ML20217C564
| ML20217C564 | |
| Person / Time | |
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| Issue date: | 09/10/1997 |
| From: | NRC |
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| Download: ML20217C564 (200) | |
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Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION
Title:
Meeting Between the NRC and Paul Gunter andDavid Lochbaum Docket Nurnber: (not applicable)
Location: Rockville, Maryland Date: Wednesday, September 10,1997 Work Order No.: NRC-1234 Pages 1-104 NEAL R. GROSS AND CO., !NC.
Court Reporters and Transcribers 1323 Rhode Island Avenue, N.W.
Washington, D.C. 20005 (202) 234-4433
- u a88 5 E87?
PDR DN2
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1 UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION 3- +++++
4 MEETING 5 +++++
6 WEDNESDAY 7 SEPTEMBER 10, 1997 8 +++++
9 ROCKVILLE, MARYLAND 10 +++++
11 The meeting was held in Room 8B-11, One White Flint, 12 Rockville, MD, at 10:00 a.m., John A. Zwolinski, 13 presiding.
14 15 PPESENT:
16 JOHN ZWOLINSKI, U.S. NRC 17 LENNY OLSHAN, U.S. NRC 18 STEVE WEST, U.S. NRC l
19 TAD MARSH, U.S. NRC 20 SCOTT NEWBERRY, U.S. NRC 21 PAUL G N TER, NIRS 22 DAVID LOCHBAUM, Union of Concerned Scientists 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRA!JSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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2 1 A-G-E-N-D-A 2 Acenda Item Page 3 INTRODUCTIONS . . . . . . . . . . . . . . . . . . . 3 4 OPENING REMARKS, LENNY OLSHAN . . . . . . . . . . . . 5 5 OVERVIWW ON PENETRATION SEALS, STEVE HEST . . . . . 6 6 PRESENTATION ON PENETRATION SEALS, DAVID LOCHBAUM 7 & PAUL GUNTER . . . . . . . . . . . . . . . . . . . 13 8
9 10 11 12 l
) 13 i
f 14 15
.16 17 18 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRAN3CRIBERS 1323 RHODE ISLAND AVE., N.W.
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3 1 P-R-O-C-E-E-D-I-N-G-S 2
(10:10 a.m.)
(
3 MR. ZWOLINSKY: Dave and Paul, I apologize 4 that the facilities weren't set up in advance more 5 appropriately. But getting past that, I am sure we can 6 get into business fairly quickly. I might turn it over to 7 Lenny Olshan, our project manager for Salem, since he has 8 had contact with you as have other members of the staff, 9 and he will assure that introductions get taken care of 10 and what have you -- some administrative comments.
11 For the benefit of everyone in the room, the i 12 meeting is between the Agency and tir. Lochbaum and Mr.
l 13 Gunter. The staff, at the end of the meeting, will be 14 happy to take questions from the members of the public, 15 but not as part of the formal meeting. So, Lenny, if you 16 would go ahead and begin.
17 MR. OLSHAN: Okay. Before I begin, probably 18 everybody at the table should introduce themselves. As 19 John said, I am Lenny Olshan, the Salem project manager.
20 MR. WEST: I am Steve West. I am the Chief of 21 the Fire Protection and Engineering Section of NRR.
22 MR. MARSH: I am Tad Marsh. I am Chief of 23 Plant Systems Branch at NRR.
24 MR. STOLZ: I am John Stolz, Director of PB-2.
25 MR. ZWOLINSKY: I am John Zwolinsky, the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4 1 D puty Dirsctor for tha Divioion of Rocctor Projecto, 2 Regions 1 and 2.
3 MR. NEWBERRY: I am Scott Newberry, Deputy 4 Division Director of the Systems Safety Division of NRR.
1 5 Fire protection is one of the responsibilities of my l 6 division.
7 MR. GUNTER: Paul Gunter. I am alth the 8 Nuclear Information and Resource Service. I am the 9 reactor watchdog.
10 MR. LOCHBAUM: Dave Lochbaum, nuclear safeoy 11 engineer for the Ultion of Concerned Scientists.
12 MR. OLSHAN: Thank you.
13 COURT REPOh?ER: I would like to go around the 14 outside too. Please speak up.
15 MR. CANNISTRARO: I am Mike Cannistraro with 16 Atomic Energy Clearinghouse.
17 MR. KEENAN: Jeff Keenan PSE&G legal.
18 MR. RULAND: I am Bill Ruland, NRC Regibn~1.
19 MR. BAJWA: Chris Bajwa, NRC NRR.
20 MR. SCHOPPMAN: Mike Schoppman, Florida Power 21 & Light.
22 MR. FONTECILLA: Herb Fontecilla with Virginia 23 Power.
24 MR. CALLAHAN: Mike Callahan, NRC, 25 Congressional Affairs.
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5 1 MR. SKEEN: Devo Skcen, NRC, EDO'o Offico.
2 MR. STELLFOX: David Stellfox, McGraw Hill 3 Nuclear Publications.
4 MR. DRICKS: Victor Dricks, NRC Public #
5 Affairs.
6 MS. CHAPMAN: Nancy Chapman, SERCH/Bechtel 7 Power Corp.
8 MS. ALLEN: Vicky Allen with 'euters. '
9 MR. DOZIER: Garry Dozier with hud Information 10 Services.
11 MR. OLSHAN: Thank you. I am passing around 12 an attendance sheet. I wonder if you could please put 13 your full name and your affiliation rather than an 14 abbreviation when you fill out the attendance sheet.
15 On August 5 of this year, Dave Lochbaum sent a 16 letter to the staff requesting this meeting -- to have the l'/ meeting along with Paul Gunter to discuss items related to I
18 fire barrier penetration seals at Salem and other nuclear 19 plants. I have handed out the agenda for the meeting. As 20 you can see, I am presenting the opening remarks. Then 21 Steve West will give a brief overview of penetration seals 22 including their purpose and our technical assessment of 23 their performance capabilities, Following that, Mr.
24 Lochbaum will chow the video tape and now, as I understand 25 it, will give a presentation also. After the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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-6 1 prosantation, wo intend to have tha opan discusalon'with
'2 Mr. Lochbaum and-Mr.-Gunter, in which we will attempt _to 3 answer all your concerns and_ address all'your questions.-
4 And should any questions and concerns remain, we will 5 address--- we will suggest the appropriate means to 6 address them in the future. We will then have the 7 concluding statements and adjourn the meeting.
8 Before I turn it over to Mr. West, Mr.
9 Lochbaum do you have any opening remarks you would like. to 10 make or-any changes to the agenda besides'the one you told
- 11 us?
I 12 MR. LOCHBAUM: Our opening remarks are going 13 to be part of our presentation. So we will just go 14 through it then.
15 'MR OLSHAN: Okay. So, Steve,'I guess I will 16 turn it over to you.
17 (Whereupon, at 10:14 a.m. off the record until-18 10:15 a.m.)-
19 !!R. WEST: I can give a few introductory 20 remarks about the slides. It is our.first' meeting with
. 21 Mr. -Lochbaum- and our first real meeting with Mr. Gunter on
- 22- fire protection issues. I want to just mention briefly a-
- 23 little-bit-about the NRR organization dealing with fire 24 protection.
25 I am sure as Paul remembers, after the Thermo-NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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7 1 Lng cxpsricnco back in 1991, NRR decid;d to incroaco ito 2 attention and efforts on fire protection and created a 3 fire protection engineering section. So since 1992, we 4 have gone from having a staff of I think two fire 5 protection engineers at NRR to a whole section -- a fire 6 protection engineering section. I am the chief of that 7 section and I now have eight engineers working for me. I 8 have got four fire protection engineers and four reactor
, 9 systems engineers. In addition to classical fire 10 protection, we are responsible for safe shutdown 11 capability and analysis with reactor systems and engineers 12 in the area.
13 I have a degree in fire protection 14 engineering. I have been with the NRC since 1985, I 15 think. In addition to the headquarters staff here for 16 reactors, we also have inspectors in the regions 17 responsible for fire protection. For example, in Region 18 1, Bill Ruland is responsible for fire protection and he 19 has inspectors in Region 1 that review and inspect fire 20 protection issues. So we have a pretty good staff looking 21 at fire protection matters.
22 I guess we have no projector. Why don't I 23 just go on, because we want to try to keep the -- get the 24 meeting over by noon. So I am going to just pass out -- I 25 was going to do this anyway. Let me pass out a slide.
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8 1 Thia 10 bnaicclly just a cartoon thct I drew. I hevo uccd 2
it to brief the ASARS and the Commission and others on 3 penetration-seals over the years. I just think it would 4 be helpful if we start off by making sure we have a common 5 understanding of what a penetration seal is and what its 6 purpose is. This won't take long.
7 If you look at this cartoon, what we are 8 depicting is three fire areas, A, B, and C, and you can 9 see going through the fire boundarios, which are the hash 10 mark lines -- those are the structural fire barriers like 11 a concrete wall. You can see passing through there from A 12 to C a cable tray and a conduit. And from A to B, you can 13 see the cable tray passing through. And the little dotted 14 portion there over the cable tray and conduit represents a i
15 penetration seal.
16 The purpose of the penetration seal is to help 17 prevent or provide reasonable assurance that a fire that 18 begins in one fire area will not spread into an adjacent 19 fire area. So in the case of this example, the little 20 squiggly line in fire area A is a fire. So we are at a 21 place now where we don't want to be. There Js a fire in 22 the fire area. And the concern is to keep that fire 23 confined to fire area A and not get into fire area B or C 24 or the areas that are above or below it.
25 In addition to the penetration seals, there NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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9 1 cro othar fire protection fectures thnt hslp provids thct 2 assurance -- fire doors, fire dampers and duct work. So 3 the whcie purpose is to confine the fire.
4 "nu can see that if you have a fire in fire 5 area A, then tray A -- which there is a little pump up 6 there in the corner -- could be damaged. And tray B is 1
7 located in fire area B and we are trying to make sure that 8 tray B remains functional.
9 The way penetration seals work is to -- we 10 have got a projector here now. Just a second. We have a 11 fire in fire area A and the whole idea is to prevent the i 12 spread of fire from this fire area into an adjacent fire 13 area. There are various types of penetration seals.
14 Whenever you penetrate a barrier or usually when you 15 penetrate a barrier, you want to seal that penetration 16 with a material that will help confine the fire and not 17 allow it to spread.
la In this example, this fire is going to spread 19 to the cables and it is going to burn up to that barrier, 20 and if you don't have a seal or some way of preventing the 21 fire from spreading from this side of the barrier to the 22 other, it is going to travel right along the cables and 23 spread into the other area. The same thing up here.
24 So typically in a nuclear power plant, it is 25 loaded cable trays that present the most significant NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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10 1 challcnga to e p nctration coal. And m:ny rooms cro 2 loaded like this -- a couple of trays. Some are much more 3- Icaded like the cable spread room.
4 There are various materials used for 5 penetration seals. I know, Mr. Lochbaum and Mr. Gunter, ;
6 your primary interest is in the silicon foam or silicon 7 based materials, which are the predominant material used 8 in nuclear power plants I have some samples here that I 9 will pass around basically to give you a feel for what the 10 materials are in case you haven't seen them. This is --
l 11 when you get this one, you can squeeze it a little bit.
l i 12 That is silicon foam. This one is harder to squeeze. It j 13 is more dense. It is silicon elastomer. In an actual I
14 nuclear power plant what you would be looking at is a hole 15 in the wall with some cables going through it. It would 16 be much thicker. It is usually the thicaness of the wall 17 or 9 to 12 inches. And there would be typically damming 18 material on either side -- a piece of carb.n fiber board 19 or some other material that they install so that when you 20 pump the foam in. the elastomer doesn't fill the whole 21 fire area up. So I will pass these around.
22 Other materials that are used are grouts, 23 hlightweight concretes, things like K-wool or a mineral 24 blanket that they stuff in penetrations and then put a 25 marinite board on either size. So there are various NEAL R. GROSS COURT REPORTERS AND TRANSCRIDERS 1323 RHODE ISLAND AVE., N.W.
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11 1 m0toricle.
2 I would like to point out that in a situation 3 like this where you have a fire, if it spreads to a cable 4 tray, any type of seal that you have in this barrier, 5 whether it is concrete, ceramic fiber or anything, as part 6 of the fire fighting effort, the seal is going to have to 7 be taken out. It doesn't matter if it is foam or anything 8 else. Because you have got a combustible material going l 9 from one area to another. So that seal is going to have 10 to be removed at some point in the fire fighting evolution 11 -- typically late in the evolution.
( 12 I would also like to point out that some of
{
the problems that you see with silicon based material, 13 14 although they are not as well publicized, you see the same 15 problems with the other materials. The silicon foam may 16 crack or split. Grout cracks. Silicon foam can have 17 voids and so can grout and so can concrete. So problems 18 with penetration seals are not unique just to silicon foam 19 or silicon based. Any type of seal can have standard 20 types of problems. Any type of seal can be missing.
21 So anyway, the purpose of the meeting today is 22 to discuss with you your questions and try to address any f 23 concerno you have on these seals -- this fire protection 24 feature right here. That is the purpose of the meeting.
25 Before I -- in closing, I just want to note that Lenny NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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12 1 mantioncd tha lotter that wa had from you, Mr. Lochbaum, 2 from August 5, 1997, and you submitted some questions with 3 that letter. And in a follow-up phone call with Mr.
4 4 Zimmerman of our staff, you said you weren't necessarily 5 looking for answers to those specific questions. You were 6 just trying to focus us on the need for a meeting, which 7 obviously we agreed with you. We will be happy in any 8 format you want to go through those questions or other
- 9 questions you have.
10 Some of your questions parallel and overlap r 11 questions that we have also received from Congressman 12 Markie in a letter dated -- I think in May -- May 5, and 13 we are preparing a response to that letter and we plan to 14 have that response issued in October. We will be happy --
15 well, not happy, but we will provide you with a copy of 16 our response to Congressman Markie, and that should 17 address all of your questions.
18 We also are -- as you know, we did a technical 19 assessment of fire barrier penetration seals that we 20 completed in July of 1996, and we are doing an update of 21 that assessment. As part of our update, we are 22 considering the comments that you submitted in I think a 23 couple of different letters. You had some comments on a 24 SECY paper -- SECY-96-146 -- which was dated July 1, 1996.
25 That SECY paper included as an attachment essentially this NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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~
13 1 report. Thare ware coma minor revisione, but we have got 2 your comments on that and we are considering your comments 3 as part of our updated assessment of penetration seals.
4 We would -- we are nearing completion of that 5 assessment, and we plan to issue th . report sometime this 6 year. And we will make sure that we forward to you, Mr.
7 Lochbaum and Mr. Gunter, copics of our NUREG supplement on 8 that. I could talk about a lot of other things, but I 9 suspect you are going to have questions and we can respond 10 to anything you have as we go through the rest of the 11 meeting. If there are any immediate questions on what I 12 have covered. If not, we can move on to your 13 presentation. Are you ready?
-14 MR. LOCHBAUM: Yes.
15 MR. ZWOLINSKY: Have we defined the purpose 16 clearly enough as far as the barrier itself?
)
17 MR. LOCHBAUM: I believe so, yes.
18 MR. ZWOLINSKY: Okay.
19 MR. OLSHAN: Do you want the TV?
20 MR. LOCHBAUM: It is going to be in a while.
21 Paul and I prepared 26 slides that basically summarize the 22 concerns we have. They pretty much supersede the 23 questions in the August 5 letter. A few questions have 24 subsequently been answered and are out of this 25 presentation altogether, and there are a few questions in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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14 1 thic procontction that waren't in the Auguot E lottor.
2 Also included in the package is the copy of 3 one of the letters that had the critique of the second 4 paper that Mr. West mentioned, and a two-page fact sheet 5 on RTV silicon foam that NURS puts out. That is what is 6 consisted in the package.
7 On slide 1 of our presentation, basically 8 there are two goals of fire penetration seals. One of the 9 statements came frota Chairman Jackson's response to 10 Senator Biden that basically says that properly designed 11 and installed silicon foam penetration seals will provide 12 an adequate level of fire resistance and will perform 13 their intended fire protection function by confining a 14 fire to the area of origin.
15 We basically agree with that statement and 16 that goal, and also the second goal which is very similar.
17 The concern we have isn't that the goals are improper or 18 not sufficient. It is that they are not being met. That 19 is really the heart of our concerns, It is that there is 20 data that shows that the goals aren't being met.
21 Therefore, the risk from fire in significantly higher than 22 currently believed.
23 Slide 2 talks about the required attributes 24 that are necessary to meet the stated goals. The properly 25 designed requires that they be conforming with the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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15 1 lic0naing bacio cnd that thay ba bound:d by qualification 2 tests. We have rearon to believe that there is problems 3 in both of these areas. For a fire seal to be properly 4 installed, it has to contorm with the design requirements 5 and it has to be maintained within those design 6 requirements. So we have reason to believe that both of 7 those parameters may not be met in all cases. Slide 3 is 8 Paul's.
9 MR. GUNTER: I would firct like to just open i
10 wi?.., our mutual concer.as that I think are clearly l
l 11 recogni" d. Joth NRC licensees and the public are 12 concerned about the issues of fire. NUREG 1150 clearly i 13 outlines that fire is recognized as a significant risk in 14 as much as 50 percent of the overall risk of core melt 15 accidents can be attributed to fire by NRC's own studies.
16 And recognizirg also in that study that. three to four 17 significant fires can occur at a nuclear power station i i
18 during its typical oporation life.
19 That, of course, was clearly demonstrated as a 20 result of the Browns Ferry fire in 1975. Out of that 21 fire, it is our understanding that there was an evolution 22 of regulations and requirements for noncombustible 23 materials to be used in fire barrier penetration seals as 24 well as t.he promulgation of other regulations with regard 25 to fire barrier wrap systems. Clearly one of the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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16 1 quactiono that wa hevo balebored io tha feet thst tharo is 2 sufficient evidence, ar.d even on the NRC's admission, to 3 show that RTV silicon foam, which has been outlined, 4 constitutes by and large the vast majority of penetration 5 seala out there in the nuclear power industry. It is 6 manufactured by Dow Corning and it is combustible.
7 What we are interested in, first of all, is to 8 just have the regulator lay out for us the evolution of 9 the noncombustibility requirement in the current 10 regulations as it exists in several regulations and l
l 11 guidelines within the NRC's overall approach to fire 12 protection.
13 So this is one question that we place -- and 14 the first question that we put on the table before you is 15 that we really need to have that evolution spelled out for 16 us as well as r.ome of what appear to be other 17 inconsistencies with this particular material, 18 particularly with regard to containment. I know that as 19 we followed the Thermo-Lag fire barrier issue over the 20 years, NRC did recognize that Thermo-Lag, being a 21 combustible material, raised some particular problems with 22 regard to containment and required the licensees to 23 address that. Given that RTV silicon foam is also 24 combustible, of course it raises a concern for us that i
25 there is some inconsistencies here with regard to the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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17 1 NRC'c cpproach to firo protection end combuctiblea.
2 MR. LOCHBAUM: One point to add there on the 3 historical evolution of that question -- since the staff 4 concluded last year that there is no technical basis for 5 the noncombustibility requirement, we assume that 6 historical evolution should be fairly easy to come up 7 with. Since that conclusion has been reached, historical 8 evolution must be readily available, 9 MR. GUNTER: Slide 4 talks about --
l 10 MR. WEST: Would you like us to answer that?
11 MP. GUNTER: It is up to you. We can either l
12 go -- we can either pause for each question or wait until 1
l 13 the end, whichever you would prefer.
14 MR. WEST: Is that the end of your 15 presentation on that question?
16 MR. GUNTER: Yes.
17 MR. LOCHBAUM: Yes.
16 MR. WEST: Okay. As you could probably 19 imagine, trying to establish the historical evolution of a 20 regulation that was started on in the 1970's is difficult.
21 But we do have some information available, and we have 22 reviewed it. In addition to reviewing the public 23 documents on the Appendix R regulation, we have discussed j 24 with previous staff members that were the principles for 25 the drafting and promulgation of the rule some of these NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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I 18 1 qt'oc t ions .
2 If you look at the statement of considerations 3 that issued the proposed Appendix R and look in the 4 section on penetration seals, the noncombustibility 5 criterion is not there. If you look at the statement of 6 considerations and the final published rule in the federal 7 register, you will find that it is there. Unfortunately, 8 it is there without explanation. That section of the rule 9 was changed and there is no comment in the statement of 10 considerations to explain that change from the proposed l 11 rule to the final rule.
l 12 As I mentioned, we discussed with the authors 13 of the rule as to why that change was made and what its 14 intent and purpose was, and we are told that it was 15 intended to preclude the use of materials such as those 16 that were involvLd in the Browns Ferry fire. It was never 17 intended to preclude the use of silicon foam or silicon 18 based materials as penetration seals. Further evidence 19 that the staff was amenable to the use of silicon foam is 20 the fact that silicon foam was the material that uns 21 installed in Browns Ferry after the fire. This it; well 22 documented in the staff safety evaluation report for the 23 restart of Browns Ferry.
24 So it is our understanding from the record and 25 these interviews that there was never any intent on the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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19 1 part of tha otcff to precluda tha uco of cilicon b ccd 2 materials as fire barrier penetration seals. That 3 judgement that the staff made back in the 1970's and in 4 1980 through Appendix R was based on first-hand 5 observations of full-scale fire endurance tests of 6 penetration seals that were made of silicon foam, which 7 demonstrated conclusively using national engineering 8 standards that the materials were effective fire barriers.
9 Now with respect to the use of silicon foam 10 inside containment and the nexus to Thermo-Lag, the 11 problem we had with Thermo-Lag inside containment is that 12 there is -- in Appendix R, the regulation itself, it does 13 specify that fire barriers -- not fire barrier penetration 14 scala -- but if you look at that cartoon I gave you and 15 assume that that is inside containment and you need to 16 enclose one of those cable trays in a fire barrier or a 17 radiant energy heat shield, the regulation says that that 18 barrier must be noncombustible. There is no requirement 19 that you can't have combustibles inside containment.
20 There are combustibles inside containment. There is cable 21 jacketing and cable insulation. There is oil in reactant 22 cooling pumps and other components inside containment.
l l 23 I noted in your August 5 letter on this 24 subject that you mentioned that the information notice 25 that we wrote on an NEI methodology that we had rejected NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5h ~
20 1
- f. 1 on combustibility, and I didn't quite follow your logic, 2 but you were implying that because we had rejected that 3 methodology that we were saying you could not have 4 combustibles inside containment, and that is not the case.
5 We were saying that the NEI methodology, which basically 6 was a scheme for declaring that a combustible material is 7 noncombustible was not technically valid. So we had a 8 problem with their methodology itself. We were not 9 concerned -- I mean, we were not addressing the use of the l l
10 material inside containment. We were addressing the l E
11 method that NEI was proposing to use to justify its use. '
12 And I think your passage is, I think, a little bit out of 13 context in your letter. I think if you read that whole 14 information notice, you will see that we definitely 15 mention in that information notice the regulatory 16 restrictions on the use of combustible materials inside 17 containment. We weren't trying to address a particular 18 application.
19 One other thing I will just mention, and this 20 is documented. It is your first dash on slide 3. This is 21 also documented in the staff's report on the Browns Ferry 22 fire. The material that was involved in the fire was l
23 ignited by a match without the flame even touching the 24 material -- quite dramatically. That can't happen with 25 silicon foam. We could sit here all day and try and get NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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21 1 thic to light off, cnd wa won't b3 cblo to do it. I would 2 invite you to take a piece home and try it. So it is 3 quite different. I mean, the properties are different.
4 The combustibility tests we are talking about here is 5 basically a pass / fail test. Then after that, you've got 6 to use some engineering judgment and make a decision on 7 whether a material is acceptable or not. Now the 8 polyurethane foam that was involved in the Browns Ferry 9 fire, which is probably like the stuff you are sitting on, l
10 is quite different than this material, which was designed 11 and intended to be used in fire barrier penetration 12 systems.
13 MR. LOCHBAUM: We recognize that. The 14 polyethylene foam that was used at Browns Ferry wasn't 15 even used as a fire barrier.
16 MR. WEST: Right.
17 MR. LOCHBAUM: It was just used for a deep 18 heat protection more than anything. So we understand 19 that.
20 MR. WJST: Okay. I just don't want anyone --
21 at least anyor.e that is in the meeting today or reads the 22 transcript later to think that a candle flame could have 23 any impact on a seal like this -- a silicon based seal.
24 It is just not going to happen. Does that address those 25 points or your questions in that area? Do you have any NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE , N.W.
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22 1 follow-up quoctiono?
2 MR. LOCllBAUM: I think we are going to get to 3 a follow-up question a little bit later.
4 MR. WEST: Okay.
5 MR. LOCliBAUM: But basically the process for 6 Appendix R took a while. I mean, it wasn't an overnight 1
7 process. And there were a number of plants in the l 8 licensing process in parallel with the evolution of 9 Appendix R.
10 MR. WEST: That is right.
11 MR. LOCHBAUM: And those parallel paths led to 12 a lot of complexities such as Salem as to what is 13 applicable regulation. So the follow-up question is going 14 to be mainly which plant is licensed to what regulation.
15 But we will get to that in just a few moments.
16 MR. WEST: Okay. All right.
17 MR. LOCFBAUM: On Slide 4, there are just some 18 basic definitions of what some of the regulations --
19 typical regulations are. As outlined in the SECY paper 20 last year, the silicon based penetration seals are 21 combustible when you test them in accordance with the 22 ASME-136 test, which is the standard test.
23 10 CFR 50, Appendix R, sub-part III.M states 24 that "a penetration seal design shall utilize only 25 noncombustible materials." Our contention is that silicon NEAL R. GROSS COURT REPORTERS AND TRANSCRIDERS 1323 RHODE ISLAND AVE.. N.W.
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23 1 form, boccuco it wao concidared combuotiblo by E-136, than 2 they don't meet III.M -- the specific requirement in 3 III.M.
4 The latest version of the branch technical 5 division 951, which has a number of acronyms along the way 6 --
but the latest version that is out for draft comment 7 dated April 1996 states that structural fire barriers, 8 including penetration designs, should utilize only 9 noncombustible materials. Similar words were contained in 10 the version that was issued sometime in the early 1980's.
I 11 So Slide 5, the first question -- in the SECY 12 paper that was issued last July and has subsequently been 13 reported, the staff intends to remove the 14 noncombustibility requirement from Appendix R, the 1 I
15 standard review plan, and so on. What is the schedule for 16 removal of those requirements?
17 MR. WEST. Let me just make one comment and 18 then I will answer your question. The standard review 19 plan is basically an integration of the Appendix A to the 20 branch technical division, ABC SPI 5.1 and the Appendix R 21 requirements. So anything that was in Appendix R was 22 translated into the SRP, and that is getting back to the 23 historical evolution. That is why that is in the SRP. It 24 was never in the branch technical position that most 25 plants are committed to meet. So that is why it is in NEAL R. GROSS COURT REPORTERS AND TRANSCRIDERS 1323 RHODE ISLAND AVE., N.W.
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24 1 th;ro.
2 Now your question is what is our schedule for 3 rule making?
4 MR. LOCHBAUM: Yes.
5 MR. WEST: Okay. We have -- that is what the 6 Commission wants to know. We have a fire protection rule 7 making underway that is much more broad than this little 8 change. We are planning to develop performance based risk l 9 informed fire protection regulation that will replace the 10 existing 10 CFR 50 48, which is the basic fire protection 11 regulation and Appendix R. We had proposed to the 12 Commission about a year ago that we eliminate Appendix R 13 altogether. That recommendation was accepted. We are 14 going down that path and we recently provided another 15 paper to the Commission with our plan and a schedule. Now 16 that plan and schedule are still being negotiated with the 17 Commission. It has not been made publicly available yet.
18 But in general, I would say that sometime next year you 19 would probably see a proposed rule.
20 I don't want to turn this into a meeting about 21 performance based risk informed regulation.
22 MR. LOCHBAUM: Me neither.
23 MR. WEST: But as I am sure you are aware from 24 working with us and observing us, the whole purpose of 25 something like that --
a rule like that is to get away NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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25 1 from thoco roci proceriptivo rcquircm:nto liko thic 2 material shall be noncombustible. We want to look more 3 like -- we are looking at seals now like their function.
4 Can it perform its function or the function it needs to 5 perform under the anticipated conditions? So it makes 6 sense through that rule making -- rather than doing a 7 separate rule making just to change this whole thing -- it 8 ma:tes sense for us to wait and just cover this as a part 9 of this bigger rule making effort we have. So that is our 10 plan. We expect that the Commission is going to accept 11 that.
12 But you should probably -- I am sorry, I don't 13 know the SECY number. But I would imagine sometime this 14 month that SECY and the SRM will be made publicly 15 available.
16 MR. LOCHBAUM: Okay. We can find it. With 1
17 that schedule, what is the plans for the plants that are 18 currently not in compliance with III.M until the rule is 19 changed? Because they still technically are in 20 noncompliance with the rules.
21 MR. WEST: Well, as far as I can determine 22 based on this update of the penetration seal assessment 23 that we are doing, there may be -- and again, I am going 24 to say may. Because we are not complete with our review.
25 There may be only two plants not in compliance, and that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBER $
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26 1 1o Dunno Arnold cnd Maino Ycnkoa. Maino Ycnkoo ic baing 2 shut down. We are still reviewing the licensing basis for 3 those two plants. And it is probably a good time to 4 mention that there are only five units by regulation that 5 are required to meet Section III.M of Appendix R. The 6 other two are H.B. Robinson 2 and Peach Bottom 2 and 3.
7 And both of those plants or those three units have an 8 exemption from this requirement. The exemption for H.B.
9 Robinson was issued on November 25, 1983, and the 10 exemption for Peach Bottom 2 and 3 was issued on November 11 14, 1986. I thin you have seen the -- at least seen the 12 Peach Bottom exemption, because I noted in your August 5 13 letter, again you had something taken out of context from 14 the safety evaluation. But I submit that that exemption 15 is tantamount to -- it establishes a precedent which would 1G be tantamount to generic approval of silicon based 17 materials. It is not configuration dependent. The 18 exemption is addressing the material itself, provided it 19 can meet the fire endurance criteria, which they were able 20 to demonstrate.
21 MR. LOCHBAUM: I guess I wouldn't argue that 22 the precedent is set, but that doesn't mean that everybody 23 else is cleared just because the precedent has been set.
24 MR. MARSH: No. No. That does not resolve 25 the issue for other plants. But the technical arguments NEAL R. GROSS COURT AEPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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27 1 that cro m da thoro cnd tha juctificctiono that cro thara 2 could apply depending upon the configuration.
3 MR. LOCHBAUM: Sure.
4 MR. WEST: So it is not meant to be a generic 5 relief or a generic exemption. But it is meant to 6 articulate our arguments.
7 MR. LOCHBAUM: So the intent is --
8 MR. WEST: We may have an issue that we need 9 to -- we may need to close the loop on Duane Arnold and 10 Maine Yankee when we are finished with our asstasment.
11 But it looks at this point like we are going to have -- we 12 are going to need to do something. In the meantime, I 13 guess we would say we are confident -- you know, we have 14 reasonable assurance that those seals are adequate. I 15 mean, they are the same seals used in 100 other units.
16 MR. LOCHBAUM: So that these five units are --
17 their licensing basis is Annex R III.M?
