ML20235A889
| ML20235A889 | |
| Person / Time | |
|---|---|
| Issue date: | 07/14/1988 |
| From: | Sniezek J Office of Nuclear Reactor Regulation |
| To: | Jordan E Committee To Review Generic Requirements |
| Shared Package | |
| ML19318E953 | List: |
| References | |
| GL-86-10, TAC-64655, NUDOCS 8808120275 | |
| Download: ML20235A889 (8) | |
Text
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JUL 141988 MEMORANDUM FOR: Edward L. Jordan, Chainnan Comittee to Review Generic Requirements FROM: James H. Sniezek, Deputy Director Office of Nuclear Reactor Regulation
SUBJECT:
LINE ITEM TECHNICAL SPECIFICATION IMPROVEMENT - REMOVAL OF FIRE PROTECTION REQUIREMENTS FROM TECHNICAL SPECIFICATIONS i
The staff met with CRGR on June 21, 1988 to review the proposed Generic Letter on the renoval of fire protection requirements from Technical Specifications (TS)
CRGR reconnended two changes to the proposed Generic Letter: (1) the relocation of the fire brigade staffing requirements from the TS to the Fire Protection Progran and (2) the retention in T5 of the requirement (via TS 3.0.3) to shut-down when the primary and backup sources of water for the Fire Suppression Water System are lost for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The enclosed proposed Generic Letter has been marked up to incorporate the first change recommended by CRGR.
The second change recommended by CRGR was, at least in part, based on NRR's statements at the meeting regarding the shutdown requirement. The NRR staff said that no circumstances could be imagined under which the shutdown require-ment could be amended without adversely affecting the ability to achieve and maintain safe shutdown in the event of a fire. We have reexamined our state-ments and CRGR's recommendation. We have now concluded that there may be some circumstances under which the shutdown requirement could be changed under the standard license condition, but only if extraordinary compensatory measures were implemented. The enclosed Generic Letter now reflects this revised post-tion and includes the appropriate cautionary guidance. With this guidance, we believe that we can rely on licensees to make appropriate judgments on the shutdown requirement using the standard license condition.
Therefore, NRR concludes that the shutdown requirement should be moved to the Fire Protection Program. The shutdown requirement would be enforceable under the license condition. Relocating the shutdown requirement would make this Generic Letter more consistent with the Comission's original position in Generic Letter 85-10 on relocating fire protection requirements out of TS. I In addition to the changes recommended by CRGR, we have clarified the guidance in the Generic letter concerning where the former TS requirements will be re-located. The revision states that these requirements shall be incorporated into the Fire Prctection Program, not just the implementing procedures. This g)g SO 9M 4 %
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d E. L. Jordan ;U'. > , L%
2 revised guidance is consistent with Generic Letter 86-10 and ensures that licensees to willrelocated any of the use the standard license condition test when making changes requirements.
position; it is merely a clarification. This is not a change in the staff's We believe the enclosed pmposed Generic Letter meets the intent and spirit of CRGR's recommendations. There' ore, we propose to issue the Generic letter without further interaction with CRGR. However, we are ready to participate in necessary.
is another review meeting cn this subject if CRGR concludes that such a meeting Original signed by James H. Sniezek James H. Sniezek, Deputy Director
Enclosure:
Office of Nuclear Reactor Regulation ;
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As stated Distribution:
0TSB R/F DOEA R/F Central Files JHSniezek FJMiraglia TTMartin CERossi LShao JRichardson JScinto RFonner SHLewis EJButcher CEMcCracken RLEmch TGDunning DJKubicki MHConran /hAJ68 2/ c o
- SEE PREVIOUS PAGE FOR CONCURRENCE '
- TSB:DOEA:NRR TSB:DOEA NPR C:TJ8 EA:NRR TGDunning:tgd RLEmc
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I TO ALL POWER REACTOR LICENSEES AND APPLICANTS
SUBJECT:
REMOVAL OF FIRE PROTECTION REQUIREMENTS FROM TECHNICAL SPECIFICATIONS (Generic Letter 88_ ) !
Generic Letter 86-10 requested that licensees incorporate the NRC-approved Fire Protection Program in.their Final Safety Analysis Reports. Generic Letter 86-10 encouraged licensees. vpon completion of this program. to apply for an amendment to their operating licenses (1) to replace current license conditions regarding fire protection with a new standars! condition and (2) to remove I unnecessary fire protection Technical Specifications (TS). ;
l ' During the past two years. the staff has gained experien::e with implementation of Generic Letter 86-10 for new operating licenses. In addition. lead-plant proposals for this license change were submitted with the endorsement of the Westinghouse Owners Group and approved for Callaw.ny and Wolf Creek. On the basis of this combined experience, the staff developed the enclosed guidance for the preparation of a license amenenent request to implement Generic and %s. ioH 3 eds. stoff'n3 teq0itt et4&
A conformin ndment would remove fire protection requirements from TS in fourh maj areas: fire detection systems fire suppression systems..and-fire barriers. The existing administrative control requirements related to fire brigades and to fire protection audits would be retained. Additional program-matic requirements have been included in the administrative controls to address the Fire Protection Program consistent with the requirements for other programs.
