15 i
l l
~
I l
l Pre-decisional- Orsft - Work in I Proaress Table S.6 AssocIntion of FMF to Table 5.7 l (SDP Table 1) approxirnate frequencies for Calculation of 1 DeltaCDF Fire Mitigation Frequency Table 5.7 - Approximate Frequencies (FMF)
FMF > -2 1 por 10 to 108
-22 FMF >-3 1 per 10' to 108
-3 2 FMF >-4 1 per 108 to 10'
-4 2 FMF >-5 1 per 10' to 10'
-52 FMF >-6 1 per 10' to 10' FMF 5 -6 Less than 10' The approximate frequency (same as FMF) is adjusted in Table 5.7 by the time that the degradation existed. In practice, as part of the initial assessment, we expect the inspector to assume that the degradations are simultaneous, and all occur for the length of time associated with the longest degradation. This is a conservative approach, and if desired, can be refined. To adjust the time of the degradation, a letter is selected based on the degradation time from the lookup Table 5.7. The degradation of 3-30 days decreases the frequency by 10, and the degradation of less than 3 days decreases the risk by 100.
l 16
Pre-decisione!- Oraft - Work In I Proaress Table 5.7 (Same as SDP Table 1)- Estimated Likelihood Rating for Initiating Event Occurrence During Degraded Period (taken from NUREG/CR-5499)
Approx. Freq. Example Event Type Estimated Likelihood Rating
>1 per 1 - 10 yr Reactor Trip A B C Loss of condenser 1 per 10- 102 yr Loss of Offsite Power B C D Totalloss of main FW Stuck open SRV (BWR)
MSLB (outside entmt)
Loss of 1 SR AC bus Loss of instr /Cntri Air Fire causing reactor trip 1 per 10 108 yr SGTR C D E Stuck open PORV/SV RCP seal LOCA (PWR)
MFLB MSLB inside PWR cntml Loss of 1 SR DC bus Flood causing reactor trip 1 per 108 10' yr Small LOCA D E F Loss of all service water 1 per 10' 108 yr Med LOCA E F G l Large LOCA (BWR)
<1 per 108 yr Large LOCA (PWR) F G H i ISLOCA Vessel Rupture
> 30 days 30-3 days <3 days Exposure Time for Degraded l
Condition l
Steo 7 Intearation of Adlusted FMF with SSD l
The FMF which has been adjusted by the length of degradation represents the integration of IF with the DR associated with each of the fire protection DlD elements. In this step FMF is integrated with .
the SSD capability that is free from fire damage and its implementation is unaffected by the fire.
U Fire damage has the capability to induce a transient, such a Loss of Cooling Accident (LOCA), or a loss i of reactor water makeup function. Assuming a postulated fire scenario, the sequences corresponding to I the appropriate initiator that are impacted by the inspection finding (s) are evaluated using Table 5.8 (Same as SDP Table 2), Risk Significance Estimation Matrix.
i i
in the FPRSSM, the CDF associated with the impact of the DID findings is strictly what is calculated.
However, for purposes of using this model, the CDF due to DID findings will be considered as the ACDF.
This is conservative since the CDF due to the DID findings is greater than ACDF. Note that in the j columns of SSD as the mitigating equipment increases in table 5.8, failure probabilities decresse by a j factor of 10. I l
17 l ,
t _ _ . _. _
e n n e d d d d w o e e n e e e e t
i e e o R R R R ll e
h r r n )
Y W G G
_ 7
(
f o n yi w e n n n e e r a d d d lo it e er v t ) e e e h e e e 6 R R R le r r r od ce l
( Y W G G G ei Rfa i
i x
r -
n t a
h io M it yta e )s _
n wc umt n t n e n n n n n w o iar R
O mdar e
aci nl et t
iar )
5 d
e d
e lo le it h
ee e
e e
e e
e i
t a
t t suads
( R R W
r r r r 1
yd un n Y G G G G m y 1 senu r a o c i
t s
t i
l i (
m E b e e) pP c aD n .
a CS f
o n -
y o c -
nf o r it i o e ia f i
i3 v o h i t
n n n n n n .
t a2 c it n d w e e e e e e g
R yi ) t ip t
ie g
e ri n O wcc niet n s
R e lo le ih e r e r e r
e r
e r
i S
MS t +ar maami t
) Y W G G G G G k s
gm idn t tedmia s n nn t r oots 4
( i 8
a s ion r le yut R 1 s sd u e
r iFnr 1t fia 1 r( ear oc o )
a a( 2 or m
e l e
P R s b i n h + a n ia it yf e n n n n n n T
I kr t
r e R wcon mayan i w
lo it h
e e
e e
e e
e e
e e
e e
P D
o s O r r le r r r r r r r
e edet )
3 Y W G G G G G G S W iv t
s yuoe nvd ( s d sdcl a r eea i
t f
a 2 1 rf e r m D a l
- S
(
a hy n
- c f on e n n n n n n n 8 o 1 wna R e ya i
it e e e e e e e 5 i
s + ) h e e e e e e e i
ce ie nmdn O s+et r
e noe svd r r 2
(
W G r
G r
G r
G r
G r r G G r
l e _
at u iv b d- t r sdye dia cl i a e 1 sr 2t r rf ea T -
r P -.