18 MR. WEST: Right.
19 MR. LOCHBAUM: Are there any plants that have 20 to meet the noncombustible versions of 9.5.1?
21 MR. WEST: Of the CMED 9.5.1? The standard 22 review plan?
23 MR. LOCHRAUM: Well, there were -- it was 24 revised over the years. So it had various acronyms 25 depending on what the branch was called at the time.
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1
.~
28 1 MR. WEST: Yoc. Wall, I'll givo you ct locet 2 a two-part answer and maybe more as I get into it. But we 3 are still looking at the licensing basis for other plants.
4 We focused first on the plants that -- the Appendix R 5 plants. Because we know the Appendix R plants and we did 6 a review of the dockets and we had sent each of those 7 plants when Appendix R became effective -- a letter 8 telling them what sections applied to them. So those 9 letters are in the docket. We found those and we were 10 able to determine easily which plants are required to meet 11 III.M. We are still looking at the licensing bases for 12 the other plants. I suspect that we are going to find -
13 there are very few plants committed to meet a branch 14 technical position that has the noncombustibility 15 criterion in it. That is part 2.
16 Part 3 is that the branch technical positions 17 are guidance. They are only one acceptable means of 18 meeting the underlying intent of the regulation.
19 Licensees can propose other means. So there are no 20 requirements in the branch technical positions. And 21 frequently, if you look at the safety evaluations of the 22 fire protection programs and the evaluations and reviews 23 the staff has done, you will find a large number of
, 24 deviations where licensees have proposed alternatives that 25 we have found acceptable. So I don't see any significant NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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29 1 probicm with any tharo 10 cn SRP plcn out th3ra cnd th3y 2 have silicon foam seals. I don't see a significant --I i 3 don't see any safety problem and I don't see a significant 4 regulatory problem.
5 MR. LOCHBAUM: And it would be -- if there was !
I 6 an SRP plant, then it would be probably handled the same 7 way as perhaps Duane Arnold and Maine Yankee?
3 MR. WEST: Yes.
9 MR. MARSH: Different vehicleu though. One is 10 a regulation with which they don't comply. The other is 11 an SRP which they did not address. Different vehicles for 12 addressing those.
13 MR. LOCHBAUM: So there might be a safety 14 evaluation for it? That was the basis for the staff's 15 approval of licensing?
16 MR. OLSHAN: What that means is that Duane 17 Arnold would need an exemption to the regulatiCn. The 18 other plant took it out.
I 'l MR. MARSH: Right. If the other plant can go 20 back and rectify that. It would be the exemption route as 21 opposed to an evaluation of a deviation from an SRP and a 22 technical just.ification for that.
23 MR. LOCHBAUM: Okay. I understand.
24 MR. MARSH: We may even get backfit based on 25 the vintage of the plant. Yes, say there is a plant out NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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30 1 thara that wh n it wec lic:nacd -- coy it 10 cn SRP plcnt 2 and when it was licensed it had grout seals --
3 noncombustible. And then sometime later in the life of 4 the plant, the licensee decided to replace its seals.
5 Maybe it said if I ever have to remove a seal, I am going 6 to replace it and I am going to put in silicon foam. They 7 could do that under 50.59. There is no staff review 8 required for that type of application. I mean, that is 9 kind of a generic answer. I mean there may be -- I can't 10 imagine one where there would be a USQ 1avolved in it.
11 MR. LOCHBAUM: We may get into that later in 12 our presentation.
13 MR MARSH: All right.
14 MR. LOCHBAUM: Slide 6 -- I kind of addressed 15 the --
16 MR. MARSH: We didn't do your last bullet on 17 top, David, and I am not sure if you wanted to skip over 18 that.
19 MR. LOCHBAUM: It sounds like at the moment, 20 you don't know of any plant that is specifically not in 21 compliance. So it is not really an issue for discussion 22 until you come to the determination.
l 23 MR. MARSH: Okay.
24 MR. LOCHBAUM. Slide 6. It sounds like we've 25 kind of hit the first question anyway. And also, my NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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31 1 undarctending io that part of tha rocponto to 2 Representative Markie will kind of address this issue.
3 MR WEST: Let me just say on the first bullet 4 -- I am not sure I really -- Congressman Markie asked that 5 question. So in our response to him, we will have an 6 answer to that question.
7 MR. LOCHBAUM: Okay.
~
8 MR. ,,EST : Like I said, we will give you that 9 also and you will have it.
10 MR. LOCHBAUM: Well, one thing is the second 11 part or the follow-up to the question would be 12 Representative Markie's questiora came in in May and it 13 has taken until October to answer a number of questions 14 including this subject -- not just this question. So it 15 is clearly not something that is sitting on a shelf and 16 readily available. Because there was an earlier partial 17 response to Representative Markie.
18 MR. WEST: right.
19 MR. LOCHBAUM: In lieu of an easy access to 20 what the licensing basis is for fire penetration seals, it 21 is questionable how the NRC or licensees can effectively 22 conduct on-site inspections, verify compliance, comply 23 with backfit requirements, et cetera.
24 MR. WEST: Well, if an inspector is going to a 25 plant to do a fire protection inspection, he would collect NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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32 1 for that plcnt within tho ccope of hio in poetion tho 2 licensing documents needed to perform his inspection. So 3 he is going to look at penetration seals. He is going to 4 get the information on the licensing basis for the 5 penetration seals. And then he can effectively conduct an 6 inspection. In fact, as part of our update of the 7 reassessment, we have gone back and looked at the 8 inspections that the staff has performed of the 9 penetration seals I think since 1992, and it has been 10 something like 88 or 90 inspections at 70 plants. So wo 11 have done a lot of inspections.
12 So the information is there. The problem I am 13 dealing with is getting all that information to me and 14 verifying it. So it is not like if we are doing an 15 inspection we don't have the information available to us.
16 It is available to us, but I need to get it, compile it, 17 look aC it, proofread it, make sure it is right. So it is 18 just a --
19 MR. LOCHBAUM: And do other things you 20 normally do, right?
21 MR. WEST: Yes, right. And do everything else 22 -- do important stuff.
23 MR. LOCHBAUM: Right. When you say there has 24 been 80 some odd inspections since 1992, those are just 25 general protections. Those aren't specifically targeted l NEAL R. GROSS i COURT REPORTERS AND TRANSCRIBERS l 1323 RHODE ISLAND AVE.. N.W.
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33 1 ct firo p natration fields, ri_at?
2 MR. WEST: No. Those are inspections where 3 the inspector reviewed the penetration seals. Now it 4 could --
5 MR. MARSH: And that may have been part of 6 another inspection activity.
7 MR. WEST: Right. It could be part of another 8 inspection activity, and it could be in different levels 9 of detail. Some inspections were focused purely on that 10 and some included it as part of a core inspection.
11 MR. LOCHBAUM: Was there an inspection manual 12 module number for the fire penetration seals?
13 MR. WEST:
14 MR. RULAND: 64704.
15 MR. WEST: Thank you.
16 MR. ZWOLINSKY: Thanks.
17 MR. WEST: Yes, that is the core inspection 18 module and it has in it the penetration seals And we 19 recently have -- or we ere in the process of y Scessing a 20 change to that to provide some additional guidance to the 21 inspectors on the seals.
22 MR. LOCHBAUM: Slide 7. We kind of addressed 23 this a little bit earlier. There is a very complex array 24 of regulations for fire penetration seals. Are feeling 25 was that rather than -- since there is only one hazard NEAL R. GROSS COURT REPORTERS AND TRANSCR$ERS 1323 RHODE ISLAND AVE., N.W.
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l 34 1 involved, it would ba c2cier to bevo juct ono rulo. It 2 sounda like the rule making will essentially move in that 3 direction.
4 MR. WEST: It is our -- yes, it is our plan 5 that this ruTo would not be a voluntary rule. It would be 6 a mandatory rule for all licensees and there would be a 7 comptahc4uoive regulatory guide for implementing the rule 1
1 8 and it would cover things like penetration -- you know, 9 all the fire protection systems and features. So that is 10 a concern we have, the complexity of the regulatory i
11 process for fire protection. And one of eur major 12 objectives is to improve that as you are suggesting.
13 MR. MARSH: It would also put licensees under 14 one set of requirements as opposed to a mixed set of 15 requirements which is the current environment.
16 MR. LOCHBAUM: Okay. That essentially 17 addresses the second question. It would then be 18 retroactive to all licensees with some kind of 19 implementauion schedule and so on?
20 MR. WEST: Right. Right. That is the plan.
21 Now that plan for that rule -- that part of the plan is 22 already publicly available. That was in a SECY paper we 23 issued last summer, I think. It is the continuation of 24 how we are actually going to do it, but it is still being 25 negotiated with the Commission. If you are interested in NEAL R. GROSS COURT REPORTERS AND TRANSCRIDERS 1323 RHODE ISLAND AVE., N.W.
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l
35 1 our pleno for tha rulo end tha reg guido end c11 that, 2 that is available.
3 MR. MARSH: You have just got to be somewhat 4 careful because it is before the Commission and the 5 Commission could say to us, here is a new direction for 6 you. We want it to be voluntary. We want it to not be 7 retroactive. It is before the Commission. It hasn't been 8 proposed in that way, but of course the Commission can 9 change its whole direction.
l l
10 MR. LOCHBAUM: And in any event, it would have 11 to go through the rule making process and all that that i 12 entails.
13 MR. MARSH: Absolutely.
14 MR. LOCHBAUM: Slide 8. The first bullet 15 points out that 10 CFR 50.71(e), which is the FSAR update 16 rule -- I don't think that is its official title, but that 17 is functionally what it does -- requires licensees to 18 update the FSAR's to include effects of "all analyses of 19 new safety issues performed by or on behalf of the 20 licensee at Commission request." The safe shutdown fire 21 . hazards and combustible loading analysis in most part were 22 required by the NRC after May of 1980, the date of this 23 rule. The question would then be, have the results from 24 these analyses performed at NRC's request been 25 incorporated into the FSAR as required by the law? The NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1303 RHODE ISLAND AVE., N.W. .
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36 1 cvid nco wa h:d from Salem io that in feet it io not.
2 MR. WEST: What was not at Salem? You are 3 saying they don't have <a fire hazards analysis?
4 MR. LOCHBAUM: Incorporated into the PSAR as 5 required by law.
6 MR. OLSHAN: Let me address that. The Salem I
7 FSAR is so -- there was a bunch of other documents and it 8 was difficult for me to see without going to those other 9 documents what is really referenced there. Do you know 1
10 for a fact that the updates have not been incorporated?
11 Because they update them at the plant in these other 1
12 documents.
13 MR. LOCHBAUM: They update them for 14 modifications and safety evaluations and things like that.
15 Not for bulletin responses.
16 MR WEST: I am not sure that the fire hazards 17 analysis is a safety analysis. Because it wasn't until 18 generic letter -- if you look at generic letter 86.10 and 19 88.12, we requested that licens9es incorporate the fire 20 hazards analysis into the FSAR. And most plants have done 21 that, I think. Hasn't Salem done that?
22 MR. OLSHAN: Well, they have. That is why I 23 am trying to understand what your question is. There are 24 thinge that you know that have been changed at Salem that 25 are not referenced in the FSAR or changed in the FSAR?
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37 1 MR. LOCHBAUM: I think in g:norcl, if you look 2 at the FSAR, it doesn't tell you what the applicable 3 regulations are. It doesn't tell you information on a 4 safe shutdown analysis. It is a separate document.
5 MR. OLSHAN: It is a separate -- that is why I 6 say the FSAR incorporates those documents by reference.
7 The FSAR, you are right, on fire protection is not very 8 specific. But everything is incorporated by reference.
l 9 MR. LOCHBAUM: Everything is incorporated?
l 10 MR. OLSHAN: Well, I mean that is the intent 11 of it. I can't tell you off the top of my head everything
.2 that should be incorporated.
i 13 MR. MARSH: Why don't we check that?
14 MR. LOCHBAUM: I would -- I guess the point is 15 I think it is a generic issue. We . ave had this before 16 the Commission already from our January 29 letter for ,
17 Maine Yankee specifically.
18 MR. MARSH: For Maine Yankee?
19 MR. LOCHBAUM: Specifically, yes. And we 20 think it is a case -- a generic issue. We just didn't 21 have the resources to go through and prove it for every 22 utility.
23 MR. MARSH: With respect to fire protection 24 issues or with respect to generally updating FSAR safety 25 assessments?
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38 1 MR. LOCHBAUM: G:norolly updcting tha FSAR for 2 safety assessments.
3 MR. NEWBERRY: Let mt comment on this. You 4 are certainly correct. There are issues in front of the 5 Commission where the Commission has directed the staff to 6 take action and you would expect an update of the FSAR's.
7 There is a paper just going up now to the Commission. I 8 would suggest that we acknowledge that that concern is a 9 valid concern and if the Agency attempts to take action on 10 it, it is probably outside the scope of this meeting. If 11 there is a specific comment we need to follow up on for 12 fire protection, we can do that.
13 MR. WEST: I would just like to make a comment 14 that at least until we get or unless we get other 15 direction from the Commission, we have accepted through 16 generic letter 86.10 and 88.12 the incorporation of the 17 fire ha:_ards analysis into the FSAR by reference. So 18 there only needs to be a line An the FSAR that refers back la to the fire hazards analysis and the safe shut down 20 analysis. So it essentially then becomes a part of the 21 FSAR and then the licensees submit annual updates or 22 annual or whatever it is -- biannual changes in accordance 23 with 50.71.
24 MR. MARSH: Like Steve is saying, it says it 25 fairly clearly in this regard with respect to fire NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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39 1 protcetion, unliko with other iccuoc, it may not ba ca 2 clear. So I thin we should -- we will just check to make 3 sure that it is incorporated by reference to the fire 4 protection or the fire hazards analysis.
5 MR. LOCHBAUM: Okay.
6 MR. ZWOLINSKY: For clarification, Dave, your 7 January 29 letter contained a couple of examples of 8 generic communications that the Agency made to the 9 industry in the late 1980's, and had the licensee for 10 Maine Yankee incorporated specifically detail associated 11 with their response to those generic letters in their FSAR 12 if I recall your letter. And I don't believe it was fire 13 protection as much as it was a couple of other technical 14 issues.
15 MR. LOCHBAUM: I just pulled some generic
- 16 communications and spot-checked them and found zero for 17 however many I checked.
18 MR. ZWOLINSKY: I think Scott's point of still 19 going before the commission is probably a fair place to 20 leave it. But as far as the update to FSAR, I know there 21 is a lot incorporated by reference, especially the fire 22 hazards analysis for most of these facilities. And if you 23 haven't seen it, those are continuing to grow to be very 24 substantive documents.
25 MR. LOCHBAUM: Slide 9.
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40 1 MR. GUNTER: I think thct wh:t wa cro -- tho 2 point we are making by these bullets is that as a result 3 of Nuclear Information Resource Service, we filed a 4 Freedom of Information Act with regard to RTV silicon foam 5 and an Office of Investigation review or investigation of 6 one particular vendor and installer for RTV silicon foam.
7 And as a result, we saw some contrasts of statements as 8 well with regard to what we saw revealed in the FOIA. One 9 particular instance was with a letter from Mr. Marsh to 10 Mr. Gerald Brown, who is an industry whistleblower on RTV 11 silicon foam. And what was at issue here is the staff has 12 found instances of penetration seal assemblies that passed 13 fire endurancu tests while exact duplicatos failed such 14 tests. Staff has found no -- has not found instances of 15 penetration seal assemblies that paseed fire endurance 16 tests while exact duplicates failed such tests.
17 on review of one particular document produced 18 through the FOIA, it was an investigative interview with a 19 Mr. Hitoshi Takahashi, Dow Corning senior marketing 20 management for the RTV silicon foam project. And what Mr.
21 Takahashi quoted was that literally you can run 100 tests 22 for the same design. If one passes, you can qualify that 23 design. Which is striking to us in that basically it 24 provides for a 1 percent pass rate to qualify a particular 25 configuration with the Dow Corning product. I think that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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41 1 what thic raisso for us le hau this OI invcotigation baon 2 incorpcrated into the review of ongoing issues and 3 evolving issues with regard to RTV silicon foam? ;
4 MR. MARSH: Yes, it has been. We are aware of 5 the investigation. We considered it as part of our 6 technical assessment. We have not found instances of seal 7 assemblies that have passed and later failed. If you have l
8 any, please provide them. We will review them.
l l 9 MR. GUNTER:_ Okay. Mr. Takahashi also l
10 reported that hydrogen gas seeping from silicon foam 11 barriers at the Perry plant exploded sometime du.iing 1984 12 to 1987. Is the NRC aware of this particular event or any 13 other events in which silicon foam fire barriers provided 14 the fuel for a fire or an explosion? I think that this is 15 particularly noteworthy in that our concern is that 16 particularly in reinstallation of thousands of seals in 17 some cases, particularly with a case-like-a Maine Yankee 18 or Diablo Canyon or Vermont Yankee where you had universal 19 failure of the fire barrier penetration seals at those 20 plants with regard to installation problems. This 21 hydrogen gas accumulation does e natitute a concern, 22 particularly when the instructions on the silicon foam 23 cans clearly state that you have to have well-ventilated 24 areas to compensate for the build-up of this hydrogen gas.
25 So essentially one of the questions before the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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42 1 NRC ctcff ct thic point 10 th t wa balicvs thic to 2 constitute an unreviewed safety issue. We would like to 3 have you clarify for us whether or not that is, in fact, 4 the case.
5 MR. WEST: We haven't been able to find any 6 documentation of this alleged Perry explosion to date.
7 Maybe we will look some more. But we haven't -- we are not 8 familiar with it.
9 MR. ZWOLINSKY: Excuse me, Steve. I 10 apologize. Is the assertion that during installation of a 11 foam barrier penetration seal that there was hydrogen 12 accumulation and it subsequently exploded?
13 MR. LOCHBAUM: Subsequent to the installation 14 of the seal. I 15 MR. WEST: When you install silicon, it is a 16 two-component system -- component A and component B and 17 they are mixed together. And when they are mixed 18 together, they expand and there is a cell structure. The 19 expansion is created by hydrogen -- it releases hydrogen 20 gas and that creates the expansion. So there is hydrogen 21 gas given off. There are precautions that are taken. I 22 am not --
I haven't heard of any -- other than this 23 pessible example, any case of this causing any kind of 24 hazard in a nuclear power plant or anywhere else. It is 25 very low concentrations. These things -- you know, in a NEAL R. GROSS COURT REPORTL9S AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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. _ . _ _. . . - _ _ _ _ . . _ _ . _ . ~ . _ . _ - . . _ _ _ _ . . - . _ _ _ _ . _ . . _ _ . _ . . . _ . _ _ _ . . _ _ _ _ . _ . _ _ . . _ _ _ .
[ . 43
[ 1 typical < nuclear powor_ plant area, there is good 2-' ventilation.- As-far as we can determine-the precautions 3 are followed and it hasntt been a problem.-
4 -MR. ZWOLINSKY: It just sounds very peculiar 4 5 for such a small. volume-to be able^to --
t j 6 MR. MARSH: It does.-
t 1
7- MR. ZWOLINSKY: -- experience such a' mixture '
l 8 and keep it confined such that you can have an explosion.
1 9 MR. LOCHBAUM: Well, if you are working up in
[ 10 the upper reaches in.a pocket somewhere, it seems i 11 reasonable that you could have the hydrogen gas escape
[ .
- 12 from that reason. There is no mechanical mixing in some i
j- ~ 13 of these corners and stairwells..
h 14 MR. ZWOLINSKY: Well, as Steve alluded, on
- - 15 review'of the record to date, we are not aware of this, j 16 If there is anything else that you can provide us to chase h 17- that one down. e
[- le MR. GUNTER: -Well, we initiated a search to
!- 19 try to look into the Perry event,'but because it was 11 20 apparently during construction phase, we haven't been able-p 21' to find anything on the docket with regard to that event.
22- So basically we are putting this question before you in so 23 much that we don't believe this information.is publicly f
i
[ 24 available-atethis point. But we believe this to
. 25 constitute a significant event that certainly wouldn't be NEAL R. GROSS i' COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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i aw- +coe e - - -
er - g. .ry- -- ==i - y -er* +- y*-
44 1 involvsd if you waro to hevo a noncombuctibic matoriel 2 installed in these penetration seals as clearly delineated 3 in the regulations and guidelines. So the concern is that 4 under the current approach that this particular event 5 underscores our ongoing concerns with the continued 6 reliance on a combustible material that not only is 7 combustible, but we believe could also initiate fire.
8 MR. LOCH 3AUM: The question -- coming back to 9 what Mr. West mentioned earlier, the 50.59, where a 10 licensee can replace a fire penetration seal.
11 MR. ZWOLINSKY: Yes.
12 MR. LOCHBAUM: If you did a 50.59 changing 13 from noncombustible material to this silicon foam, the 14 fact that it generates hydrogen introduces another failure 15 load that wasn't there initially. That :s an unreviewed 16 safety question. It has to come before the Commission and 17 get reviewed. It can be approved, but it is an unreviewed 18 safety question because the hazard wasn't there with the 19 other stuff.
20 MR. WEST: I don't think we are agreeing that 21 there is a hazard.
22 MR. LOCHBAUM: I uaderstand.
23 MR. WEST: Okay?
24 MR. LOCHBAUM: Okay. Hydrogen explosions are 25 not a hazard?
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45 1 MR. WEST: I am not going to stipulato that 2 the hydrogen gas that is released from the seal when it is 3 installed creates an explosion hazard. If you have 4 evidence that it does, we will be happy to accept it.
5 .MR. GUNTER: Well, what we are presenting to 6 you is the transcript -- we can clearly provide you with 7 the transcript. But you have that transcript.
8 MR. WEST: We have the transcript.
l 9 MR. GUNTER: That is corree So what we are 10 asking you to do, though, because that Perry event was not 11 publicly docketed, at least to the best of our knowledge, 12 is that we are putting it on the record that we would like 13 to request that event to be further investigated by NRC as 14 possibly initiating this whole unreviewed safety issue. _
15 MR. WEST: We will review it. We will do 16 further review and get back to you on the results.
17 MR. GUNTER: Okay. Slide 11 -- again, with 18 regard to --
19 MR. MARSH: I just want the record to show 20 though - I want the record to show that what we have d.>ne 21 thus far does not indicate that there is any kind of 22' hazard with this. No plant has ever experienced it to our 23 knowledge. They are not reported through 50.72's or 24 50.73's. With the vast amount of penetrations out there, 25 I think there would be more experiences of this sort if it NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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46 1 waro a real hazard. Wa have got probably over a million 2 penetrations'out there. If-we were generating enough
'3 hydrogen that there would be some type of hazard, I think j
- 4 we would have-seen some experience of this sort.
- j. 5 MR WEST: Well, nonetheless, we will look.at 6- this event and see if we can find something.
4 7 MR. LOCHBAUM: Let me address that. If this j 8 event did happen at Perry, like.it is alleged to have 9 happened, it happened during construction days. It 10 doesn't have to be reported on a 50.72. We were not 11 saying the licensee failed to report it. He didn't have t
! 12 to. And that same scenario could have happened at other-
'13 plants and they are not required to report it either. So 14 just the fact that you don't have reports doesn't mean.it s
15 didn't happen at those millions of seals.
{
} 16 MR. WEST: We will look. We will look.
- 17 MR. ZWOLINSKY
- But I think.the staff's 18 reaction is one of quizzical understanding, in part i 19- because we-have e.xtensive knowledge -- extensive
- 20 inspection of how licensees have upgraded their 21 penetration seals. I have-had the opportunity to be 22 involved with Vermont Yankee and Maine Yankee. We 23- certainly -- Vermont Yankee replaced the majority of their 24 seals with a very aggressive program and Maine Yankee also 25 was under a similar program prior to the ceasing of their NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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47 1 oparntion. But cc Tad clludcd, tha numboro cro very larga 2 as far as the number of these seals that have been put in 3 place. So staff is committed to take a look at this and 4 we will go from there.
5 MR. LOCHBAUM: That is fair enough.
6 MR. WEST: Mr. Lochbaum, before you go on, I 7 just want to point out that you've got about 45 minutes.
8 I notice you have a lot of slides left.
9 MR. LOCHBAUM: 45 minutes? I thought we went 10 until 1:00.
11 MR. WEST: No, we were planning to go to 12 12:00, 13 MR. MARSH: If you need until 1:00, we can go 14 until 1:00.
15 MR. OLSHAN: Well, we have the room until 16 1:00. I didn't know how long it would take.
17 MR. GUNTER: Well, we will try to be concise.
18 MR. ZWOLINSKY: So will we, 19 MR. GUNTER: Again, on slide 11, with this 20 whole issue of redundant fire testing to produce a passed 21 test. Again, as provided in a letter by Mr. Brown on 22 Bisco fire index reports -- fire testing index reports --
23 that produced 15 of 34 RTV silicon foam fire tests which 24 resulted in flame throughs. I believe that document is 25 available to staff as well. If not, it certainly can be NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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48 1 meda cvcilcblo. But 10 NRC or NRR aw ro of tho multiplo 2 Bisco fire test failures?
3 MR. WEST: Well, we believe there is probably 4 I don't know how many failures out there. In developing a 5 product, you could test --
I mean, you may test -- as Mr.
6 Takahashi said, you may test 100 things and only pass one.
7 There is going to be failures. We have never claimed that 3 there are not fire test failures in development. We have 9 not seen evidence of duplicate assemblies -- one passing 10 and one failing or come percentage passing and some 11 percentage failing.
12 MR. LOCHBAUM: Mr. Takahashi's thing was 13 testing the same assembly 100 times until you get one to 14 pass. It wasn't testing a product. He continued testing 15 until he got it passed.
16 MR. WEST: Well, like I said, we have not seen 17 those test results. If you can -- if you have them and 18 they are used in a nuclear power plant, we will t s ke a 19 look at it. These particular test results here, I don't 20 know if it is the same test assembly or a different one, 21 but we have not seen any tests that indicate there is a 22 test that passed in one test -- or configurations that 23 passed in one test and failed in another.
24 MR. GUNTER: The report that was published by 25 the Office of Investigation on the Dow Corning product --
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49
.1 now granted, this wao for alleged material falso
- 2. statements andLalleged deliberate failure to follow part _
3- 21 notification.--One of'the issues that the-investigator 4- outlined in the evidence that was presented to NRR ---if I-5- can put my hand on it quickly enough here - _but it is 6 enumerated to'NRR that-to concern of the-OI is that the multiple tests of the same configuration raise some-
~
7 8 concerns with the Office of Investigation. That is 9 published in the report here. And, of course, staff does 10, have this report. But I think that we are -- we remain 11 concerned with that regard that you can essentially bound 12 a number of configurations through multiple testing 13 essentially until you pass the test on the same 14 configuration.
15 MR. WEST:- You know, if you have -- I mean, 16 that is anecdotal information.- If you have test reports 17 or' data that shows that that is the case, we will be happy 18 to consider it.
19- MR-. GUNTER: Well,'wouldIthat not have been:a 20 follow-up-as a result of the report provided by.OI? I 21 mean, it would seem to us that it is not up to us as the
-22 public --
23 MR.- WESTi- We did,.as part of our technical-24 assessment, a number of inspections at Bisco and other 25 vendors. And we did not find through our inspections NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE LSLAND AVE., N.W.
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1 ovidenco cf thic happsning. Dow Corning does not test 2 products for application. They don't test end-use 3 configurations. I will say as a fire protection engineer 4- that.there are situations where a test may pass one day 5 and'may fail the next for whatever reason. These are --
6 you know, there are variables involved in fire, Typically if that is the case, you-have a very non-conservative 8 configuration.
9 MR. GUNTER: Well, just to read into the 10 record from the OI report on its investigation. It'is 11 enumerated on number 25. "Takahashi contended that it was 12 permissible.to run 100 qualification tests of the same 13 design and if only one of these tests passed, it is 14 considered qualified." Exhibit 5, page 32.
=15 MR. ZWOLINSKY: Well, he is speaking for 16 himself, not for the NRC. The-NRC staff has been pretty 17 clear as to --
18 MR. GUNTER: Mr. Takahashi was under oath to l "19 testify -- as part of an investigative interview before 20 NRC OI and made those statements. Again, referencing the 21 same 8/20/97 letter from Mr. Marsh to Mr. Brown, "As a 22 result of our,FOIA' request" -- and this is slide 12'--
23- "NRC recently refused to release fire endurance test reports conducted between February of 1978 and March of 25 l'982 because.they contain business, confidential, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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51
-1 proprietary information. ~ Those had'to do with threo-hour 2' fire' tests conducted by Brand Industrial Service 3 Corporation _with regard to RTV silicon foam." _Obviously, 4' we are concerned'with-regard to what those test reports
~
_5 produced _with regard to whether it'was a pass or fail.
6 But_ initially,' our-concern with regard _to the withholding 7 of these documents within their entirety raises questions 8 with regard to how-can a 15 to 20-year-old report of -
9 testing used to qualify fire barrier penetration seals.for 10 nuclear power _ plants contain proprietary information.- I 11- think this raises some concerns with regard to the fire 12 test reports that came out of the Thermo-Lag cases as well-13- that were eventually the subject of Department of. Justice 14_ criminal proceedings.
15 Slide 13, damming boards are frequently but 16 not always installed on both sides of penetration seals 17 with regard to silicon foam. On a-tour of the North Anna
- 18. nuclear power station which I was on in the emergency 1
-19 diesel generator room, I: personally saw fire barrier 20- penetration seals using RTV silicon _ foam that did not have 21 damming boards on the EDG side and asked-the manager with.
22 regard to that and he basically said that they were dammed 23t on the' opposite side of the wall and that that was enough 24 to qualify them.
25 --
But it does raise concerns with regard to the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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52 1 feet that by NRC'o own findings, thore cro numarous 2 instances of missing damming boards or ceramic shields for 3 these fire barrier penetration seals.
4 MR. LOCHBAUM: Slide 14 quotes a fairly 5 lengthy passage from information notice 88.04 from 6 February of 1988 concerning plant modifications and the 7 concerns that the NRC had at that time that these 8 modifications were being made without an associated 9 technical review to make sure that the design remained 10 bound by its qualification exam. And I guess the question
( 11 is in the time period since 1988, does the NRC still have j
[ 12 any assurance that these modified fire barrier penetration 13 seals remain bound by qualification tests?
14 MR. WEST: Yes, I think we have reasonable 15 assurance. I mean, the whole purpose of the information 16 notice in 88.04 was obviously to point out this 17 discrepancy to the licensees. Since that time, we have 18 conducted a -- as I mentioned earlier, a large number of 19 inspections following up on items like this. We also have 20 through, and this will be documented more in the updated 21 NUREG report -- have available on the docket a lot of 22 information from licensees that describes the changes that 23 they have made to their procedures and processes to insure 24 that they have covered items such as this.
25 MR. LOCHBAUM: Okay. Slide 15. There is a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RPODE ISLAND AVE., N.W.
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53
-1 listing of - . sus ebbrevicted listing. Thora are more 2 examples, but reports of installation problems in the last
-3 10 years, dating back to 1987. Wolf Creek repaired 35 4 percent of 1700 seals. 75 percent of 5200 seals did not 5 meet acceptance criteria at Pilgrim. 85 percent of the 6 1400 penetration seals at Vermont Yankee required repairs 7 or upgrades. Last year, Sequoia was assessed a $50,000.00 8 civil penalty for inadequate design control of fire 9 barrier penetration seals. Last year and ongoing into 10 this year, Maine Yankee was in the process of replacements 11 and repairs to 90 percent of its penetration seals. So 12 there is a longstanding-pattern of problems within the 13 industry of widespread and fairly broad penetration seal 14 problems.
