ML20245D426
| ML20245D426 | |
| Person / Time | |
|---|---|
| Issue date: | 05/27/1988 |
| From: | Sniezek J Office of Nuclear Reactor Regulation |
| To: | Jordan E Committee To Review Generic Requirements |
| Shared Package | |
| ML20245D430 | List: |
| References | |
| NUDOCS 8806090007 | |
| Download: ML20245D426 (13) | |
Text
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#AY 2 71983
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MEMORANDUM FOR: Edward L. Jordan, Chairman Committee to Review Generic Requirements FROM: James H. Sniezek, Deputy Director Office of Nuclear Reactor Regulation
SUBJECT:
LINE ITEM TECHNICAL SPECIFICATION IMPROVEMENTS - REMOVAL OF FIRE PROTECTION REQUIREMENTS The staff prepared the enclosed CRGR review package for a line item improvement in Technical Specificaticos (TS) to remove fire protection requirements. CRGR review and approval of this action is required. The Comissien's Interim Policy Statement on Technical Specification Improve-J ments recognized the advantages of improved TS and endorsed the recommendations of the nuclear industry and the NRC staff for a program to develop improvements in TS. An important part of that program is the implementation of line item improvements for TS. The removal of fire protection requirements from TS was ' recomenced by Generic Letter 86-10. This change was also approved for Callaway and Wolf Creek on a lead-plant basis. Guidance for this line item improvement will be provided by a Generic Letter to all power reactor licensees and applicants. The draft Generic Letter is included in the CRGR package. The Generic Latter provides an alternative by which fire protection requirements may be renoved from TS. With this change, additional fire protection programmatic requirements would be included in the administrative controls section of TS. This package has been reviewed by OGC, and OGC has,with the one exception discussed in item (iv) of the attached CRGR review package,no legal objection to the proposed action. Please schedule a meeting at the earliest opportunity for CRGR review of this proposal. a Ja[s Sniezek Deputy Director O d f ce of Nuclear Reactor Regulation
Enclosure:
As stated l lba n o an -a ~in d
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Attachment CRGR REVIEW PACKAGE f PROPOSED ACTION: Issue a Generic Letter with guidance to allow fire protection requirementstoberemovedfromTechnicalSpecifications(TS). CATEGORY: 2 RESPONSE TO REQUIREMENTS FOR CONTENT OF PACKAGE SUBMITTED FOR CRGR REVIEW
'(i) The proposed generic requirement or staff position as it is proposed to be sent out to licensees.
Enclosure A is the proposed Generic Letter to be sent to all power reactor licensees and applicants. It provides guidance for use by licensees in requesting amendments that will allow fire protection requirements to be removed from the TS. (ii) Draft staff papers or ot'her underlying staff documents supporting the requirements or staff position. Generic Letter 86-10 " Implementation of Fire Protection Requirements" Section F. Addition of Fire Protection Program into the FSAR:
"Therefore, each license? should include, in the FSAR update required by 10 CFR 50.71(e) that will fall due more than 6 months after the date of this letter, the incorporation of the' Fire Protection Program that has been approved by the NRC, including the fire hazards analysis and major commitments that form the basis for Fire Protection Program.
This incorporation may be by reference to specific previous submittals and the NRC. approvals where appropriate. Upon completion of this effort, including the certification required by 10 CFR 50.71(e)(2), the licensee may apply for an amendment to the operating ifcense which amends any current license conditions regarding fire protection and substitutes the standard condition.
"At the same time the licensee may request an amendment to delete the technical specifications that will now be unnecessary."
NUREG 1024, " Technical Specifications -- Enhancing the Safety Impact" Recommendation 5: "The preparation and organization of the Standard Technical Specifications should be reviewed to assure that they are consistent with 10 CFR 50.36 and only contain requirements that have a sound safety basis." 52 FR 3788 INTERIM COMMISSION POLICY STATEMENT ON TECHNICAL SPECIFICATION IMPROVEMENT 1 This Policy Statement acknowledges the recommendations of industry and the NRC staff as well as studies of TS problems and the role of short-term (line item) improvements in the overall program to implement ' improvements in TS. I
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.(iii) Each proposed requirement.or staff position shall contain the sponsor-ing office's position as to whether the proposal would increase requirements or staff positions, implement existing requirements or staff positions, or would relax or reduce existing requirements or l ~ staff positions.
The proposed Generic Letter provides guidance on the removal of fire protection requirements from TS, consistent with the recommendations of Generic Letter 86-10, see Enclosure B.- Therefore, it will implement an existing staff position. The position' replaces fire protection systems TS with a license condition referencing the Fire Protection Program and some. additional administrative control TS. This treatment is consistent.with the way other programs implemented by license condi-tion are addressed in the TS. The staff has used this treatment for new licenses since the issuance of Generic Letter 86-10. . (iv) Theproposedmethodofimplementationalongwiththeconcurrence(and any comments) of OGC on the method proposed. The removal of fire protection requirements from plant TS is voluntary, and these changes would be proposed by licensees in accordance with the regulatory requirements for license amendments. With one exception OGC comments on this package were incorporated and OGC had no legal objections to it. 0GC has a legal objection to the last sentence in the third paragraph on page 2 of-enclosure I to the proposed Generic Letter. This excerpt from an OGC note explains the objection:
"5) Same page, para, that starts with " Fourth..." The last sentence is not acceptable. You cannot now predict that in all cases the If you mean licensee's evaluation will come out with this conclusion.
to dictate that the licensee must get NRC approval for this change -- if you mean to assert that any change in this feature automatically entails an unreviewed safety question -- that feature belongs in the TS.