y e s c s mh it n n n n n n n n n e
r s R tewad ) e e e
e e e e e
e e
e e
i n v i e e -
O sh y n 1
(
e r r e
r r r r r r da r s cu G G G G 3 t ad G G G G 2 2e e r d p )P _
g oe D t
intn oS S t h a Ee vleimf A B C D E F G H o o -
i t
i I
n k r2 iF
_ L(2 _
Pre-decialonel- Draft - Work In I Proaress Stoo 8 - General Rules for Analvina FPRSSM Since a fire barrier failure is represented by a probability, the ACDF is a combination of two contributions: a contribution where the barrier fails, and one where the barrier succeeds. Table 5.1 can be used to calculate both of these terms. For purposes of discussion, the term referring to the case where the barrier falls will be called the double room term (DRT) and the case where the barrier j succeeds will be called the single room term (SRT). The SRT and DRT are shown by the figure below, i Single Room Term (SRT) Fire Barrier Prevents Firm! Smoke Propagation Fire Area C Fire Area B SSO Train A S SD Train B 3-hour fire barrier (fire barrier Fire affected area successful. No fire / smoke impact
'on Fire Area B Double Room Term (DRT) Fire Barrier Falls to Prevents Fira/ Smoke Propagation Fire Area B Fire Area C SSD Train A SSD Train B Fire affected area l
l h 3-hour fire barrier fails (Fire / smoke i impacts Fire Area B) '
The safe shutdown (SSD) equipment failed for the SRT is the combination of mitigating equipment, associated cables, and actions in fire area C alone. The SSD equipment failed for the SRT is the combination of mitigating equipment, associated cables and actions in C alone.
As a result, the SSD DOR in Table 5.1 can be different depending on whether the SRT or DRT is calculated. Note that the mitigating equipment for the DRT is a subset or can be equal to the mitigation equipment for the SRT.
However, both the SRT and DRT are not needed in all cases. The following rules provide guidance on when to use these terms. SSD/SRT and SSD/DRT should be calculated or estimated for the entire i
19 i
s e
Pre-decielonel-Draft WorkinIProaress initiator for the fire area (s) for the following comparison:
Rules:
(1) if SSD/SRT = SSD/DRT and the only finding is against a fire barrier, Delta CDF = 0.
(2) if the fire barrier has a high degradation and rule #1 doesn't hold, just use the DRT to calculate Delta CDF.
(3)if the fire barrier has a medium degradation and rule #1 doesn't hold, For 3 hr. barrier: use only DRT if SSD/DRT is greater than or equal to 10 times SSD/SRT For 1 hr. barrier: use only DRT if SSD/DRT is greater than or equal to 3 times SSD/SRT Otherwise use SRT + DRT l (4)if the fire barrier has a low degradation, For 3 hr. barrier: use only SRT if SSD/DRT is not greater than or equal to 100 times SSD/SRT Otherwise, use only DRT For 1 hr. barrier: use only DRT if SSD/DRT is greater than or equal to 10 times SSD/SRT Otherwise, use SRT + DRT Once it is established which terms (DRT, SRT) are needed to calculate Delta CDF, these terms are calculated on a sequence by sequence basis, such that the appropriate credit for SSD is given to each sequence.
Step 9 - Modifications necessary to add impact of spurious actuations The decision to use the SRT, DRT, or both terms is made prior to consideration of spurious actuations.
However, once this decision is made, the impact of spurious actuations on SSD should be added .
provided the spurious actuation (s) increases the severity of SSD by at least a factor of 10. If the I spurious actuation (s) pass this test, then a factor of -1 should also be added to the FMF to account for the probability of spurious actuation (s).
l 20 i
s d
g n n y a d c s n i
d n g D a n e n S M g u i d S
_ i q n S n
)M F )
s g s e e i F h S i d
S n m n u F r
it R P n So Ri a e
id in la V
n io D
I D F w F g
i s f
sn t k F e M n tpi o Pc is T f v
it n
f o F iy ei t Fe r s o it ig t n cd
( p in r e s n a e ey d
e lp p cn ys s t g io io it l
a ir mc t s A aoc gn e r 2ar i n r a
n t
a u F ssen j u r e oI u eu f 2 Q e o e s squA x e n f o d f t l n t
a sq a s c ad %fbo c f n s ne oo di f e
ha S
e E
v t
o n io arf se f o le u
err c _
nt e t a n io itolan otc PeH g ir F
v e in dn e o o R L c -
he ap n it a m t it l a
t / ip e n m ai a r eo r it _
t ig e r l
a u in t
i la g r e gn g e MrP it mt h n o r
f e u iss t
e eg i e n e _
eo f o G D Q A D t
Ine t
In G g ig r inre ir s - - - - - i e F f
a 1 2 3 4 5 6 7 8 nF i f o er R p p p e
p p p p p _
e f na (
t e te t t e t e t e t e t e _
S S S S S S e o ioe _
t v S S _
r Sc c e ci t ei psn s e e n n es e s
cnia I
n _
c e _
aif y ic 1 _
cn 2 l
s e s i g
e f g r
e i i O a nS g
or g N n P i k E i Ss i I
n kR g kr il s k in W
o Ria t isr d s iu nl t
t
- nnoe i f
e r
f t
per s
f a it f o e D
r t
cePo w y n
cc ne a
t
_ - t f ie b ) o m v
o r o r t l
e d it os a r e o a nse n i t n in o Ps E f
i t
n c
e o s s l
s e s E e p m es I
r e E P id s it c
e r
e d
oa ic n t
e e For t
M s n o d en i
r R o l p e ef i r 1 P it 1 a n e c n
se nr P a
- 5. P n ns v
r e si o ir f a ed c
eo ri t on it o b
e s t he r g I yog f
t r
o p
in La ua gn ci ep p
t
/o Pr in i m
ii sm s g o n e t y
n inu n e
_ Fmr r s oa s i d
in t
n e S r
c f
S e
a e e
e f nd f d - s r t
e on nsr is 1 g
- c D
ia t
as r t ioo t t cc (
e r pi n ed 2
p e
y S s
ah ee n e
t t pg pp Sf i S
ei r s ss nn Y Pi n
_ ii
r e
Pre-decIslonal-_ Oratt - Work in I Proaress Attachment 1 Appilcation of Fire Protection Risk Significant Screening Methodology to Hypothetical Case Studies Case 1: Cable Screadino Room A single CSR exists in a plant. The CSR is located adjacent to a fire area which contains the RSP. / 3-hour barrier separates the two fire areas. The CSR has an automatic carbon dicxide suppression system. A fire scenario can be developed which will damage cables and expose the barrier to fire. The ignition frequency for the CSR is SE-3/yr.