15 The point of this slide is it goes back to-the 16 required attributes of a properly designed and installed 17 seal. This is basically evidence that there'is a problem 18 with the installation of the fire penetration seals and it 19 has not gone away. It is still out there as evidenced by 20 recent examples at Sequoia and Maine Yankee. Slide 16 --
21 MR. WEST: Wait a minute. Let me make a 22 couple of points from your slide. The first one is that 23 we have -- as I just mentioned, we have seen significant 24' and documented improvements in penetration seal programs 25 in the nuclear industry since 1988. In addition to the IN NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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54 1 88.04 that wa juct tolkcd about, wa iccued a couple of 2 other supplements -- or at least a,nother information 3 notice and a supplement to that around the same timo 4 frame. And we issued another information notice in 1994.
5 We think, based on our review of the 6 information, that those actions on the part of the NRC has 7 resulted in significant improvements in the industry.
8 Maine Yankee appears to be an anomaly. They never, from 9 what they tell us, really did a thorough review of the 10 penetration seals after reviewing the information notice.
11 But the Pilgrim, Vermont Yankee, et cetera, these 12 improvements were made directly in response to the 13 information notice and there are a lot of other examples 14 where that is the case, which we will document on our 15 NUREG.
16 With respect to Sequoia, the problems with the 17 fire barrier penetration seals were but one problem of 18 many with their whole fire protection program. They 19 weren't given a $50,000.00 civil penalty because of their 20 penetration seals. They had major programmatic breakdown.
21 That was an example of the programmatic breakdown. That 22 was, in our view, taking an inordinate amount of time to 23 repair or correct.
24 MR. MARSH: To come to that statement, we look 25 at the LERs -- what the statements were in the LERs. How NEAL R. GROSS y COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE,, N.W.
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55 1 thay trendad with tima. Whct typso of daficiencios waro 2 being found in those LERs. We also looked at the 3 inspection reports and what was being cited in those 4 inspection reports. So there is a lot of assessment going 5 into what we are going to upgrade this report to, 6 MR. LOCHDAUM: I guess we should add that the 7 NRC's actions in 1988 did prompt a lot of these 8 corrections. I mean, we are not trying to discredit or 9 discount those efforts. That did lead to a lot of the 10 improvements. I don't mean to state or imply anything 11 other than that.
12 MR. MARSH: Right. But I don' want you to 13 conclude from these examples that the state of penetration 14 seals out there right now is terrible. We don't think it 15 is. We think that progress has been made because of the 16 inspection reports. It has been noticeable and it has 17 been measurable by the LERs and by inspection reports, 18 MR. LOCHBAUM: Okay. Slide 16 is a follow-up 19 to the data in slide 15. The SECY paper last year poirated 20 out that 26 percent of the fire penetration seal problems 21 reported between 1988 -- excuse me, 1989 and 1993 involved 22 seals that were not installed or simply missing.
23 Information notice 88.04 stated that some installed fire 24 barrier penetration seal designs may not be adequately 25 qualified with a design rating for penetration fire l NCAL R. GROSS l COURT REPORTERS AND TRANSCRIBERS
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56 1 barricre. Agnin, ws cro just pointing out that c firo 2 barrier that is not installed or missing cannot be 3 considered properly installed, which is one of the 4 requirements to meet the goal.
4 5 Slide 17 --
6 MR, ZWOLINSKY: And we are not taking 7 exception with that at all, 8 MR. LOCHBAUM: I think we agree on that.
9 Slide 17 --
there is a -- Region 2 conducted an inspection 10 of 18 sites within Region 2, and the result of those 11 inspections are documented in a letter dated November 12 1994. They looked at 72 percent of the 18 sites. They 13 found -- they reported unsatisfactory results at 6 of the 14 sites or 46 percent of those inspected. Examples of some 15 of those problems were at Hatch. There is a lack of cross 16 reference between the seal and test data. The NRC 17 indicated that no follow-up was conducted. Oconee test 18 documents were inadequate with repairs needed. The NRC 19 indicated that no follow-up was done. At Robinson, the 20 inspection was satisfactory but final repairs were not 21 inspected by the NRC. At St. Lucy, the tested 22 configuration of penetrations was not reviewed by the NRC.
23 A 46 percent passing score is not acceptable.
24 Slide 18. This is a quote from the SECY paper 25 of last July. "The NRC staff concluded that the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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57 1 p;natration csel programa in the industry remain 2 satisfactory. The staff found neither plant-specific 3 problems or generic problems of safety significance." I 4 think the data on the previous slide shows that there is 5 quite a bit of plant-specific problems or generic 6 problems. So I think this statement must be predicated on 7 the fact that none of these problems had any safety 8 significance. I just cannot understand how missing fire 9 barriers and all those issues that were just reported on 10 previous slides -- none of those could have had any safety 11 significance at all.
12 MR. WEST: We're going to -- a big part of our 13 updated NUREG report is going to address safety 14 significance and risk significance of penetration seals.
15 MR. MARSH: Let me take a look at some of 16 these items. Lack of cross reference between seal and 17 test data. That does not equate to a safety problem. It 18 is a lack of cross reference between data. Okay? Test 19 documents --
20 MR. LOCHBAUM: Just a minute. Information 21 notice 88.04 reported that there was a concern by the 22 staff at that time that modifications to the penetration 23 seals were being done without being bound by a 24 qualification exam. If Hatch has a problem that they are 25 not keeping a cross reference, then that means Hatch could NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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l 3
58 1 ba doingl--
l <
2 MR. MARSH: Certainly a question _is there.
3 But you can't conclude from.that finding that there is a 4 safety issue that-is there. Yo1r have to pursue what was-5 the problem at issue. -
l 6 MR. LOCHBAUM: Absolutely correct. That__one
- 7 issue by itself would not be safety significant. The- >
l 8 potential is there. ;
9 MR. MARSH: Potentially, yes. The test l .10 documents were inadequate. I mean, what does tha.c mean?
11 That may mean that there is again a cross reference 12 problem. To test a configuration -- if there is a L 13 configuration that hasn't been tested, that is different.
14 or if you are missing a penetration completely, that is .
15 different.
16 MR. LOCHBAUM: Well, also -- I guess to point 17 out, these are NRC inspection reports. The NRC typically '
l . 18 doesn't report problems of-no safety significance when'-
L
( 19 they go out to look at fire penetration seals. I mean, i -
f 20 they are not -- if the test documents were insufficient in 21 that they didn't have secondary reviews or --
22 MR. WEST: That is not true. We report -
23 problems with compliance all the time. If a' seal is
_24- supposed to be installed and it is not installed and the 25- inspector observes it, it typically would be documented.
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59 1 And tha innpaction rcport dossn't nococccrily or typically 2 address the safety significance of the problem. There is 3 all kinds of examples of non-safety violations and other 4 problems of minor significance, but they are still 5 documented if they are observed by an inspector.
6 MR. LOCHBAUM: But a compliance issue goes 7 back to the old question of what is the adequate level of 8 protection. I mean compliance with the regulations 9 assures adequate protection. If you don't have 10 compliance, you may or may not have adequate protection.
11 MR. WEST: That is true. You may or may not.
12 That is the hence. That is why you look at the safety 13 significance and the enforcement models to find out how it 14 all equates.
15 MR. LOCHBAUM: Okay. Well going back to the 16 previous slide where we have all these upgrades to over 17 half -- from the slides at all these plants. None of 18- those could have any safety significance at all?
19 MR. WEST: Wait a minute. We have got to -- I 20 guess the answer to your question in your second bullet on 21 slide 18. What we are saying is at the time in the summer 22 of 1996, we concluded that the condition of the 23 penetration seal programs in the industry was 24 satisfactory. We weren't saying that in 1978 it was 25 satisfactory or in 1988 it was satisfactory. We were NEAL R. GROSS COURT REPORTERS AND TRANSCR!DERS
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60 1 coying thnt in 1996, following ths offorto of the staff, 2 the issuing of the information notice, and the efforts of 3 the industry to look at their programs and see if they 4 have those problems and make repairs, that those 5 information notices were effective in bringing problems to 6 the attention of industry and having them taken care of.
7 MR. LOCHBAUM: When did Maine Yankee's report 8 come out?
9 MR. WEST: Maine Yankee's report came in --
10 MR. LOCHBAUM: After the SECY paper.
11 MR. WEST: Right after the SECY paper. And 12 our report acknowledges that there may be problems out 13 there. We didn't say there weren't any problems out 14 there. It is clear we stated probably in the abstract, 15 the executive summary, and a couple of places in the 16 report that given the number of seals out there and the 17 fact that they are changed all the time that occasionally 18 problems will be found.
19 MR. LOCHBAUM: Okay. I agree with that 20 totally.
21 MR. ZWOLINSKY: But you have redundancy of 22 function, arguments, separation criteria, cable 1 23 penetration to be found for light function quite some 24 distance away. There is other factors that come to bear 25 as to actually the penetration.
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61 1 MR. LOCHBAUM: Suro. Dafinitely. I cgrco 2 with that.
3 MR. ZWOLINSKY: Which gets into just the 4 overall regulatory philosophy of defense in depth and --
5 MR. MARSH: Before you go on, Dave, I would 6 like -- we have looked hard at Maine Yankee's 7 imperfections and what they did and how they did it and 8 their criteria for it. They declared a great many of 9 their penetration seals as needing repair or needing 10 replacement. It was a c.tetty conservative judgment that 11 they used to come to that point. And by their 12 estimations, there were a few cases where there was a i 13 totally missing penetration seal -- a few. There were l 14 some, but there were very few. But there was a large 15 number of penetration seals that didn't meet the tested 16 configuration. That means if it was tested at 9 inches or 17 8 inches, there may have been 7 inches and they declared 18 it inoperable and changed it out, although it could very 19 well have given & great deal of fire protection associated 20 with that. You shouldn't be misled by the large numbers 21 of repairs at Maine Yankee. It was a good thing to do. I 22 don't want to criticize them for doing that. But I don't 23 want to make a judgment that there was a large number and 24 a big safety problem that was there. There was a large 25 number of penetration seals that didn't come up to the NEAL R. GROSS COURT REPORTERS AND TRANSCPIBERS 1323 RHODE ISLAND AVE., N.W.
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62 1 tested configuration. =Maybo'not a 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />. It may havo .
2 given you a 2.5 hour5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> instead of a 3 beur or a 45 minutes 3 instead of a 1-hour. .But I Want to make sure you 4 understand that-point..
5 MR. LOCHBAUM: Sure. Does the fire protection 6 -- does your section -- I don't know the exact title.
7 MR. WEST: Production engineering section.
8 MR LOCHBAUM: Okay. Does that section look 9 at the IPE's for. fire risk?
10 MR. WEST: 'The IPEEE's are the ones that do 11 the fire risk. It is a program that is led by research
- 12 but we provide significant support and we participate in 13 the fire protection reviews.
14 MR. LOCH 3AUM: What is your understanding of 15 what the range of assumptions that licensees use for the
- 16. odds that a fire penetration barrier or seal will be 17 breached as a result of a fire, such that you get-a fire i 18 going from one-fire area to the other? What is the fire 19 propagation probability?
20 MR. WEST: I don't know off the top of my
. 21 head. Typically the dominant risk factor is for damage to 22 redundant components located in the same fire area.rather 23 than the fire spreading from one fire area to another. .It 24 is.a fairly high probability of success that the seal and
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i
63 1 going to ba conteined.
2 MR. LOCHBAUM: Okay. The ones I have looked 3 at so far -- all of them show a zero percent chance that 4 there will be fire propagation across the barrier for a 5 fire rated assembly. There is a zero percent chance that 6 the fire will propagate across a non-fire rated barrier to 7 an adjacent fire area. Giving the examples of missing, 8 inadequately installed and all this other stuff, I just 9 find it incredible to believe that the probability is 10 zero. It may be very small, but there is no way that it 11 is zero. So I think that the IPE's --
12 MR. NEWBERRY: Did you look at the next step l
13 if you were to assess this? Staff is looking at these 14 things and still have some questions. Plants are taking 15 actions as a result of some of their studies. But even if 16 you were to estimate a reasonable likelihood of failure, 17 would that change the result of the study?
18 MR. LOCHBAUM: It would make it more safe. I 19 would suspect that would be the case.
20 MR. NEWBERRY: Well, I just wonder if even if 21 there was a 10 percent failure, would that cause that type 22 of event to contribute any more to --
23 MR. WEST: I think, Scott, that the risk 24 assessment that we are going to document in our updated
-25 NUREG on seals is going to show that it doesn't matter.
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, .__-_n
64 1- MR. MARSH: It in dominnted by other thinga'as 2 opposed to being dominated by the breaches across areas. -
3- MR. LOCHBAUM: Then why have the seals at all?
4 MR. MARSH: It is a defense in depth. It is 5 one of the fire protection measures. I mean there are 6 many parts on varying safety significance. And just 7 because one is not significant doesn't mean that you don't l
8- have it. I eean, it is another feature of the plan. It l 9 is important.
10 MR. LOCHBAUM: But then it has a very 11 negligent -- from the background --
12 MR. MARSH: But that is from a risk 13 perspective -- from a risk perspective.
14 MR. LOCHBAUM: If you are going to risk in I
15 forming regulations, then you would say don't fix them.
16 MR. MARSH: It is going to be risk in form.
17 That doesn't mean it is going to be risk alone.
18 MR.. WEST:
Let me add one clarification. It 19 may be acceptable on a case-by-case basis not to have 20 seals today. Our letter 86.10 which we published in 1986 21 obviously says that. It is in the NUREG 15.52, 22 MR. ZWOLINSKY: Clearly'many of our newer 23 facilities will be employing real physical separation, 24 independence of trains. That goes a long way to 25- ameliorate what we thought was necessary in days gone by.
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. . . - ~ .. . . _ . - .. - -~. - .-- . - . , - - . - . . - . -.
. 65 1: MR. LOCHBAUM: Right. I assume that is part 2 of the reason for the low safety significance from 3 breaching of barriers. Because there is separation.
4 There are not two things put side by' side on the other 5 side of.~the wall.
! 6 MR. ZWOLINSKY:- And you are also aware that i 7 when the licensee performs these IPE's, the assumptions
- 8 that are made are that you have essentially a pristine 9 power plant. It is designed, constructed, and looks 10 exactly the way the paper looks. And our analysts are 11 using that. What you are finding in some of these 12 examples are other than what an analyst thought while he 13 was doing his work.
14 MR. LOCHBAUM: We are going to try to address 15 that as part of the 50.54 effort responses for design 16 bases. That is that the IPE's assume a pristine plant.
17 The 50.54 design responses show that that is clearly not 18 the case. There should be a greater uncertainly or 19 somehow that should be factored in to the risk analysis in 20 some form or fashion. I don't know how that would be 21 done. Since that is the reality, the analysis needs to be 22 corrected.
23 MR. ZWOLINSKY: And what measure or what value 24 does the probability of core damage default to is clearly ,
25- a subject of debate. When you have a facility such as NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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66 1- Salem that noods-to cpand quito coma tima in.the recovery 2 mode. They obviously went from a fairly pristine number 3 to some ianknown number and then back.
.4 MR. LOCHBAUM: Right.
5 MR. ZWOLINSKY: Okay? And how far did they 6 dip down? They obviously dipped low enough that their 7 management felt that plant was in need of major recovery, 8 and thus they shut those units down.
9 MR. MARSH: Timing. I want to' talk about 10 timing. Steve has an appointment at 12:30. So I would 11 like to get wrapped up by 12:30 if we can. I know that is 12 a little short of 1:00, but that appointment came up 13 suddenly.
14 MR. LOCHBAUM: Well, I think we are doing 15 pretty good. We were originally trying to wrap up by 16 12:30 anyway.
17 MR. MARSH: Okay.- But you've got the video 18 that you want to show.
19 MR. LOCHBAUM: It is just a few segments. I 20 am not going to show the whole thing. Just a few 21 segments.
22 MR. MARSH: We wanted the opportunity to 23 comment on that video as you go through it.
24 MR. WEST: We may have questions on it.
25 MR. LOCHBAUM: Slide 19 -- we have kind of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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67
_1 covered-thio.clrocdy. Mr. Ruland gave ma the chapter and 1
2- the number that has the inspection criteria, so I will 3 take a look at that. And I will just skip that slide 4 until I can have a chance to look at-that.
I would like to make one comment on 5 MR. WEST:
j 6 it. JI don't think the license -- I mean, the inspection 4 7 procedure directs the inspector to look at penetration i
8 seals and it gives a little bit of guidance. But I don't 9 think that is particularly reflective of the licensee's
. 10 own procedures for surveillance. I mean, we give one 11- paragraph and the surveillance procedures are pages.
12 There really is -- your second bullet there I just don't 1
13 agree with. Other than the fact that we are saying we are 14 going to look at penetration seals and they are going to 15 do it too. But their own procedures for surveillance are l
16 much more comprehensive.
17 MR. LOCHBAUM: So those comprehensive 18 procedures are-the ones that led to the 3900 out of 5200 19 not being installed and so on?
20 MR. WEST: That is what somebody found report.
21 MR. GUNTER: -Okay. We have cued up this 1 22 video, which was produced by a Canadian fire protection 23 vendor-and' supervised by underwriter Laboratory of Canada 24 with regard to a standardized fire test of an-RTV silicon 25 foam assembly. We have skipped-all of the test assembly ,
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68 1 materici cnd creentially wa cro cutting to the firo to:t 2 itself. So this will just be a couple of minutes.
3 MR. MARSH: All right, but there may be some 4 -- if it is the same video, there may be some aspects that S are before this that may be relevant to what you are going 6 to show.
7 MR. GUNTER: Okay. Do we have volume on this?
8 (Whereupon, the video was shown at this time.)
9 MR. GUNTER: I think that what this particular 10 video -- the concerns that it raises for us first of all 11 are that clearly RTV silicon foam constitutes fuel for a 12 fire as well as being constituted as a fire barrier. The 13 issue that not only does it constitute fuel for a fire but 14 also it harbors fire as was demonstrated by the fact that 15 cfter the hose stream test was applied, the material 16 reignited. The deep seated fire nature of this particular 17 material has also been documented through communications 18 between Mr. Conrad McCracken in his essessments of RTV 19 silicon foam. Those documents are available as well.
20 But of additional concern is that one of the 21 constituent products of combusting RTV is also 22 hydrochloric acid that is in the off-gas and in the emoke 23 as well as large amounts of debris generated by the heavy 24 smoke that results from the combusting. But all of these 25 we believe to constitute fire hazards that could quickly NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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69 be allovicted if a noncombustible material were utilized 2 as a fire barrier.oenetration seal material. Sa I think 3 that unless you have any further comments with regard to
-4 that particular segment--of the video, those are 5 essentially our concerns.
6 MR. WEST: Okay. A couple of -- are-we going 7 to see more of the video? I F1 8 MR. GUNTER: No. We don't have any plan to 9 unless --
10 MR. WEST: Well,_we don't -- we have seen that 11 video before. A couple of observations. I think first 12 and foremost is that that configuration that was tested is 13 nou representative of any penetration seals installed in 14 any nuclear power plant in the United States. It is not 15 representative.
16- MR. GUNTER: Could I ask by_what qualification 17 you are saying it doesn't meet any industry application?
18 MR. WEST: Well, to our knowledge, at least up 19 through several months ago, the overlay system which was 20 tested in this test is not used in this country.
21 MR. GUNTER: That is the RTV or the Dura 22 Systems overlay?
23 MR. WEST: Right.
,. 24 MR. GUNTER: Correct.
i
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1 country.
2 MR. GUNTER: Correct.
3 MR. LOCHBAUM: If it hadn't been for the 4 overlay system, that test would not have passed.
5 MR. WEST: How can you say that?
6 MR. LOCHBAUM: Because the foam was 95 percent 7 consumed by the test.
8 MR. WEST: Well, that is a good observation, 9 We don't know. We don't know.
10 MR. LOCHBAUM: You can't reasonably believe 11 that it would pass the test without the overlay.
1
! 12 MR. WEST: I believe -- well, based on the
! 13 tests that we have witnessed, we have never seen any kind i
l 14 of performance like that before. And it has not had this 15 extra overlay on it. Never.
16 MR. GUNTER: You have never witnessed a test 17 that fostered deep-seated fires?
18 MR. WEST: Yes, we have. Silicon foam and 19 silicon elastomer are sacrificial materials. They provide 20 their fire protection by being slowly consumed in a fire.
21 That is how they work. The material is slowly, about an 22 inch an hour during the fire test, consumed. It is like 23 charcoal burning. You start out with a nice black 24 charcoal briquette and it burns in very slowly and you are 25 left with a nice white ash. It is almost totally NEAL R. GROSS COURT REPORTERS At4D TRANSCRIBERS 1323 RHODE ISLAND AVE.. N.W. t (202) 234 4433 WASHINGTON, D.C. 20005-3701 (202) 234 4433 t i
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71 l' consumsd. You cre left with on inort ach. Silicon focm 2 works the same way.
It is designed to work that way. Now 3 most --
as you mentioned earlier, most silicon sea 19 have j 4 damming materials which are ceramic fiber board or i 5 materials like that which are porous. And when they are l 6 tested in the fire, the damming material itself provides !
7 about 45 minutes or an hour of fire resistance. That is a 8 porous material that when the silicon foam behind it is 9 heated up and it off-gases, it just flows through it. It 10 just flows through the damming board and it burns a little 11 bit. You see little wispy flames. Nothing is getting 12 through that steel. So what you are seeing there is you 13 are cooking the silicon foam in there. It is escaping 14 through wherever it can -- it is probably being 15 pressurized and escaping through wherever it can escape 16 and you see these flares.
17- Now I would like to see a side-by-sida test of 18 that configuration or ever a simpler configuration -- that 19 is a very complicated configaration -- but I would like to 20 see a side-by-side test of a configuration that uses that 21 system and a traditional configuration. I mean, you raay 22 be'right. I mean it may or may not pass. I don't want to 23 say because we don't know. I mean, we didn't do a 50 detailed review of this test report itself.
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72 1 tcoto without tho demming boarda?
2 MR. WEST: I think maybe one or more of the 3 Watts Bar tests may not have had a damming board. I don't 4 know for sure. I think my answer would be no because I 5 don't know.
6 MR. LOCHBAUM: But staff is aware of where the 7 damming boards are not installed?
8 MR. WEST: We have been -- it is my 9 understanding that there are tested, qualified 10 configurations that don't use damming boards on both sides 11 of the seal -- maybe on one side and not the other side.
12 And if the seal is thick enough, it will work. I mean, if 13 the silicon foam is thick enough -- if it is 2 feet thick, 14 it is going to work. I mean, I don't know if it has to be 15 2 feet thick, but since it is a consumable product, if you 16 put enough in, it will work without a damming board. Some 17 ' seals are installed with temporary damming be,ards. They 18 may just use a piece of cardboard and then after it is 19 cured, they take it off.
20 A couple of other observations on your video, 21 though, before we get too far off track. We don't agree 22 that the silicon foam was extinguished and reignited. We 23 don't think it was ever extinguished. The hose stream did 24 not reach the silicon foam.
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73 1 otrotm.
2 MR. WEST: No , the steel did. The steel did.
3 That steel -- if they wanted to put that fire out, they 4 could have put that fire out. They would have pulled that 5 steel off, if it could come off, and they would have put 6 it out. They did a three-minute hose stream test.
7 products of combustion -- maybe it does give 8 off hydrochloric gas. As we told you when we were 9 discussing the same issue in Thermo-Lag, so does 10 everything else that is going to be burned at the plant.
11 So do the cables and those cable trays I showed you on my 12 cartoon. They are giving off the same products of 13 combustion. Remember, you are in a situation you don't 14 want to be in. You have a fire and it is not a pretty 15 thing. There are things going to be happening. I mean, 16 there are products of combustion given off. That is why 17 the fire brigades have breathing apparatus and protective 18 clothing. I mean, it is not some situation you and I are 19 just going to walk into and deal with. It is a bad 20 situation.
21 MR. LOCHBAUM: So do the fire protection 22 people wear face masks and protective clothing?
23 MR. HEST: Right.
24 MR. LOCHBAUM: What about the equipment that 25 is maybe on the other side of the wall from this stuff?
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74 1 MR. WEST: Tho equipmont on tha other cida of 2 the wall is going to be protected because the fire and its 3 products aren't going to spread from one side to the 4 other. That is the whole purpose of the seal. Now in 5 this case, I don't know if you noticed in the test -- this 6 was a very unusual little furnace. But that ;hing is 7 vented right into the building where they were doing the 8 test. I never saw anything like it in my life. You saw 9 the flames shooting up through the -- it wasn't exhausted 10 outside through an afterburner like in most test 11 laboratories. So anything going out either one of the 12 stacks on either end was just raining right back down into 13 the lab. It could have been -- I am sure some of the 14 stuff -- I don't even know if any of the stuff was from 15 the silicon foam to tell you the truth because it looked 16 to me like it was entombed in the steel. That may have 17 just been the cable jacket.
18 MR. LOCHBAUM: I think that was for the first 19 half hour that it was burning the cable jacket and cable 20 wrapping.
21 MR. WEST: Yes, but when they took that thing l 22 off and they did the hose stream test, that steel was 23 still there. I don't know where all the ash from the foam l
24 came from. I know there are openings there and you had 25 flares. There is going to be some getting out of there.
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75 i But how much, th2y didn't report that.
2 With respect to one other point made, Paul, on 3 fire hazards is the silicon being a fire hazard itself.
4 We don't see it that way and that is well documented in 5 NUREG 15.52.
6 MR. GUNTER: What I said was that it 7 constituted fuel for a fire.
8 MR. WEST: It does -- it would constitute fuel 9 for a fire. But relative to the rest of the fuel in the 10 fire area, it is very small typically. If you have a 11 cable tray loaded with cables and you have a seal at one 12 end, that seal is a very small contribution to the fuel 13 load. And the surface area available is insignificant 14 compared to the surface area available on the cables. You 15 had more cable trays -- I am not trying to be 16 argumentative, I just want you to understand.
17 MR. GUNTER: Okay.
18 MR. WEST: There are things that burn in 19 nuclear power plants.
20 MR. GUNTER: I understand that.
21 MR. WEST: The cables are the most 22 significant.
23 MR. LOCHBAUM: I think we can see that. It is 24 because of that that you need the fire seals. I mean if 25 it wasn't for the other stuff, you wouldn't need them.
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76 1 MR. GUNTER: Right. But I think th t our 1
2 concern again restated is that the current system that is 3 deployed by and large throughout the U.S. industry by our 4 determination constitutes a point of transition for the 5 fire from one zone to another because it is combustible 1
6 and it can harbor fire. Now whether or not -- that test 7 may very well have been harbored to one degree or another 8 by the damming system represented there. But 9 nevertheless, the fire was moving through that fire 10 barrier penetration seal because the material was 11 combustible. There were corrosive products being 12 generated and transported as a result of that 13 combustibility, and that stands in stark contrast to what 14 we currently read to be clearly throughout the regulation 15 with regard to guidance for noncombustible materials. We 16 would believe that noncombustible requirement to be the 17 most conservative and common sense approach to 18 constructing a fire barrier. This doesn't constitute --
19 this just doesn't make sense to us.
20 MR. LOCHBAUM: If you used a noncombustible 21 material like the law would tend to imply, then the 22 question of deep seated fires is not even a relevant 23 issue. So if you -- if all the plants in the country had 24 noncombustible fire seals and they were to go out tomorrow 25 and do a 50.59 to put in thiu RTV foam, it would appear NEALF. GROSS COURT REPORTER!; AND TRANSCRIBERS 1323 RHODE I!iLAND AVE., N.W.
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77 1 that c USQ would como in baccuco you havo doop occted 2 fires and you have potential for combustible material, 3 high product material, heavy smoke, and all the other 4 aspects. So it wouldn't seem that it would be possible to 5 do that in a 50.59 done properly. That is basically the 6 point where we are at with RTV foam.
7 MR. MARSH: I don't know how that would pan 8 out. I really don't. And I don't want you to think that 9 we were agreeing with you on that -- whether a 50.59 would 10 result in a USQ would depend on a lot of aspects.
11 MR. LOCHBAUM: I know that. In fact, in the 12 recent past it has not because Maine Yankee was changing 13 out with RTV foam and they didn't have it before. And I 14 assume they followed the 50.59 process and they must have is come up with the answers all no, otherwise they would have 16 let you guys know.
17 MR. MARSH: I thought they had foam before 18 too. Some were probably changed out from noncombustible 19 to combustible -- to the RTV. That is probably so 20 MR. LOCHBAUM: Well, they were missing under 21 this report anyway.
22 MR. MARSH: Right. Well, I guess one of the 23 real keys to this whole question about the use of silicon 24 foam is that they have been demonstrated through tests 25 like this to achieve their intended function. And in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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78 1 fcet, thio vcndor that did thia tact c1cimo that thic tect 2 passed. That on the unexposed side where the measurements 3 are taken, everything was hunky dory.
4 MR. LOCHBAUM: With the application of their 5 product.
6 MR. MARSH: Yes, that configuration with the 7 application of their product.
8 MR. LOCHBAUM: Well, I think --
9 MR. ZWOLINSKY: We haven't reviewed that.
10 MR. WEST: We have to review that. I am not 11 sure we would agree with that conclusion.
12 MR. LOCHBAUM: Sure. I understand that.
13 MR. WEST: That is just their claim.
14 MR. LOCHBAUM: I think the point that we made 15 earlier though is that the information we have from Dow 16 Corning is that they run -- they are aware that tests like 17 that are run until you get one that passes and then you 18 qualify the configuration. And if that is happening, that 19 is totally wrong. That needs to be fixed.
20 MR. GUNTER: For the sake of just continuing 21 here to finish --
22 MR. ZWOLINSKY: Excuse me, Dave. I want to 23 follow up on that point. If a configuration is being 24 tested and it fails and a like configuration is being 25 tested and it fails and so on and so forth, and on the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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79 1 10th or tho 20th tima it p:0000, thoy Agancy chould not 2 allow that type of phenomenon to take place is your point.
3 MR. LOCHBAUM: No. The Agency could. But the 4 chances of that configuration propagating a flame would be 5 90 percent instead of zero, like I mentioned earlier.
6 Because you tested the same configuration 10 times and 9 l 7 of them failed. So the chances of a fire in reality 8 failing would be 90 percent and not zero. So it could be 9 perfectly fine to use that configuration as long as you j 10 properly treat it --
the fire propagation probability 11 across that fire seal. That is all we are saying.
l 12 MR. ZWOLINSKY: Okay.
13 MR. GUNTER: Slide 21 generated -- as a result 14 of some sound specific concerns, we had raised the issue 15 of RTV silicon foam as a proposed .~estart issue for Salem l 16 Unit 2.
17 MR. WEST: What was that? Say that again? I 18 am sorry.
19 MR. GUNTER: We were seeking to raise RTV 20 silicon foam as a restart issue for Salem Unit 2. And as 21 a result of our inquiries, we were basically told that the l
22 standard by which Unit 2 would be licensed happened to be l
23 the APSCB 9.5.1 revision 0, which was explained to us --
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80 1 point of vicw. Whan wa want into tha public documont room 2 to review the standard that Salem 2 was being licensed 3 under, wc could only find APSCB 9.5.1 in the superseded 4 sections of the NRC public document room. And clearly 5 stamped throughout the revisions of this particular 6 standard are superseded. There are several superseded 7 stamps on --
8 MR. WEST: Can I see that, Paul?
9 MR. GUNTER: Sure.
10 MR. WEST: I think maybe what we need to do is 11 give you a copy of the actual branch technical position 12 that we were referring you to in our letter.
