ML20236M551
| ML20236M551 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 07/08/1998 |
| From: | Croteau R NRC (Affiliation Not Assigned) |
| To: | Mulligan M AFFILIATION NOT ASSIGNED |
| References | |
| GL-91-18, NUDOCS 9807140123 | |
| Download: ML20236M551 (5) | |
Text
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NUCLEAR REGULATORY COMMISSION dQy'(
WASHINGTON, D.C. 30000 4001 July 8,1998 Mr. Michael J. Mulligan 5420 Maltdie Court Sugar Hill, GA 30518
Dear Mr. Mulligan:
In an E-mail message dated June 8,1998, which is enclosed, you questioned the integrated effect of fire protection deficiencies at the Vermont Yankee Nuclear Power Plant. The specific licensee event reports that you mentioned are being evaluated by NRC inspectors as part of the normalinspection process.
With respect to the integrated effect of fire protection deficiencies, nuclear power plants use the
" defense in depth" concept of echelons of fire protection to ac5ieve a high degree of fire safety.
The objective of the concept is to: (1) prevent fires from startiag, (2) promptly detect, control, and extinguish those fires that do occur, and (3) protect struc'ures, systems, and components important to safety so that a fire that is not promptly extinguished will not prevent the safe shutdown of the plant. The several layers of fire protection produced by the defense-in-depth concept offer reasonable assurance that weaknesses or deficiencic.; in one layer will not present an undue risk to public health and safety. To achieve defense in depth, each operating reactor maintains an NRC-approved fire protection program. The licensees have designed the fire protection programs by analyses that: (1) considered potential fire hazards, (2) determined the effects of fires in the plant on the ability to safely shut down the reactor, or on the ability to minimize and control the release of radioactivity to the environment, and (3) specified measures for fire prevention, fire confinement, fire detection, automatic and manual fire suppression, and post-fire safe-shutdown capability.
Each echelon of fire protection defense in depth (i.e., prevent fires, detect and suppress fires, design systems to limit fire damage), should meet certain minimum requirements; however, strengthening any one can compensate in some measure for weaknesses, known or unknown, in the others. In some cases, reductions in defense in depth can be immediately corrected.
For example, combustibles can be removed if found in a combustible free zone. In other cases, more time is needed to correct the problem (e.g., repair an inoperable fire detection system or install a missing fire barrier). In still other cases, fire protection features are purposefully a
removed from service (e.g., a fire barrier penetration seal may be removed to allow a new cable s
run). When immediate corrective actions cannot be taken, licensees implement compensatory measures to restore, in some measure, the reduction in defense in depth created by the h,
j degraded, inoperable, or nonconforming condition until permanent corrective actions can be
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part of NRC-approved fire protection programs, which are controlled by Section 50.48, " Fire i
protection," of Title 10 of the Code of Federal Regulations (10 CFR 50.48), plant technical specifications, and fire protection license conditions. Such measures can effectively h
compensate for the reduction in fire protection defense-in-depth.
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For typical fire protection deficiencies (e.g., inoperable fire detection and suppression systems, degraded fire barrier penetration seals) the plant administrative procedures or technical requirements specify the aooronrista enmpensatory measures. Fire watches are the most 9907140123 990708 j
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i common form of compensatory measure for typical fire protection system deficiencies. The appropriate compensatory measures foi unique conditions (e.g., multiple fire protection deficiencies, the unexpected discovery that redundant post-fire safe shutdown systems are not protected in accordance with the regulatory requirements) need to be evaluated on a case by case basis and tailored to the particular circumstances. NRC Generic Letter (GL) 91-18, Revision 1, "Information to Licensees Regarding NRC Inspection Manual Section On Resolution of Degraded and Nonconforming. Conditions," provides guidance for reviewing licensee actions involving degraded and nonconforming conditions.- For unique situations, in addition to a fire watch, enhanced compensatory measures may be warranted to fully address potential safety issues presented by the nonconformance. Examples include enhancing controls over combustible materials and hot work, briefing operators and fire brigade members on the
. nonconforming condition, implementing temporary operating procedures, prestaging manual fire fighting equipment, and installing temporary fire protection features.
Fire watches are personnel trained by the licensee to inspect for the control of ignition sources, fire hazards, and combustible materials; to look for signs of incipient fires; to provide prompt notification of fire hazards and fires; and, in some cases, to take actions to begin fire suppression activities. The primary purpose of the' fire watch is to look for fire hazards and other conditions that could lead to a fire. Therefore, the fire watch strengthens the first echelon of fire protection defense in depth (fire prevention) by compensating for the weakness introduced by the inoperable, degraded, or nonconforming condition. Fire watches may also detect fires, call out the fire brigade, give exact information regarding the nature and location of the fire to the fire brigade, and initiate fire suppression activities for incipient stage fires. These actions all strengthen the second echelon of fire protection defense in depth (fire detection and
- suppression). (Whether or not a fire watch engages in incipient stage fire fighting activities is based on the individual licensees' training and procedures.)