Example 1 A.
The 3-hour wall has a high degradation. The automatic carbon dioxide suppression system has a high degradation. The fire brigade has a medium degradation. Each of these degradations have lasted longer than 30 days.
Since the barrier has a high degradation, only the DRT is used for SSD. No credit is given for i SSD for the DRT since no equipment or human actions (RSP) exist to mitigate core damage outside of the two areas separated by the degraded barrier.
The fire mitigation factor (FMF) = IF + FB + AS + MS where IF = ignition frequency FB = fire barrier ,
AS = automatic suppression / detection 1 MS = manual suppression / detection Thus FMF = -2.3 + 0 + 0 - 0.5 = -2.8 l l
Thus you enter Table 1 of t.ie SDP where the Approx. Frequency = 1E-2 to 1E-3. Degradation l is greater than 30 days. Therefore, choose C from the table. i The SSD has been determined as none for the DRT. Therefore, select the appropriate column from Table 2 of the SDP. As a result, the color representing the change in CDF is Red.
)
Example 18.
22
_ _ _ . . . , . . . _ _ _ _ _ _. . - . . . - )
~
Pnnsocisione! - Droit - Worir In I Proareas
' Suppose the 3-hour wall has improved to a medium degradation. All other degradations remain the.same. SSD for the SRT is 1E-1 due to the RSP which is a factor of 10 less than SSD.for the DRT. Therefore, we can still only use the DRT.
Thus FMF = -2.3 - 1 + 0 - 0.5 = -3.8 Enter SDP Table 1 in Approx Freq 1E-3 to 1E-4. ~ Since they all last longer than 30 days, choose D from Table 1.
Given SSD equal none still, Table 2 still produces Red.
Examole 1C. >
Suppose the 3-hour wall and automatic suppression are repaired such that no degradation
- exists in either. The manual suppression continues to have a medium degradation.
Since the 3-hour barrier only has a low degradation, we need to check the relationship
- between SSD/DRT and SSD/SRT. SSD/DRT is not greater than 100 times the SSD/SRT, therefore just use the SRT here.
Thus FMF = -2.3 + 0 - 1.25 - 0.5 = -4.05 Enter SDP Table 1 in Approx. Freq 1E-4 to 1E 5. Since all degradations lasted longer than 30 days, choose E from Table 1.
Given SSD is equivalent to the human recovery of a failed train Table 2 produces a White.
- Case 2: Auxiliarv Feedwater Room A AFW fire area contains a TDAFW pump. The only other AFW pump, the MDAFW pump, is located in a different fire area. Its cabling runs through the AFW room, but is protected by a 1-hour fire barrier. The AFW room contains an automatic sprinkler system. The cable for the -1 MFW pumps have not been traced. The ignition frequency for the AFW room (excluding that !
equipment protected by the 1-hour fire barrier) is 3E-3/yr. j i
in this case, the initiator that the fire produces is a transient. Loss of AFW, and no credit for MFW means that the dominant sequences will be those which have those failures. The two !
sequences which are dominant given the transient initiator are (1) loss of AFW, loss of MFW, j
- and loss of feed and bleed and (2) loss of AFW, loss of MFW, and loss of HPR. Each of these ;
sequences will need to be evaluated for the AFW room since fire failures impact these j sequences. 1 High pressure injection is not located in the AFW room, and therefore feed and bleed is available after the fire. The RHR which provides cooling for the sump after feed and bleed i operations, and feeds into high pressure injection for high pressure recirculation, is not located l in the AFW room either.L Therefore, HPR is available also. I 23 i
Pre-decisional - Oratt - Work In I Proaress Examole 2A
. The 1-hour barrier has a high degradation. The automatic sprinkler suppression system has a high degradation. The fire brigade has a medium degradation. Each of these degradations have lasted longer than 30 days.
- Since the barrier has a high degradation, only the DRT is used for SSD.
For sequence 1, the SSD/DRT is 1 train due to the feed and bleed. For sequence 2, the SSD/DRT is 1 train due to HPR.
The fire mitigation factor is the same for sequences 1 and 2. It is:
FMF = -2.5 + 0 + 0 - 0.5 = -3.0 j For each case, table 1 produces D.
For both sequence 1 and 2, table 2 produces a White (since each sequence has 1 train as ]
SSD/DRT). Therefore, example 2A produces 2 Whites for the AFW room.
Examole 2B Suppose the 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> barrier is repaired. Therefore, it has a low degradation. The automatic sprinkler system and the fire brigade continue to have the same degradations as in Example 18.-
The fire mitigation factor is the same for sequences 1 and 2. It is:
FMF = -2.5 - 1 + 0 - 0.5 = -4.0.