-"The basic concept of 50.59 (and the 50.59 analogs such as the fire TS) is that these are features that the regulations do not require to be covered by the TS and that the licensee is given the authority and responsibility for the required technical determination. If the licensee's judgement cannot be trusted to assure safety, then this is the wrong way to 90."
NRR decided to leave this sentence in for the following reasons. The restriction in the Fire Protection Program to shutdown when all sources of fire suppression water are lost is an important restriction. NRR believes the Fire Protection Program is the appropriate place for the restriction and that relaxing the restriction would not be allowed under the standard fire protection license condition without NRC approval. NRR believes that relaxing this shutdown restriction would " adversely affect the ability to achieve and maintain safe shutdown in the event
of a fire." Furthermore, NRR believes that this proposed Generic Letter is an appropriate vehicle for providing that guidance to licensees. (v) Regulatory analysis generally conforming to the directives and guid-ance of NUREG/BR005S and NUREG/CR3568. A formal regulatory analysis is not applicable because the removal of fire protection requirements from TS is voluntary. The information presented in this package clarifies existing guidance and will facil-itate the implementation of the recommendations contained in Generic Letter 86-10. (vi)- Identification of the category of reactor plants to which the generic requirement, or staff position, is to apply. l This guidance is applicable to eli power reactors. (vii) For each category of reactor plants, the evaluation should be priori-tized and scheduled in light of other ongoing regulatory activities. The evaluation is to consider information available concerning any of the following factors as may be deemed appropriate and any other in-formation relevant and material to the proposed action. (a) Statement of the specific objectives that the proposed action is designed to achieve. The proposed Generic Letter was developed to provide guidance to all power reactor. licensees for the preparation of a license amendment request to remove fire protection requirements from TS. (b) General description of the activity that would be required by . licensees in order to complete the action. The proposed Generic Letter outlines the course of action licensees would follow. This includes the incorporation of the NRC-approved Fire Protection Program into the FSAR, the certifica-tion required by 10 CFR 50.71(e)(2), and the submission of propos-ed changes to the TS that are consistent with the guidance in the Generic Letter. (c) Potential change in risk to the public from the accidental offsite release of radioactive material. None. (d) Potential impact on radiological exposure of facility employees and other onsite workers. None.
(e) Installation and continuing costs associated with the action, including the cost of-facility downtime or construction delay. The cost impact on the licensee is that associated with the ad-ministrative burden to propose a change to TS and actions re- a i quired to ensure that the requirements removed from the TS are i included in the Fire Protection Program. On a continuing basis, I there should be a net cost savings for licensees and for the staff as noted in item (g) below. (f) The potent 1a1 safety impact of changes in plant or operational complexity, including the relationship to proposed and existing regulatory requirements and staff positions. The fire protection requirements removed from TS would be re- 4 tained as part of the Fire Protection Program requirements. Therefore, there would be no negative impact on plant or operational l complexity. j (g) The estimated resource burden on the NRC associated with the proposed action and the availability of such resources, j t The NRC resource burden associated with changes to the TS should l be minimal. Enclosure C to this package includes a model Safety Evaluation Report for use by NRC Project Managers in processing conforming amendments. The Project Manager should be able to process the amendment without input from a technical specialist, j l and the staff resource burden should be much less than the average 0.1 staff-year expenditure for a multi-plant action that { requires input from a staff specialist. The resource burden of j this change to TS is expected to be less than the resource burden I for all future changes to fire protection that would otherwise be encountered if these requirements are retained in TS. (h) The potential impact of differences in facility type, design or , age on the relevancy and practicality of the proposed action. l Facilities licensed before 1974 will generally have custom format l l TS. Although the changes follow the STS format, they would be adaptable to custom format TS with a minimum of effort. Differ-ences in facility type and design would have nc impact. l (i) Whether the proposed action is interim or final, and if interim, the justification for imposing the proposed action on an interim basis. This action is considered final in that there are no further changes under consideration. (viii) For each evaluation conducted pursuant to 10 CFR 50.109, the proposing office director's determination, together with the rationale for the
determinationbasedontheconsiderationsofparagraphs(1)through (vii)above,that (a) there is a substantial increase in the overall protection of public health and safety or the common defense and security to be derived from the proposal; and (b) the' direct and indirect costs of implementation, for the facilities affected, are justified in view of this increased protection. Because this initiative ~is voluntary, backfit considerations are not applicable. (ix) 'For each evaluation conducted for proposed relaxations or decreases in current requirements or staff positions, the proposing office direc-tor's determination, together with the rationale for the determination based on the considerations of paragraphs (1) through (vii) above, that: (a) the public health and safety and the common defense and security would be adequately protected if the proposed reduction in re-quirements or positions were implemented, and (b) the cost savings attributed to the action would be substantial enough to justify taking the action. With the addition of the approved Fire Protection Program to the FSAR and the use of the standard license condition on fire pro-tection, the staff concludes that on balance there is no overall decrease in current requirements or staff positions. Although existing fire protection requirements will be removed from TS, they will remain in the Fire Protection Program. i
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x~--- - UNITED STATES Enclosure A'
" \ NUCLEAR REGULATORY COMMISSION .