13 MR. GUNTER: Okay, is that --
14 MR. WEST: I don't think this is it.
15 MR. GUNTER: Is that APSCB 9.5.1?
16 MR. WEST: Well, it is Appendix A to APSCB 17 9.5.1.
18 MR. LOCHBAUM: Would that be in the public 19 document room?
20 MR. WEST: Well, I think I have it here. I 21 can probably just give it to you.
22 MR. LOCHBAUM: I would rather try to get it 23 from the public document room.
24 MR. ZWOLINSKY: We can affix it to the 25 transcript.
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81 1 MR. LOCHBAUM: I would w nt to tOct to oco if 2 it is a public document.
3 MR. GUNTER: Clearly the concern that we have 4 here and if you can address it, we would welcome it. But 5 the standard -- as we believe currently. the standard has 6 been superseded. Or at least there is confusion with 7 regard to which standard applies in this case. And 8 clearly if it is superseded, the issue is that it has then 9 been set aside as inferior. Because of the lack of the 10 noncombustibility requirement in this particular standard 11 as it was used to restart Salem 2, we would believe that 12 to be inferior. Because we believe that the fire barrier 13 standard should include a noncombustibility requirement 14 for fire barrier penetration seals. And that is lacking 15 in this particular addition. But if that is the case, we 16 would like to know what the legal standing of the 17 superseded document is with NRC and is a superseded 18 document readily available for NRC inspectors and 19 licensees in reviewing fire hazards analysis or whatever 20 for these particular plans.
21 Another point of clarification that we need in 22 slide 22 was in our inquiries with regard to how APSCB 23 9.5.1 was invoked or applied to Salem. We were referred 24 to a document dated 11/20/79, and that particular 25 document, as in An.endment 21 -- in fact, when we pulled NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS
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83 i tha docum:nt, it w o for Unit 1 oporating licenca -- tho 2 Salem operating license. And to us, it did not appear to 3 apply to Salem Unit 2. So we would need some 4 clarification on that.
5 MR. OLSHAN: The document is Unit 1. But the 6 SER that accompanies it has on it Unit 1 and Unit 2 7 because I have it right here. The safety evaluation 8 report for Unit 1 and Unit 2.
9 MR. GUNTER: And when was --
10 MR. OLSHAN: And then it was refelenced in the 11 Unit 2 supplement safety evaluation -- the same safety 12 evaluation. Supplement 5 I believe it is. I don't have 13 it with me. The Salem 2 license -- SER rather.
14 MR. GUNTER: Okay.
15 MR. OLSHAN: It references this safety 16 evaluation. But you are correct, the 1979 document was 17 only for Unit 1.
18 MR. GUNTER: Right.
19 MR. OLSHAN: But it had an SER that applied to 20 both.
23 MR. GUNTER: And the date of issuance for that 22 with regard to Unit 2 would have been in advance of Unit 2 23 licensing?
24 MR. OLSHAN: Well, the assumption is that Unit 25 1 and Unit 2 were designed the same way. That is correct.
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83 1 I mocn, thio io o cofoty ovcluation of a dacign, not of 2 the actual plan. This was a design and the design was the 3 same.
4 MR. GUNTER: You see, part of the confusion 5 that we are experiencing -- and I would imagine with 6 regard to licensees as well -- is that various licensing 7 commitmenta are made by documentation and it is difficult 8 to sort out which commitments apply to who, particularly 9 with regard to where some commitments would require the 10 noncombustibility requirement by date of their licensing 11 -- the actual issuance of the operating license as per the 12 Code of Federal Regulations.
13 MR. OLSHAN: Yes, I agree with you 100 14 percent. This is new to me and it took me a long time to 15 figure out what the license was saying. That is why Steve 16 said earlier that it is taking him quite a bit of time to 17 get all that stuff together. It is confusing. I agree 18 with you. But the facts are the way we presented them.
19 That SER spplied to both units, 1 and 2.
20 MR. GUNTER: Okay.
21 MR. LOCHBAUM: I have the second bullet on 22 slide 22, which you basically just addressed. It took 23 quite a bit of time to answer Senator Biser's question.
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r 84 1 that that offort io cxp;nd:d ovary timo ovarybody or ovary 2 time everybody --
3 MR. WEST: You mean when we are doing a review l
l 4 of an issue?
l 5 MR. MARSH: That is why we are taking so long 6 to review the conferences. It taken time to review the l
! 7 documents.
8 MR. LOCHBAUM: I mean when the licensees are 9 out doing work and changing plants, do you think they go l
10 through this rigmarole every time to figure out what they 11 are supposed to be doing here?
12 MR. WEST: Yes.
13 MR. LOCHBAUM: How. That is on the record.
.14 Wow.
15 MR. OLSHAN: There are a lot of things about 16 Appendix R that surprised me when I got into it. First of l
17 all, it is the only -- rne of the few regulations that --
18 MR. LOCHBAUM: I worked for 17 years and I 13 didn't go through this much effort for all these things.
20 MR. MARSH: Fire protection is confusing.
21 Fire protection is convoluted. Appendix R doesn't apply
! 22 to everybody. It is only certain pinnts. That is the 23 arrows coming in and going out. It is confusing.
24 MR. LOCHBAUM: We are into the conclusion 25 section. We will try to go through this fairly quickly.
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l.
85 1 Slida 23 10 bocically comothing I think most peoplo cgroo 2 to that licensing requirements for fire penetration seals 3 are extremely complicated making both compliance and 4 enforcement very difficult. And our recommendation was 5 that as the NRC proceeds with rule making, a unified rule 6 applicable to all plante should be adopted. That sounds 7 like where the direction is heading.
8 The second bullet on slide 23 was industry 9 experience demonstrates a pattern of fire barrier 10 penetration seal problems. At the time this was written, 11 I was basing the statement on the second paper that the 12 NRC had no applicable instruction guidance. I learned at 13 this meeting that that is not the case. I will take a 14 look at that ir. formation.
15 Slide 24 goes back to the question of risk 16 assessment. The possibility of fires cannot be assumed to 17 be limited to any one fire area unless 100 percent of the 18 fire barrier penetration seals for that area are properly le designed and properly installed. Given the longstanding 20 and widespread design and installation problems, the 21 prchability that fires propagates across a fire barrier is 22 greater than zero. Since the probability of propagating l
l 23 across the fire barrier is not zero, the individual plan 24 examinations are non-conservative if they assume 100 25 percent fire barrier integrity.
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86 1 MR. MARSH: IPEEE caid that.
2 MR. LOCHBAUM: IPEEE said that. And just as 3 an add, everyone I have looked at to date assumes 100 4 percent integrity, but I have only looked at 4 or 5. So 5 it is not -- I haven't looked at them all.
6 MR. NEWBERRY: Just a comment there. The 7 IPEEE -- I don' t want to try to put words in your mouth --
8 but their intent is not to be conservative. The intent is 9 to provide a realistic assessment. I would assert that it 10 is not realistic in your opinion.
11 MR. LOCHBAUM: It is neither realistic nor 12 conservative. I would use those words. Let me just keep 13 my own. Slide 25 -- we are somewhat concerned that the 14 use of combustible rather than noccombustible fire barrier 15 material penetration seals make constitute an unreviewed 16 safety question unless the adverse consequences have been 17 evaluated and deemed not to challenge operation of 18 equipment in adjacent non-fire areas. Examples we use are 19 hydrochloric gas and other smoke-carried debris.
20 MR. MARSH: Would you agree, Dave, if the 21 configurations that are out have been tested and the stafi 22 has concurred in the tests that they are qualified and 23 they are constructed in accordance with those tests or 24 configured in accordance with those tests that they would 25 not be in 'ISQ?
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87 1 MR. LOCilBAUM: Yoo. That gozo back to tho 2 first two goals we had on the first slide that we agreed 3 with. That properly designed and installed fire seals 4 provide adequate assurance. Our concern is that they 5 don't.
6 MR. WEST: You are saying even if they are 7 made of silicon foam?
8 MR LOCllBAUM: Even if they are made of 9 silicon foam. They can meet those requirements. The 10 concern we have is that there are test results showing 11 that they may not. There are concerns about the design 12 and testing, but it is possible for a silicon foam rubber 13 seal to meet this requirement.
14 MR. GUNTER: I think that one of the is requirements that clearly has to be challenged though is 16 the whole issue of combustibility. I know that this is 17 the point that we continually chase around on, but from a 18 common sense point of view, a fire barrier shouldn't be 19 combustible. There are materials -- I mean, what is 20 puzzling to us -- just as one concluding remark, what is 21 most puzzling to us is that the most expensive material 22 that could be deployed or that was deployed in terms of 23 what is out there on the market -- the most expensive 24 material - found the widest acceptance through the l
25 industry. That is a concern.
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88 1 MR. WEST: Wall, Paul, thoro oro rocsono for 2 that. We didn't get into all the advantages and other 3 properties of these materials that makes them attractive 4 for nuclear power plant applications. It is not just used 5 as a fire barrier. I mean, the elastomers can be used as 6 health seals and for watertight seals. They can be 7 combined with other materials to make radiation shielding.
8 They are easy to install. You know, you inject that foam 9 into an opening and it expands around anything that is in l
10 there and forms a friction fit. They age extremely well.
l 11 We are not aware of any aging problems with silicon foam i
12 materials or silicon based materials. So there is a range I
13 of properties with these materials that makes them very 14 attractive. And the fire resistance is only one of them.
15 I mean, they are very good fire resistant materials. It 16 is not just used in the nuclear power industry. I mean, 17 these things are used throughout the United States in any 18 number of a.pplications.
19 MR. LOCHBAUM: Not the way they are used in 20 the fire industry, though. They are qualified and backed 21 by tests in a different way than the nuclear power 6 22 industry does it.
23 MR. WEST: In what way?
24 MR. LOCHBAUM: There is actually -- they don't 25 have this one out of a 100 testing criteria thing and they NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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89 1 don't hava -- they cro backcd up by lictings cnd othar 2 documents that show the configuration you have is backed 3 up by a qualification test and that doesn't seem to be t.he 4 case in the industry -- the nuclear power industry.
5 MR. WEST: Well, I will go back to what we 6 said before. We have not seen any evidence that there are 7 seals installed in nuclear power plants that have passed 1 8 out of 100. And we would invite you or anyone else to 9 submit information to show that and certainly we would l 10 look at that.
11 MR. LOCHBAUM: Well, part of the frustration 12 that we have is we try to get a copy of the fire test 13 results and you have them and won't give them to us. So 14 there is a little oit of frustration on our part to try to 15 give you the data that you are asking for.
16 MR. WEST: The other frustrating part is that 17 --
again, just to retort is that the office of 18 Investigation has provided evidence -- sworn testimony --
19 MR. WEST: They have not provided evidence.
20 MR. GUNTER: They have provided sworn 21 testimony to staff with regard to this 1 percent pass 22 rate. That was provided in the Office of Investigation 23 report on RTV silicon foam. So I believe that the onus is 24 not on the public at this point to provide you w!th test 25 reports. That should have been follow up in terms of a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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90 1 tcchnicol iccuo that w:c reiced out of tha OI 2 investigation that I believe is the onus of NRR.
3 MR. WEST: Oh, I am not saying the onus is on 4 the public. I agree with you. What I am saying is we 5 have looked for such reports and we have not fcund any.
6 We have invited these individuals that tell us t. hat this 7 situation exists to give us some information to ga on. We 8 have conducted inspections at these vendor facilities that 9 you have named looking for these test reports.
10 MR. MARSH: Looking for that 1 out of 100.
11 MR. WEST: And we have reviewed a large number 12 of tests. I don't know what the situation is with the 13 FOIA. I don't recall not -- I don't think NRR has test 14 reports that we are withholding. Typically, we don't have 15 the test reports.
16 MR. GUNTER: We can provide the index.
17 MR WEST: Normally we review test reports on 18 site. That is not something that is submitted and 19 docketed and reviewed. We accept the commitment that they 20 will have the Co's and then the detailed review and 21 inspection is done on site. So we don't have a huge 22 library of test reports. I know the business is very 23 competitive and the vendars are very cautious about giving 24 out propriett.ry information. 3ut if you want to give us 25 more information on that, we will look at what test -- you NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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91 1 know, who hoo tha toot reporto end wh t th y cro.
2 MR. LOCHBAUM: The last slide, slide 26, is 3 that fire penetration sesl problems have been around for a 4 decade and they are still on the table today. I guess we 5 teel they should be -- the pace at which these things are 6 resolved should be picked up. If the NRC was in a rule 7 making phase to remove the noncombustibility things and 8 some of these things, we would have a form to formally 9 register any concerns or problems we had.
10 MR. MARSH: You'31 have that opportunity like 11 everybody else.
12 MR. LOCHBAUM: Sometime next year.
13 MR. MARSH: Whenever it goes out for public 14 comment is when you will have the opportunity to do that.
15 MR. LOCHBAUM: I just -- they have been around 16 for a long time. A year from now or sometime is still a 17 long timra.
ld MR. MARSH: '4our thesis is that there is a 19 safety problem out there? Your thesis is they don't '
20 balance? There are issue <. that warrant more significant 21 action?
22 MR. LOCHBAUM: Yes.
23 MR. MARSH: What would you propose?
24 MR. LOCHBAUM: First of all, I think the 25 plants that are not in compliance with their licensing NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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92 1 b2cio nord to go through cn cxcmption er whatovcr it tckto 2 to fix that.
3 MR. MARSH: I agree.
4 MR. LOCHBAUM: Second, the rick analysis that 5 these plants are submitting that shows what the risk of 6 fire is needs to accurately reflect reality and not be 7 conservative. So that needs to be fixed. I also would 8 suggest that the information from the information notices 9 go out on an information only basis. No requirement for 10 response.
11 MR. MARSH: What do you mean? I am not sure I 12 understand what you mean.
13 MR. LOCHBAUM: 88.04 went out to lots of 14 people and said there is a problem that we are informing 15 you about, but you are not required to take any action.
16 MR. MARSH: You would propose them to take 17 action?
18 MR. LOCHBAUM: I think that the evidence from 19 all these other plants shows that there may be problems 20 and it would be worthwhile having every licensee come back 21 and say we are okay. Unless you roll that in as part of 22 the 50.54 responses that recently came in on the time 23 basis.
24 MR. MARSH: I think what you are saying is you 25 propose another generic letter of some sort which requires NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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93 1 licOncoac to coma bock to uo.
2 MR. LOCHBAUM: Unless the staff is considering 3 that th1 responses to the 50.54 on design basis means that 4 everybody is in full compliance and any further problems 5 will be looked at fairly harshly by the staff. Because we 6 have now said everything is okay.
! MR. MARSH: Would you be swayed if we told you 8 that we have gone through all the LERs from licensees 9 since 1988 and what they reported to us and we have gone 10 through the inspection reports to see what people have 11 done?
12 MR. LOCHBAUM: We kind of addressed that in 13 our critique of the SECY paper.
14 MR. MARSH: Well, it is since then. I mean we 15 are saying since that time we have gone beyond that.
16 MR. LOCHBAUM: No. I mean the critique of the 17 SECY paper pointed out that most licensees -- many 18 licensees, I don't know about most -- have removed fire 19 protection requirements from the tech specs, so they are 20 no longer required to submit LERs.
21 MR. MARSH: Some have. Many have removed 22 them. Some will report anyway. It is a mixed bag. That 23 is why you have to look at the inspection reports as well
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94 1 reporto, i i !
2 MR. LOCHBAUM: Well, we kind of looked at --
j 3 we aoked at the Region 2 information from 1994 and 46 j 4 percent of the plants that we looked at were shown to be 5 unsatisfactory. That is a summary of the inspection t
j 6 reports and the summary showed 46 percent to be l 7 unsatisfactory. So I would conclude that tnere seems_to i 1
, 8 be a problem. '
i l- 9 MR. GUNTER: Just a closing note though.
- - 10 Again, to just revisit this whole issue of the 11 combustibility of these seals. The evidence in the j 12 guidance and regulations of NRC clearly have this -
l ,
13 noncombustibility requirement in there. I understand that
- 14 the NRC,'in their. review of the evolution of the 15 noncombustibility requirement basically can't find the ,
j 16 analysis that derived this requirement to be injected into 17 Appendix R and elsewhere. But I submit that that analysis i
18 has-to be there somewhere.
l 19 MR.-WEST: Have you looked for it?
J l - 20 MR. GUNTER: Well, you know, certainly we has.
21 tried to determine how the noncombustibility requirement g _ 22 was. promulgated. - But we certainly-don't believe that.it i 23 was entered in as a typo. It was there as a result of.
- 24 somebody's analysis or some group's doing the analysis, j 25 and'was injected there deliberately. And if that is the NEAL R. GROSS i-COURT REPORTERS AND TRANSCRIBERS
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- - , , - , , , , .,-,y,.- , .fe ry'r,w,,,, ,py.,.y,,, .- ,,em ,..,,,,,--y 9.,p-., .v, ,,m,y,._,,,,__,--,.,-v%-, -
. - - , , , y , .,,yy,,-%,,,w.,,
95 1 coco, th n thoro cro ASTME 136 tecto thnt chould ba 2 required of fire barrier material to determine whether or 3 not they are a combustible or a noncombustible.
4 MR. WEST: Paul, as we said in response to 5 your first question this morning, it was a deliberate and 6 conscious decision on the part of the staff to incorporate 7 the noncombustibility criteria in Appendix R. It was 8 intended, we believe based on interviews with the people 9 that did it, to preclude the instellst:on of materials 10 like those that caused or that attributed to the Browns 11 Ferry fire. We were told expressly that it was not 12 intended to preclude the use of silicon based materials.
13 In 1979 or .'.980 when they were doing this, they weren't 14 thinking of E-136.
15 MR. GUNTER: Was :he standard available to 16 staff at the time?
17 MR. MSST: I believe the standard was probably 18 available.
19 MR. GUNTER: Well, again, we are confused that 20 the standard was not then applied, particularly to a 21 material that has been so widely deployed.
22 MR. WEST: If you look at Appendix R and the
! 23 statement of considerations for the final rule, you will 24 find in there references to ASTM standards for specific 25 requirements in the rule -- like for -- I think ASTMF.'.19
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96 1 10 roforcnc;d. You don't find cny roforcnco for ;
2 combustibility. It was a qualitative -- from what we can .
3 tell, it was one of a qualitative kind of consideration.
4 MR. GUNTER: Then why wasn't fire resistant 5 material simply put into the regulation? Why was 6 noncombustible material defined for the regulation?
7 MR. WEST I don't think we can tell you 8 directly. I mean none of us were here then either. We 9 are trying to put the pieces of the puzzle together too.
10 I mean, we have not found a documented explanation.
11 Normally, you would expect any change that is made between 12 the proposed rule and the final rule, the basis for the 13 change to be documented in the statements of 14 consideration. If you look at that Section 3M of Appendix 15 R and the statements of considerations, you will see the 16 changes made, but there is not a satisfying explanation.
17 It is unfortunate. I agree with you. I would like to 18 know. Like I have said, I have talked to the guy that 19 wrote it and he told me why he did it and I believe him.
20 But it would be nice to have a piece of paper I could give 21 you and say, here Paul, this is the story.
22 MR. GUNTER: Well, the story is that common 23 sense dictates that --
24 MR. WEST: The story is engineering.
25 MR. GUNTER: Well, there may be some NEAL R. GROSS COURT REPORTERS AND TRAN"CRIBERS 1323 RHODE ISLAND AVE.. N.W.
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9'/
1 difforcncoo thoro th;n.
2 MR. WEST: A lot of times good engineering 3 doesn't necessarily make common sense. Look at the Metro 4 rails down Rockville Pike. The big steel things that are 5 on it are all rusted. You say, why are they letting that 6 rust? Well, it is sacrificial corrosion. It is designed 7 that way. That doesn't mean the thing is going to rust 8 and fall down.
9 MR. OLSHAN: Aren't these re-entry vehicles 10 with a --
11 MR. WEST: Blade materials, yes.
12 MR. OLSHAN: I mean you see those things 13 reenter and they are going up --
14 MR. WEST: I think that makes sense. You 15 sacrifice something to save something else.
16 MR. OLSHAN: I was going to say, you wouldn't 17 thought of that from common sense. Engineering judgment, 18 but not common sense. And this 10 the same type of thing, 19 isn't it? It is sort of a sacrificial material.
20 MR. GUNTER: Well in that, though, we have 21 ceen significant evidence to believe that it is more than 22 sacrificed. But that there are hazards associated with 23 this material that we don't believe have been reviewed.
24 MR. LOCHBAUM: I guess my comment is I don't 25 care if they use kerosene in the fire barriers. If they NEAL R. GROSS COURT REPORTERS AND TRANSCRIDERS 1323 RHODE ISLAND AVE., N.W.
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98 1 con bnck it up with c 1 or 3R firo rating tact end it ic
) properly designed and installed, use kerosene. I don't 3 care. But my concern is that we don't he.ve the proper 4 assurance that it is designed, installed, and tested 5 proporly. I think the data shows that.
6 MR. WEST: What data? You haven't given us 7 any data. What data?
8 MR. LOCHBAUM: I think all the information 9 with licensees reporting all these problems. That is 10 prima facie evidence that there is a problem with fire 11 penetration ceals.
12 MR. MARSH: Could that not be that they found 13 problems and fixed them?
14 MR. LOCHBAUM: Sure. For those licensees, 15 that is definitely --
16 MR. MARSH: So why do you conclude that the 17 problems still exist?
.: 3 MR. GUNTER: Because they are using the same 19 material to fix them.
20 MR. MARSH: There may be some problems that 21 are still out there. We are not saying that it is a 100 22 percent clean environment. Just like in LERs for safety 23 related equipment --
for a pump that is degraded or a pump 24 that has blown up. You don't conclude that there is a 25 generic problem with the pump and you have to replace all NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE.. N.W. 1 (202) 234-4433 WASHINGTON, D.C. 20005 3701 (202) 234-4433
99 1 thoso pumps.--
2 MR. LOCHBAUM: But-when you receive this many 3 problems,-- you don' t conclude that everythirt sise is - okay -
'4 necessarily. That seems to be a stretch also.
2 l1 5 MR. MARSH: The trend in LERa is significantly
[ 6 down.
i' i- 7 MR. LOCHBAUM: That goes back to -- they-took i
8 them out of tech specs.
9- MR. MARSH: And inspections.
! 10 MR. LOCHBAUM: They pulled them out of tech 1-j 11 specs.
} 12 MR. MARSH: And inspections. We have been .
j- '
- _ 13 doing inspections.
14 14R. GUNTER: Can I just -- in closing, can we 1
4 15 ge some sense of what kind of exchange we are going to j 16 have hcu? What is to be reviewed? Where'do we go-ifrom 4-3;.l 17- here?
T_
18 MR. ZWOLINSKY: Dave,-did'you have any h _19 additional: concluding remarks-before I wrap up?
i j 20 MR. LOCHBAUM: No. .That pretty much wraps it
- 21- up=for-me.
i~
[ .22 MR. ZWOLINSKY: Okay. Well, obviously-I think l J
E 23 it-has been very beneficial.for-you to come in and chat 24_ with us face to. face. - I think your suggestion in the J 25 August 5 le'tter has borne fruit. We may not totally-agree NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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100 1 or mnyba wa agroo to dicagroo period on certain incuos.
2 But fundamentally, I do believe that the issue 3 sufficiently complicated historically speaking that it 4 warrants -- it certainly warranted h'.ving an opportunity 5 to meet face to face.
6 It would be our intent to take the 7 transcription and review it. Wanting to assure that we 8 have done a number of things. In particular, did we 9 answer your questions and concerns in as complete a manner 10 as we possibly could at the current time, noting that we 11 feel we owe some answers to questions that you've raised 12 that will best be answered in the response to Congressman 13 Markie. We will certainly commit to provide certain 14 documents to you such as that.
15 We also will seek to identify any possible or 16 potential allegations that have either new or different --
17 to what the staff has been aware of.
18 MR. LOCHBAUM: I wouldn't spend a lot of time 19 on that if I were you. My experience with the allegation 20 process since I have joined ECS has been it doesn't seem 21 to be worth anybody's time. So I wouldn't spend a lot of 22 time working on that.
23 MR. ZWOLINSKY: It is part of our internal 24 process and we will go through it.
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101 1 though.
2 KR. ZWOLINSKY: Okay. We will also seek to 3 identify commitments that we have made during the meeting.
4 In some cases, information was not readily available that
- 5 through a little research or whatever we can probably
.1
- 6 generate certain documents or pull those from the files.
) 7 Ildo believe that there are certain answers that you
! 8 should get from us that go beyond the scope of what we 9 were able to provide at the meeting, and I would think the 10 majority of those would be found in the response to 11 Congressman Markie. So we are relying on that somewhat to 12 be reaponsive in part to your August 5 letter and-to 13 issues that came up today that we were perhaps not'100 14 percent complete on.
15 I think once we have that laid out, we would 16 have to ask ourselves have we covered all the bases, and 17 you might want to ask us that question also. I know you 18 want to undertake search within the public document room 19- looking for certain information and what have you. There 20 are certain documents that are at our ready that we can 21 appe:td to the transcription just for general information
~
22 to the-public beyond yourself, which I think might be 23 helpful. And Paul, I am thinking in particular of this 24 one safety evaluation that has been written for both units 25 but yet-it is on the Unit 1-docket, for example, and we NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE.. N.W.
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102 1 will cppand a couple of those.
2 I note in your -- we will also append your 3 slides as part of the summary. I note in the back you 4 have a three or four page discussion. I didn't have a 5 chance or opportunity to read that.
6 MR. LOCHBAUM: Was that the letter?
7 MR. ZWOLINSKY: Yes.
8 MR. LOCHBAUM: Oh, that was a letter we 9 submitted to Mr. Miller in Region 1 at Salem. That was 10 just a --
11 MR. ZWOLINSKY: Okay. I didn't focus on it.
12 MR. LOCHBAUM: That was the critique of the 13 SECY paper that we did. That has been around the room 14 before.
15 MR. ZWOLINSKY: So that has been accommodated 16 within a past discussion. Does that generally comport i
17 with your expectations?
18 MR. LOCHBAUM: I think so. We came into this 19 meeting realizing that not all of the questions would be 20 answered today. We realized that there were ongoing staff 21 activities related to the response to Representative 22 Markie that would clearly answer some of the questions we 23 raised. We didn't mean to preempt that or we don't 24 anticipate -- we fully recognize the reason for the 25 response coming at that time.
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103 1 Ao fcr oc the meeting itoolf, I think we era 2 satisfied with the information we provided. I think you 3 have an understanding of what our concerns are. We have a 4 better understanding of the staff's direction and 5 problems. Some of the scheduling for next year. I had no 6 idea. I wasn't aware of that at all. And also the 7 inspection guidelines. I had looked for that and missed 8 it. So I am glad to have that information and I will take 9 a look at it.
10 MR. ZWOLINSKY: Okay.
11 MR. LOCHBAUM: So I think the meeting met our 12 objectives of what we wanted to do with this meeting.
13 MR. ZWOLINSKY: Okay.
1* MR. GUNTER: There are two specific requests, 15 though, that I would just like to enter. With regard to 16 the Perry event, we believe that that does warrant, with 17 regard to the hydrogen gas accumulation that was noted 18 there in the transcript of the investigative interview 19 with OI. We believe that that warrants NRC attention.
20 That is beyond the scope of the public document room.
21 MR. ZWOLINSKY: We committed that we would 22 look into that event.
23 MR. GUFTER: Yes. I would hope so. And again 24 as a results of the OI investigative interview with Mr.
25 Takahashi, there is this, we believe, very significant NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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104
_1 iceue whoro 100 tests, yot got one test to pass and that
-2 qualifies _the configuration. Again,-that is beyond the 3 scope of the public documrant room at this point and was 4 part of the OI's formal report to NRR. We believe that 5 that would warrant further at. ention.
- 6. MR. MARSH: And as Steve said, Paul, we did 7 look. We will look.at the-transcript again. We did look, 8- We did inspect those facilities and we didn't find any-9' evidence of that statement being true.- _We will look again 10 at the transcript. ,
11 MR. ZWOLINSKY: And we will' document that 12_ appropriately.
13 MR. GUNTER: Thank you.
114 MR. .ZWOLINSKY: Anything else?
-15 MR. LOCHBAUM: I appreciate the opportunity to 16 come here and talk with you.
- 17 MR. ZWOLINSKY: Okay. Thank you very-much for-
,18 your time. I think we will go_ ahead-and bring this 19 meeting to a close. A few of us can stay by if anyone 20 else has questions of_the staff.
- 21 (Whereupon, at;12
- 35.p.m.=, t're meeting was-22- concluded.-)
I 23 4
24 i:
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i ERRATA SHEET FOR TRANSCRIPT OF SEPTEMBER 10, 1997, MEETING BETWEEN THE NRC AND PAUL GUNTER AND DAVID LOCHBAUM PAGE LINE CHANGE 4 13 " COURT REPORTER" should be "MR. MARSH" 7 11 Delete "and" between " reactor systems" and " engineers" 7 18 "1" should be "I" 8 2 "ASARS" should be "ACRS" 8 9 " fire boundaries" should be " fire area boundaries"
, 9 5,6,8 " tray" should be " train"
! 10 6 " silicon" should be " silicone" (applies throughout transcript)
- 10 18 " carbon" should be " ceramic" i
10 23 "K-wool" should be "kaowool" 12 12 "Markie" should be "Markey" (applies throughout) 14 5 "NURS" should be "NIRS" 19 21 " reactant" should be " reactor"
, 19 22 " cooling" should be " coolant" 22 22 "ASME" should be " ASTM"
. 23 1 "E" should be " ASTM" J 23 5 "951" should be "9.5-1" 23 20 " division, ABC SPI 5.1" shculd be " position, APCSB 9.5-1" 24 8,9,21 " performance based risk informed" should be " performance-based, risk-informed" 24 11 Add a comma after " regulation"
- 26 11 " thin" should be "think" l 27 17 " Annex" should be " Appendix" 27 21 "CMED" should be "CMEB" 29 25 Before "Yes" should be "MR. WEST
- "
< 33 1 " fields" should be " seals" 33 24 "are" should be "our" 34 8 " penetration" should be " penetrations" 36 18 "86.10" should be "86-10" 36 18 "B8.12" should be "88-12" 37 12 After " incorporated" add "is" 38 16 "86.10" should be "86-10" and "88.12" should be "88-12" 39 2 " thin" should be "think" 41 4 "MR. MARSH" should be "MR. WEST" 44 15 " load" should be " mode"
- 52 5,16 "88.04" should be "88-04" j 53 7,20 " Sequoia" should be "Sequoyah" (applies throughout)
< 54 21 " breakdown. That.." should be " breakdown, that.."