Therefore, choose E from table 1 of SDP.
To decide whether a DRT, or both the DRT and SRT is needed, compare the SSD/DRT with SSD/SRT. SSD/DRT has already been calculated above for both sequences.
For sequence 1, SSD/SRT is made up of the MDAFW and feed and bleed, which are two diverse trains. For sequence 2, SSD/SRT is made up of MDAFW and HPR, which are again l
' two diverse trains. The SSD/SRT for both sequences is the same again.
Therefore, in each case SSD/DRT = 100 times SSD/SRT. Thus the DRT is the only term needed for sequences 1 'and 2. The SSD/DRT was 1 train for both sequences.
Therefore, from table 2 of SDP, each of sequences 1 and 2 produces a Green. Rules for adding Greens are under development. Addition of Greens may become a White.
l t
24 I
1 NRC Responses to Second Round of Stakeholder Comments on Draft FP Baseline
( Prepared by: Leon Whitney, FPES/SPLB/NRR/NRC Prepared on: June 10,1999 Industry Comment:
Inspection basis (last sentence) is inconsistent with the objective:
l The last sentence of bases "This inspectable area verifles aspects of the initiating events and Mitigating Systems cornerstone for which there are no performance indicators to measure performance" confilcts with the final phrase oi the inspection objective " ensures that procedures, equipment, fire barriers, and systems exist so that the capability to safely shut down the plant is ensured."
The inspection bases indicates that the " conventional" fire protection aspects are i
to be inspected while the objective indicates that both the " conventional" and the
" App. R FSSD" aspects are to be inspected.
l ' NRC Response: " Mitigating Systems," as defined within the NRC's New Reactor Oversight Process, includes (in general) protection against external events including fire, and (in particular) nuclear plant fire protection: fire barriers, fire detection, fire suppression, and post-fire safe shutdown capability (the Oversight Program's initiating Events Cornerstone includes control of ignition sources and combustible material].
1 Industry Comment: j l
1 I
02.02.b appears to be demanding that we have an unannounced fire drill in a high risk area at a time of their choosing:
Ultimately the Intent of the comment was to have the Inspection module make it clear that a fire drill ja a required ; ment of the inspection for the licensee (as i indicated by the NRC response) A:a that requiring it to be unannounced in a {
specific location will have a resource impact on the licensee. An unannounced fire drill is one for which the time and location are totally unknown to the drill l participants and is a requirement of the program, as each fire brigade / member is l l required to participate in a minimum number of drills at a specific frequency including unannounced drills. To alter the scheduling to have an unannounced drill in the specific week can upset the normal drill scheduling. This is not to say the sites will not do this but to Indicate that it is not a no impact request. As to high risk area, most plants will have only a few (5-6) areas that would be considered high risk in a PSA sense. Other areas such as lube oil storage areas would have a significant conventional fire risk or hazard. Normally all plant power block areas are covered in the FSSD analysis, so all fire areas are " plant l areas that could require the conduct of a post-fire safe shutdown".
1 I
i Triennial general guidance, should say pick a different high risk area than the i previous inspection, to be most comprehensive should also include a sampling check of lower risk areas. Otherwise the utilities will do a " teach *'io test" and rigorously keep the high risk areas at 100% and let other medium and low areas degrade: l The comment was intended to aid in the eventual review of ine full breadth d fire areas of a plant, reducing the potential to have that inspection team re-rsview an area previously inspected and found acceptable. Unless there is an explicit 1 statement to vary the areas inspected from the previous inspection, the same areas could indeed be chosen as the selection criteria would be the same. The only difference driving choice of a different area would be industry or site specific events triggering a need to review a specific area different from the previous inspection (such as the JAFitzpatrick hydrogen fire triggering inclusion of a site's hydrogen storage area in the scope of the inspection).
NRC Response: The baseline procedure guidance for development of the triennial team's inspection plan charges the team leader with taking into account " previous industry problems and reactor events," and also considering the " scope of previous fire inspections, so that the inspections are not repetitively focused on the same areas or fire zones."
Please note that all NRC inspection procedure inspection requirements are requirements upon the inspectors, not the licensees. The inspection Requirements section of the baseline has been rewritten and now states "The triennial inspection may also include ... observation of a fire brigade (and possibly offsite fire department) drill for a simulated fire in a high risk area." Note the use of the word "may," which gives the inspection team the freedom to credit recent, closely observed fire brigade drills or actual responses. Note also that there is no mention in the revised wording of whether the drillis announced or unannounced. The NRC believes that licensee conduct of a fire drill during a triennial inspection is of small regulatory impact relative to the NRC's need to onfirm the credibility of that aspect of nuclear fire safety.
The Inspection Requirements section of the baseline continues to require the resident inspectors to " observe a fire bridgade drill (preferrably in a high risk area), or actual response of a plant fire brigade in any plant area," providing the resident inspectors with the flexibility to observe fire drills or actual fire responses throughout the reactor plant, but maintaining NRC emphasis on nuclear fire safety.
Industry Comment:
03.01/2 include the referenced information from the FPFI module to allow this to be self sufficient:
The commenter's impression was that the routine and triennial inspections in this draft module would, under the new assessment process replace the FPFl. If this were true having a inspection module that would be used as only an information source for other modules and not as a stand alone inspection implementing document did not make sense. If the FPFI la not being superceded by this
module, a reference to its use and place in the hierarchy would be appropriate in the beginning of the module. Ex. The FPFI modulo XXXXX is used in the evaluation of y cornerstone degradation evaluation, not this module. This would clarify the relationship of the modules like the relationship of the plant status module to this module referred to in the specific guidance 03.01.