[ G
.i WASHINGTON, D. C. 20856
[
%,,,, (draft)
' 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, upon 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 standard condition and (2) to remove-
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, unnecessary fire protection Technical Specifications (TS). - N 4 l
During the.past two years. the staff has gained experience 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 Callaway and Wolf Creek. On the basis of this cambined experience, the staff developed the enclosed guidance 3 for the preparation of a license amendment request to implement Generic Letter 86-10. A conforming amendment would remove fire protection requirements from TS in three major areas: fire detection systems, fire suppression systems. and fire j barriers. The existing administrative control requirements related to fire ! I brigades and to fire protection audits would be retained. Additional program-matic requirements have been included in the administrative controls to address j 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 conforming to this guidance will be expeditiously reviewed by the NRC Project Manager for the facility. Proposed amemdments that deviate from this guidance will require a longer, more detailed review. Please contact the Project Mana2er if you have questions on this matter. Sincerely. l i I Frank J. Miraglia i~ Associate Director for Projects Office of Nuclear Reactor Regulation
Enclosures:
As stated 6 4
Enclosure 1 GUIDANCE FOR REMOVAL OF FIRE PROTECTION REQUIREMENTS FROM TECHNICAL SPECIFICATIONS INTRODUCTION f This enclosure provides guidance for the preparation of a license amendment request to implement Generic Letter 86-10. Suchanamendment(1) institutes the standard license condition for a Fire Protection Program, (2) removes requirements for fire protection systems from Technical Specifications (TS), and (3) adds administrative controls to TS that are consistent with those for other programs implemented by license condition. The submittal must also include the update of the Final Safety Analysis Report (FSAR) to include the Fire Protection Program, if this has not been completed as requested by Generic Letter 86-10. The staff's intent in recommending in Generic Letter 86-10 that fire protection , x requirements be removed from the TS was to further the goal of Technical Spec-
- , ification improvement as delineated in other NRC policy statements. It is not ~ l the staff's intent to reduce the level of fire safety. l t
This guidance was developed on the basis of the review of lead-plant proposals { for Callaway and Wolf Creek and from staff experience in implementing Generic Letter 86-10 for recent operating licenses. DISCUSSION This section addresses the elements a licensee should include in a license amendment request to remove fire protection requirements from TS. l First, the NRC-approved Fire Protection Program must be incorporated into the j 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 comitments that form the basis for the NRC-approved Fire Protection Program. This may be accomplished by referencing the documents which define the licen-see's Fire Protection Program as identified in the NRC's Safety Evaluation Reports. The staff does not intend to repeat its review of the approved Fire Protection Program incorporated in the updated FSAR. The staff may audit the updated l FSARs to assure that they have incorporated the approved Fire Protection Program. Licensees should not use this FSAR incorporation as an opportunity to make changes in the approved Fire Protection Program. Licensees should wait until the standard license condition is in place and then use the IThe NRC-approved Fire Protection Program includes the fire protection and post-fire safe shutdown systems necessary to satisfy NRC guidelines and re-quirements; administrative and technical controls; the fire brigade and fire protection related technical staff; and other related plant features which have been described by the licensee in the FSAR, fire hazards analysis, respon- 4 ses to staff requests for additional information, comparisons of plant designs to applicable NRC fire protection guidelines and requirements, and descriptions of the methodology for assuring safe plant shutdown following a fire. 1
4 procedures described in the license condition to make any necessary changes in the Fire Protection Program. Second. the Limiting Conditions for Operation (LCO) and Surveillance Require-ments associated with fire detection systems, fire suppression systems, and fire barriers would be removed from the TS. An index of these specifications is provided in Enclosure 2. The existing administrative controls related to fire brigades and fire protection audits are to be retained in TS. Also, any specifications related to the capability for safe shutdown following a fire. e.g.. see Item 8(j) in Enclosure 1 to Generic Letter 81-12. are to be retained in TS. Third. all operational conditions. remedial actions, and test requirements presently included in the TS for these systems shall be incorporated into the Fire Protection Program implementing procedures. In this manner, the former TS requirements will become an integral part of the Fire Protection Program and changes subsequent to this amendment will be subject to the standard license condition. These remedial actions include shutdowns currently required by TS 3.0.3 when an LCO and its associated Action Requirements cannot be met. An example of such a requirement is the shutdown required for the loss of the fire suppression water system and failure to establish a backup water supply within 24 hours. Fourth. the standard fire protection license condition in Generic Letter 86-10 must be included in the license. Any other current fire protection license conditions shall be removed. This license condition precludes changes to the approved Fire Protection Program with at prior Comission approval if those changes would adversely affect the abliity to achieve and maintain safe shutdown conditions in the event of a fire. The shutdown requirement that applies because of a failure to establish a backup water supply within 24 hours after a loss of the fire suppression water system is an example of a Fire Protection Program requirement that could not be changed without prior Comission approval. Finally, the administrative controls section of the TS shall be augmented to support the Fire Protection Program. This shall be accomplished by additions to two specifications. First. the Unit Review Group (Onsite Review Group) shall be given responsibility for the review of the Fire Protection Program and implementing procedures and the submittal of recomended changes to the Company Nuclear Review and Audit Group (Offsite or Corporate Review Group). Second. ) Fire Protection Program implementation shall be added to the list of elements for which written procedures shall be established, implemented and maintained. The Emergency Plan and the Security Plan were used as models to determine the i These appropriate administrative control for the Fire Protection Program. additions will provide administrative controls for the Fire Protection Program that are equivalent to those for other programs that are implemented by license condition, .The enclosed marked pages of the Westinghouse Standard Technical Specifications (STS) serve as a model for the changes to the administrative controls. If the plant's TS differ from the STS. additions to the administra-tive controls for the Fire Protection Program should be proposed that are consistent with the administrative controls for the Emergency and Security ' Plans. l
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i In Generic Letter 86-10, licensees were reminded of their responsibilities to report deficiencies in the Fire Protection Program which meet the criteria of 110 CFR 50.72 cnd 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 determine 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) implementing procedures to include operational conditions, remedial actions, and test requirements for fire protection removed from the TS, and (3) a license amendment. The license amendment will (1) institute the standard fire protection license condition, (2) remove the fire protection systems TS, and (3) add administrative controls to support the Fire Protection Program.