55 1 " treaded" should be " trended" 56 21 " Lucy" should be "Lucie" 59 12 "hence" should be " truth" 4
59 13 "models" should be " manual" 4 60 23 " light" should be "like" 62 7 " Production" should be " Fire protection" I Enclosure 3 l
2
64 14,15 " risk in forming" should be " risk-informed" 64 16 " risk in form" should be " risk-informed" 64 21 "15.52" should be "1552" (applies throughout) 67 20 "found report" should be "found and reported" 73 11 "and" should be "in" 75 10 Add comma after "small" 77 22 "MR. MARSH" should be "MR. WEST" 78 6 "MR MARSH" should be "MR. WEST" 78 10 "have to review" should be " haven't reviewed" 80 16 "APSCB" should be "APCSB" 83 2 " plan" should be " plant" 83 23 "Biser's" should be "Biden's" 84 6 " conferences" should be references" 85 12 " instruction" should be " inspection" 86 25 "in" should be "a" 88 6 " health" should be HELB" 89 16 "MR. WEST" should be "MR. GUNTER" 90 20 "CO's" should be " seals" 92 22 -" time" should be " design" 95 1 "ASTME 136" should be " ASTM E-136" 95 10 " attributed" should be " contributed" 95 25 "ASTME 119" should be " ASTM E119" 96 14 "3M" should be "III.M" 97 11 " Blade" should be " ablative" 98 1 "3R" should be "3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />" 100 20 "ECS" should be "UCS"
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Enclosure 4
UNION OF I
,, #V
! CONCERNED C SCIENTISTS ~M- -
i EMII
~ '
i i
. Fire Barrier Penetration Seals I
i The Union of Concerned Scientists -
~
The Nuclear Information &-Resource Service !
I
~
~
)
. September 10,~1997- -
j j
l ~
e
' ~
Enclosure S l
UNION OF CONCERNED Sa"""5"
~
Goals
~
E H HI B " Properly designed and installed silicone foam penetration seals will provide an adequate level of fire resistance arid will perform their intended fire protection function by confining a fire t.o the area of.
origin." (Chairman Jackson to Sen. Biden,07/29/97) ;
i' E "The goal is to provide a fire barrier penetration seal that will remain in place and retain its integrity when i
subjected to an exposure fire, and subsequently, a fire suppressing agent. This will provide reasonable assurance-that the effects of a fire are limited to discrete fire areas and that one division of safe-shutdown-related systems will remain free of fire damage." (IN 88-04,02/05/88)
Slide 1
. ]
I
. UNION OF -
a:
CONCERNED Sa"" "
- Required Attributes M EMBEIBl EProperly designed
- when coriforming with licensing bases
- when bounded by qualification tests . .
Prop.erly installed .
- when conforming with design requirements
- when maintained within design requiremerits -
O e b t
4 Slide 2 a .
l t
1 f
. UNION OF -
CONCERNED !'
Sc'5""S"
. " Properly Designed" Concerns
~
E55551 ,
What is the historical evolution of regulations and requirements for non-combustible materials used in fire barrier penetration seals?
j
- Browns Ferry fire in March 1975 was initiated by a candle igniting combustible material used in a penetration. ~
"The staffis concerned that where combustible materials are used in penetration seals, such materials may be ignited and transmit a fire from 'one fire area to another." (NRC safety evaluation,11/14/86)
- Can combustible materials be used in fire barrier penetrations seals inside containment? ,
Slide 3
- . 1
' UNION OF CONCERNED
" Properly Designed" Concerns (continued)
EElli
~
E Silicone-based penetration seals are ' combustible' when tested,in accordance with ASTM E-136,
~
" Behavior (if Materials in a Vertical Tube Furnace."
(SECY-96-146,07/01/96)' .
E " Penetration seal designs shall utilize only noncombustible materials." (10 CFR 50, App. R SubpartIII.M)
E " Structural fire barriers (e.g. walls, floors, ceilings), -
including penetration designs, should utilize only 'l noncombustible materials."-(draft BTP SPLB 9.5-1, <
04/96)
B t
Slide 4
UNION OF-CONCERNED
" Properly Designed" Concerns '
Sa'""S" (continued)
E What is the status of the staff's oft-stated intention to remove the.noncombustibility requirements?
E What is the. legal status of those plants which are licensed to App. R HI.M and the "non-combustible" versions of BTP 9.5-1?
E Since these plants do not comply with their licensing bases, have their owners sought deviations?
EIf not, is the NRC granting." implicit enforcement discretion" in apparent conflict with the Chairman's stated position on the subject?
~
l .
Slide 5
UNION OF CONCERNED ssProperly Designed" Concerns Sa"" = $
(continued) i .
EEll l E Does NRC staff have readily accessible listing of the I
applicable fire barrier penetration seal regulations for
- each plant (i.e., listing like that in SECY-97-156 for reactor vessel ASME code cases)?
~
EIf not, how can NRC staff effectively:
- conduct onsite inspections of penetration seals
~
- verify compliance with licensing bases
- comply with the backfit requirements'ofl0 CFR 50.109
- review and accept IPE risk assessments related to postulated fires g *
,4
. i
~
.}
sm 6 )
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l
UNION OF-CONCERNED " Properly Designed" Concerns Sa""S" !
(continued)
M .
H HI E Fire barrier. penetratic., seals have a simple function --
- preventing. fires from propagating. Rather than a l complex array of regulations, it seems that a "one hazard, one rule" approach would be best.
~
~
t E Fire codes ~for non-nuclear buildings (hospitals, schools, '
apartments, etc.) are governed by "living" regulations such that changes to the fire code are retroactively applicable. Why not equivalent fire protection for nuclear power stations?
e e t
Slide 7 m - - - - - - . - -
UNION OF CONCERNED " Properly Designed" Concerns- H scisunsa (Continued) l um ammassi E 10 CFR 50.71(e)' (effective.05/80) requires licensees to update their FSARs to include the effects of"all analyses of new safety issues performed by or on behalf i
of the licensee at Commission request." j E The safe shutdown / fire hazards / combustible loading analyses were required by the NRC after 05/80.
E Have the results from these analyses been incorporated into FSARs as required by 10 CFR 50.71(e)?
EIf not, does the NRC intend to take any measures to enforce 10 CFR 50.71(e)? .
~
Fide 8
- r
UNION OF CONCERNED " Properly Designed" Concerns ~
Sc'"""=
(continued) 3 2
~
EEUll E "The staff has not found instances of penetration seal
. assemblies that passed fire endurance tests while exact duplicates failed such tests." @edyard Marsh letter to Gerald Brown,08/20/97)
~
E " Literally you can run 100 tests for the same design. If one passes you can qualify that design." ('Hitoshi Takahasi, Dow Corning, NRC OI Official Transcript, 08/24/94) !
mis the NRC NRR staff aware of this NRC OI investigation report?
- % 9
i UNION OF CONCERNED " Properly Designed" Concerns (continued)
Elli E Mr. Takahasi also reported that hydrogen gas seeping from a sili. cone foam barrier at thc Perry plant l .
" exploded" sometime during 1984 to 1987.
EIs the NRC staff aware of this Perry event, or any other~ event in which silicone foam fire barriers provided the fuel for a fire or explosion?
E The instructions on the cans used to mix silicone foam contain explicit cautions about providing ventilation during installation because of the hydrogen gas 4
released. R sude 10 1 .
UNION OF CONCERNED -
" Properly Designed" Concerns Sa"""
~
(continued) 4
- M E HIl E "The staff has not found instances of penetration seal assemblies that passed fire endurance tests while exact i duplicates failed such tests." (Ledyard Marsh letter to Gerald Brown,08/20/97)
E 15 of 34 fire tests resulted in failures. (Gerald Brown i
letter on Brand Industrial Services Company's Bisco i j Fire TestingIndex,05/14/97) -
EIs the NRC NRR staff aware of the Bisco fire test
' data?
\' . .
1 i
Slide II
I
' UNION OF CONCERNED " Properly Designed" Concerns 1 Sa"""S" l
(continued)
E HII
~
E "The staff has not found instances of penetration seal assemblies that passed fire endurance. tests while exact duplicates: failed such tests." (Ledyard Marsh letter '
to Gerald Brown,08/20/97) -
E NRC recently refused to release fire endurance test reports conducted between 02/78 and 03/82 because they contain " business confidential (proprietary) '
information" (NIRS FOIA request,08/97)
- How can 15-20 year old reports of testing used to qualify fire barrier penetration seals for nuclear power plants contain proprietary information?
- Given indications (including the Thermo-Lag events) that -
qualification testing may be suspect, " sanitized" versions of l qualification tests must be made publicly available immediately.
l
' Slide 12
.c ..
l
UNION OF CONCERNED " Properly Designed" Concerns- -
Sa"" = S i
(continued)
M EMERI .
l E Damming boards are frequently, but not always,
! installed ori both sides of a penetration sealed with l silicone foam. -
E How is the installation adequacy verified when a
-damming board is permanently placed before the silicone foam is applied?
E Are penetrations with one or both damming boards missing supported by fire endurance tests of "unp.rotected" silicone foam?- ~
S O
- e f
e
- UNION OF CONCERNED " Properly Designed" Concerns Sa"""$" ' ~
(continued) l a uni E "The NRC review also has identified a current practice that can affect the qualification status of installed seals. Plant modifications are being made that require running new cable and c.onduits through existing penetration seals. These modifications are '
generally being made without an associated technical '
review to ensure that the resulting penetration seal design configuration or design parameters are consistent with those validated by initial qualification tests." @ 88-04, 02/05/88) t E What assurance does NRC have that m~odified fire i penetration seals remain bound by qualification tests?
i Slide 14
- j. ~
UNION OF CONCERNED
- ="=*
" Properly Installed" Concerns .
33lll EReports ofinstallation problems:
- repairs to 35% of more than 1700 penetration seals inspected at Wolf Creek in 1987 (SECY-%-146, 07/01/96 & IN 88-56, 08/04/88)
- 3900 of 5200 (75%) fire barrier' penetration seals "did not meet acceptance criteria" at Pilgrim (NRC letter,10/13/88)
- repairs / upgrades to 85% of1400 penetration seals inspected at Vermont Yankee in 1993 (SECY-96-146,07/01/96) t
- $50,000 civil penalty imposed upon Sequoyah licer see for
" inadequate design control of fire barrier penetration seals. (NRC -
letter,11/16/96)
- replacements / repairs to 90% of penetration seals at Maine Yankee i 1
in 1997 (LER 50-309/96-017, 07/29/96) .
E This " Decade of Deficiencies" clearly reflects installation problems.
' Slide 15
. r
UNION OF CONCERNED " Properly Installed" Concerns
- '"""*" ~
~
(continued)
~
E HIl E 26% of the fire barrier penetration seal problems reported b.etween 1989 and 1993 involved seals that '
were not installed or missing. (SECY-96-146, 07/01/96)~
~
E "...some instaIIed fire barrier penetration seal desigiis may not be adequately qualified for the design rating of the penetrated fire barriers." GNRC IN 88-04,02/05/88)
E A fire barrier penetration seal that is "not instaIIed"
. or " missing" cannot be considered " properly 1
' installed" by anyone's definition.
~
Slid: 16
i UNION OF CONCERNED
" Properly Installed" Concerns !
- '"""" ~
(continu.ed)
~
MBHil E Region H evaluation of fire barrier penetrations seal programs at 13 of18 sites (72%) reported
~ .
unsatisfactdry results at 6 sites (46% of those inspected). (Ref: NRC Ietter dated 11/17/94)
~
- Hatch: " Lack ofX-ref between seal and test data - no followup was
. conducted" ,
- Oconee: " Test documents were inadeg / repairs needed - no followup done
- Robinson: Satisfactory inspection but " Final repairs were not inspected."
- St Lucie: " Tested config of pene were not reviewed."
E 46% passing score is NOT even minim ~ ally acceptable.
Slide 17 -
U N I'O N O F CONCERNED aProperly Installed 3, Concerns Sa"""S"
~
(continued)
~
Ell 1 1
E "The [NRC] staff concluded that the penetration seal programs in industry remain satisfactory. The staff t
found neither plant-specific problems or generic problems of safety significance." (SECY-96-146, l
07/01/96)
! E Satisfactory programs? By what measure? Does the NRC staff mean initially or after all of the repairs ~?
E No safety significance? Why impose civil penalties such
- as at Sequoyah? If missing and non-installed fire barrier penetration seals have no safety significance, then why make heensees mstall them?
1
union or CONCERNED
" Properly Installed" Concerns -
Saa"'=
(continued)
BIEEHIII l E NRC's " inspection procedures do not.give specific guidance.for inspecting fire barrier penetration j seals." (SECY-96-146,07/01/96)
E Considering that many licensees develop their. .
j internalinspection programs based on NRC's i Inspection Manual, the NRC's lack of specific j
guidance probably means that licensees' inspection i .
procedures also lack specific guidance.
e
--*se --- --
, -# , __,, - _.__m
j .- .
UNION OF CONCERNED i, Sc"==S j
~
" Combustibility" Concerns .
~
EHil E Fire endurance test'(10/96) of RTV silicone foam showed heavy smoke from burning RTV foam.
~
'E >> test video segment <<
E Chemical content suggests that the b' u rning RTV silicone foam generates hydrochloric gas.
E Combustible fire barrier material may p~ose unreviewed safety question - can safety related
~
equipment on unaffected side of fire barrier be impaired by smoke and residue?
E Combustible fire barrier material poses chaIIenge to
- . fire barrier rating via deep-seated fire potential.
E >> test video segment << -
^
sm j , .
UNION OF CONCERNED Sa"""5" Salem-Specific Concerns M EMIll E NRC recently indicated that Salem Unit 2 is licensed to fire penetration seal requirements specified in APSCB 9.5.1 Rev. O dated 11/24/75 as revised 05/01/76, '08/23/76, 02/24/77 and 03/78.
E Copy of BTP APSCB 9.5.1 obtained in 08/97 from NRC PDR is liberally stamped " Superseded."
E" Supersede: to cause to be set aside; to force out of use as inferior; to take the place, room or position of; to displace in favor of another" .
E What is the legal standing of a " superseded" ~
document?
~
EIs a " superseded" document readily available for NRC inspectors and-lice'nsees? .
~
~
Slide 21
i,
~
union og CONCERNED Salem-Specific Concerns Sc'-
~
(continued)
H HI
~
I E NRC Project Manager for Salem informed NIRS that i
BTP APSCB 9.5.1 was invoked or applied to Salem i
Unit 2 via the license amendment transmitted to ~
l PSE&G by NRC letter dated 11/20/79. ~
- Document is Amendment No. 21 to the Salem Unit 1 operating j license.
l - Salem Unit 2 received its operating license on 05/20/81.
4 E How many man-hours did the NRC staff take to
! answer Senator Biden's questions dated 07/11/97? .
1 - If fire protection licensing bases information is so difficult (i.e., time-l consuming) to review, is it reasonable to believe that such effort is l made for all appropriate design and licensing reviews?
~
l .
~
l s a 22 .
y ---.- --. - -w *,- - _ - _ _ _ _ _ _
U Ni~O N O F j CONCERNED -
So'""'5" Conclusions E
- IIII l; l -
8
- E Licensing requirements for fire barrier penetration seals are extremely complicated, making both
! compliance and enforcement very difficult.
- If NRC pursues rulemaking, a unified rule applicable to ALL l operating plants (one hazard - one rule) should be adopted.
MIndustry experience demonstrates pattern of fire
' barrier penetration seal problems over the last -
decade, yet NRC had no applicable inspection ,
l guidance. ~
a Slide 23 n - - - - - - - - - -
UNION OF CONCERNED ~
$ '"""5" Conclusions (continued)
H HI EPostulated fires cannot be assumed to be limited to one fire a.rea unless 100% of the fire barrier .
penetration seals are properly ~ designed and properly -
instaIIed.
E Given the longstanding and widespread design and installation problems, the probability that a postulated fire will propagate across a fire barrier is .
greater than 0.
~
E Since the probability of fire propagating across fire barriers is not zero, IPEs are non-conservative if they
~
assume'100% fire barrier integrity.
1
- ~
UNION OF _ j i CONCERNED ~
- *'"mS" Conclusions (continued) l' M E E H HI l
! E Use of combustible rather than non-combustible fire barrier material in penetration seals may constitute
, unreviewed safety question unless potential adverse
. consequences from products of combustion have been evaluated and deemed not to challenge operation of equipment in unaffected fire areas.
- HCL gas and other smoke-carried debris could cause equip:acnt failures on the~ " unaffected" side ofs fire barrier.
- Deep-seated silicone foam fires can challenge rating of fire barriers -
(I.e., smoldering silicone foam could flare up long after the one or three hour rating period). - -
i l '
l T' .
sue 25
\
l .
i
. ~
i UNION OF CONCERNED Sc'""=
Conclusions (continued) s E55511 "
E NRC.has tolerated fire barrier penetration seal problems for over a decade: .
E Fire barrier penetration seal problems should be championed to a swift resolution rather than being allowed to remain undetected and uncorrected.
t j
e 4
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- a. 26
-_ m --------_---------__M -
0 NUCLEAR INFORMATION AND RESOURCE SERVICE 142416th Street Suite 404, Washington, DC 20036 Tell202 328-0002 Fax /202-462-2183 email: nirsnet@isc.apc.org
' NUCLEAR POWER RELIANCE ON COMBUSTIBLE FIRE BARRIERS:
DOW CORNING RTY SILICONE FOAM PENETRATI,0N SEAL 5
.' July 1997 The Risks And Consequences From Fire At A Nuclear Power Station Art High According to Nuclear Regulatory Commission (NRC) study NUREG-1150, based on 20 years of experience, over the course of a typical nuclear power station's operation there will be 3 to 4 signi8 cant Gros. This same study points out that Are can constitute as much as 50% of the overall risk of an accident that leads to the reactor's highly radioactive Sael core being damaged.
~ As a result of a near catastrophic Gro on March 22,1975 at Tennessee Valley Authority's Browns Ferry nuclear power station in Alabama, NRC reviewed its Are protection code and the vulnerabilities of reactor safety systems to Sre with particular attention to safe shutdown capability. The cause of the Are was the ignition of a cable penetration sealing materikt by an electrical worker using a candle to check for air leaks. The penetration seal material, polyurethane foam, was a Sammable material. It caught Sre and burned out of control for seven hours .
destroying 1,600 power, control and instrumentation cables to numerous reactor safety systems,.
including the reactor's emergency core cooling system (ECCS). The current Sre protection code made law as a result of the Brown's Ferry Sre requires Penetration seal designs shall utilize only non-combustible material and shall be quali8ed by tests comparable to tests used to rate Sre barriers." [10 CFR $0 Appendix R Section III subpart M.) '
A teak accident occurred on March 7,1997, at Boston Edison's Pilgrim nuclear power station which led to a spill of 4300 gallons of combustible insulating oil over a 7000 square feet inside the station's turbine building. Fortunately, the oil did not ignite. The Pilgrim nuclear power station relies on thousands of controversial Are barrier penetration seals to divide Are zones within .
the reactor. Because of the large area of the oil spill, NRC determined that a Bre could have disabled both the normal and emergency systems used to cool the reactor Aiel.' A Gre could have spread throughout the plant because of faulty 6re barriers, potentially leading to the release of radioactivity into the environment at great risk to public health and safety. Pilgrim's Are hazards analysis did not foresee an oil spill occuning in this manner or in this area of the station. '
U.S. Reactors Are Out-Of-Complia ce With Current Federal Fire Protection Code' ' '
Like the Pilgrim station oil spill, an accident on this order or greater could occur today ,
potentially involving a Sre at any of the 106 U.S. nuclear power stations which rely on a combustible material installed as 6re barrier penetration seals in the thousands of holes where electrical cables pass through walls, ceilings and floors. The seals are required to prevent to passage of 5re, smoke, and hot gas from one Are zone in the power station to another Bre zone -
for example from the cable spreading room to the reactor's control room. Yet, a Dow Corning product, RTV silicone foam, has been acknowledged by the NRC to be combustible. Numerous fire tests by commercial Are protection vendors and installers in the United States, Canada, and overseas have resulted in " flame-thru" of the RTV penetration seals under standardized test conditions. However, not only is the material combustible which can allow fire to propagate 4
__m.ms.,, _w a . - , .,
Cddque of NRC's " Technical Assar~ ment of Fire BarderPoestadea
{ Seals la Nuclear Power Plants," SECY.96146, July 1,1996
\
Backsmund
. l
,In February 1997, UCS learned of a potential nuclear safety problem involving fire barrier penetration unis using silicone foam. Fire barriw penetration seals are utilized around piping, conduits, and cable !
trays that penetrate walls and floors to prevent a fire from propagating from one area to an adjoining area. Fedwat laws enacted following b Browns Fwry fin in 1975 require each nuclear power plant ;
to be capable of achieving and n'alataining a safe shut down condition even if all of the equipment la any single fire area is completely disabled. Fire protection designs at nuclear power plants rely on ;
confining the consequences of a fire to a single area. Confinement is essential, bwause the equipment -
, niied upon for safe shut down may be located in an area a$oining the one experiencing a fire.
The information providea to UCS fadicates that gilicone foam mansfactured by Dow Coralag (and -
marketed by 3M) and used in many anclearpower plants operadag la the United States is combastible .
and therefore la yletaties of the federal aguladen la 10 CPR Part 80, Appendia R. Subpart M.
UCS evaluated b information. The most recent NRC position on fire barrier penetration seals, including those using silicone foam, appears in memorandum titled " Technical Assessment of Fire Barrier Penetration Seals in Nuclear Poww Plants," numbwed SECY.96146, and dated July 1,1996, from Mr. James M. Taylor, then Executive Director for Operations, to the NRC Commissionws. UCS reviewed this SECY paper and its attached technical report with respect to the recent allegations ,
involving silicone foam penetration seals. UCS has the following comm,ents:
Ceausests ' '
~
i 1) In the last sentence in the first paragraph on page 3 of the SECY paper and in the abstract and .
l .
exwutive summary of b technical report attached to the SECY paper, the NRC staff states i
that it "found neithw plant specific problems nor generic problems of safety significanos." '
} Dese statements contradict esber lefonnation provided la the techalcal report.
4 i
Section 5.4, " Review of' Plant Specific Corrective Action Programs," of the technical report
! details the staffs review of fu epenetration seal programs at several licensus. Swtion 5.4.1 '
- l. reports that an inspution of more than 1700 silicone foam penetration seals at the Wolf Creek ,
Oonerating Station prompted rqairs to more than 600 of the seals (~35%)in 1987. Sectica .
' 5.4.3 reports that the Vermont Yenkee Nuclear Power Station licenses had to repair more tha j 900 and upgrade nearly 300 of the 1400 the barrier penetrations at the facility (-85%) in ISE Swtion 5.4.4 reports that the Diablo Canyon licenses detamined in 1994 that approximately '
l 100 penetrations with silicone foam fire barriw material had missing damming boards and tW; j the deficiencies were believed to have existed since construction (Unit 1 roosived its opacima L
license in 11/84 and Unit 2 roosived its opwating license in 08/85). In addition, Section 5.3,
! ' Review of Previous NRC Inspection Results," of the technical report states that the "NRC is -
[ currently tracking cornetive actions for penetratiore seal deficionoles at Diablo Canyon and j , IP3" [ Indian Point 3]. -
4 l' Section 5.8, " Combustibility of Silicone Based Seal Materials," of the technical report statu
- j that silicone based penetration seal materials are " classified as ' combustible' when tested ir.
- accordance with ASTM E 136, ' Behavior of Materials in a Vertical Tube Furnace at 7500l
{ . which is a combustibility test method accepted by the NRC." Table 1. " Representative i
Population of Seal Types," of b technical sport indicates that the typical plant (of 32 plauts
! February 27,1997 - Union of Concerned Scientists .
Page.1 L _ _ .__ _ . L . . _ ,_ _ .a m _____ . _ _ _ . _ _ _ _ . . _
7
.1 i
Cddque of NRC's " Technical Assessment of Pl e BanierPenetados 1 Seals la Nuclear Pewer Plants," SICY.96146, My 1,1996 l surveyed) had 1668 penetrations sealed by milicone foam.10 CFR Part 50, Appendix R Subpart M states that " Penetration seal designs shall utilla only noncombustible matwials.' l The NRC staff found both plant specific problems and at least one generic problem (i.e., .
l illegal use of combustible matwial) with silicone foam fin penetration seals. The staff must, thwefon, have determined that bse known problems have no safety significance. However, .
In Section C.12 of Appendix C to NUREO.11$0 Vol. 2, "Seywe Accident Risks: An '
Assessment for Five U.S. Nuclear Power Plants" December 1990), the NRC staff states that based "on plant experience over the last 20 yiars,(it has been observed power plants will have three to four significant f1ros over their operedng lifetime" and that .
.. fins contribute "7 to $0 percent" of the overall core damage iWquency. The Ensoutive Summary of the technical report attached,to the SECY paper states that " fire bhrriers offer -
masonable assurance that a fire will not spread 60m one plant area to another." no NUREG - -
1150 risk assessments assumed the fire penetration seats pwform their safety function of :
preventing a fire bom propagating to a$oining areas. Thus, if silloons foma fire penetration *
- seals fail, the risk may be significantly higher than the 7 to 50% core damage ihquency reported in NUREG 1150. Plast-specific problems or gesede problems with the poteadal to prevent er degrade the fire barder functies of silicone foam penetration seals must be considered safety sisalficant.
- 2) The fourth item in the third paragraph on page 3 of the SECY paper indicates that the staff intended to issa an Information Notice summarizing the SECY paper and stating that the * ' '
' twhnical report was available in the NRC's Public Document Room. A review ofInformation -
Notices issued by the NRC in 1996 and through February 14,1997, did not locate such an Information Notice. Per a telecon with Mr. Steve West of the NRC's Office of Nuclear
' Reactor Regulation on February 19,1997, the NRC did not issu this intended Information - '
Notice because it published the materp in NUREG 1552, " Firs Banier Penetration Seals in Nuclear Power Plants," dated July 31,1996. This document was verified to be readily - .
available through the Public Document Room.
- 3) N first full paragraph on page 2 of the Exwutive Summary of b twhnical report attached to the SECY paper states that fire banier penetration seals ars " universally accepted building . .
components." De report falls.to meados that combusdble silicone foam penetraties seals me-expressly forbidden la German $d Korean nuclearpowerplants forsafety seasons.
,4) The first full paragraph on page 3 of the Exwutive Summary of the technical report attached to the SECY paper states that " failure of a penetration seal is generally not as significant a fire
' threat as a failure of a structural fire banier" (i.e., wall or floor). The mport states that failure, ,
of a penetration seal would have minor safety significanoe if"that are no combustible materials in the agacent fire area in the vicinity of the failed seal." -
Nas are mi, leading statements that do not provide adequate justification for actual and potential silicone foam penetration seal failures. Thws is no evidence provided in the SECY paper and its attached technical report that suggests that there is r low probability of .
combustible mataints being in the adjacent area in the vicinity of a failed wa!. Assamlag that the probability is sufficleady low simply because it supports the desired conclusion is peer engineedag pracdce. .
February 27,1997 Union of Concuned Scientists Page 2
U Cddque of NRC4 "fochnical Assessment of Fire BarderPenetreden '
Seals in Noclear Pewer Plants," SECY 96146, July 1,1996 In addition, thm statements imply that the sole function of a fire barriu penetration seal is to prevent fire inom r:opagating into an adjoining fire area. Fire barrier penetration seals also function to minimin b passage of hot, combustible gases into adjoining areas. Since many
- of b airborne byproducts of a fire are toxic and othws are corrosive, their ready transport into a4 joining areas can be problematic. *
- 5) Thore is a significant discrepancy between the average number of penetration seals in nuclear plants as reported in Section 2.1, " Population and Types of Seals," and Table 1
- Representative Population of Seal Types." The text states that there are about 2000 l
, . penetration wals in an average plant, while the table reports that thwe are 3380 per plant.
This discre*pancy does not affect the concl,usions of this critique no matter which numbw is oorrect. Either valu reprwents a large anabar of penetration osals at nuclear power plots.
- 6) Section 4.4, " Inspection Procedures," of b technical report attached to b SECY paper states that the NRC's " ins'pection procedures do not give specific guidance for laspecting fire barrier penetration seals." .
NRC Inspection Manual Chapter 60710 " Refueling Activities," is to be pwformed "During every ohr refaling after b laitial refuling" unless plant problems warrant more frequent inspections. Incleded on the short listing ofitems to be verified during an inspection conducted undw Chapter 60710 is the verification that: " Plant conditions are being maintained as required by TS" [Twhnical Spwificatidas, part of the operating license]. As documented both by the NRC's Inspector General's office and by Dme magazine, Millstons
, Unit 1 conducted refuling outages for 20 years outside ofits design and licensing bas's. e .
Considering that NRC inspectors failed to detect and/or report non conformances in an area explicitly covered under a periodic inspection program while no guidance on fire penetration seals is even implicitly provided, it is Jarealistic for the NRC to assume that prior NRC fim .
protection laspections provide reasonable assurxce that fire barrierpenetrolion seals conform
. with safety regulations. '
- 7) Section 5.1, ' Review of Penetration Seal 2 art 21 Reports," of the technical report attached to the SECY paper states that t , NRC searched its database of reports submitted in accordance
'with 10 CFR Part 21 " Reporting'of Defects and Noncompliance," for reports involving * -
penetration seals and found only two such notifications. The low number of reports implies . -
that penetration seals have not been an industry problem. However, the real reason for the low number of reports is explained in Section 5.6.1, "Dow Corning Corporation." .In b NRC's
- own words, "sesi products were neither safety related nor basic components (as desen%ed in 10 CFR Part 2T/ and thus, "the deficiency reporting requirements of Part 21 are not ,
applicable." .
De NRC cannot realistically expect to find many Part 21 reports on a problem that it '
- conalders not to be reportable. Thwefore, the low number of Part 21 reports involylag silicone
- foam penetrusion seals does not ladicate that there have been few problems with the madertal, February 27,1997 Dnion of Concerned Scientists
, Page 3
i .
i .
Cddque of MRC4 "Twhalcal Assessenest of Fire Barder Penetredes
- Seals la Nuclear Pewer Plants," SECY 96146, Jaly 1,1996 i i l 8) Sution 5.2.1," Review of Liceani Event Reports," of the technical repon attached to b SECY papw states that 0.5 percent of b licensw event repons (LERs)in its database through j 1994 involved fire barrier penetration wals. The low numbw haplim that penetration seals L have not bun an industry problem. Howeyw, a primary reason for the low number of LERs is l explained by NRC Genwic Letters 8610 " Implementation of Fire Protation Requirements,"
dated April 24,1986, and 8812, " Removal of Fim Protection Requirements 60m Technical l Spwifications," dated August 2,1988. Genwic Lettw 8610 moeuraged licensus to incorporate fire protection mquirmnents into their Final Safety Analysis Reports (FSARs) and esmove these requirements bom hir Twhnical Spwifications via a license amendment. ,
Generic Letter 8812 explained that "A conforming amendment would remove fire protection .
aquirements Don TS la font maior areas: firs detection systems, fire suppreselon systems, fles l '
borders, and fire brigade staffing requirapents" [ emphasis added). Many, if not all, lisensen . -
) relocated fire protection requirements 6oin their Technical Spwifications to their Final Safety i Analysis Reports.
1 t
i .
The LER soporting threshold of 10 CFR Parts $0.72 is significantly lower for FSAR
! nonconformanew than for Twknical Spaifteetions. If the numbw of nonconforming a
pen:tration seals was constant each and every year, the number of LERs would steadily i dwline with time as more and more licensus relocated fire protection mquirements to bir
! FSARs. Desfere, the NRC should met astdbete a declialog tread la the number of LERs -
1 levolvlag fles barder problems as a sign of incmased licensee swanness without a mors -
i - ,
dgusa came.effwa analysis: ,
l -
^
l 9) Section 5.2.1," Review of Lloonsee Event Reports," of b technical roport attached to the i
SECY paper states that the NRC "found no reports of safety significant failurus of penetration I wals." Table 2, " Penetration Seal Problems Reponed in LERs," indicatu that 26% of the ,
s penetration seal problems reported between 1989 and 1993 involved seals that were not ,
j - installed or missing.