Licensees and applicants are encouraged to propose changes to TS that are consistent with the guidance provided in the enclosures. Proposed license amendments confoming to this guidance will be expeditiously reviewed by the NRC Project Manager for the facility. Proposed amendnents that deviate from-l this guidance will require a longer, more detailed review. Please contact the Project Manager if you have questions on this matter.
Sincerely.
Frank J. Miraglia Associate Director for Projects Office of Nuclear Reactor Regulation
Enclosures:
As stated
Enc 1csure 1
$a$rg ieyi(e$ent g
s GUIDANCE HR REMOVAL OF FIRE PROTECTION REQUIRDiENTS FROM TECHNICAL SPECIFICATIONS INTRODUCTION ..
This enclosure provides gridance for the preparation of a license amendment request to implement Generic Letter 86-10. Such an amendment (1) institutes the standard license conMtion for a Fire Protection Program (2) removes requirements for fire protection systems from Technical Specifications (TS),
g)# ad '*7 adds administrattue otheEprograms controls istl emented by license toThe condition. TSsubmittal that aremust consistent also with t include the update of the Final Safety Analysis Report (FSAR) to include the Fire Protection Progras if this has not been completed as requested by Generic Letter 86-10.
The staff's intent is ressumending in Generic Letter 86-10 that fire protection requirements be removed from the TS was to further the goal of Technical Spet-ification improvement as delineated in other NRC policy statements. It is not
' the staff's intent to ruhte the level of fire safety.
This guidance was develayed on the basis of the review of lead-plant proposals for Callaway and Mc1f Creet and from staff experience in implementing Generic Letter 86-10 for recent aperating licenses.
DISCUSSION This section addresses the elements a licensee should include in a license amendment request to reasse fire protection requirements from TS.
I First, the NRC-approved Fire Protection Program must be incorporated into the FSAR and submitted with the certification required by 10 CFR 50.71(e)(2), as requested by Generic Letter 86-10. The FSAR update includes the incorporation of the Fire Protection Program, including the fire hazards analysis and major f.Nunitments that fors the basis for the NRC-approved Fire Protection Progras.
This may be accomplished by referencing the documents which define the 11cen-see's Fire Protection Program as identified in the NRC's Safety Evaluation Reports.
The staff does got intend to repeat its review of the approved Fire Protection Program incorporated in the updated FSAR. The staff may audit the updated FSARs to assure that they have incorporated the approved Fire Protection Program. Licensees shenid not use this FSAR incorporation as an opportunity to make changes in the approved Fire Protection Program. Licensees should wait until the standard Mcense condition is in place and then use the I The NRC-approved Fire Protection Program includes the fire protection and post-fire safe shutdown systems necessary to satisfy NRC guidelines and re-quirements; adnimistrative and technical controls; the fire brigade and fire protection related techdcal staff; and other related plant features which have been described by te licensee in the FSAR, fire hazards analysis, respon-ses to staff requests for additional information, comparisons of plant designs to applicable IstC fire protection guidelines and requirements, and descriptions of the methodolog for assuring safe plant shutdown following a fire.
fo(L > r e3 a u . .s ra ,oq procedures descr to the license condition to make any necessary changes in the Fira Protect AMsgram.
Second. the Li tig hedi for Operation (LCO) and Surveillance Require-ments associa d wS fire etion systems, fire suppression systems. end-fire barriers ildte from the TS. An index of these specifications is provided in E)simere 2. The existing a kinistrative controls related to Se protection audits are to be retained in TS. Also, any p>istif to there capability for safe shutdown following a fire.
specifications e.g.. see Itas SW h Enclosure 1 to Generic Letter 81-12. are to be retai_ned -
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st ff' Third, all operstimul conditions, remedial ac ons, anc M m, .e3 .n /eMse *fre oneQ >
presently includiet the 15 for these systems shall be incorporated into the 1 Fire Protection FrwsW: :7 tin ;r:: d: - In this manner, the former TS l
requirements will tusse an integral part of the Fire Protection Program and changes.subsequesta this amendment will be subject to the standard license condition. These amedial actions include shutdowns currently required by TS 3.0.3 when an LEBausits associated Action Requirements cannot be met. An example of such a suprirenset is the shutdown required for the loss of the fire suppression water gutes and failure to establish a backup water supply within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. .