Any questions on this matter should be directed to the NRC Project Manager for
. your facility.
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Enclosure 2 MARKUP 0F WESTINGHOUSE STANDARD TECHNICAL SPECIFICATIONS 3 6.0 ADMINISTRATIVE CONTROLS N 6.5 REVIEW AND AUDIT [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 group 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 asillustratedinthefollowingexamplespecifications.] c; 6.5.1 [ UNIT REVIEW GROUP (URG)]' FUNCTION 6.5.1.1 The[URG]shallfunctiontoadvisethe[PlantSuperintendent)onall matters related to nuclear safety. 6.5.1.2 through 5.6.1.5 (No change) RESPONSIBILITIES 6.5.1.6 The[URG]shallberesponsiblefor:
- a. through 1. (No change)'
- m. Review of the Fire Protection Program and implementing procedures and the submittal of recommended changes to the LCompany Nuclear Review and Audit Group].
6.5.1.7 through 6.7 (Nochange) 6.8 PROCEDURES AND PROGRANS 6.8.1 Written procedures shall be established, implemented, and maintained covering the activities referenced below: I a. through 9 (No change)
- h. Fire Protection Program implementation.
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w INDEX OF REMOVED FIRE PROTECTION SPECIFICATIONS AND BASES 3/4.3.3.8 Fire Detection Instrumentation ., Table 3.3-11 FIRE DETECTION INSTRUMENTATION 3/4.7.11 FIRE SUPPRESSION SYSTEMS 3/4.7.11.1 Fire Suppression Water System 3/4.7.11.2 Spray and/or Sprinkler Systems 3/4.7.11.3 CO 2Systems 3/4.7.11.4 Halon Systems 3/4.7.11.5 Fire Hose Stations Table 3.7-4 FIRE H0SE STATIONS 3/4.7.11.6 Yard Hydrants and Hydrant Hose Houses Table 3.7-5 YARD HYDRANTS AND HYDRANT HOSE HOUSES 3/4.7.12 Fire Rated Assemblies 1 i I s
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-1 UNITED STATES Enclosure B
\o NUCLEAR REGULATORY COMMISSION 1 5 ! wAsmeeofoss, o. c. nossa April 24, 1986 l
To ALL POWER REACTOR LICENSEES AND APPLICANTS FOR POWER REACTOR LICENSES Gentlemen: l
SUBJECT:
IMPLEMENTAh0N0FFIREPROTECTIONREQUIRENENTS (GENERIC LETTER A6-10) In the Spring of 1984, the Consnission held a series of Recional Workshops on the implementation of NRC fire protection requirements at nuclear power plants. At those workshops, a package of recently developed NRC outdance was' distributed to each attendee which included NRC staff responses to industry questions and a document titled " Interpretations of Appendix R." The cover memo for the package explained that it was a draft package which . would be issued in final form via Generic letter following the workshops. ! The guidance approved by the Comission is appended to this letter, and is in the same femat as the draf t package, i.e., " Interpretations of Appendix { R" and responses have been modified from the draft package, and a number of industry questions raised at or subsequent to the workshops have been added and answered. This package represents recent staff assessment of these questions and provides quidance as to acceptable methods of satisfyino , Consnission regulatory requirements. Other methods propo,ed by licensees i for complying with Commission regulations may also be satisfactory and will
. be considered on their own merits. To the extent that this guidance may be.