It appears that the NRC's conclusion regarding safety significant failures is based on that fact I
that b fire barriers was not anded (i.e., because thers was no fires during the period that i the penetration seals were missing). It is poor eaglasering judgement to disconst the
- significance of a degraded or misslag safety featum because the accidset it is latended to
unitigate did not occur. "# -
! The proper prooms is to determine if the aquired fhaction of the safety feature would have r
been fulfilled in the event of an accident. In the case of a missing penetration seal, that ,
- f. standard probably cannot be met; therefore, thers were ledeed safety-significant failures of l- per r+ntion seals. Quite simply, the fact that fire barriw penetration seals have a rating of one
! or 6 e hours imparts safety significanoe to them, L . . 7 i no NRC's conclusion on the safety significance of the reported failures also contradicts NRC l' and industry actions. As one example of many such events, the NRC isand the Tennessu 4 Valley Authority (TVA) a Severity Level IV violation on May 27,1988, because 16 wall
- penetrations at the Sequoyah Nuclear Plant was not sealed in accordance with design drawings. It is difficult to reconcile the NRC considwing 16 degraded penetration seals as
- . having sufficient safety significance as to warrant enforcement action, yet considering literally j hundreds of degraded and missing penetration seals as having no safety significanoe at all. ' i
( Febmary 27,1997 Union of Concerned Scientists Page 4 L
l.__._._..__..__. _ _ _ _ _ _ _ _ _ _ __..____'._
7 3 !
i Caldgme of NRC) " Technical Assessment of Pire BarderPenetrutloa i
Seals la Nuclear Pewer Plants," SECY.96146, July 1,1996 l
1 i
More scently, by lettw dated Novembw 16,1996, the NRC imposed a civil penalty of
- j 550,000 on TVA for a Sevaity Level 111 violation for nonconfonsing fire protection
- conditions, including " inadequate desig~n control of nre barriw penetration seals" identifid at t
j the Sequoyah Nuclear Plant. According to Section S.S.2, " Civil Penalty Assessment," of the ! '
i .
NRC's Enforcement Manual (NUREG/BR 0193), a purpose of the civil penalty is to "emphasias the importance of adhersace to requirements." It would seem that the NRC is '
i practicing select:ye enfortement when it fines TVA for acaconforming fire barder penetrution i
seals, yet tolerseas the gesede industry problem of noncomforslag, combusible Rm bander '
metadal.
}
l The ladustry provides another typical example. By letter dated October 2,1992, the Virgin Electric and Power Company (VEpCQ) informed the NRC of Ave Sre barder penetration seal
- l i
deficloacia at their North Anna Power Station. VEPCO instituted a Are watok imediately
! '. upon detection of the sonooaforming Are barders and the Are watch remained is place until the danciencim were corrected. Tim uw of Sre wataba as compearatory actions is standed industry practice. If nonconforslag fire barrier penetration seals pesed no undu safety hasard
- - as the NRC staff claims la this SECY paper, then the industry would not spend the time and
. effort squired to establish and maintain fire watches. '
' 4 herefers, the actions taken by the NRC and the ladustry indicate that aeaconfonalog Ret
- bander penetraties seals have safety sigalficance. * ,
A
- 10) Swtion 5.8, " Combustibility of Silicone Based Seal Maiorials," of the toobalcal report attachd '
to the SECY paper states that " properly tested, configund, installed, and maintained silicone- '
based penetration seal assemblin are not credible fire hasards" and that when combustible matwials "are properly managed, are accounted for in the plant design and operation, and are
- lacorporated as integral components of the plant fire protection program, including the fire hasards analysis, they are acceptable." These arguments are sound as a general rule, but they are invalid when applied to combustibls silicon foam penetration seals.
no NRC stafflists a number of combustible materials present in nuclear power plants, including dinal generator fuel oil, charcoal filters, lubricating oils, and flammable gases.
Due matwials are not und as Are barriws -in fact,it is due to the presence of theos .
oombustible materials that f' &nrriers are required. The fire baniws ensus that a fire involving the combustible matwials in one area dow not propagate thmugh the walls and '
Aoors to involve the combustible matwials in a4oining areas.
' For obvious reasons, fire barria material must be noncombustible. However, the NRC repor that "a silicone-based penetr-tic a seal assembly could contribute some fuel to a fire" which clearly contradicts the ese. he ihnetion to be performed - that of a fire barrier.
no Undawriters Laboratory of Canada (ULC) subjected RTV foam to a three hour 8:e -
endurance tat in the fall of 1996 in accordance with ASTM.E814, the standard accepted by ,
the NRC. This test, pwformed at the squat of DuraSystems,Inc. of Canada, clearly
- demonstrated the combustibility problem associated with RTV form - the foam was 95% -
consumed and was completely burned through in several areas. Without the intesrity of seal ,
overlays applied on the exposed and unexposed surfaces of the penetration, the Game would have passed through the RTV fia " barrier." nis test dramatically eveals that, except for February 27,1997 Union of Concerned Scientists Page5
\ .
Cddque of NRC4 "Techalcal Assessnest of Fire BarderPenetrades -
Seals la Nucleat Pewer Plants," SECY 96146, .kly 1,1996 limited applicaeless of very small penetrations, a fire barder perfenns betterghhg.it! RTV foam than with RTY foam.
. The ULC test included thumocouples positioned at various depths la the RTV foam to record temperatures durios the test. M test results conclusively demonstrate that the RTV foam continued to burn for several hours 48st b furnace used during the endurance test was shut off. N accepted definition of"self extinsulshing material"is a material that does not support burning once an extenal flame source is removed. Clearly, RTV foam is not "self-extinsvishing." , .
Whether silicose based penetreden seal assemblies are endible fire heards is lealevant. m fact that they are fim conf %ss apresests
- n sedens safety concern. .
- 11) Section 3.8, " Combustibility of Silicone Based Seal Materials," of the technical report attached
' to the SECY papw states that the NRC staff " concluded ht the benefits r# b silloose-based -
penetration seal materials outwelsh any potential conewns regarding ma" al combustibility."
Thors do not soms to be any benefits from fire barrin material that, in b NRC's own words, "could contribute some fuel to a fire." '
- 12) Finding (2) of Section 6, " Summary of Findings," of the technical report attached to the SECY paper states that there have been "no reports of fires that challenged the ability of nuclear
, poww plant fire related structural barriers or fire rated penetration seals to confino a fus."
, his sessament is false. * ,
The March 22,1975, fire at the Browns Fury Nuclear Plant in Athens, Alabama was reported in NRC Bulletin 75 04, " Cable Fire at Browns Ferry Nuclear Poww Station," dated March 24, 1975, and its supplements dated April 3,1975, and November 3,1975. This fire started in the cable spreading room and propassted through a fire rated penetration to ignite a fue in the Unit I reactor building. The fire burned for nearly six hours. During that time, nummons safety systems wws disabled by fire damage to power and control cabling. All of the emergency core cooling systems on Unit I were non functional for seywal hours. The fire also disabled several safety systems on Unit 2. -
- 13) Finding (3) of Section 6. "Su2 mary of Findings," of b technical report attached to b SECY paper states that there "is no evidence of problems with the materials used to construct nuclear poww plant fire barrier penetration seals." His statement is true only if the NRC does not consider sencompliance with federal regulaslems to be a problem. .
~
10 CIR part 50, Appendix R Subpart M states that " Penetration seal designs shall utillas only noncombustible materials." Section 5.8, " Combustibility of Silicone Based Seal Materials," of
. the technical report attached to the SECY paper states that silicone. based penetration seat matwials are " classified as combustitile'when tested in accordance with ASTM E 136,
' Behavior of Matwials in a Vertical Tube Fureace at 750'C,' which is a combustibility test
. method accepted by b NRC
- Table 1, " Representative Population of Seal Types," of the
. technical report indicates that the typical plant (of 32 plants surveyed) had 1668 penetrations sealed by silicone foam.
February 27,1997 Union of Concerned Scientists ' Page 6
- t,.' .
j ,
1 '
Cddque of NRC's 'Techalcal Assessament of Fire BarderPenetration -
i 3 .
Seals la Naclear Pewer Plants," 5ECY.96146, Jkly 1, IDH -
t
{
i 14)
Finding (6) of Section 6, " Summary of Findings," of the technical report attached to the SEC i paper states that a "large body of fire endurance tests has established the firerosistive i
j capabilities of the penetration seal matedals, dwigns, and configurations installed is nuclear poww plants." This statement is misleadles.
i .
- Section 3.12. " Comparison of Tuted to As. Built Configuration," of the twhnical report attached to the SECY paper states that the NRC's fire protection regulations and review i
- guidance do not provide specific " guidance for comparing tested configurations to as-built s
l-oonin urations? Clearly, the results from a successful test of a penetration seal only apply to .
j ,differsat configurations that are bounded by the tested configuration. The lack of specific guidamos suggests that thwe may be wide variability in how individual liosaseos applied* tesl sosults to lastallation specifications. k cannot be determlaed from the available latesmaden if .
all licensees propedy centrolled test asults to ensus that all plant pesetades seal
- ceafigurudens me bened by tested configuendens. .
t i
{-
ne first fill paragraph on page 2 of the Executive Summary of the technical rep j
to the SECY paper, the NRC staff states that fire barrier penetration seals are " universally j
- accepted building components? The NRC staff falls to mention that it is' malverssfily accepted '
building practice to use certified listings for firestop configurations. These listings, certified an independent organlaation like Underwritws Laboratory or Underwriters Laboratory of Canada, spwify the minimum and maximum fire barrier thicknesses depending upon the -
) ,
penetration's width and thickness as well as the numbw and slas of pipes or cable trays passing through the penetration. These certified listings are salversally necepted standards used .
to dwign, install and inspect fire barrier penetrations seals la industrial and commercial
! buildiass, except in nuclear power plants. Because owtified listings are not used in nuclear power plants, rigorous controls that assure testing configurations bound actual con 6 urations j- that are installed in the plants are vital. To apent an important point, it cannot be detemdaed from the available leformaales if all licensees propedy controlled test sesults to ensus that all
} plant p.auiion seal configurations are bound by tasted configurations, i
- 15) Finding (10) of Sution 6, "Sumasiry of Findings," of the technical report attached to the SECY paper states that thers "is no basis for the criteria in Appendix R and the SRP (Standard
' Review Plan) that specifies that peaetration seal materials be noncombustible." His statement
) .
is tudeus. 1 .
l
- De meses that matedal used as a fim barder for suelearpower plant safety must be
' mescombusdble is self evident.
t .
t . ,
- 16) ' Finding (11) of Section 6, " Summary of Findings," of the technical report attached to the .-
SECY paper states that " satisfactory staff review guidance and ladustry practices, methods, s '
~and procedures are available and are used to meet the regulatory requirements for fire barrier -
penetration seals? His. statement directly contradicts aumerous other statements made la this i
t smoe document. , -
First,10 CFR part 50, Appendix R, Subpart M states that " Penetration seal dwigns shall utilias only noncombustible materials." Swtion S 8, " Combustibility of SilicomeBased Seal L
Materials," of the tehnical report attached to the SECY paper states that silicone-based j penetration seal materials are " classified as ' combustible' when tuted in accordance with '
e t February 27,1997 -
Union of Cosicorned Scientirts r '
Page 7
- _ _ _ _ _. i _ _
- \
.' s .
Cdigne of MRC4 " Technical Assessment of P1m BarderPenetrades *
, seals la Nuclear Pewer Plants," SECY.96146, Ady 1,1996 ASTM E.136, thavior of Matwists la a Vertical Tube Furance at 750'C,' which is a combustibility test method accepted by the NRC." Herefore, this segulatory requirernest has 331 been met by ladustry practices, emethods, and procedures. - -
' Second, Section 4.4, " Inspection Proceduns," of the technical report attached to the SECY paper states that the NRC's "laspection procedums do not give specific guidance for inspecting Are barrier penetration seals." nerefore, the NRC staffs avlew guidance with aspect to laspecdag fire barder penetrualen seals is neither v. *iable ser used, e
Third, Table 2, " Penetration Seal Problesas Reported la LERs," of the techalcal report attached to the SECY paper indicates that 26% of the penetration seal problems reported between 1949 '
and 1993 lavolved seals that wwe not lasplied or missing. Desefen, ladastry praedcas, .
methods, and procedoms wen not sufficl6st to even sogaire that penetrusion seals be lastalled.
e * '
.r. , .
+
4 February 27,1997 Union of Concerned Scientists
, Page 8 ,
_9
4 Cdtique of NRC's " Technical Assessment of Fire BarderPenetrusion Seals la Nuclear Pewer Plants," SECY.96146, .kly 1,1996 Concluslens 3
The NRC staffs position on silicone foam fire bardw penetration mais as expressed in SECY.96146 is inadequate due to numwous flaws and inconsistencia. '
l The NRC concluded that silloons foam is combustible.10 CFR Part 50, Appendix R. Subpart M -
prohibits the uw of combustible matwial in fire barriw penetration wals. The NRC staffs acceptanc!
of this nonconforming rendition rop, resents wholwale discretionary enforcement without adequat jnstification. '
4 . -
4 4
h NRC and the ladustry have documented numwous probkas with missing and degraded fits
~
barrier penetration seals. Risk assessments prepared by and for the NRC indicate that fire contributes up to 50% of the over 11' core damage Aequency'Therefors, fire burier penetration' seal problems are*
safety alanificant. . '
, mecommendaden ..
. (1) Combustible matwial used in fire barriw penetration seals must eithw be: ,
(a) removeda' nd rep! aced with a confonning (nonoombustible) material, or (b) accogted on a case-by case basis following inspections that assure fire retardant overleys exist on hath sides of the penetration that provide the assisned firs ratins '
despite the presence of the combustible foma - .
(2) The NRC's internal and the nuclear ladustry's fire protection inspection procedures must be ,
upgraded to include specific guidance on fire barrier penetration seals.
(3) The NRC must develop and issue spec'ific guidanc4 controlling fire barriw penetration seal j testing configurations comparable to the universally accepted certified listings. * '
l 4
Report prepared by: Origind signelly , .
, David A. Lochbaum Nuclear Safety Enginew Union of Conewned Scientists ' .
s 1
j .
i February 27,1997 Union of Concerned Scientists Page 9
___ _. ___ . r m _ _ . _.
____J_-_--____-----
umTrosTATss
[
t, NUCLEAR REGULATORY COMMISSION WAteHNOToN, D. C. MOS
\,, -
November 20, 1979 Docket No. 50-272 l
4 Mr. F. P. Librizzi, General Hinager Electric Production Production Department Public Service Electric and Gas Co@' any 80 Park Place, Room 7221 Newark, New Jersey 07101 '
Dear Mr. Librizzit '
The Comission has issued the enclosed Amendment No. 21 to Facility Operating .
License No. DPR-70 for the Salem Nuclear Generating Station Unit No. 1.
This amendment adds license conditions relating to the co@Ietion of
- facility modifications for fire protection in response to your letters dated Septed er 14, 1977 Deceder 19,1977, July 19,1978 July 26..1978, . .
Septeser and Noveder 8,1978, Septeser 26, 1978, February 15,1979, March 2,1979 5,1979.
We have discussed the contents and conditions of this Itcense amendment with meters of your staff. Although certain procedural details related to the ventilation system remain under review we are proceeding with the issuance of this amendment because only twelve months remain before the October with 1980 deadline for i@lementation of all modifications associated this program. This date was set in late 1976 and recognizes that such modifications should be completed as soon as consideration of the nature of the modifications. practical, with Some major due modifications may require a year to co@lete.
By the provisions of 10 CFR Part 2, paragraph 2.204, you may request a hearing with respect to all or any part of this amendment within twenty (20) days from the date of the notice in the Federal Register of the issuance of this amendment. If you do not request a hearing, this amendment day period. will become effective on the expiration of that twenty (20)
By Amendment No.11 we issued Technical Specifications to incorporate limiting conditions for operation and surveillance requirements for existing fire protection systems. We request that you propose revised Technical Specifications related to facility modifications required by ,
the enclosed amendment by July 1980.
Enclosure 6
l
- i Mr. F. P. Librizzi i
Public Service Electric and Gas 2- November 20, 1979 i :
We have determined that no license amendment fee is required to accompany
- your response to the aforementioned request. This determination is limited to those applications or requests to incorporate our recanmended Technical 1
Specifications and those to add surveillance and other requirements for operable systems that have been added at our request. Any other unrelated i changes or requests that you might choose to includa in the fire protection :
requests would be subject to amerdment fees in accoiiance with Section- l 170.22 of 10 CFR Part 170. '
I Copies lof the related Safety Evaluation and the Notice of Issuance
! are also enclosed. '
[ Sincerely, i
i 4
,a
!?
A. Schwencer, Chief i Operating Reactors Branch #1
} Division of Operating Reactors i
Enclosures:
1 Amendment No. 21 to DPR-70
- 2. Safety Evaluation
- 3. Notice of Issuance I
CCt W/ enclosures
- See next page i
i s
f e
w= -~v-se v - -me,e-w+- n + _ ,-..-n- ,,--w.~~--vv,--ve- e-,-- - -rw, e~,ve--,- nv---,----------e--r-em-,vu ,s,-
Mr. F. P. Librizzi 2
Public Service Electric and Gas Company November 20, 1979 cc: Mark J. Wetterhahn, Esquire Richard B. McGlynn, Comissioner
. Conner, Moore and Corber Department of Public Utilities Suite 1050 . State of New Jersey 3
1747 Pennsylvania Avenue, NW 101 Connerce Street Washington, D. C. 20006 Newark, New Jersey 07102 Richard Fryling, Jr. Esquire Deputy Attorney General Assistant General Solicitor State House Annex Public Service Electric and Gas Company State of New Jersey 80 Park Place 36 Wet: State Street Newark, New Jersey 07101 Trent;n, New Jersey 08625 Gene Fisher,, Bureau of Chief Director, Technical Assessment Divisior Bureau of Radiation Protection Office of Radiation Prograns (AW-459) 380 Scotch Road U. S. Environmental Protection Agency Trenton, New Jersey 08628 Crystal Mall #2-Arlington, Virginia 20460 Mr. Hank Midura, Manager Salem Nuclear Generating Station
. U. S. Environmental Protection Agency Public Service Electric and Gas Company Region II Office 80 Park Place ATTN: EIS COORDINATOR Newark, New Jersey 07101 26 Federal Plaza New York, New York 10007 Salem Free Library 112 West Broadway Mr. E. N. Schwalje, Manager Salem, New Jersey 08079 of Quality Assurance Public Service Electric and Gas Company Leif J. florrholm 80 Park Place U. S. Nuclear Regulatory Commission Newark, New Jersey 07101 Drawer !
Hancocks Bridge, New Jersey 08038 Mr. R. L. Mitt 1, General Manager Licensing and Environment Attorney General Public Service Electric and Gas Company Department of Law and Public Safety 80 Park Place State House Annex Newark, New Jecsey 07101 Trenton, New Jersey 08625 Samuel E. Donelson, Mayor 4 Lower Alloways Creek Township Municipal Hall Hancocks Bridge, New Jersey 08038 4
c - - - - , -w.,- - - - , - , ,m - - - , , ,
UNITED STATt8
[ NUCLEAR REGULATORY COMMIS$lON g WASHlWGTON, D. C. 20666 e....
PUBLIC SERVICE ELECTRIC AND GAS COMPANY DOCKET NO. 50-272 SALEM NUCLEAR GENERATING PLANT, UNIT NO.1 AMENDMENT TO FACILITY OPERATING LICENSE
' Amendment No. 21 License No. DPR-70 l
l 1. The Nuclear Regulatory Comission (the Commission) has found thatt A. The facility will operate in conformity with the provisions of the Atomic Energy Act of 1954, as amended (the Act), and the rules and regulations of the Comission; B. There is reasonable assurance (1) that the activities authorized
-by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Comission's regulations; C. The issuance of this amendment will not be inimical to the comon defense and security or to the health and safety of the publict and D. The issuance of this amendment is in accardance with 10 CFR 51 of the Comission's regulations and all applicable requirements have been satisfied.
- 2. Accordingly, operating license DPR-70 is amended by adding parag:aph C.5 to read as follows:
C.5 Public Service Electric and Gas Coinpany shall maintait; 5 effect and fully implement all provisions of the approved fire ti rotection plan. The approved fire protection plan consists of the document entitled. Salem Nuclear Generation Station Unit No.1 Fire Protection Program Evaluation Comparison BTP APCSB9.5-1 Appendix A" which includes: Initial Issue, submitted with letter dated September 14, 1977 additional information submitted with letters of July 19 July 26, September B, and September 26, 1978 and February 15 March 2 and November 5, 1979 The licensee may proceed with and is reqdired to complete the modifications identified in " *agraphs IIC, !!!A, IIIB, IVA, and
e 2-
, IVC of the NRC's Fire Protection Safety Evaluation (SE), dated November 20, 1979 for the facility. These modifications will be completed in accordance with the schedule in Table 1 of the SE. If any modification cannot be completed on schedule, the licensee shall submit a report explaining the circumstances and propose, for staff approval, a revised schedule.
- 3. This license amendment becomes effective as of twenty days from the date of publication of the notice of issuance unless a hearing has been requested.
FORTNENULEARREGULATORYCOMMISSION
.. 46W A. 'Schwencer, Chief Operating Reactors Branch #1 Division of Operating Reactors Date of Issuance: November 20, 1979
, _.i! . , .
- l l
\
I .
4
]
$AFETY EVAL.UATION BY THE OFFICE OF NUCLEAR REACTOR REGULAT?ON
< RELATED TO AMENDMENT N0. 21 TO FACILITY OPERATING 1,1 CENSE NO. OPR-70 PUBLIC SERVICE ELECTRIC AND GAS C0W ANY. .
i PHILADELPHI A ELECTRIC COWANY.
! DELMARVA POWER AND LLGHT COWANY. AND ATLANTIC CITY ELECTRIC COW ANY '
SALEM NUCLEAR GENERATING $TATION UNIT N0. 1 DOCKET NO. 50-272 1
3
- FIRE PROT _ECTION REVIEW 4
4 J
R 4
e e
e
i SALEM NUCLEAR GENERATING STATION SAFETY EVALUATION REPORT FIRE PROTECTION REVIEW UNIT NOS. 1 AND 2 TABLE,0F CONTENTS
- 1. INTRODUCTION II. FIRE PROTECTION 5YSTEMS DESCRIPTION AND EVALUATION l
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A.. Water Supply Systems B. Automatic Sprinkler and Manual Water Syssoms C. Gas Suppression' Systems D. Foam Suppression System .
E. Fire Detection Systems
!!!. OTHER ITEMS RELATING TO THE STATION FIRE PROTECTION PROGRAM A. Fire Barriers B. Fire Doors and Dampers C. Penetration Fire Stops D. Comunication Systems E. Reactor Coolant Pressure Boundary Integrity .,
. IV. ' FIRE PROTECTION FOR SPECIFIC AREAS Y. ADMINISTRATIVE CONTROLS AND FIRE BRIGADE VI. TECHNICAL SPECIFICATIONS ,
VII. CONCLUSIONS e
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- SALEM NUCLEAR GENERATING STATION UNIT NOS. 1 AHO 2 .
Fire orotection Safety Evaluation Report
- 1. INTRODUCTIO'l -
We have reviewed the Salem Nuclear Generating Station Unit Numbers 1 and 2 fire protection pmgram and fire hazards analysis submitted by the licensee. The submittal, including their answers to six NRC requests .
for_ addi.tionaljnfqnnation, was in response to our request,to evaluate
' his fire protection program agMnst the guidelines of Appendix A to l STP APCSS 9.5-1, " Guidelines for Fire Protection for Nuclear Power .
l Plants." As part of the review, we visited the plant site to examine the relaticnship of safety related components, systems, and structures s in specific plant areas to both combustible materials and to associated fire' detection and suppression systems. The overall objective of our review of the Salem Nuclear Generating P.lant fire protec. ion program was to er.sure that in the event of a fire at either facility, Units 1 and 2 would maintain the ability to safe'ly shutdown, remain in a safe shutdown condition, and minimize the release of radioactivity to the environment.
Our review included an evaluation of the automatic and manually operated water and gas fire suppression systems, the fire detection systems, fire barriers, fire doors and dampers, fire protection administrative controls,
. fire brigade training, and plant fire protection Technical Specifications.
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Since Unit 1 and 2 are of the same design, except where noted, the comments 1
- . made in this report apply to both units.
i l Our conclusion, given in Section VII is that the Fire Protection Program at the Salem Nuclear Generating Station Unit Nos.1 and 2 is adequate at the present time, and meets General Design Criterion 3. However, to further ensure the ability of the plant to withstand the damaging effects j of' fires that could occur, we are requiring, and the licensee has agreed to provide, additional fire protection system improvements. Until the ,
- comitted fire protection system improvements are operational, we con-4 sider the existing fire detection and suppression systems; the existing l barriers between fire artas; improved administrative procedures for i
control of combustibles and ignition sources; the trained onsite fire brigade; the capability to extinguish fires manually; ar.J the fire pro-taction technical specifications provide adequate protection against a fire that would threaten safe shutdown. These additional fire protection features will be~ completed for Unit Number 1 prior to the end of its second refueling outage. For Unit Number 2, the program will be imple-m ented prior to the first refueling outage. The schedule for specific protection system improvements is presented in Table I at Ehe and of this report.
- This report sumarizes, the results of our evaluation of the Fire Protec-tion Program at the Salem Nuclear Generating Station. -
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!!. FIRE PROTECTION SYSTEMS DESCRIPTION
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A. Water Suooly Systems The water supply system is connon to both units and consists of two full capacity 2500 gpm diesel engine driven fire pumps, and a separate i motor driven pressure maintenance (jockey) pump whose capacity is ,
30 gpm at 110 psig. Each pump has its own driver with independent power supplies and controls. Separate pump discharge headers connect to the yard fire main loop at points approximately 5 feet apart and ar,e underground. Post indicator valves are provided to isolate the pump discharge headers in the main yard loop. They are also provided to isolate sections of the fire loop for maintenance and repair.
The cwo fire pumps, their associated fuel oil day tanks, the Jockey pump and the station fresh water pumps are located in the fire pump house. The fresh water pumps are separated from the fire pumps by a three hour barrier. The fire pump room is protected by a wet pipe sprinkler system with heat actuated sprinkler heads. Floor drains are provided which would limit the spread of oil in the event of a leaking oil tank. The fire pumps ar,e mounted on 12-inch high concrete foundations. Separate alarms monitoring pump runnirig, prime mover availability, or failure to start are provided for the pumps in the plant control room. The fire pumps are installed in a'cc'ordance to the applicable sections of NFPA 20. We have evaluated the above design .
and criteria and found that it is an acceptable alternative to locating the equipment in separate rooms.
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The water supply source is from two 350,000-gallon fresh water tanks of which 200,000 gallons in each is reserved for fire protection. ,
Make-up to the tanks is supplied from on-site production wells. The fire pumps can take suction from either or both tanks. The fire suppression system requiring the greatest water demand is the deluge system for the main transformers. This water demand is 1400 gpm at 70 psig plus 1000 gpm' for the hose streams. This is within the design capacity of 2500.gpm for the system.
We have reviewed the design criteria aad bases for the water supply systems and conclude that these systems meet the guidelines of Appendix A to Branch Technical Position 9.5-1 and are, therefore, acceptable.
B. Autobatic Sprinkler and Manual Water Systems '-
The automatic sprinkler system and manual hose station hose standpipo system are fed by the main yard loop with multiple connections to interior fire protection systems header, e.g., the auxiliary building, ,
turbine buil 'ng, service building and reactor building. Each sprinkler system and manual hose station has an independent connection to the fire protection header fed from two' directions, therefore, a single failure cannot impair both the primary and backup fire protection system.
Yalves in the fire protection system which are not electrically super-vised, with indication in the control room, will be locked and super-vised in their normal ooerating position and checked periodically.
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The automatic sprinkler system,s, i.e., wet sprire,er system, pre-action sprinkler systems, deluge and water spray systems, are designed to the requirements of NFPA Standard No.13. " Standard for Installation of Sprinkler Systems," and NFPA Standard No.15. "Stan-dard for Water Spray Fixed system." ,
Manual hose stations ?are located throughout the plant to ensure that
- an effective hose stream can be directed to any safety related area j in the plant. These systems are consistent with the requirements of NFPA Standard No.14. " Standpipe and Hose System for Sizing, Spacing, and Pipe Support Requirements."
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Aret that have been equipped or will be equipped
- with automatic water suppression systems are:
(A) Water-Operated Deluce Systems Deluge systems actuated by water-pilot line automatic sprinkler heads are provided for the following equipment
- areas:
(1) Nos.11 and 12 Turbine Oil Storage Tanks (2) No.1 Seal 011 Unit .
- (3) No.1 Turbine Oil Reservoir .
(4) No.1 Turbine Oil Makeup Tank (S) Nos.11A and 118 Feedwater Pump Turbine Oil Coolers (6) No.1 Turbine Oil Conditioner (7) No.1 Feedwater pump Lube Oil Tank
- To be installed in accordance with Table 1.
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(8) No:. 1. 2 and 3 Station Air Compressors (9) Nos. 21 and 22 Turbine 011 Storage Tanks (10) Nos. 2 Seal Oil Unit (11) No. 2 Turbine Oil Reservoir (12) Nos. 21A and 218 Feedwater Pump 'urbine Oil Coolers (13) No. 2 Feedwater Pump Lube 011 Tank ,
(14) No. 2 Turbine 01'1 Conditioner (B) Electrical 1v-Operated Deluce Systems '
Re-cycling deluge system.: actuated by continuous strip overheat detectors are provided for the following equipment areas:
(1) No.1 Control Room Emergency Air-Conditioning Unit Charcoal l
Filter .,
(2) No.14 Auxiliary Building Standby Ventilation Unit Charcoal Filter (3) No.1 Containment Pressure Relief Unit Charcoal Filter (4) No.12 Fuel Handling Area Ventilation Unit Charcoal Filter
, (5) Nos.11 and 12 lodine Removal' Units Charcoal Filturs (6) No. 2 Contml Room Emergency Air Conditioning Unit Charcoal Filter *
(7) No. 24 Auxiliary Building Standby, Air-Conditioning Unit
. Charcoal Filter (8) No. 2 Containment Pressure Relief Unit Charcoal Filters (g) No. 22 Fuel Handling Area Ventilation Unit Charcoal Filter (10) Nos. 21 and 22 lodine Removal Units Charcoal Filters l
,'- 4' (C) Air Operated Celuce Systems '
Deluge systems actuated by air-pilot automatic sprinkler heads are provided for the following equipment areas:
(1) No.1 Main Transfomer, Phases A, B, and C
, (2) Nos.11,12,13 and 14 Reactor Coolant Pumps (3) Nos.11 and 12 Station Power Transfomers (4) No.1 High,and Low Pressure Tuttine Bearing Housings (5) No.1 Auxiliary Transformer -
, , (6) Heating Boiler Fuel Oil Pump and Heater (7) No. 2 Main Transformer, Phases A, B, and C (8) Nos. 21, 22, 23 and 24 Reactor Coolant Pumps (9) Nos'. 21 and 22 Station Power Transfomers (10) No. 2 High and Low Pressure Turbine Bearir.) Housings (11) No. 2 Auxiliary Transformer (D) Wet-Pipe Serinkler Systems Wet-pipe sprinkler systems, consisting of piping systems which are filled with water, which will spray from heat actuated sprinkler heads, are provided for the following arns:
(1) Service Building - Elev. 88 ft.,100 ft.,113 ft., and 127 ft., and the cable vaults carrying cables between the Auxiliary Building and the Turbine Building..