NRC Response: The NRC plans to issue the FPFI " draft temporary instruction" as a permanent inspection procedure (IP) to (1) provide the triennial team with a detailed source of inspection conduct processes and inspection lines of inquiry and guidance, (2) provide the NRC with a standby procedure for the conduct of major fire protection team inspections in reaction to degraded licensee performance, and (3) provide licensees with a potential and voluntary basis document for fire protection self-assessments (as l requested by industry during the November,1998 FPFI Workshop. As part of its preparation to issue the FPFI procedure as an IP, the NRC is currently revising the FPFI procedure to emphasize its modular nature, so that selected portions of it can be readily utilized in other than full-scope major NRC team inspections.
Industry Comment:
03.02A should also request supporting calculations:
The calculations referred to in the comment are not the supporting calculations for the IPEEE, but the supporting calculations for the FSSD analysis such as structural steel calculations, hydraulic calculations for sprinkler systems etc. and are intended to be included in 3.02a, inspection preparation not 3.02b, fire risk report.
NRO Response: Detailed engineering calculations are not normally requested during inspection preparation activities. Such calculations typically are selectively requested by the inspection team when and if it is determined that such reviews are necessary.
Industry Comment:
03.02b the inspection results and non plant specific fire event information have little to do with ranking fire areas according to risk and so should not be the j responsibility of the SRA to acquire / address: ;
i This information, while possibly useful to the SRA is not Information that requires ;
his/her specialized training to acquire , and therefore should be provided by a !
more generalized person to the SRA, i.e. the inspection results for the site as related to fire issues could be extracted by the site resident inspector. The intent of the comment was to conserve the limited SRA resource.
NRC Response: No guidance is provided in the baseline procedure to the triennial inspection team on the practical aspects of obtaining specific documents or information.
- Further, which team members are involved in obtaining the information resources described in the baseline procedure are not stated. Typically, information acquisition is !
worked out between the team leader and licensee representatives through the issuance i
l
p-of a pre-inspection letter to the ::censee, discussions during the information gathering site visit and conference calls, l
l
)
l
R Draft- i INSPECTABLE AREA: Fire Protection CORNERSTONES: Initiating Events (10). Mitigating Systems (90)
INSPECTION BASES: Fire is a significant contributor to risk. In many cases, the risk due to fires is comparable or exceeds the risk from internal events. Fire protection defense-in-depth is accomplished through control of combustibles and ignition sources, mitigation of fires that do occur through fire detection and automatic and manual suppression capability, and a well l analyzed and implemented post-fire safe shutdown capability. Safe shutdown capability j includes the existence of adequate fire barriers to establish the fire area or fire zone '
configuration and to ensure the shutdown equipment functionality assumed in the post-fire safe shutdown analysis. If defense-in-depth is not maintained through a well functioning licensee fire protection program, post-fire safe shutdown of the plant may be challenged. This inspectable area verifies aspects of the initiating Events and Mitigating Systems cornerstone for which there are no performance indicators to measure performance.
LEVEL OF EFFORT: On a monthly basis, the resident inspector will tour high fire risk plant areas to assess: control of transient combustibles and ignition sources, operability and availability of fire detection, manual and automatic suppression capabilities, and barriers to fire propagation (e.g., fire doors, fire dampers).
In addition, every 3 years, an inspection team consisting of a fire protection engineer, a ;
mechanical engineer, and an electrical engineer will conduct a one week, risk-focused, onsite !
inspection of all three components of defense in-depth, with emphasis on post-fire safe shutdown capability and configuration management, but including review of fire protection administration and fire protection systems and features.
01 INSPECTION OBJECTIVE l
The inspection objective is to assess whether the licensee has implemented a fire protection program which adequately controls combustibles and ignition sources within the plant, provides adequate fire detection and suppression capability, and ensures that procedures, equipment, fire barriers, and systems exist so that the capability to safely shutdown the plant is ensured.
02 INSPECTION REQUIREMENTS 02.01 Routine insoection. The resident inspector's assessment of the licensee's control of ;
- transient combustibles and ignition sources is addressed on a more frequent basis in the Plant
[: Status inspection procedure. Select high fire risk areas based on the plant specific risk l information matrix or the generic RIM 2 document for the subject reactor plant. (It is planned L that risk information will be contained in an attachment to Manual Chapter 2515 of the new NRC reactor oversight and inspection program.)
i L
L
l Draft j
- a. Monthly the resident inspector will tour high fire risk plant areas to assess the operability and availability (but not necessarily the design) of fire detection and ,
manual and automatic suppression capabilities and equipment and barriers to l' fire propagation, and fire protection related compensatory measures.
- b. ~ Annually the resident inspector will observe a fire brigade drill (preferrably in a high risk fire area), or actual response of a plant fire brigade in any plant area. )
l l
02.02 Triennial Insoection. Conduct a one-week triennial team inspection of the licensee's fire protection program emphasizing post-fire safe shutdown capability and configuration management, but including review of fire protection administration and fire protection systems and features. i l a.- Inspection Preparation: The inspection team leader will manage and coordinate a 2-3 day information gathering site visit accompanied by the team members and the senior reactor analyst (SRA) designated to support the team. The SRA will provide a report to the team leader containing plant specific fire risk results. The team leader will use the fire risk results report and input from the other team members to develop an inspection plan. 1
- b. Inspection Conduct: The inspection team leader will manage and coordinate the conduct of a one week triennial fire protection inspection emphasizing post-fire safe shutdown capability and configuration management. The inspection should be either plant area-based or system-based, depending on the structure of the licensee analysis. The triennial inspection may also include observation of a simulated post-fire safe shutdown from outside the control room (e.g. from a remote shutdown panel and/or remote control stations, or possibly at a remote shutdown panel associated with the plant simulator), and observation of a fire brigade (and possibly offsite fire department) drill for a simulated fire in a high risk area.