2 inconsistent with prior outdance (including Generic Letter 83-33), it is intended that the current letter takes precedence. If you have any questions, you should contact the NRC Pro.iect Manager for your facility. In the lettered sections below, some additional topics are covered which also bear on the interpretation and implementation of NRC fire protection requirements. The topics are: (Al schedular exemptions, (B) revised inspection program, (C) documentation required to demonstrate compliance, (D) quality assurance requirements applicable to fire protection systems. (E) notification of the NRC when deficiencies are discovered, and (F) addition of fire protection program into FSAR. A. Schedular Exemptions The Appendix R implementation schedule was established by the Comission in 10 CFR 50.48(c), promulgated together with Appendix R in November of 1980. Allowing time to evaluate the need for alternative or dedicated shutdown systems, which require prior NRC approval before installation, and time for design of and NRC review of such systems, the Comission envisioned that implement *.f on of Appendix R would be complete in 4 to 5 years, or approxi-mately by the end of 1985. Many schedule extensions were granted by the
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staff under the " tolling provision" 50.48(c)(6), and under 10 CFR 50.12, the longest of which now extends into 1987. Some licensees have proceeded expeditiously to implement Appendix R and are now finished or ne with that effort. while continuing to file requests for schedule extensions, and thereby have barely begun Appendix R modifications needed to comply with Sectinn III.G and and 111.L. Schedule extension requests have been received seeking implementa-tion dates of 1990 or beyond. As the 50.48(c) schedule time frame wasinintended and ending the 1985 timeto be a one-time frame, extensions well schedule commen the 1980-1982 beyond this schedule (particularly where ma,ior modifications remain to be completed) undemine the purpose of the schedule, which was toFor achieve ex-that reason, . l peditious compliance with NRC fire protection requirements. additiona ' requests will be granted sparingly based on the followino criteria:
- 1. Theutilityhas,si$cethepromulgationofAppendixRin1980, l proceeded expeditiously to meet the Commission's requirements. l
- 2. The delay is caused by circumstances beyond the utility's control.
- 3. The proposed schedule for completion represents a best effort .
under the circumstances.
- 4. Adequate interim compensatory measures will be taken until com-pliance is achieved.
The NRC is currently reviewing all dockets of plants covered by the 50.48 schedule to determine schedule deadlines. When this review is completed, i each licensee will be infomed of the deadlines. B. Revised Inspection Program In 1982, the NRC developed an inspection program to verify compliance with the requirements of 10CFR50, Appendix R. This program was primarily oriented towards reviewing safe shutdown features of those pre-1979 licensees From 1902 thattohad the completed Appendix R modifications and selected NTOL clants. present, a number of Appendix R compliance inspections have been performed. In many of the initial inspections it was found that licensees had made significant errors in implementing a number of Appendix R requirements. L In The NRC will continue to conduct inspection of fire protection features. the case of completed modifications, the inspection team will review com-In the case of incomplete modification, pliance with apolicable requirements. the inspection team will review licensee approach ThetoNRC compliance, will attempt plans and to review schedules for completino such modifications. implementation of fire protection features on a schedule that will minimize the chances of ifcensees implementing features in a manner that does not meet with staff approval. Additionally, requests for this review and/or inspection by licensees will be granted within NRC resource constraints. d
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3 l C. Documentation Required to Demonstrate Compliance i The " Interpretations" document attached to this letter states that, where the licensee chooses not to seek prior NRC review and approval of, for example, a fire area boundary, an evaluation must be performed by a fire : protection engineer (assisted by others as needed) and retained for future ; NRC audit. Evaluations of this type must be written and organizedGuidelines to facil-for i itate review by a person not involved in the evaluation. what such an evaluation should contain may be found in: (1) Section B of Appendix R and (2) Section C.I.b of Branch Technical Position (RTP) CMEB 9.5-1 Rev. 2 dated July 1981. All calculations supporting the evaluation The should be available and all assumptions clearly stated at the outset. NRC intends to initiate enforcement action where, for a given fire area, compliance with Appendix R is not readily demonstrable and the licenseeThe +erm does not have available a written fire hazard analysis for the area.
"readily demonstrable" includes situations where ccmpliance is apparent by observation of the potential fire hazard and the existing protective features.
D.; Quality Assurance Requirements Applicable For fire protection systems the licensee should have and maintain a quality assurance program that provides assurance that the fire protection systems will be designed, fabricated, erected, tested, maintained and operated so that they will function as intended. Fire protection systems are not
" safety-related" and are therefore not within the scope of Appendix 8 to 10 CFR Part 50, unless the licensee has committed to include these systems under the Appendix B program for the plant. NRC guidance for an acceptable quality assurance pronram for fire protection systems, given in Section C.4 of Branch Technical Position CMEB 9.5-1 Rev. 2 dated July 1981, has generally been used in the review and acceptance of approved fire protection programs for plants licensed after January 1, 1979. For plants licensed prior to January 1, 1979, similar guidance was referenced in footnotes 3 and 4 to 10 CFR 50.48. They are contained in BTP APCSB 9.5-1 and Appendix A thereto i and in " Nuclear Plant Fire Protection Functional Responsibilities, Adminis-trative Control and Quality Assurance" dated June 14, 1977.