Fourth. the staatstfire protection license condition in Generic Letter 86-10 aust be included tute license. Any other current fire protection license conditions shall tesumoved. This license condition precludes changes to the approved Fire Protaties Program without prior Consnission approval if those changes would aeramely affect the ability to achieve and maintain safe shutdown conditients the event of a fire. The shutdown requirement that applies because statailure to establish a backup water supply within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after a loss of tiefire sgpression water system is an example of a Fire Protection Progrenseguirement that Md c:t be chr;:d eith::t ;rt:r
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Firally. the teletrati ntrols section of the TS shall be augmented to support the Fire Program. This shall be accomplished by additions to two speciff First, the Unit Review Group (Onsite Review Group) shall be given ibility for the review of the Fire Protection Program and implementing and the submittal of recommended changes to the Company Nuclear ew ametitt Group (Offsite or Corporate Review Group). Second. I ction heen iglementation shall be added to the list of elements i Fire P fcr ch writtssgutadures shall be established. implemented. and maintained.
T Em rgency Plunaud tie Security Plan were used as models to determine the proptlate adshAmative control for the Fire Protection Program. These additions will simett adulaistrative controls for the Fire Protection Program i that are equiniusts these for other programs that are implemented by license condition. Tle emAmed unrked pages of the Westinghouse Standard Technical Specifications (W serve as a model for the changes to the administrative controls. If Sefaut's 15 differ from the STS. additions to the ahinistra-tive controls kret Fire Protection Program should be proposed that are consistent with essenteistrative controls for the Emergency and Security
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In Generic Letter 86-10, licensees were reminded of their responsibilities to report deficiencies in the Fire Protection Program which meet the criteria of 10 CFR 50.72 and 10 CFR 50.73. Other conditions which represent deficiencies of this Program and are not encompassed by the above reporting criteria should be evaluated by the licensees to detennine appropriate corrective action.
Summary The implementation of Generic Letter 86-10 to remove fire protection TS will entail (1) a revision to the FSAR to incorporate the approved Fire Protection Program,(2 i p!r:ntin; pe:et :: t: %:1M: operational conditions, remedial ac ons, Md requirements for fire protection removed from the TS, and (3 a licens amendment. The license amendment will (1) institute the standard 1 ire prote ion license condition, (2) remove the fire proter: tion systems T! and (3) add administrative controls to support the Fire Protection Program Any desti ns on this tter should be directed to the NRC Project Manager for yo facili ty.
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- '- Enclosera 2 MARKUP 0F WESTINGHOUSE STANDARD TECHNICAL SPECIFICATIONS 6.0 ADMINISTRATIVE CONTROLS i 6.5 REVIEW AND AUDIT y
[The method by which independent review and audit of unit operations is accomplished may take one of several forms. The licensee may either assign this function to an organizational unit separate and independent from the gvoup having responsibility of unit operation or may utilize a standing committee composed of individuals from within and outside the licensee's organization.
Irrespective of the method used, the licensee shall specify the details of each functional element provided for the independent review and audit process as illustrated in the following example specifications.]
6.5.1 [UNITREVIEWGROUP(URG)]
FUNCTION ,
- 6. 5.1.1 The [URG] shall function to advise the [ Plant Superintendent] on all matters related to nuclear safety.
6.5.1.2 through 5.6.1.5 (No change)
RESPONSIBILITIES
- 6. 5.1. 6 The [URG] shall be responsible for:
- a. through 1. (Nochange)
- m. Review of the Fire Protectior. Program and implementing procedures and the submittal of recosnended changes to the [ Company Nuclear, Review and Audit Group].
- 6. 5.1. 7 through 6.7 (Nochange) 6.8 PROCEDURES AND PROGRAMS 6.8.1 Written procedures shall be established, implemented, and maintained covering the activities referenced below:
- a. through g. (nochange)
- h. Fire Protection Program implementation.
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INDEX OF REMOVED FIRE PROTECTION SPECIFICATIONS AND BASES 1 3/4.3.3.8 Fire Detection Instr $ mentation .,
Table 3.3-11 FIRE DETECTION INSTRUMENTATION 3/4.7.11 FIRE SUPPRESSION SYSTEMS 11 3/4.7.11.1 Fire Suppression Water System 3/4.7.11.2 Spray and/or Sprinkler Systems --
.3/4.7.11.3 C0 Systems 1 2
3/4.7.11.4 Halon Syst a s 3/4.7.11.5 Fire Hose Stations Table 3.7-4 FIRE HOSE STATIONS 3/4.7.11.6 Yard Hydrants and Hydrant Hose Houses l
Table 3.7-5 YARD HYDRANTS AND HYDRANT HOSE HOUSES 3/4.7.12 Fire Rated Assemblies G e 1* 2* t (Fhe. At of ed e Stiff,'n3 deg rhe me nisb 1
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