INSPECTION GUIDANCE:
General Guidance Triennial Insoection. The purpose of this triennial team inspection procedure is to selectively review the fire protection program at the subject reactor plant, in one week the inspection team can not possibly confirm the post-fire safe shutdown capability of the equipment necessary to provide all safe shutdown functions in each plant fire area. Rather, as described below, the team should use all available plant-specific risk, event, and technical information (including the results of licensee self-assessments) to confirm safe shutdown capability (i.e. post-fire existence of all safe shutdown functions) for fire scenarios in from one to five selected and prioritized plant areas, rooms or zones. In addition, the team will assess the design adequacy of fire protection systems and features and fire protection program administration (including administrative controls such as compensatory measures and fire brigade response and capabilities).
Draft General topical areas for team member review during preparation are: the power plant's design, layout, and equipment configuration; the current licensing basis (i.e., fire protection regulatory framework); and the licensee's strategy / methodology for accomplishing post-fire safe shutdown. Additionally, prior to the site visit (and using any modification packages obtained during the information gathering visit), the team members should become knowledgeable regarding plant design changes or modifications implemented since the plant's post-fire safe shutdown capability was last reviewed by the NRC staff.
Specific Guidance 03.01 Routine insoection. Fire prevention is the most important attribute of a fire protection program. Consequently the prevention attribute is addressed in the more frequently performed Plant Status procedure.
- a. Monthly: This inspection should not attempt to address all high fire risk areas each month. It should focus on one or possibly two plant areas and concentrate on the operability of the detection and suppression systems and fire barriers for the areas. The monthly is not intended to perform a design review for that area.
The Specific Guidance Section and Appendices A and B of the referenced draft FPFI inspection procedura provide guidance for how to review the fire detection and manual and automatic suppression capabilities, and barriers to fire propagation.
Compensatory measures are put in place to compensate for degraded detection, suppression, safe shutdown or fire barrier features. The compensatory measures should be adequate to compensate for the degraded function.
- b. Annual: Fire brigade response is the major component of manual fire suppression at commercial reactor plants. The attributes that are important to consider for evaluating fire brigade performance are contained in the Specific Guidance section and Appendix A of the referenced draft FPFIinspection procedure.
03.02 Triennial Insoection.
The triennial inspection is intended to provide a risk focused look at the three components of defense-in-depth (prevention of fires, detection and suppression of fires, and the ability to safely shut down after a fire) with emphasis on post-fire safe shutdown capability and configuration management. The triennialinspection is the only portion of the baseline inspection program that focuses on the design of the fire protection systems and features that assure post-fire safe-shutdown. The inspection will adopt, as appropriate, techniques developed in the referenced draft FPFI inspection procedure.
The inspection team should consist of a fire protection engineer, a mechanical engineer, and an electrical engineer. The risk focus will be provided by a senior reactor analyst who will provide extensive input into the planning process.
r Draft
- a. Inspection Preparation:The team members should develop an awareness of the l plant's current post-fire safe shutdown licensing basis through review of 10 CFR 50.48,10 CFR 50 Appendix R (if applicable), NRC safety evaluation reports (SER) on fire protection, the plant's operating license, Updated Final Safety l Analysis Report (USAR), and approved exemptions or deviations.
The team members should become familiar with the licensee's methodology for accomplishing post-fire safe shutdown conditions. Sources of information include: calculations and analyses, the Updated Final Safety Analysis Report (USAR), the latest version of the Fire Hazard Analysis (FHA), the latest version of the Post-fire Safe Shutdown Analysis (SSA), fire protection / post-fire safe shutdown related 10 CFR 50.59 documentation, plant drawings, and emergency / abnormal operating procedures. The intent of this effort is to make the inspectors familiar with:
- The licensee's methodology for achieving safe shutdown conditions in the event of fire in any area of the plant, e The systems credited for each fire area, room or zone by the licensee as surviving the fire for accomplishing required shutdown functions (e.g.
reactivity control, reactor coolant make-up, reactor heat removal, process monitoring, supporting functions) necessary to comply with the safe shutdown requirements of 10 CFR 50.48 (a) and plant specific licensing requirements.
- The support system requirements of each shutdown system, and e The licensee's approach for identifying and resolving associated circuits of concern. The electrical review should include the assumptions and boundary conditions used in the performance of the analyses.
- The procedures in place for accomplishing post-fire safe shutdown.
The team members should become familiar with the historical record of plant-specific fire protection issues through review of plant specific documents including: previous NRC Inspection results, internal audits performed by the reactor licensee (e.g., self-assessments and Quality Assurance audits), Event Notifications submitted in accordance with 10 CFR 50.72 and Licensee Event Reports (LERs) submitted in accordance with 10 CFR 50.73.
b, Fire Risk Report: The senior reactor analyst (SRA) will develop and present to the inspection team leader a fire risk results report using the process of Appendix l of the referenced draft FPFI inspection procedure. The report will
, identify plant-specific, fire risk significant plant areas, structures, systems, I
components (SSCs), and operator actions developed from risk information such as Individual Plant Examinations of External Events (IPEEEs). The fire risk results report may also consider:
i Draft e resident and regional inspector developed inspection results, e plant-specific and non-plant specific fire event information, e licensee developed fire hazards analyses and plant-specific post-fire safe shutdown operating procedures, e licensee developed fire protection program self-assessment i documentation.