E. Notification of the NRC When Deficiencies,s are Discovered !' Licensees are reminded of their obligation to notify the NRC of fire protection i deficiencies which het the criteria of 10 CFP 50.72 or 10 CFR 50.73 as i t applicable. f F. Addition ot Fire Protection Program into FSAR 1 Most licenses contain a section on fire protection. License conditions for 1 plants licensed prior to January 1,1979, contain a condition requirino imple- l mentation of modifications consnitted to by the licensee as a result of the j BTP review. These license conditions were added by amendments issued between j 1977 and February 17, 1981, the effective date of 10 CFR 50.48 and Appendix R. f 1 4 - - - - - - - - .1M ~
4 I Two points should be noted in regard to these conditions: (1) they did not expiteitly cover required fire protection features where modifications to the existing plant configuration or procedures were not required, and (2) some of the provisions in these conditions may have been superseded by Sections III.G. J. 0, and L of Appendix R. License conditions for plants licensed after January 1,1979 vary widely in scope and content. Some only list open items that must be resolved by a j specified date or event, such as exceeding five percent power or the first refueling outage. Some reference a comitment to meet Appendix R; some reference the FSAR and/or the NRC staff's SER. These variations have created problems for licensees and for NRC inspectors in identifying the eperative and enforceable fire protection requirements at each facility. l These license conditions also create difficulties because they do not specify when a licensee may make changes to the approved program without requesting a license amendment. If the fire protection program comitted to by the Itcensee is required by a specific license condition or is not part of the FSAR for the facility, the provisions of 10 CFR 50.59 may not be applied to make changes withJut prior NRC approval. Thus licensees may be required to submit amendment requests even for relatively minor changes to the fire protection program. The aforementioned problems, in general, exist because of the many submittals that constitute the fire protection program for each plant. The Comission believes that the best way to resolve these problems is to incorporate the fire protection program and major comitments, including the fire hazards analysis, by reference into the Final Safety Analysis Report (FSAR) for the facility. In this manner, the fire protection program, including the systems, the administrative and technical controls, the organization, and other plant features associated with fire protection would be on a consistent l status with other plant features described in the FSAR. Also, the provisions
-! of 10 CFR 50.59 would then apply directly for changes the licensee desires to make in the fire protection program that would not adversely affect the ability to achieve and maintain safe shutdown. In this context, the detemina-tion of the involvement of an unreviewed safety question defined in 150.59(a)(2) would be made based on the " accident.... previously evaluated" being the postulated fire in the fire hazards analysis for the fire area affected by the change. The Comission also believes that a standard license condition, requiring licensees to comply with the provisions of the fire protection program as described'in the FSAR, should be used to ensure uniform enforcemuit of fire protection requirements.
Therefore, each licensee should include, in the FSAR update required by 10 CFR 50.71(e) that will fall due more than 6 months after the date of this letter, the incorporation of the fire protection program that has been approved by the NRC, including the fire hazards analysis and major comitments that fom the basis for the fire protection program. This incorporation may be by reference to specific previous submittals and the NRC approvals where appropriate. Upon completion of this effort, including the certification required by 10 CFR 50.71(e)(2), the licensee may apply for an amendment 4
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i to the operating license which amends any current license conditions regarding fire protection and substitutes the following standard " condition: i Fire Protection (Name of Licensee) shall implement and maintain in effect all provisions of the approved fire protection program as described in the Final Safety Analysis Report for the facility (or as described in submittals dated -------------) and as approved in the SER dated
------------{and Supplements dated ------------) sub.iect to the following provision:
The licensee may make changes to the approved fire protection program without pncr approvci of the Commission only if thou chances would not adversely affect the ability to achieve and maintain safe l j shutdown in the event of a fire. I The licensee may alter specific features of the approved procram provided (a) such changes do not otherwise involve a change in a license condition or technical specification o'r result in an unreviewed safety question (see 10 CFR 50.59), and (b) such changes do not result in failure to complete the fire protection program as approved by the Comission. As with other changes implemented under 10 CFR 50.59, the licensee shall maintain, in auditable fonn, a current record of all such changes, including an analysis of the effects of the change on the fire protection program, and shall make such records available to NRC inspectors upon request. All changes to the approved program shall be reported annually to the Director of the Office of Nuclear Reactor Regulation, along with the FSAR revisions required by 10 CFR 50.71(e). Temporary changes to specific fire protection features which may be neces-sary to accomplish maintenance or modifications are acceptable provided interim compensatory measures are implemented. At the same time the licensee may request an amendment to delete the technical specifications that will now be unnecessary. Inclusion of the fire prctection program in the FSAR will be a prerequisite for licensing for all now under review. The standard license condition will be included in new licenses. Sincerely, arre11 i., se hut, e.puty Director Office of P clear Reactor Regulation
Enclosures:
- 1. Interpretations of Appendix R
- 2. Appendix R Questions and Answers
- 3. Fire Protection License Condition J
Enclosure C , MODEL SER Underscored blank spaces are to be filled in with the applicable facility information. The information identified in brackets should be used as applicable on a plant-specific basis. 7 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. TO FACILITY OPERATING LICENSE NFP-- AND AMENDMENT NO. - T FFACILITY OPERATING LICENSE NFP-- [ UTILITY NAME] DOCKET NOS. 50- AND 50- [ PLANT NAME], URITS 1 ANF2 INTRODUCTION By letter dated _ , 1988, [ utility name] (the licensee) [ proposed that the existing license condition [s] on fire protection be replaced with the
' standard condition noted in Generic Letter 86-10 and also] proposed changes to the Technical Specifications (TS) for [ plant name]. The proposed changes would remove requirements for fire detection systems, fire suppression systems, and fire barriers as recomended by Generic Letter 86-10. The proposed changes would also modify the administrative control requirements of the TS to add requirements for the Fire Protection Program that are similar to requirements for other programs implemented by license condition. Guidance on these proposed changes to TS was provided to all power reactor licensees and applicants by Generic Letter 88 _ , dated _ , 1988.