(2) Fire Pump House - Elev.100 ft. -
(3) Heating Boiler House - Elev.100 ft.
(4) No.1 Turbine Perimeter - Elev. 88 f t. ,100-f t. , and 120 f t.
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-(5) No. 2 Turbine Perirneter - Elev. 88 ft.,100 ft., and 120 f t, f
(6) Auxiliary Building Drunning and Baling Storage Area - Elev. i 100 ft.
(7) Auxiliary Building Resin Storage Areas - Elev. 122 ft. H q
(8) Auxiliary Feed Pump / Remote Shutdown Panel - Elev. 84 ft.* ii (9) Charging Pump -
Elev. 84 ft.*
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We have reviewed the, design criteria and bases for the water suppres- '!
sten systems and conclude that these systems with the additional -
sprinkler systems ,to be installed meet the guidelines of Appendix A to Branch Technical Position ASB 9.5-1 and are in accordance with the applicable portions of the National Fire Protection Association (NFPA)
Code 3, and are, therefore, acceptable.
C. Gas Suporession Systems Total flooding low pressure CO 2 and/or Halon systems are orovided for the following areas:
(A) Automatically-Actuated Carbon Dioxide Floodino Systems 1 Automatically-actuated flooding systems are provided for the following areas: -
(1) Nos.1A,18, and 1C Diesel-Generator Rooms. and .D.G Control Rooms-Eley,100 ft, and Day Tank Areas - Elev.122 ft.
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- To be installed in acenrdance with schedule in Table I.'
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(2) Nos.11 and 12 Diesel Fuel Oil Storage Tanks
'( 3) No.1 Exciter Enclosure Elev.140 ft.
(4) Diesel Fuel Oil Transfer Fump Rooms (Unit No.1) - Elev.
84 ft.
(5) Nos. 2A, 2B, and 2C Diesel-Generator Rooms and Control Rooms - Elev.100 ft. and Day Tank Areas - Elev.122 f t.
(6) Nos. 21 an'd 22 Diesel Fuel Oil Storage Tanks (7) Diesel Fuel Oil Transfer Pump Rooms (Unit No. 2) - Eley.
84 ft.
(8) No. 2 Exciter Enclosure - Elev.140 ft.
l (B) Automatically Actuated 'Halon Flooding Systems _ .
(1) No.1 Relay Room - Elev. '100 f t.*
(2) No. 2 Relay Room - Elev.100 ft.* ,
(c) Manually Actuated Carbon Dioxide Flooding Systems Manually-actuated flooding systems are provided for the following areas: -
(1) No.1460V Switchgear Room - Elev. 84 ft.
(.2 } No. 1 4160V Switchgear Room - Elev. 64 ft.
(3) No. 1 Electrical Penetration Area - Elev. 78 ft.
(4) No. Z 460V Switchgear Room - Elev. 84 ft.
(5) No. 2 4160V Switchgear Room - Elev. 64 ft.
(6) No. 2 Electrical Penetration Area - Elev. 78 ft.
- To be installed in accordance with schedule given in Table L e
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These. systems are designed to flood the protected areas with carbon dioxide in concentrations up to 50 per cent. Carbon dioxide fire protection for all areas, except the Exciter Enclosures, is supplied from a 10-ton Cardox refrigerated storage tank (one per unit) located on Elev. 84 ft, of each Auxiliary Building outside the Diesel Fuel Oil Pump Rooms and is discharged to the protected areas either auto-matica'lly or manually as indicated above. The carbon dioxide fire protection for the Generator Exciter Enclosure for each unit is supplied from a 750-lb. refrigerated storage tank located on Elev.120 ft. in ec h Turbine Area. Each tank contains a sufficient supply of carbon dioxide for tv' 'ull discharges into the largest protected area.
'There re three diesel generator sets per unit and each set is flooded by independent CO 2 actuation. The CO2system for each Diesel-Generator Room and its associated Control Room and day tank area are actuated together. The CO 2system for the two Diesel Fuel Oil Pump Rooms for each unit are also actuated together. All other areas are independently actuated.
The CO2 suppression system is designed'in accordance with,NFPA Standards Numbers 12 and 12A. We have reviewed the design criteria and basis for these fire suppression systems. We conclude that e
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, these systems satisfy the provisions of Appendix A to Branch Tech-nical Position 9.5-1 and are, therefore, acceptable.
D. Foam Suporession System .
A manually actuated foam system with a capacity of 300 gallons is located in a Foam Tank House south of the Turbine Area, for the pro- '
j tection of No. 1 Fue,1 011 Storage Tank.
The system has been designed and installed in accordance with NFPA Standard No. 11 to cover the liquid surface in 30 minutes. The foam solutiun is double strength. -
35 protein foam concentrate.
We have reviewed the design criteria and bases for the foam suppres-sion system and we conclude that the system satisfias- the provisions of Appendix A to Branch Technical Position 9 S-1 and is, therefore.
- acceptable.
E. Fire Detection Systems The fire detection system consists of the detectors, associated elec-trical circuitry, electrical. power supplies, and the fire annunciation panel. The types of detectors used at the Salem Nuclear Generating Stationareionization(productsofcombustion),andthermal(heat sensors). The system is continuously supervised with a NFPA 72D Class B supervised system.
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Fire detection systems will give aucible and visual alarm and annun-ciation in the control room. Local audible and/or visual alarms are 41so provided. . . .
The licensee has agreed to install additional smoke detectors in the following areas:
(a) Peripheral rooms .of the control room complex - Elev'.122 ft.
(b) Spent and new fuel storage area (c) Piping penetration a'rea - Elev. 78 ft. -
(d) Control Area Air Conditioning System Equipment l (e) Corridor Area - Eley 100 feet (f) Redn Storage (g) Aux'iliary Building Ventilation Equipment ,
(h) Boric Acid Pumps (t) Safety Injection Pumps (j) Component Cooling Pumps (k) Auxiliary Feedwater Pumps (1) Charging Pumps (m) Containment Spray Pumps .
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(o) Storage Tank Recirculation Pumps (p) Residual Heat Removal PuT.ps
- (q) Emergency Air Compressor (r) Chilled Water System Chillers .
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(s) Mechanical Penetration Area (t) Piping Penetration Area (Elev. 78 f t.)
(u) Inner Piping Penetration Area .
(v) Outer Pipi.ig Penetration Area ,
(w) General Containment (one detector in each recirculating fen)
(x) Reactor Coolant Pumps (y) Service Water Pump's We have reviewed the fire detection systems to ensure that fire detectors are located to provide detection and alam of fires that could occur. We have also reviewed the fire detection systems design criteria and bases to ensure that it confoms to the applicable sections of NFPA No. 740. We conclude that the design and the installation o'f 'the fire detection systems with the additional detectors to be installed, meet the guidelints of Appmdix A to Branch Technical Position ASB 9.5-1 and the appitcable psrtions of NFPA No. 72D, and are, therefore, acceptable.
III. OTHER ITEMS RELATING TO THE STATION FIRE PROTECTION PROGRAM A. Fire Barriers All floors, walls, and ceilings enclosing separate fire areas are rated at a minimum of 3-hour fire rating with exception of the pene-trations discussed in Sections III, B and C. The main control room area contains peripheral rooms which are located within the main control-room 3-hour fire barrier. These peripheral rooms are provided with detectors and alarms and minimum one-hour fire rated ceilings and fire deers.
, -The licensee has provided acceptable documentation to substantiate the fire rating of-the 3-hour barriers.
! B. fire-Coors and Damp'ers We have also reviewed the placement of the fire doo'rs to ensure that 4
l fire doors of proper fire rating have been provided. The fire rating of the doors as ,a minimum will be 1-1/2 hour rating based -
on the fire loading of.the particular fire areas.
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Ventilation penetrations through barriers are protected in some areas by standard fire door / dampers. The licensee will provide one of the i following for the rest of the unprotected ventilation penetrations:
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- 1. Ut. listed fire rated door type dampers at each penetration.
l . . 2. Coat the ventilation ducts with a flame retardant material to I a minimum fire rating of 1-1/2 hours based on the fire loading of
. the area. In addition the licensee will provide rated fire I
dampers on all supply and exhaust openings in the ducts.
I The licensee has-provided the necessary information to demonstrate
, to our satisfaction that fire door / dampers and their method of instal-lation can provide a fire rating equivalent to the fire barrier or the fire loadtng of the fire area. The fire door / dampers are and will be installed in accordance with NFPA 90-A.
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C.- penetration Fire Stoos Penetrations, including electrical penetration saals, through rated barriers are sealed to provide fire resistance equivalent to the barrier itself. The licensee has provided the necessary infonnation v to demonstrate that the penetration seals used in the penetrations for cable trays, conduits, and piping and their method of installation can provide a fire rating equivalent to the fire barrier.
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- We conclude that.the fire barriers, barrier penetrations, fire doors ,
and dampers 'with the additional doors and dampers to be installed meet the guidelines of Appendix A to Technical Position ASB 9.5-1 and are, therefore, acceptable.
D. Comunication Systems Fixed emergency comunication using voice-powered head sets is available
- at specific locations throughout the station. There is-also a public address syttem on each unit which is powered by an inverter normally fed from the 230 volt alternating current vital bus C and backed up by the 125 volt direct current emergency bus C. To satisfy the guide-lines of Appendix A to BTP ASB 9.5-1, the licensee has comitted, at t our request, to provide an additional comunication system consisting of portable radio units. To preclude a single electrical failure from causing the loss of, all communication systems, the licensee has docu-mented that the fixed repeater and other accessories associated witn the portable radio ecmunication system of each unit will be powered from a different 125 volt direct current emergency bus as that of tne public address system for that unit.
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- -The licensee has committed to perfcrm a preoperational test to demonstrate that the frequencies used will not affect the actuation of protective relays. We conclude that the addition of this new l
I communication system satisfies our guidelines set forth in Appendix A to Branch Technical Position ApCSB 9.5-1 and therefore is acceptable.
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- . 'E. Reactor Coolant Pressu're Boundary Intecrity -
- We expressed a concern to the licensee that _ spurious valve operation
- caused by fire may affect theintegrity. of the reactor coolant pressure
- boundary. We required that the licensee examine each interface at
> the reactor coolant pressure boundary and either demonstrate the capability of the design to withstand spurious valve operation caused by fire without the-loss of reactor coolant pressure boundary integrity,
- or modify the design to assure integrity.
The examination performed by the licensee revealed that.the' pressurizer relief lines having the electrically and pneumatic operated valves and'which are connected to the pressurizer relief tank, were the only interfaces.which were not isolated from the high pressure reactor coolant system by two normally closed' valves. Each of the'two pressurizer relief lines in Unit I has a normally closed pneumatic operated relief valve in series with a normally open motor-operated Each pressurizer relief line in Unit 2 has one more pneumatic valve.
operated valve per line than Unit 1. This add, i tional valve is normally i
closed and connected in parallel-with the other air operated valve.
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. The spurious opening of a single pneumatic operated relief valve caused by-a fire could lead to compromising the reactor coolant boundary integrity if the valve is not c,losed before the design pressure limits of the pressurizer relief tank are exceeded. Each pressurizer relief line can be isolated by either closing the pneumatic or motor operated valve from the' main control room or from the corresponding' power distribution and motor control centers.
The licensee contends that there is sufficient time available to l . -
l diagnose the situation and isolate the relief line while the pressurizer is relieving to the pressurizer relief tank. -
Our review determined that the existing provisions and future modi-fications for fire protection in the relay room and other areas of the station where the electrical circuits and cables associated with the pressurizer relief valves ,are located, are consistent with minimizing the probability of a fire causing the opening of the pressurizer relief lines, and, therefore, we conclude that the design in this regard is acceptable. Furthermore, the consequences resulting f rem the spurious opening of a relief, valve caused by a fire or other reasons compounded with the failure of the valva to close within the speciffed time, have been analyzed by the NRC staff. It has been detennined that..the consequences resulting from this- event are satisfactorily mitigated by the engineered safety feature systems.
IV. FIRE PROTECTION FOR SPECIFIC AREAS A. Relay and Switchoear Rooms Relay and switchgear rooms containing redundant electrical divisions are provided for each unit. These rooms are separated from each other and the balance of the plant by a minimum of 1-1/2 hour rated , ,,
. fire barriers... The, relay and switchgear rooms for Unit 1 are separated from their counterpart's in Unit 2 by two 1-1/2 hour rated fire barriers and a comon corridor. There are a minimum of two access doors to each of the rooms and the doors are located at opposite ends of the' rooms.
Currently a manually actuated total flooding CO 2 system is installed in the switchgear rooms and manual hose stations are,provided for the relay rooms. The licensee has agreed, at our request, to provide an automatic Halon system for the relay rooms.
When the Halon system is actuated, the ventilation system isolates the rooms and smoke venting can be initiated by manually actuating the exhaust fan. In addition, smoke detectors are installed that alarm in the control room. The back'up fire suppression system is the hose stations located in the imediate vicinity of the access doors and portable extinguishers.
All power, control, and instrumentation cable have passed the IEEE No. 383 Flame Test. Al' cable trays within these rooms have a minimum separation-distance of 18 inches vertical and 12 inches horizontal, as well as a fire resistant barrier of asbestos woven
19 cloth on the bottom of each tray. The licensee has perfomed tests to show that the cables usec will not propogate a fire from tray to tray with a vertical separation distance of 12 inches. In addition, the higher voltage trays are installed above the lower voltage trays.
The licensee has comitted, at our .'equest, to establish an emergency shutdown procedure and necessary modifications to assure the capability to achieve safe shutdown in the event of an exposure fire in* these ,
rooms which might disable redundant cable divisions of system neccssary for safe shutdown. The applicant will provide an alternative shutdown method for our review. This alternate shutdown method will include where necessary the rerouting of instrumentation cable to the hot shutdown panel. The procedures and modifications for hot and' cold shutdown will be implemented by the second refueling for Unit 1 and the first refueling for Unit 2.
We have reviewed the licensee's fire hazards analysis and fire protection provided for the relay an,d switchgear rooms and consider that appropriate fire protection has been provided and after the modifications and procedures are iinpleMted will conform to the provisions of Appendix A to BTP ASB 9.5-1 and are, therefore, accept-able.
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- 3. Safety Related Pumo Areas ,
In 'the safety related pump areas, such as the auxiliary feed camp area and the charging pump, the pumps are located in close proximity to each other. Access to the pumps is usually an open corridor. We were concerned that a common exposure fire could jeopardize the safety
- function of two or more of the pumps. At our request, the licensee has comitted to install automatic water sprinkler systems in these areas.
In' addition, a one hour rated fire barrier or, alternativ1y, a one-half hou barrier and a sprinkler system will be provided, where necessary, to separate redundant cable trains serving these pumps. Both trains of the auxiliary feedwater system will be protected in this manner.
We hate reviewed the licensee's fire hazards analysis for this area and canclude that appropriate fire protection has been provided and _
J af ter modifications are implemented will meet the guidelines of Appendix A of BTP 9.5-1 and is, therefore, acceptable.
C. Diesel Fuel Oil Storace Rooms-The diesel- fuel oil storage area, located on elevation 84, contains two 7-day diesel oil storage tank rooms,-two transfer pump rooms, and the plant's CO2 system 10 ton storage tank. The f. ire suppression i
system for this area is an automatic CO2 total flooding system.
We were concerned that a diesel oil fire in the tank rooms or the diesel oil transfer pump rooms could jeopardize the entire plant's CO suppression system, if manual fire suppression systems had to 2
be used. The licensee, at our request, has comitted to install, in addition to the CO 2 ystem, s one of the following systems in tr.e diesel storage tank area:
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. 1. An auto atic open head deluge or open head spray nozzle system
- 2. An au:c atic closed head . sprinkler system
. 3.- An automatic AFFF system, the foam being delivered by a sprinkler or spray system.
We have reviewed the licensee's Fire Hazards Analysis for this area
- and conclude that appropriate fire protection will be provided and after the modifications are implemented will meet the guidelines of Appendix A of BTP ASB 9.5-1 and is, therefore, acceptable. '
D. Other Plant Areas In order to provide a defense-in-depth design so that a fire will not prevent the performance of necessary safe plant shutdown functions, the licensee has committed to perform a fire interaction analysis on
. all redundant mechanical and electrical systems and components t
necessary for safe cold shutdown which are separated only by distance and are within 20 feet of each other. The analysis will postulate a fire in installed or transient combustibles and failure of the primary ff.r1 suppression system.
Where additional protection and/or separation is required to assure a safe shutdown condition, the applicant has committed to:
(1) relocate one or both divisions to achieve a minimum of 20-ft.
separation be' tween divisions, or (2) pr:vice a one-hour fire rated barrier such as 1" inch ceramic ff:er separating one safety related train from the other or fr: a commen exposure fire and area automatic sprinkler syste s 4
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, will be provided to afford pr:tection against exposure fire at the interactions, or (3) provide an alternate shutdown method that is independent of
. the interaction area.
The licensee's Fire Hazards Analysis addresses other. plant areas not specifically discussed in this report. The licensee has committed to install additional detectors, portable extinguishers, hose stations, and some additional emergency lighting as identified in the licensee's installation schedule. We find these areas with the comt.itment made by the licensee to be in accordance with the
. guicelines of Appendix A of BTP ASB 9.5-1, and the applicable sec-tions of the National Fire Protection Association Code and are, therefore, acceptable.
V. ADMINISTRATIVE CONTROLS-The administrative controls for fire protection consists of the fire protection organization, the fire brigade training, the controls over
. combustibles and ignition sources, the prefire plans and procedures for fighting fires and quality assurance.
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i In response to Appendix A to Branch Technical Position ASB 9.5-1, the licensee described his proposed procedures and controls. The licensee has agreed to revise his administrative controls and training procedures to, follow supplemental staff guidelines contained in " Nuclear Plant Fire Protection Functional Responsibilities, Administrative controls and Quality Assurance," dated 6/14/77, and implement them by December 31,1979.
The administrative procedures for the control of combustib1'es and ignition sources is complete for Unit 1 and will be implemented prior to fuel loading for Unit 2. The present fire brigade consists of a trained three-man brigade. The applicant has committed to have a plant fire brigade of at least five members that will be organized to provide imediate response to fires that may occur at the site. The full brigade will be fully trained and on site by December 31,1979. The plant fire
, brigade will also be equipped with stored closed circuit oxygen-type breathing apparatus, portable communications equipment, portable lanterns, and other necessary fire fighting equipment. Spara oxygen cylinders and recharge capability are provided to satisfy the guidelines of Appendix A to Branch Technical Position ASB 9.5-1.
The fire fighting brigade participates in periodic drills. Liaison between the plant fire brigade and the local fire departments has been established. The local fire departments have been on plant tours and have also been involved in training sessions with the plant fire brigade.
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'de conclude that the fire brigade equiement and training conform to the
) recommendations of the National Fire Protection Association, Appen' dix A -
- to Branch Technical Position ASB 9.5-1 and supplemental staff guidelines and are, therefore, acceptable.
VI. TECHNICAL SPECIFICATIONS We have reviewed the plant Technical Specifications issued for Salem
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Nuclear Generating Station Unit Nos. I and 2 and find that they are con-sistent with our Standard Technical Specifications for fire protection.
Following the implementation of the modifications of fire protection systems and administrative controls resulting from this review, the Technical Specifications will be modffied accordingly to incorporate the limiting corditions for operatien and surveillance requirements to reflect these modifications.
VII. CONCLUSION The fire protection system for Salem Nuclear Generating Station Unit Nos.1 and 2 was evaluated and found to meet General Design Criterion
'3 " Fire Protection" at the time the original Safety Evaluation Report was issued in October,1974.
As a result of investigations conducted by the staff on the fire protec-tion systems, fire protection criteria were developed' and further requirements were imposed to improve the capability of the fire protec-tion system to prevent unacceptable damage that may result from a fire.
At our request, the licensee conducted a re-evaluation of their fire crotection system for Salem Units 1 and 2. The licensee submitted in
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j September,1977, a Fire Hazards Analysis for both units and subsecuently
-in response to our positions, six revisions to the Analysis. He also has compared his system, in detail, with the guidelines of Appendix A to :
Branch Technical Position ASB 9.5-1, " Guidelines for Fire Protection for Nuclear Plants."
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During the course of our review we have reviewed the licensee's submittals and his responses to our' requests for additional information. In addition.
[ we have made two site visits to evaluate the fire hazards that exist in '
- the Salem Nuclear Generating Station and the design features and protec-l tion systems provided to minimize these hazards.
- The licensee- has completed some modifications or proposed to make addi-tional modifications to improve the fire resistance capasility for fire doors, dampers, fire barriers and barrier penetration seals.
The licensee has also proposed to install additional sprinkler systems
!- for areas such as the auxiliary feed pump area, charging pump area, and various other areas, as.well as an automatic Halon system in the relav l rooms. To ensure that fires can be detected rapidly and the plant opera-I tors infomed promptly, additional detectors will be installed in various areas of the plant.
In addition, the licen'see has-committed to establish emergency shutdown
. procedures to bring the olar.t to safe cold shutdown condition in the 4
,-.c -
, event of a damaging fire in the relay rooms, the switchgear rooms and other safety-related areas.
The licensee is comitted to making all improvements by the second r'efueling for Unit 1 and the first refueling for Unit 2, thus meeting his ifcense condition. We have reviewed the licensee's schedule and find it acceptable and have included it in Table I.
We find that the Fire Protection Program for the Salem Nuclear Generating, Station with the improvements already made by the licensee, is adeouate i at the present time.and, with the scheduled raodifications, will meet the guidelines contained in Appendix A to Branch Technical Position ASB 9.5-1 and meets the General Design Criterion 3 and is, therefore, acceptable.
1 Until the connitted fire protection system improvements are operational, we consider the existing fire oetection and suppression systems; the existing barriers between fire areas; improved administrative procedures for control of combustibles and ignition sources; the trained onsite fire brigade; the capability to extinguish fires manually; and the fire protection technical specifications provide adeouate protection against a fire that would- threaten safe shutdown.
Our overall conclusion is that a fire occurring in any area of either Salem Nuclear Generating Station will not prevent that plant from being brought to a controlled safe cold shutdown, and further, that such a fire would net cause the release of significant amounts of radiation.
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, TABLE I MODIFICATION IMPLEMENTATION SCHEDULE Action Sta tus Item No. planned Action item Description Unit 1 Unit 2 l_ 1. Make orsanizational revisions to assign the station superin- Completed Complett-i tendent responsible for all aspects of firefighting and fire protection.
- 2. List the Fire Protection' Program as "QA Applicable." Completed Complete
! 3. Perform detailed review of applicable procedures for ade-Completed Ceep'1_ ett quacy in addressing the requirements of Appendix A to Branch Technical Position 9.5-1 and revise as necessary.
- 4. Replace the wood planks on the new fuel storage pit with Completed Complete, wood which has been treated with a flame retardant.
- 5. Prepare an engineering procedure for perfoming additional Completed Complett fire hazards analysts to reflect future station modifi-citions.
- 6. - Approximately six (6) fire area boundary doors which are Completed ccitplatt not currently locked or alamed will be locked, provided with a time delay alam to indicate in the Control Room--
when the door has been left open, or routinely inspected by a roving watch. This action will take into account.
station security plans currently being studied for the Salem Station.
- 7. Remove the backup hydrogen storage stations from Elev. Completed Compl et 122 feet at the we.t end of the Auxiliary Building, or enclose the present station in a 3-hour fire rated ,,
concrete enclosure with forced ventilation to.the outdoors.
- 8. Add a wet pipe sprinkler system fo'r the Dimethylamine Deleted. Tanks have storage tanks 1ccued in the stear.: generator blowdown been removed.
sample rooms, Elev.100 feet in the Auxiliary Building.
- 9. a. Ionization type fire detectors will be added as indi- Comoleted C:r.oleted cated in Section II-E of this recort to provide general area protection of safety related equipment.
These detecto s will alarm and annunciate in the Control Roem e.m alarm locally.
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28 -
Action
, item Status No.
Planned Action item Oescrittion Unit 1 Unit 2
- 9. b. Installation of additional automatic smoke detectors which alam and annunciate
- in the control room.- in the following areas:
l (1) Peripheral rooms within the control Compl eted Completed 4
room complex in which the operator
- - does-not have visual surveillance from the main console.
-(2) Piping penetration area elevation 78 Compl eted - r.omol eted i feet. --
(3) New and spent fuel pool area. Completed Fuel Loadin i
- 10. Auxiliary Building floor penetrations for piping, cable. Completed Completed and ventilation ducting that have not been sealed will be sealed with silicone foam to provide a fire stop with 2 a fire rating greater than the area fire area load as reported by the fire hazards analysis.
- 11. The. lower electrical penetration area supply and return Completed Completed
- _' air ventilation dampers will be controlled to shut upon '- '
a CO 2 discharge into the lower electrical nenetration
- i. . area l
12.- Add fire rated ventilation damners, which will shut by Completed Completed
! both fusible-link and C0 discharge, in the exhaust air duct from each diese$ fuel oil storage tank room
- and each fuel oil. transfer pump room.-
13 Approximately ten (10) additional emergency lights Completed Completed i will be insta11ad, as required, to provide for safe evacuation from all. areas of the station.
4 l 14.- -Install a hose house at each yard hydrant. Hose Completed Completed J house will meet the requirements _of NFPA Standard t No. 24 except the eouipment stored-in each house a will be that which is necessary and appropriate
'for the intended application.
- 15. One (1) fire hydrant,- presently specified on the Completed Completed Cire protection System drawing, Figure D.1-1, that has not been installed, will be installed.
L16. Add a second 4-inch diameter s:ater sucoly header with Completed Ccmoleted
.a:proorf ate isolation valves from the common Auxiliary
~3uilding Hencer to each lactor Containment upstream of 4.
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29 -
1
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Sta tus item No. Planned- Action Item Descriotion Uni 1 Unit 2
- 16. the Containment penetration isolation valve as shown (con,t'd) schematically in Figure 3.5-2. ,
Add appropriate' 6-inch valves in the Auxiliary Building comon fire , water supply header.
. 17. The hose standpipe root isolation valves and the completed Comp.leted yard main. post indicater valves will be provided with locking devices. ,
- 18. Add one~ hore station in the mechanical penetration Complet.ed Completec area of each unit near the entrance to the Fuel Handling Building. Provide with 150 ft. lengths
- of 1-1/2 inch fire hose and adjustable fog pattern 1 electrical safe type nozzles.
- 19. Extend the existing fire water standpice in the Completed Coqqleted Auxiliary Building corridor to rea:h Elevation 4 . 122 fee +.. Add a hose station at Elevation 122 feet with 150 feet 'of 1-1/2 inch fire hose and an adjustable fog pattern electrical safe type nozzle.
20.
Add a fire hydrant in the yard near the Service Completed Completed Water Pump House.
-- 21. Two (2) dedicated air breathing units (Bio-paes) Completed Completed with two (2) spare cylinders will be stored at the Reactor Containment entrance for each unit on Elevation 100 feet in the Mechanical Penetration Area. . Thi: will be accomplished by relocating four (4) of the t 'enty (20) units presently avail-able at the station.
- 22. In addition to existing CO2 type extinguishers, two 1/80 1/80 portable water extinguishers will be placed in the vicinity of the Control Room, Computer Rooms and the
- Watch Engineer's Office.
4 E
e
- ,_ . ~ Action Status item No, planned Action' Item Descriotion Unit 1 Unit 2 23.: Instrumentation will be provided in the exhaust air Completed Completed ducts from the Battery Rooms'to indicate loss of ventilation flow with annunciation in the Control Room.-
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-24. Add dikes around each emergency air compressor and Completed Completed each chil'aed water system chiller to contain the -'
spread of lube oil leakagt.
- 25. Provide manually operated isolation. dampers in the 7. apleted Completed supply air and returm air ventilation ducts serving l
the Druming and Baling Area to pemit area isola- -
tien from the remainder of the Auxiliary Building ventilation systems.
- 26. . Implementation of staff supplemental guidance contained in " Nuclear Plant Fire prettetion Functional Responsi-bilities. Administrative Controls, and Quality Assurance," dated June 14, 1977 for:
-, a.- Administrative Procedures, Fire Completed Completed Brigade Size, and Testing Program
- b. Storage of Combustible Material Completed Comnieted near Safety Related Conduit / Cable or Equipment.
- 27. Installation of a portable radio system Second refueling First refuel incorporating repeaters as necessary for_ the fire brigade and operations personnel. Preoperational testing will be performed to demonstrate that the frequencies used'will not affect the '
actuation of protective relays. Fixed repeaters installed to permit use of the portable radios will be protected from exposure , fire damage.
.o
Action item No. Planned Action Item Description Unit 1 Unit 2
- 28. a. Verification that all fire doors used Compl eted Completed to protect openings in walls con-taining safety-related equipment and/or conduit / cable have a fire rating .
of at least 1-1/2 hours and that the rating is commensurate with the fire hazards analysis for the area assuming an exposure fire. .
- b. Installation of fire doors' as a result 1./80 12/79 of 2Ba above. '
- 29. a. Install in all 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire barrier Engineering Solution comoleted October 197 ventilation penetrations one of the R following designs: Implementation by Second refueling First refueling (1) Rated fire door / dampers in all ventilation penetrations .
(2) 1-1/2 hour fire retardant coatings on the duct work plus fire dampers at all louvers. t The NRC will review the design prior to installation. In addi-tion the following areas will be .
modified to conform to this position:
- 1. Control Room Same as above 1
- 2. Relay Room Same as above l
- 3. Switchgear Rooms 10/80 10/80
- 4. Diesel Fuel Oil Storage End of first Fuel loading Area-Inlet and Exhausts refueling
- 5. Fuel Oil Transfer Pump End of first Fuel loading Room Inlet and Exhausts refueling
- 6. Radwaste Area (Drumming and 10/80 10/80 Bailing Area) .
(covered under Item 25) l
- 30. Installation of fixed 8-hour capacity -
Completed comoleted self-contained emergency lighting of the flourescent or sealed beam type.
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- - 32 -
. Action Item flo. - -
Planned Action item Description Unit 1 Unit 2 l
- 31. Installation of an outs'ide hydeant Completed Ccmpl eted for back up fire suppression for '
the service water pump house with
- a hose house over the hydrant and 1 1/2 inch hose preconnected to the hydrant outlet. Also, pmvisions for a second hose of sufficient length to er.able the second hose stream from the -
hydrant in the event that'the second hose must be routed differently and when more than one hose stream is needed to fight
. the fire. -
- 32. Installation of automatic, zoned,
, pre-action, dry pipe sprinklers in following areas:
a harging Pump Area Second refueling First refueli
- b. suxiita./ Feed Pump Area Second refueling First refueli
~
3
- 33. Instal 1ation of an automatjc Halon total Second refueling f[oirdinfiystein"in ~the"rel'a,y ro5ms. First refueli 34' Installation of additional hose stations Completed Completed near the battery rooms so that the rooms .
can be reached with a maximum of 100 feet of hose. In addition the hoses will be
. equipped with the aooropriate nozzles to combat electrical fires.