The development, presentation and finalization of the plant specific fire risk report may require approximately one week of effort. It is expected that in many cases the plant specific fire risk report for the previous triennial inspection may only need minor updates to incorporate plant modifications or changes to fire .i' protection methodology implemented since the previous inspection.
- c. Information Gathering Site Visit and Inspection Plan: '
The inspection team leader will manage and coordinate a 2-3 day information gathering site visit accompanied by the team members and the senior reactor analyst (SRA) designated to support the team. The purpose of the information gathering site visit is to gather the site specific information important to ;
inspection planning and for the SRA to clarify risk assumptions with licensee risk i analysts. In advance of the information gathering site visit, the team leader should provide the licensee a list of information and documents that will be ;
needed to prepare for the inspection, and the inspection team should already i have reviewed previous inspection information and docketed information about ;
the licensee's fire protection program in order for the on-site information exchange to be as effective as possible.
The inspection plan developed by the team leader for the triennial inspection should take into account:
e the results of licensee self-assessments; e the results of previous fire protection inspections including resident, regional, and team inspections, and any related corrective actions; i e the fire risk report, e previous industry problems and reactor events.
The plan should also consider the scope of previous fire inspections, so that the inspections are not repetitively focused on the same areas or fire zones.
- d. On-site inspection: The inspection team will confirm post-fire safe shutdown capability for fire scenarios in from one to five selected and prioritized plant areas, rooms or zones. In addition, the team will assess the design adequacy of fire protection systems and features for the areas, rooms or zones.
m Draft i
The inspection will be conducted during a one week onsite inspection period. .
Based on input from the SRA and team members, the areas, rooms, or zones I selected for review will be determined by the team leader and documented in the inspection plan. For those features applicable to the selected area, rooms, or
)
J zones, specific inspection guidance pertaining to the features is contained in the i referenced draft FPFI inspection procedure, l
In assessing risk significance of inspection findings in one or two of the three areas of defense-in-depth, some effort will need to be applied in the other defense-in-depth areas to support processing the issue through the (inspection findings) Significance Determination Process.
1 1 RESOURCE ESTIMATE: i I
This procedure is estimated at 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> per year for routine inspection and 108 hours0.00125 days <br />0.03 hours <br />1.785714e-4 weeks <br />4.1094e-5 months <br /> every 3 yccrs for the triennialinspection .
REFERENCES:
IN 97-48,"In 4 equate or inappropriate Interim Fire Protection Compensatory Measures," July 9,1997.
NRC " Fire Protection Functional Inspection (FPFI) Draft for Prairie Island inspection, April 6, 1998.
l
Draft ATTACHMENT ROUTINE INSPECTION GUIDANCE TABLE CORNERSTONE RISK PRIORITY EXAMPLES j Equipment or actions that could cause i INITIATING EVENTS (10) Transient combustibles (rags, wood, lon or contribute to initiation of fires in high exchange resin, lubricating oil, or Anti- ]
i fire risk areas or near equipment Cs) are not in areas where transient required for safe shutdown. combustibles are prohibited. Transient l combustible amounts in other areas do not exceed administrative controls.
Ignition sources (welding, grinding, brazing, flame cutting) have a fire watch. Planning includes precautions and additional fire prevention measures ,
where these activities are near i combustibles. l 1
l MITIGATING SYSTEMS (90) Fire Barriers in high fire risk areas. Doors and dampers that prevent the j spread of fires to/or between high fire Detection Systems for high fire risk risk areas remain in place arxi are areas functional.
Automatic suppression systems for high Electrical cable fire wraps and fire risk areas penetration seals that protect the post-fire safe-shutdown train are not Manual suppression from fire brigade damaged.
Compensatory measures for degraded Fire detection and alarm system is fire detection equipment, suppression functional for high fire risk areas.
features and fire propagation barriers.
Automatic suppression system sprinklers are not blocked.
Fire brigade performance indicates a prompt response with proper fire fighting techniques for the type of fire encountered.
Manual fire suppression equipment is of the proper type and has been tested.
Degraded fire detection equipment, suppression features and fire propagation barriers are adequately compensated for on reasonably short-term bases.
NRC Clarification Questions: " Stakeholder Comments on Draft FP inspection Module" l Prepared by: Leon Whitney, FPES/SPLB/NRR/NRC l Prepared on: May 25,1999 i
- l First Commenter l "The inspection basis (last sentence) is inconsirtent with the objective."
NRC Clarification Comment: Please explicitly specify the sentences which are inconsistent and j state what the perceived inconsistencies are. I "Section 02.02.b appears to be demanding that we have an unannounced fire drill in a high risk area at a time of NRC's choosing."
NRC Clarification Comment:
The NRC notes that the subject sentence begins with the phrase "may also include" rather than "will include." Nevertheless, NRC inspection teams do expect the licensee to conduct one fire drill during the onsite inspection period. The location of the drill may be unannounced to the fire brigade. However, the inspectors will have discussed with the licensee the timing and character of the fire drill during the information gathering visit weeks in advance of the inspection. A mutually agreeable scenario would be agreed upon at that time.
Is the commenter's issue the phrase "high risk area?" Are there other phrases which the commenter could suggest (e.g. " plant area in which a fire could require conduct of a post-fire safe shutdown")? Should the passage have some other form of rewrite?