BACKGROUND Following the fire at the Browns Ferry Nuclear Power Plant on March 22, 1975,
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the Comission undertook a number of actions to ensure that improvements were implemented in the Fire Protection Programs for all power reactor facilities. Because of the extensive modification of Fire Protection Programs and the number of open issues resulting from staff evaluations, a number of revisions and alterations occurred in these programs over the years. Consequently, licensees were requested by Generic Letter 86-10 to incorporate the final NRC-approvedFireProtectionProgramintheirFinalSafetyAnalysisReports(FSARs). In this manner, the Fire Protection Program -- including the systems, the ad-ministrative and technical controls, the organization, and other plant features associated with fire protection -- would have a status consistent with that of other plant features described in the FSAR. In addition, the'Comission con- ! cluded that a standard license condition, requiring compliance with the pro-visions of the Fire Protection Program as described in the FSAR, should be used to ensure uniform enforcement of fire protection requirements. Finally, the Comission stated that with the requested actions, licensees may request an amendment to delete the fire protection TS. The licensees for the Callaway and Wolf Creek plants submitted lead-plant , proposals to remove fire protection requirements from their TS. This action was an industry effort to obtain NRC guidance on an acceptable format for license amendment requests to remove fire protection requirements from operat-ing plant TS. Additionally, in the licensing review of new plants, the staff has approved applicant requests to remove fire prot'ection requirements from TS i
issued with the operating license. Thus, on the basis of the lead-plant pro-posals and the staff's experience with TS for new licenses. Generic Letter 88- was issued to provide guidance on removing fire protection requirements from TS. O O EVALUATION g Generic Letter 86-10 recomended the removal of fire protection requirements from the TS. The basis for this recommendation is that although a comprehensive Fire Protection Program is essential to plant safety. many details of this program that are currently addressed in TS can be modified without affecting nuclear safety. Such modifications can be made provided that there are suitable admin-istrative centrols over these changes. These details, that are presently included in TS and which are removed by this amendment. do not constitute performance requirements necessary to ensure safe operation of the facility and. therefore. do not warrant being included in TS. At the same time, suitable administrative controls ensure that there will be careful review and analysis by competent individuals of any changes in the Fire Protection Program including those technical and administrative requirements removed from the TS to ensure that nuclear safety is not adversely affected. These controls include: (1) the TS administrative controls that are applicable to the Fire Protection Program; (2) the license condition on implementation of. and subsequent changes to. the Fire Protection Program; and (3) the 10 CFR 50.59 criteria for evaluating changes to the Fire Protection Program as described in the FSAR. The specific details relating to fire protection requirements removed from TS ! by this amendment include those specifications for fire detection systems, fire suppression systems, and fire bariiers. The administrative control require-ments have been modified to include Fire Protection Program implementation as an element for which written procedures must be established, implemented. and maintained. In addition. the audit responsibilities of the [ Unit Review Group] were expanded to include the review of the Fire Protection Program and imple-menting procedures and submittal of recommended changes to the [ Company Nuclear ReviewandAuditGroup]. The TS changes proposed by the licensee are in accordance with the guidance provided by Generic Letter 88 ___. as addressed in the items below. (1) Specification [6.5.1.6.UnitReviewGroupResponsibilities].wasrevised to add the review of the fire protection program implementation and the submittal of recommended changes to the [CNRAG (Company Nuclear Review andAuditGroup)]. ! (2) Specification [6.8]. Procedures and Programs. was revised to add Fire ) Protection Program implementation to those programs for which written procedures shall be established, implemented, and maintained. (3) Specification [3.3.3.8].FireDetectionInstrumentation.itsassociated Surveillance Requirements, and Bases were removed. (4) Specifications [3.7.11.1through3.7.11.6].FireSuppressionSystems, their associated Surveillance Requirements, and Bases were removed.
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- 3 (5) Specification [3.7.12],FireBarriers,itsassociatedSurveillance ,
Requirements, and Bases were removed. .. r As required by Generic Letter 86-10, the licensee confirmed that the NRC-approved Fire Protection Program has been incorporated into the FSAR. [Also, the licensee has proposed that the existing licensing condition on the Fire Protection Program be replaced with the standard condition noted in Generic Letter 86-10. OR The licensee confirmed that the current license condition on fire protection ~Is the standard condition provided in Generic Letter 86-10.] The licensee confirmed that the operational conditions, remedial actions, and test requirements associated with the removed fire protection TS have been incorporated into the Fire Protection Program implementing procedures. This is'in accordance with the guidance of Generic Letter 88 _. On the basis of its review of the above items, the staff concludes that the licensee.has met the guidance of, Generic Letter 88- ~ Therefore, the staff
. finds the proposed changes acceptable.
ENVIRONMENTAL CONSIDERATION These amendments involve changes to the use of the facility components located within the restricted area as defined in 10 CFR Part 20. The staff has deter-mined that the amendments involve no significant increase in the amounts and no significant change in the types of any effluents that may be released off site, and that there is no significant increase in individual or cumulative occupa-tional exposure. The staff has determined that the amendments involve no significant-hazards consideration, and there has been no public coment of such finding. Accordingly, the amendments meet the eligibility criteria for categor-icalexclusionsetforthin10CFR51.22(c)(9). Pursuantto10CFR51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of these amendments. CONCLUSION The Comission made proposed determinations that the amendments involve no significant-hazards consideration, which were published in the Federal Register (53 FR )on 1988. The Comission consulted with the State of
. Tpublic comeiits were received, and the State of did not have any comments.