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l The overall effect of the enhancements provided by the continuous or regular presence of fire watches (in combination with other interim compensatory measures, if warranted) in the affected areas adequately compensates for weaknesses in the fire protection program created by inoperable, degraded, or nonconforming conditions.
Sincerely, Original signed by Richard P. Croteau, Project Manager Project Directorate I-3 Division of Reactor Projects - 1/II Office of Nuclear Reactor Regulation Docket No. 50-271
Enclosure:
As stated
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DISTRIBUTION for Yellow Ticket #0980129 dated July 8. 1998 Docket File PUBLIC PDI-3 r/f (w/inc.)
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t' Vermont Yankee Nuclear Power Station cc:
Regional Administrator, Region 1 Jonathan M. Block, Esq.
U. S. Nuclear Regulatory Commission Main Street 475 Allendale Road P. O. Box 566 King of Prussia, PA 19406 Putney, VT 05346-0566 Mr. David R. Lewis Mr. Raymond N. McCandless Shaw, Pittman, Potts & Trowbridge Vermont Division of Occupational 1
2300 N Street, N.W.
and Radiological Health j
Washington, DC 20037-1128 Administration Building l
Montpelier, VT 05602 Mr. Richard P. Sedano, Commissioner Verment Department of Public Service Mr. Gautam San 120 State Street,3rd Floor Licensing Manager I
Montpelier, VT 05602 Vermont Yankee Nuclear Power Corporation Public Service Board 185 Old Feny Road State of Vermont Brattleboro, VT 05301 120 State Street Montpelier, VT 05602 Resident inspector Vermont Yankee Nuclear Power Station Chairman, Board of Selectmen U. S. Nuclear Regulatory Commission Town of Vemon P.O. Box 176 P.O. Box 116 Vemon, VT 05354 Vemon, VT 05354-0116 Mr. Peter LaPorte, Director Mr. Richard E. McCullough ATTN: James Muckerheide Operating Experience Coordinator Massachusetts Emergency Management Vermont Ysnkee Nuclear Power Station Agency P.O. Box 157 400 Worcester Rd.
i Govemor Hunt Road P.O. Box 1496 Vemon, VI' 05354 Framingham, MA 01701-0317 l
G. Dana Bisbee, Esq.
Mr. Gregory A. Maret 4
Deputy Attomey General Director of Operations 33 Capitol Street Vermont Yankee Nuclear Power Corp.
Concord, NH 03301-6937 185 Old Ferry Road Brattleboro, VT 05301 Chief, Safety Unit Office of the Attomey General Mr. Michael J. Daley j
One Ashburton Place,19th Floor Trustee and Legislative Representative Boston, MA 02108 New England Coalition on Nuclear Pollution, Inc.
Ms. Deborah B. Katz Box 545 Box 83 Brattleboro, VT 05301 Shelbume Falls, MA 01370 I
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- e From:
" Michael Mulligen" <m. mulligan @worldnet.att. net >
To:
" Victor Dricks" <VLD@nrc. gov >
Date:
6/8/9811:28am
Subject:
Safety concem: Systemic Defect in licensee reporting and LER's Mr. Dricks Remember I'm speaking to the NRC, not you My Dricks!
Vermont Yankee LER 98-001-01 and 98-008-00 highlights a systemic defects in licensing reporting. VY analyzes the faulty.6re seals in the context of the isolated de6ciencies of the seal. That the seal had a partial barrier which would slow down the propagation of the fire, and there was detection devices, Are extinguishing devices, the Are brigade, and appendix R safe shutdown is more flexible with equipment than in the past.
The public never get an idea, and sometimes I think the utility forgets, the numerous times Are barriers which were defective throughout the plant. The public might think it is only one fire barrier at fault, when in reality it was a rnanagement and NRC deficiency which allowed lots of fire barriers to be degraded, placing the plant way outside the fire analysis. Let us not forget the appendix "R" was found to be largely unworkable until recently.
Many fire components like cable vault CO2 system and the Recirc MG set sprinklers were improperly sized or built.
What I am trying to get at is, through the majority of the lifetime of this defective ssal, a broad array of fire safety components and procedures was found to be defective. There has been no analysis or documentation of trying to place these defects in context of the whole problem. There has been no attempt to place these defects in the most limiting combination of defects and plant procedures, maybe even in the context of risk. This process oflooking at these events in isolation protects the utility and you. Thus you don 1 reflect back to the utility the true characterization -
of the problem, which delays them from quickly getting to the true root cause and early correction of there problems.
l This method of analyzing events at the plants are widespread throughout the country. Utility pressure has defined how you characterized problems at the plants, which is corrupt. INe communicated many times with the NRC i
surrounding these concem and through many different NRC forums. My l
impression of your non-answers, is to not get down on paper how you really work. Only through the smoke and mirrem of the Wizard of Oz do you really regulate. Its looking more like the utilities behind the curtain who are playing with the switches than you mike mulligan j
i ENCLOSURE