Is the commenter's issue that the fire drill is unannounced? This is not equivalent to unplanned or unsupervised.
Please expand the comment to illustrate exactly what the commenter's fire drill issue is.
"The triennial general guidance should pick a different high risk area than the previous inspection, to be most comprehensive, it should also include a sampling check of lower risk areas. Otherwise the utilities might be tempted to " teach the test" and rigorously keep the high risk areas at 100% and let other medium and low areas degrade."
NRC Clarification Comment: Only in two places does the phrase "high risk" appear,02.01b and 02.02b, both of which are related to observation of fire brigade drills or actual responses.
Everywhere else the inspection planning is described as looking at selected risk significant areas, in some cases up to five such areas during each inspection, the selection of which is driven by a high number of determinants. Does the commenter believe that the selection processes are flawed such that the same plant locations will always be selected? If so, please elaborate on how this is so.
"Section 03.01/2: Include the referenced information from the FPFI module to allow this to be sufficient."
l
NRC Clarification Comment: The basic premise of the development of the baseline procedure was that the FPFI team inspection procedure will be published as part of the inspection i program (that is, as a final rather than draft document), that the FPFI team inspecSon procedure would be the fundamental source of inspection lines of inquiry for the inspectors who conduct baseline / triennial activities, and that the inspectors who conduct baseline activities would be well qualified to extract information from the FPFI team inspection procedure. This obviates the necessity to replicate FPFI team inspection procedure information within the baseline procedure. Considering this information, does the commenter still believe that extracts should be put in the baseline procedure?
"Section 03.02a should also request supporting calculations."
NRC Clarification Comment: There was a typographical error whereby 03.02b was labeled 03.02a. The first 03.02a does ask for supporting calculations. Given that the "SRA's report will not focus on the validity fo the modeling assumptions of the IPEEEs," It is not clear why (in the true 03.02b on the bottom of the fourth page) the SRA would necessarily need to ask for supporting calculations and analyses. Please elaborate or explain.
Section 03.02b: The inspection results and non plant specific fire event information have little to do with ranking fire areas according to risk; this should not be the responsibility of the SRA to acquire / address."
NRC Clarification Comment: Consider that inspection results (hypothetically for example repetitive findings of large quantities of transient combustibles in a given plant location) may affect SRA fire risk calculations. Also, the term "non-plant specific fire event information" refers to generic data which the SRA would use as input to his plant area fire risk calculations. It is not understood why the team's SRA should be prohibited from either of these information sources. Please elaborate.
Second Commenter "The main comment I have on the proposed guidance deals with the source of their criteria. The source of the data for the sprinkler systems, for example, comes from recent versions of NFPA 13. Those of us with older plants will not meet this criteria, 4 even though we will be in full compilance with our committed code of record. This could {
result in being classified with a high degradation category deficiency, while being completely in compilance with our commitments.
One specific example is as follows: Older sprinkler codes only considered an l obstruction below the head to be a problem if it was greater than 48" wide. The !
guidance provided states that an obstruction below the head of 24" or greater requires a head below the obstruction. A high degradation condition would be identified if two or more heads were obstructed in this manner. This would not be that uncommon with the presence of 24" wide cable trays and ducts.
It seems like we will be expected to backfit our systems to meet the current code if we are to have a satisfactory inspection." j NRC Clarification Comment: This stakeholder comment appears to be directed toward the criteria used in the FPRSSM dah significance determination process. The staff considers
p ]
h l
situations in which FPRSSM risk values would result in Commission backfit actions to be !
unlikely. Nevertheless, risk assessments should consider all relevant information. Within the I i FPRSSM process, equipment and systems which were installed under commitments to older l codes may be characterized as degraded (hypothetically, judged to be less than fully effective relative to newer, state-of-the-art designs). It is possible that such a degradation could be considered as an input into a risk significance determination calculation. However, the stringent ,
criteria of 10 CFR 50.109 (Backfitting) would need to be met before a change to licensee code l l commitments would be directed by the Commission.
Third Commenter if parts of the " Draft FPFl" module are going to be the basis / criteria applied in the triennial (or any other inspections) associated with this module, the specific review ;
l criterla should be incorporated into this module to make it a " stand alone" document. '
Referencing a " draft" document is not consistent with accepted practice in the nuclear !
regulations. I NRC Clarification Comment: As stated above, the basic premise of the development of the baseline procedure was that the FPFI team inspection procedure will be published as part of the inspection program, that is, as a final rather than draft document. Furthermore, as stated above, the FPFI team inspection procedure will be the fundamental source of insoection lines of inquiry for the inspectors who conduct baseline / triennial activities. As such, the line items in the FPFI procedure are not requirements upon the licensee.
" Risk significant"should be more stringently defined as " risk significant fire safe shutdown areas." Due to the IPEEE analysis methodology, an area may De " risk significant in IPEEE terminology, but not necessarily in safe shutdown terminology." I i
NRC Clarification Comment: The point of this stakeholder comment is not clear. It would be ,
helpfulif the commenter could elaborate on the specific baseline procedure passages in which ;
the term " risk significant" causes confusion, and then elaborate on the confusion which is perceived to result.
"The module does not indicate if the corrective action program will be included in the triennial review scope."
The NRC Reactor Assessment and Oversight Task Force plans to pilot and issue an inspection module specifically directed at the assessment of licensee corrective action programs. There is no intent to duplicate that effort within the fire protection inspectable area.
4