On the basis of the considerations discussed above, the staff concludes that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Comission's regulations, and (3) the issuance of these amendments will not be inimical to the common defense and security or to the health and safety of the public. h Principal Contributors: Dennis J. Kubicki, SPLB/ DEST ) Thomas G. Dunning, OTSB/DOEA
, PD /DPR ~
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Dated: _,, 1988 l j
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hM j 1 P MEM0FANDUM FOR: Edward L. Jorden, Chairman Robert M. Bernero, NMSS Denwood F. Ross, RES Joseph Scinto, OGC James H. Sniezek,'NRR THROUGH: C. J. Helter.es, Jr. , Deputy Director Office for Analysis and Evaluation of Operational Data FROM: M. Chiramal, Chief Engineering Section ! Feactor Operations Analysis Branch, DSP, AE00 5UBJECT: SUMMAFY AND ISSUE IDENTIFICATION - CPGR AGENDA ITEM, MEETING NO. 139 Encir;ed .for your information and use is the CRGR staff summary for the follo-irg CRGR review item: Froposed resciution of USI A-17 " Systems Interattien in Nuclear Power Pl a nts . 1 This 06tter is scheduled'fer CRGR review at Meeting No, 139 on Tuesday 21, 1988 in Room 10811, CWFN free 2:00 p.m. to 3:00 p.m. Patthew Chiramai, AEOD
Enclosure:
As stated ccw/ enclosure: V.Stello i e
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9 .a Summary and Issues Identification CRGR Agenda ' tem - Meeting No. 130 f IDENTIFICATI0N' Proposed resolution of USI A-17 " Systems Interaction in Nuclear Power Plants." CNECTIVE The staff has requested CRG9 consideration of the proposed resolution of Unresolved Safety issue A-17 " Systems Interecticn in Nuclear Power Plants," prior to issue for public coments. This issue was presented to CRGR in April 1986 and the encleted draft resolution has addressed CPGP cements, as well es ACRS coments and additional staff coments. BACKGROUND (a) The packa;e subnitted fer CRGP review was transmitted by memorardum dated
. Pay 19, 1988 from E. S. Beckjord to E. L. Jordan. The package included the following documents:
(1) NUREG-1229 "Reguletory Analysis for Proposed Resolution of USI A-17.* (2) Proposed Generic Letter. (3) Esckgreurd informat'on for CPGR review of USI A-17 resolution. (4) Summary of USI A-17 references. (5) NUSEG-1174 " Systems Interaction in Nuclear Power Plants: Technical Fincings Related to 051 A-17," (6) Verificar. ion of licensee actions in response to Generic Letter. (b) CPGP has revicwed all the above decuments previously, However, the present package has been revised te address the comments ard concerns raised by CPGR and ACRS. In particular, ite, 7 2 ebeve, the proposed Generic Letter,
+ cludes a requiremnt that all utilities certify that their plant is protected frem internal flooding and water intrusion. Previously the staff had proposed to rely en other activities, such as NRC and INPO generic communications.
(c) ACRS concerns have been addressed. (d0 The DES staff contact on this subject is Dale Thatcher, USI A-17 Task J Panager. l l 1
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- D:SCUSSION/ ISSUES The. safety issue in USI A-17 is the ccncern that nuclear. plants systems may The dependencies con *,stn hidden dependent f es which could be safety significant.
cf concern fer A-17 involve safety significant events or adverse systeins interac-tices (A9is) which are due to a single f ault or 'ailure in one system which prc: agates to erother system by spatial, functional, or ht.can-interventional coupling. In the proposed resolutien, the staff has concluded that the Asis involve subt'e and often very complicated dependencies. Total elimination of ASIS is Hence, the staff is recocinending the following censidered unschievable. c st-effective actions, rather than recommending that each plant undertake a corrprehensive study to uncover +11 ASIS. (1) Issuance of a generic letter which includes: (a) tne bases for resolution of A-17 (3) a surrary of infcmation for use in ongoing operating experience reviews (c) a request (pursuant to 10 CFR 50.54f) for all utilities to certify that their plant is protected from internal plant flooding and water irtrusion. (2) Recognition that !be USI A-46 resolution will address seismically induced systems interactions to the extent that cornponents and systerns stut dcwn the plant are protected, given a loss nf r.eeded offsite ;cwer. to safely (hew plants, not covered by A 46, have been reviewed to current requirements which address seismically induced systems interactions.) (3) Corrunication of infomation internal to NPC for review of PRAs and for evaluation of electric power supplies as part of GI-128. (4) Identifi:ation and definition of concerns related to A-17 of (The objective and other programs which have not been specifically addressed. this prograc is to definr. the corcerns with sufficient specificity to pemi t the-t to be prioritized as potential generic safet.y issues.) In its review of the preposed resolution package the Comittee may wish to
.cor. sider the following issues:
This (1) This USI was. reviewed and conrented upon by CPGR in April 1986. package was revised to address the CPGP ccmment that the proposed actions j to be taken by licensees and the FPC' staff be stated more explicitly, (2) Those concerns raised by the ACRS or A-17 which have not been addressed in the prcposed resciution are planned to be defined, identified, and considered as candidate generic issues. 1 - -- - -}}