- 35. The total rerouting of the hydrogen lines - Completed Completed to the volume control tank away from safety related equipment, cables, and conduit.
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9 4
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. 33 Action Item flo. Planned Action item Description Unit 1 Unit 2
^
36' Installation of one of the following fire 10/80 First refueli':
suppression systems as back up to the -
automatic total flooding CO2 system for the diesel oil storage tank rooms,
- a. An automatic open head deluge or open head spray nozzle system.
~
- b. An automatic closed head [sprinklari ,
- c. An automatic AFFF syttem. the foam being delivered by a sprinkler or -
spray system.
- 37. Implementation, modification and installa-tion of an alternative shutdown caphbility Impisnentation by:
so that hot shutdown capability can be maintained and cold shutdown can be accom- Second refueling First refueli plished wi'lin 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> independent of the relay, rwitchgear and control rooms. This will include the rerouting of cables where .
practicable, installation of automatic sprinklers and half-hour fire barriers between redundant trains and equipment located within 20 feet of each other and written procedures.
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. 34 Environmental Consideration We have determined that the amendment does not authorize a change in effluent types or total amounts nor an increase in power level and will not result in any significant environmental impact. Having made this determination, we have further concluded that the amendment involves an action which is insignificant from the standpoint of environmental
" impact and, pursuant to 10 CFR 551.5(d)(4), that an environmental impact statement or negative declaration and environmental impact appraisal need not be prepared in connection with the issuance of this amendment.
Conclusions -
' We have found that the Fire' Protection Program for the S&lem Nuclear Generating Station with the improvements already made by the licensee, .
is adequate at the present time and, with scheduled modifications, will meet the guidelines contained in Appendix A to Branch Technical Position ASB 9.5-1 and meets the General Design Criterion 3 and is, therefore acceptable.
We have concluded, based on the considerations discussed above, that:
(1) because the amendment does not involve a significant increase in the probability or consequences of accidents previously considered and does not involve a significant hazards consideration, (2) there is reasonable assurance that the health and safety of thi public will not be endangered by operation in the proposed manner, and (3) such activities will be conducted in compliance with the Commission's regu-lations and the issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public.
Da te: November 20, 1979 4
l i c 4
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1 7590-01 SN!YL'DSTATESNUCLEARREGULATORYCOMMISSION DOCKET NO. 50-272 PUBLIC SERVICE ELECTRIC AND GAS COMPANY.
PHILADELPHI A ELECTRIC COMPANY.
DELMARVA POWER AND LIGHT COMPANY. AND ATLANTIC CITY ELECTRIC COMPANY NOTICE OF ISSUANCE OF AMENDMENT TO FACILITY OPERATING LICENSE 1
The U. S. Nuclear Regulatory Commission (the Commission) has '
issued Amend' ment No. 21 to Facility Operating License No. DPR-70, issued to Public Service Electric and Gas Company, Philadelphia Electric Company Delmarva Power and Light Company and Atlantic City Electric 1 Company (the licensees), which revised Technical Specifications for operation of the Salem Nuclear Generating Station, Unit No.1 (the facility) located in Salem County, New Jersey. The amendment will become effective twenty days from the date of publication of this notice of issuance unless a hearing has been requested.
The amendment adds a license cordition pertaining to the completion of facility modifications to improve the fire protection program.
The application for the amendment complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations. The Commission has made appropriate findings as required by the Act and the Commission's rules and regulations in 10 CFR Chapter I, which are set forth in the the license amendment. Prior public notice of this amendment was not required since the amendment does not involve a significant hazards consideration.
- e e *
- s 7590-01 1 -2 l
The Commission has detertnined that the issuance of this amendment will not result in any significant environmental impact and that pursuant to 10 CFR 151.5(d)(4) an environmental impact statement or negative declaration and environmental impact appraisal need not be prepared in connection with issua,nce of this amendment.
For further details with respect to this action, see (1) the licensee's submittals dated September 14, 1977, December 19,1977. July 19, 1978. July 26,1978 September 8,1978. September 21, 1978 February 15, 1979, March 2,1979 and November 5,1979,(2) Amendment No. 21 to License No. DPR-70, and (3) the Comission's related Safety Evaluation.
All of these items are available for public nspection at the Commission's Public Document Room,1717 H Street, N.W., Washington, D. C. and at the Salem Free Public Library,112 West Broadway, Salem, New Jersey. A copy of items (2) and (3) may be obtained upon request addressed to the U. S. Nuclear Regulatory Comission. Washington, D. C. 20555, Attention:
Director, Division of Operating Reactors.
Dated at Bethesda, Maryland, this 20th day of November,1979.
FOR THE NUCLEAR REG l'LATORY COMMIS$10N
/
, )HM &
A. Schwencer, Chief Operating Reactors Branch #1 Division of Operating Reactors a
p maaou p* lt UNITED STATES s*
2
} NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 30eu4001
\, .. ... /
NRC INSPECTION MANUAL SPLB INSPEU10N PROCEDURE 64704 FIRE PROTECTION PROGRAM PROGRAM APPLICABILITY: 2513, 2515 SALP FUNCTIONAL AREA: PLANT SUPPORT (PLTSUP) 64704 01 INSPECTION OBJECTIVES 01.01 Evaluate the overall adequacy and implementation of the licensee's approved Fire Protection Program with the exception of the requirements specified in 10 CFR 50, Appendix R. Sections !!!. G. J L. and 0.
01.02 Review the procedural incorporation and implementation of any changes permitted or required by the NRC in the Fire Protection Program.
01.03 Determine the adequacy of the licensee's system for conducting program-matic changes necessitated by quality assurance (0A) audit results, generic deficiencies, or licensee events.
64704 02 INSPECTION REQUIREMENTS 02.01 Obtain and review the documentation constituting the licensee's approved Fire Protection Program.
02.02 Verify that the licensee has developed technically adequate procedures to implement the entire Fire Protection Program. At a minimum, review the procedural guidance providtd for the following items:
- a. Combustible Material Control / Fire Hazard Reduction
- 1. Combustibles in safety-related and adjacent plant areas.
- 2. Bulk flar.nable and combustible liquids and gases storage.
- 3. Hydrogen lines in safety areas.
- 4. Plastics.
- 5. Anti-contamination clothing and shelving.
- 6. Wood.
Issue Date: 09/08/97 64704 DeJ1arounJ2
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- b. Housekeeoina l 1. Control of combustible waste products.
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- 2. Storage of radioactive materials.
- 3. Control of hazardous chemicals.
- 4. Control of smoking.
- c. Administration / Fire Control Cacabilities
- 1. Disarmed or inoperable fire detection or suppression systems.
- 2. . Maintenance and surveillances on fire suppression, detection, and emergency comunications equipment.
- 3. Site personnel fire fighting training.
- 4. Site personnel fire fighting qualifications.-
- 5. Onsite fire protection staff responsibilities.
- 6. Fire emergency plans and actions.
- 7. Fire / emergency personnel designations.
- d. Fire Risk Maintenance Evolutions
- 1. Welding, cutting and/or grinding.
- 2. Temporary heat processes.
- 3. Coating and roofing materials.
- 4. l.eak testing.
02.03 Evaluate the implementation of the guidelines provided for the following items in the licensee's Fire Protection Program:
- a. Items listed in 02.02 above,
- b. Ventilation,
- c. Emergency communications.
02.04 Verify the proper installation, operability, and maintenance of fire protection systems and equipt.ent through performing the following actions:
- a. Walk down the fire suppression water system to verify system operability as required by the Technical Specifications (TS).
- b. Walk down at least two of the following fire suppression systems to ensure operability-as defined in the TS:
- 1. Any sprinkler / spray system.
- 2. High/ low pressure CO, system, 64704 - 2.- Issue Date
- 09/08/97
- 3. Halon system,
- c. Tour the plant to verify that the following fire protection requirements
, are being met:
- 1. Standpipe and hose stations are operable in all areas important to safety.
- 2. Adequate portable fire extinguishers are provided at designated i
places in each fire zone.
- 3. Access to fire suppression devices is not being restricted by any materials or equipment.
l 4. Inspections and maintenance on all fire suppression equipment or l devices were satisfactorily performed.
- 5. The general condition of all fire suppression devices is satisfactory (e.g., pressure gauges read in the acceptable range, water extin-i
' guishers are filled, nozzles are clear as indicated by visual inspection).
- d. Evaluate the licensee's criteria for determining fire barrier functional-ity with respect to requirements and licensee commitments.
- e. Inspect the fire barriers between selected plant fire areas and ensure that the following fire barrier components are functional:
- 1. Fire barrier penetration seals (review licensee resolution of concerns identified in IN 88 04 " Inadequate Qualification and Documentation of Fire Barrier Penetration Seals;" IN 88 04 Supplement 1: IN 88 56. " Potential Problems with Silicone Foam Fire Barrier Penetration Seals:" and IN 94 28 " Potential Problems with Fire Barrier Penetration Seals").
- 2. Fire doors.
- 3. Fire dampers (review licensee resolution of concerns s 89 52, " Potential Fire Damper Operational Problems").pecified in IN
- 4. Fire coatings for structural steel (ensure the coating provides a fire resistance equivalent to the fire barrier rating).
Verify that the components are not damaged, degraded or missing, and that the licensee has fire test results, evaluations, or other suitable documentation (e.g. , Underwriter Laboratory listings), that establish that the as-installed barriers are comparable to or bounded by the fire tested configurations or have the required fire resistance rating.
Verify that the licensee has: administrative procedures which ensure fire barrier configuration control; a surveillance program which confirms important barrier attributes: clear and logical fire barrier operability criteria which result in the prompt establishment of appropriate compensatory measures, when needed: and appropriate installation, maintenance, and repair procedures.
Issue Date:- 09/08/97 64704 1
I
- f. Visually inspect selected cable / raceway fire wraps. Ensure that the added weight of the fire barrier system has been accounted for in the licensee's raceway seismic analyses.
Verify that the fire wraps are not damaged, degraded or missing, and that the licensee has fire test results and evaluations that establish that the as-installed fire wraps are comparable to or bounded by the fire tested configurations.
Verify that the licensee has: administrative procedures which ensure fire wrap configuration control; a surveillance program which confirms important wrap attributes: clear and logical fire wrap operability criteria which result in the prompt establishment of appropriate compensatory measures, when needed: and appropriate installation, maintenance, and repair procedures.
- g. Review the record for surveillances conducted since this inspection procedure was last performed to verify that:
- 1. The fire detection and suppression systems currently meet the TS operability testing requirements.
- 2. Operability for these systems has been satisfactorily demonstrated at the required frequencies.
- h. Ensure that adequate emergency breathing apparatus is operable and available for control room personnel.
- 1. Verify that the fire alarm and supervisory signaling systems have been tested and are operable in compliance with licensee commitments.
02.05 Evaluate the readiness of the licensee's personnel to prevent and fight fires, including the following aspects:
- a. Fire Briaade Readiness
- 1. Brigade composition.
- 2. Qualifications.
- 3. Training.
- 4. Manual firefighting ecuipment and turnout protective clothing availability and operab'lity,
- b. Fire WatcMs. Interview three people who stand fire watch and evaluate their knowledge of their duties, responsibilities, and required actions,
- c. Other Personnel
- 1. Randomly interview at least five licensee >ersonnel to evaluate their understanding and knowledge of the Fire )rotection Program.
- 2. Assess the quality of fire protection / prevention training provided at the licensee's site indoctrination to verify compliance with requirements.
64704 Issue Date: 09/08/97
7 02.06 Review the adequacy and implementation of the 0A program for fire protection with respect to the following:
- a. Management inspections,
- b. Fire prevention / protection audits.
- c. Addressing and correcting all fire protection discrepancies.
- d. Reviews for fire protection generic applicability.
- e. Fire Protection Program shanges.
- f. System / equipment alterations.
- g. Tests, surveillances, and maintenance reviews.
- h. Records.
02.07 Effectiveness of Licensee Controls
- a. Evaluate the effectiveness of the licensee's controls in identifying, resolving. and preventing problems by reviewing such areas as corrective action systems. root cause analysis. afety committees. and self assessment in the area of fire protectioa.
- b. Determine whether there are strengths or weaknesses in the licensee's controls for the identification and resolution of the reviewed issues that could enhance or degrade plant operations or safety.
64704-03 INSPECTION GUIDANCE General Guidance
- a. The Fire Protection Program is designed to give defense-in depth against fires. This procedure is to be utilized to evaluate the following aspects of this defense:
- 1. Preventing fires and their spread.
- 2. Detection and suppression of fires.
- 3. Hitigation of fire damage.
- b. Evaluate the licensee's procedures for and implementation ci the Fire Protection Program. An evaluation of the adequacy of the plan itself is not necessary as this has previously been performed by NRR durin licensing process and any further changes in the plant modifications impacting fire protection or prevention) are subject to NRR plan (
approval,
- c. Specific inspection requirements will vary depending upon the comitments made in the licensee's Fire Protection Program. This procedure has been written to incorporate the most recent guidance provided in 10 CFR 50.
Appendix R: NFPA 8031983: and BTP CMEB 9.5-1 to ensure satisfactory fire orotection and prevention. A review of the licensee's program should Indicate to the inspector which inspection requirements are applicable.
Issue Date: 09/08/97 64704
- d. The initial performance of this procedure includes all of the aforemen-tioned inspection requirements. All followina insoections need not include insoection reauirements 02.0L or 02.02, as it is not necessary to re evaluate the Fire Protection Program and its procedures. Rather, an evaluation of all programatic and procedural changes made since the last inspection should suffice. ,
Soecific Guidance :
03.01 Insoectio1 Recuirement 02.01. The licensee's fire Protection Program consists of the :1re Hazard Analysis, the facility's Technical Specifications, and possibly,dition.the a license con NRR Fire Protection Safety Evaluation Report if included as 03.02.a.1 Insoection Reauirement 02.02.a.1
- 1. Are safety related systems isolated or separated from combustible materials? No combustibles are permanently permitted in safety areas unless they are an integral part of tne system (e.g., cable insulation on exposed cables, reactor coolant pump lube oil or emergency diesel generator fuel oil) or are controlled in quantity to previously analyzed levels.
- 2. Are flamable and combustible liquids inside of structures limited in quantity to the minimum amounts necessary to meet the requirements of one shift's operations?
- 3. Are safety cans used to store and dispense flamable liquids used inside buildings or structures?
- 4. Is ventilation for operations involving the use of flamable or combustible liquids or of materials in solution with these liquids (e.g., paints) provided?
03.02.a.2 Insoection Reauirement 02.02.a.2
- 1. Bulk gas storage is not permitted in areas associated with or structures housing safety-related equipment, except as analyzed and determined to be acceptable.
~ 2. Bulk storage of flammable or combustible liquids or gases must be at least 50 feet from any permanent building or structure.
- 3. Closed containers shall be used for the storage and handling of flamable liquids.
03.02.a.3 11soection Reauirement 02.02.a.3. Hydrogen lines in s6fety areas s1all be seismic Class I. sleeved to vent directly outside in case of a break, or ecuipped with excess flow valves so that hydrogen concentration wil' not exceed 2% in the affected area.
03.02.a.4 Insoection Reauirement 02.02.a.4. Use of plastics is to be minimized. Polyvinyl chloride, neoprene, and any other halogenated plastics are to be used only when the use of non-combustible materials is not feasible and is at locations totally inaccessible to ignition or the effects of fire exposure.
64704 Issue Date: 09/08/97
03.02.a.5 11soection Reauirement 02.02.a.5. Anti-contamination clothing and sielving aresent the dual hazards of combustibles in safety-related l
areas anc the 30tential for low level radiological fires if the clothing'is con';aminated. These concerns shall be addressed in the licensee s Fire Protection Program.
03.02.a.6 Insoection Reauirewnt 02.02.a.6. The use of combustible scaffold-ing, shoring, and forms within a structure greatly increase the fire l
hazard due to the nature of these materials and the constrLetion or
! maintenance activities associated with their use. All combustible wood in any form is prohibited from use in safety-related areas, i Only fire retardant treated wood (or non combustible metals) may be I
used for scaffolding shorin , or other forms required for mainte-nance or construction activi ies.
03.02.b.1 Insoection Reauirement 02.02.b.1. Are transient fire loads asso-ciated with plant maintenance, modifications, or construction activities in safety related buildings controlled by the licensee's Fire Protection Program?
03.02.b.2 Insoection Reauirement 02.02.b.2 Are radioactive materials stored in closed metal tanks or containers and shall be in areas free from any ignition sources (including smoking) or combustibles?
03.02.b.3 Insoection Reatirement 02.02.b.3. Chemicals pose the threat of an increased fire lazard due to the potentially flammable and explosive natures of these substances, as well as the potential for the release of toxic or noxious byproducts of combustion, and so, are they_
p handled appropriately?
03.02.b.4 Insoection Reauirement 02.02.b.4 Is smoking prohibited at or in the vicinity of hazardous operations or mater'als? Also, are "No Smoking" signs posted per <;he licenwe's commitments in safety relat-ed areas or in areas that would e at a threat to safety-related areas?
03.02.c.1 Insoection Reauirement 02.02.c.1. Inoperability of fire detection or suppression systems requires that TS action statements be performed. In addition, are alternate fire protection developed when any of these systems are removed from service? plans 03.02.c.2 Insoection Reauirement 02.02.c.2. Are maintenance and surveillance programs and procedures established which meet the requirements of ,
the TS. the vendor technical manuals, and any other applicable licensee commitments?
03.02.c.3 Insoection Reauirement 02.02.c.3. Does site-wide training provide instruction on site and contractor personnel re discovering a fire or hearing the fire alarm, quirements and when upon using combustibles, the requirements governing the use of materials and the actions necessary in the event of a combustible liquid spill or gas release / leaks?
03.02.c.4 Insoection Reauirement 02.02.c.4
- 1. Do fire watch qualifications include hands-on training on a practice fire with the extinguishing equipment to be used while on fire watch?
Issue Date: 09/08/97 64704
- 2. Are control room personnel proficient in the use of the provided form of emergency air breathing apparatus?
- 3. Is the Fire Protection Program engineer qualified as a result of having a degree in an engineering curriculum of accepted standing with not less than 6 years of engineering attainment indicative of growth in engineering competency and achievement 3 years of which shall have been in responsible charge of fire protection engineering work?
- 4. (a) Formulation and assurance. of the Fire Protection Program'c implementation may be delegated to a staff composed of personnel with knowledge of and experience in nuclear plant safety,
~i (b) Are staff personnel assigned collateral duties or assignments that would significantly distract from their fire protection duties?
(c) Is the staff responsible for the following:
(1) Training of site and contractor personnel and fire drills implementation and critiques.
(2) Reviewing all proposed' maintenance, modifications, or
! construction activities to ensure that adequate fire i
protection considerations are included in the proposed Work.
(3) Implementing periodic inspections of the plant for ;
compliance with all fire protection requirements, includ-ing combustible material control, fire detection and suppression equipment and barrier operability, and ;
emergency lighting and safe shutdown capabilities. '
03.02.c.5 Insoection Reauirement 02.02.c.5 a
, 1. All personnel designated to take actions for fire emergencies should be trained in these actions and in the overall emergency plan.
- 2. Strategies for fire fighting in all safety-related areas and areas in which a fire would present a hazard to safety-related equipment should be developed and made available at the scene.
, 03.02.c.6 Insoection Reauirement 02.02.c.6
- 1. Are personnel who are to react as either members of the fire brigade or as members of the emergency event teams for site fires designated in writing by the licensee?
- 2. Do fire brigade or emergency response team members have any duties that would conflict with their brigade or. team responsibilities?
Assignment to both the fire brigade and an emergency response team is prohibited. Do they remain mutually exclusive?
03.02.c,7 Insoection Reauirement 02.02.c.7. No specific inspection guidance provided.
64704 -
8- Issue Date: 09/08/97 n- t-, --
-.--,_.,,.-mm , -- y
l 03.02.d.1 Insoection Reauirement 02.02.d.1. Are cutting and welding operations in progress authorizec by an appropriate permit? Ensure that combustibles have been moved at least 35 feet away from such ,
operations or are properly covered. Is a fire watch with an extinguisher posted for the duration of the work and for 30 minutes thereafter to ensure that sparks or drops of hot metal do not start fires? If cutting or welding on a wall, floor, or ceilin ,
- watch stationed at the opposite side of the partition? g, is a fire Additional fire watches may be required during cutting and welding operations where sparks or molten metal may drop several floors to areas containing significant quantities of combustible materials.
NFPA 518. Cutting and Welding Processes. includes provisions for safeguardin ,
operation.e.g the hazards associated with welding and cutting y 03.02.d.2 Insoection Reauirement 02.02.d.2. Are heating devices placed so as to avoid overturning and/or installed in accordance with their listing including clearance to combustible material, equipment, or construction?
03.02.d.3 : nsoection Reauirement 02.02.d.3 Are asphalt and tar kettles
'ocated in a safe place or on a fire resistive roof at a point where
, they avoid ignition of combustible material below. Is continuous
' supervision maintained while kettles are in operation and metal kettle covers and fire extinguishers should be provided?
03.02.d 4 Insoection Recuirement 02.02.d.4. Are leak testing procedures utilizing airf'ow determinations or similar methods performed using one of the commercially available technicues? Open flame or combustion generated smoke tests should not >e permitted.
03.03.a Insoection Reauirement 02.03.a. No specific inspection guidance
- provided.
03.03.b Insoection Reauirement 02.03.b i
- 1. Separation of the smoke ventilation system from the normal ventila-tion system is the preferred configuration, but the normal system may be utilized if there exist automatic or manually controlled dampers to isolate the normal ventilation in case of fire. However, separate smoke and heat vents are required in areas where the potential exists for heavy smoke conditions (e.g., cable spreading rooms or diesel fuel oil storage areas).
- 2. Is the fresh air supply intakes to areas containing safety related equipment located remotely from smoke and heat vents?
- 3. Smoke ventilation from areas.that may contain radioactive substances should not be ventilated outside the building, but rather. should be vented to gas treatment facilities.
- 4. Are enclosed stairwells designed to minimize smoke infiltration?
- 5. No plastic ventilation ducting is permitted.
- 6. Are fire areas separated in the ventilation system through sectioning off and through the use of fire dampers?
Issue Date: 09/08/97 64704
03.03.c Insoection Reauirement 02.03.c. Are portable radio comunications or fixed emergency communications systems available and operable?
03.04.a Insoection Reauirement 02.04.a. At a minimum, during this walkdown include an eva'uation of the operability and material condition of the fire suppression water su) ply system including a check that the system has two separate fire f' ghting water supplies, each including:
- 1. A water storage tank with a volume of water adequate to supply at i
l maximum demand for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> (separate redundant suctions in one or more intake structures from a large body of water are sufficient).
- 2. Controls to ensure the continuance of at least the minimum water volume required (administrative controls. including locks for tank outlet valves are unacceptable as the only method of control).
- 3. Fire pumps.
- 4. Supply valves aligned and controlled by locks or electrical supervision devices with audible signals to ensure the continuance of the water supply to all portions of the fire suppression system.
(a) Fire suppression system sectional isolation valves (e.g., post indicator valves) shall be in their normally re except as needed for maintenance or repairs. quired positions (b)
Outside hydrants, water shall be adequately storabe protected tanksand y isolation indicator valves valves.
- 5. Adequate protection of suppression equipment to ensure that it would not be susceptible to freezing due to cold weather.
03.04.b Insoection Reauirement 02.04.b. No specific inspection guidance provided.
03.04.c.1 Insoection Reauirement 02.04.c.1
- 1. Are standpipes and hose stations placed such that at least one effective hose stream will be able to reach any location that contains or presents an exposure to fire hazard to structures, systems, or components important to sefety?
- 2. Are standpipes and hose stations also appropriately placed inside PWR and non inerted BWR containments.
03.04.c.2-3 Insoection Reauirements 02.04.c.2-3. No specific inspection guidance provided.
03.04.c,4 Insoection Reauirement OLOLcA. Are inspections conducted at least monthly and maintenance performed annually, or as specifically re +ed as an inspection result. Detailed guidance for the reqtitrad ine . iion and maintenance procedures for all equipment may be fou..J in usciated NFPA standards.
03.04.c.5 Insoection Reauirement 02.04.c.5. No specific inspection 9.lidance provided.
64704 Issue Date: 09/08/97 L
1 03.04.d Insoection Reauirement 02.02 d. No specific inspection guidance provided.
03.04.e Insoection Reauirement 02.04.e. No specific inspection guidance provided.
03.04.f Insoection Reauirement 02.04.f
- 1. Are cable trays constructed of metal with thick walled tubing used for conduits. Thin, flexible metallic tubing should be used only in short lengths to connect com)onents to equipment. Thin walled metal tubing should not be used a", all.
- 2. Do cables have automatic fire suppression wetting down systems or be accessible to manual hose standpipe systems?
- 3. Are cables designed and maintained to permit wetting down by fire suppression systems without electrical faulting?
- 4. Are cable raceways used only for cables?
03.04.9 Insoection Reauirement 02.04.a. No specific inspection guidance provided.
03.04.h Insoection Reauirement 02.04.h
- 1. Control room emergency breathing apparatus can be in the form of either self contained, full face, positive pressure masks a) proved by the National Institute for Occupational Safety and Healt1 or of an air manifold piped in from a reservoir. If using self-contained units. the operating life should be at least one half an hour with two additional air bottles provided for each unit. In addition, on site recharging facilities shall be available with a six hour reserve air supply.
- 2. Do air manifolds have an uninterrupted air supply with enough masks available to outfit all required control room personnel?
- 3. Are air bottles fully charged with their last inspections having been performed within the required time period?
03.04.1 Insoection Reauirement 02.04.1 No specific inspection guidance provided.
03.05.a.1 Insoection Reauirement 02.05.JLl. Does each shift have a fire brigade of at least five members from the shift brigade? The brigide leader and two other members should have sufficient training or knowledge of plant safety-related systems to understand the effects of fire and fire suppressants on the safe shutdown capability. The shift supervisor cannot be a member of the brigade.
03.05.a.2 Insoection ReaJirement 02.05.a.2. Do all brigade personnel have annual physical examinations?
03.05.a.3 Insoection Reauirement 02.05.a.3
- 1. Training shall consist of classroom instruction, fire fighting practice, and drills as described in Appendix R.Section I.
Issue Date: 09/08/97 64704
- 2. Attempt to schedule this inspection so as to be able to observe and evaluate either a fire drill or a practice session.
03.05.a.4 Insoection Reauirement 02.05.a.4. Manual firefighting equipment and turnout clothing should meet the minimum specifications provided by NFPA 803-1983.
03.06.a Insoection Reauirement 02.06.a
- 1. Does the plant manager or his designated fire protection manager periodically inspect the plant using prepared checklists. Areas of primary containment or of high radiation normally inaccessible during plant operations should be inspected as conditions permit, but at a minimum, during each refueling outage.
- 2. Does the fire protection manager conduct weekly walk through inspections to ensure implementation of recuired controls? During major maintenance periods the frequency of taese walkthroughs should increase to daily.
03.06.b Insoection Reauirement 02.06.b. The following are the three fire protection audits required by TS:
- 1. An annual audit to be conducted by an offsite fire protection specialist on the licensee's corporate staff or a consultant.
- 2. A 24 month audit by the licensee's OA organization.
- 3. A 3 year independent audit to be conducted by a consulting fire protection firm.
03.06.c Insoection Reauirement 02.06.c. Does the onsite review committee address and recomend corrective action for all fire protection discrepancies. Are recommendations made reviewed by the offsite review comittee, which either concurs with or disapproves the recomended procedural changes.
03.06.d Insoection Reauirement 02.06.d. All events related to fire protection onsite (or those occurring at other facilities, if the information is made available to the utility) should be reviewed by the Fire Protection Program manager and the onsite review committee for generic applicability to the overall site Fire Protection Program.
03.06.e Insoection Reauirement 02.06.e
- 1. Are all Fire Protection Plan changes or recommended changes evaluated for their impact on fire safety and submitted to NRR for approval?
- 2. Are systems established to permit programmatic changes and to implement them once approved?
03.06.f Insoection Reauirement 02.06.f. Have adequate methods to evaluate system / equipment alterations been established to ensure that these changes do not circumvent the fire )revention or suppression systems or create a greater chance of fire camage to safety or safety-related areas?
64704 Issue Date: 09/08/97
l l 03.06.g Insoection Reauirement 02.06.0 Are guidelines provided to ensure I
a proper management review of all tests, surveillances, and maintenance conducted on the fire protection systems?
03.06.h Insoection Reauirement 02.06.h. Are records prepared and maintained to provide evicence that the Fire Protection Plan criteria are being l
met? Are these being retained for a minimum of 5 years as required by TS?
l 03.07.a Ins >ection Reauirement 02.07.a . When safety issues. events, or pro)lems are reviewed, the acequacy of the results of licensee 1 controls may be assessed by determining how effective the licensee !
was in performing the following:
- 1. Initial identification of the problem. !
- 2. Elevation of problems to the ) roper leve'. of mana resolution (internal communica;1ons and procedures)gement for
- 3. Root cause analysis.
- 4. Disposition of any operability issues.
- 5. Implementation of corrective actions,
- 6. Expansion of the scope of corrective actions to include
, applicable related systems, equipment, procedures, and personnel
! actions.
! 03.07.b Insoection Reauirement 02.07.b. The determination of whether there are strengths or weaknesses in the licensee's controls .will be limited to those issues, events, or problems reviewed in detail. The evaluation will not draw sweeping conclusions about the licensee's overall control programs, but will be very specific in identifying any licensee strengt1s or weaknesses encountered with the indtvidual items reviewed.-
l Note: For additional guidance on licensee controls, please refer to IP 40500, i l " Effectiveness of Licensee Controls in Identifying, Resolving, and i j Preventing Problems." ,
t 64704 04 INSPECTION RESOURCES !
2' Completion of this inspection procedure is expected to take, on the average, 25 hours2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br /> of direct inspection effort at.a site. '
l
__64704-05 REFERENCES
, 10 CFR 50.48. !
10 CFR 50 Appendix A. Criterion 3.
10 CFR 50,. Appendix R.
~
Facility Fire Hazard Analysis Report.
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Issue Date: 09/08/97 13 - 64704 l
Facility Technical Specifications.
NRC Appendix A to Branch Technical Position BTP 9.51, " Fire Protection Program."
NRC Branch Technical Position BTP CMEB 9.5.-1, " Fire Protection Program."
NRR Fire Protection Safety Evaluation Report.
NUREG 0800 Section Program," July 1981. 9.5.1. Rev. 3. " Standard Review Plan - Fire Protection Regulatory Guide 1.39, " Housekeeping Requirements for Water-Cooled Nuclear Power Plants."
Regulatory Guide 1.120, " Fire Protection Guidelines for Nuclear Power Plants."
SAR, Chapters 3, 9, and 17.
The following National Fire Protection Association (NFPA) Standards:
l NFPA 10 1984, " Standard for Portable Fire Extinguishers."
NFPA 14-1983, " Standard for the Installation of Standpipe and Hose Systems."
NFPA 51B 1984, " Standard for Fire Prevention in Use of Cutting and Welding Processes."
NFPA 72D 1979.
- Standard for the Installation, Maintenance and Use of Proprietary Protective Signaling Systems."
NFPA 8031983. " Standard for Fire Protection for Light Water Nuclear Power Plants."
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{ END 64704 Issue Date: 09/08/97
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