RIS 2005-07, Performance of Manual Actions to Satisfy the Requirements of 10 CFR Part 50 Appendix R Section Iii.G.2
| ML042360547 | |
| Person / Time | |
|---|---|
| Issue date: | 04/19/2005 |
| Revision: | 0 |
| From: | Hiland P L NRC/NRR/DIPM/IROB |
| To: | |
| Qualls P, NRR/DSSA/SPLB, 415-1849 | |
| References | |
| GL-86-010 RIS-05-007 | |
| Download: ML042360547 (5) | |
ML042360547 April 19, 2005NRC REGULATORY ISSUE SUMMARY 2005-07COMPENSATORY MEASURES TO SATISFYTHE FIRE PROTECTION PROGRAM REQUIREMENTS
ADDRESSEES
All holders of operating licenses for nuclear power reactors, except those who havepermanently ceased operations and have certified that fuel has been permanently removed from the reactor vessel.
INTENT
The U.S. Nuclear Regulatory Commission (NRC) is issuing this regulatory issue summary (RIS)to inform addressees that alternate compensatory measures as otherwise required by the approved fire protection program may be used for a degraded or inoperable fire protection feature under certain circumstances, in accordance with the discussion in this RI This RIS describes the proper method for changing the approved fire protection program (FPP) to use an alternate compensatory measur No action or written response is required.
BACKGROUND INFORMATION
The purpose of this RIS is to discuss how a licensee, with the standard license condition for fireprotection, may change the approved FPP to use alternate compensatory measure This RIS is in response to industry feedback from the October 13-15, 2004, public workshop in Atlanta, GA (ADAMS Accession No. ML043430240) on implementing changes to compensatory measures in the approved FP Generic Letter 86-10, "Implementation of Fire ProtectionRequirements," dated April 24, 1986, specified a process for revising the operating licensecondition to allow licensees to remove fire protection technical specifications and put them in the approved FP The standard license condition for fire protection is given in Generic Letter 86-10: Fire Protection (Name of Licensee) shall implement and maintain in effect all provisions of theapproved fire protection program as described in the Final Safety Analysis Report for the facility (or as described in submittals dated _____________) andas approved in the SER dated ____________(and Supplements dated
____________) subject to the following provision: The licensee may make changes to the approved fire protection program without prior approval of the Commission only if those changes would not adversely affect the ability toachieve and maintain safe shutdown in the event of a fir Licensees without the standard license condition for fire protection may have to submit changes to theirFPP for NRC review and approva Licensees may not change a compensatory measure required by the licensee'stechnical specifications without NRC review and approval by license amendment.Currently most licensees have adopted this license condition and moved the fire protectioncompensatory measures from technical specifications to the approved FPP in accordance with the guidance in Generic Letter 88-12, "Removal of Fire Protection Requirements From Technical Specifications," dated August 2, 198
SUMMARY OF THE ISSUE
In certain situations a licensee may prefer to implement an alternate compensatory measure tothe one required by the FP For example, the compensatory measure required by a licensee'sapproved FPP for a degraded fire barrier is typically an hourly fire watch or, in the case of an inoperable fire suppression system, a continuous fire watch with backup fire suppressionequipmen Fire watches may not be the most effective compensatory measure for degraded or inoperable fire protection features or post-fire safe-shutdown capability (see InformationNotice 97-48). A licensee may choose to implement a different compensatory measure or combination of measures (e.g., additional administrative controls, operator briefings, temporary procedures, interim shutdown strategies, operator manual actions, temporary fire barriers, temporary detection or suppression systems). Such a change may be made to the approvedFP However, the licensee must perform a documented evaluation of the impact of the proposed alternate compensatory measure to the FPP and its adequacy compared to the compensatory measure required by the FP The evaluation must demonstrate that thealternate compensatory measure would not adversely affect the ability to achieve and maintainsafe shutdown in the event of a fir Any change to the FPP must maintain compliance with the General Design Criteria and 10 CFR 50.48(a), and must be retained as a record pursuant to 10 CFR 50.48(a). The licensee's change to the FPP is subject to inspection by the NRC throughthe Reactor Oversight Process (ROP). The evaluation of the alternate compensatory measure should incorporate risk insightsregarding the location, quantity, and type of combustible material in the fire area; the presence of ignition sources and their likelihood of occurrence; the automatic fire suppression and fire detection capability in the fire area; the manual fire suppression capability in the fire area; andthe human error probability where applicable.As a reminder to licensees, additional information on compensatory measures can be found inInformation Notice 97-48, "Inadequate or Inappropriate Interim Fire Protection Compensatory Measures," dated July 9, 199 Information Notice 97-48 provides background on the use of compensatory measures, discusses situations in which fire watches were used inappropriately, and gives examples of alternate compensatory measures that may be preferred for degraded or inoperable conditions associated with post-fire safe-shutdown capability or degraded fireprotection feature Another source of information is Generic Letter 91-18, Revision 1,
"Information to Licensees Regarding NRC Inspection Manual Section on Resolution ofDegraded and Nonconforming Conditions," dated October 8, 1997, which discusses, among As of the date of this RIS, the most current guidance is Generic Letter 91-18, Revision 1, "Information toLicensees Regarding NRC Inspection Manual Section on Resolution of Degraded and Nonconforming Conditions,"dated October 8, 1997, ADAMS Accession No. ML031200701 and Attachment 1 to Generic Letter 91-18, datedOctober 8, 1997, ADAMS Accession No. ML031200704.other topics, compensatory measures and timely corrective action Licensees may want toreview and consider guidance provided to NRC inspectors and discussed in the most up-to-dategeneric communication on timeliness of corrective action The reliance on compensatory measures is one of the factors in the inspector guidance when evaluating timeliness of the corrective actio The expectation in the guidance is to promptly complete the corrective action at the first available opportunity and eliminate the reliance on the compensatory measure.
BACKFIT DISCUSSION
This RIS requires no action or written response and is, therefore, not a backfit under 10 CFR50.10 Consequently, the NRC staff did not perform a backfit analysis.
FEDERAL REGISTER NOTIFICATION
A notice of opportunity for public comment was not published in the Federal Register becausethis RIS is informational.SMALL BUSINESS REGULATORY ENFORCEMENT FAIRNESS ACT OF 1996 The NRC has determined that this action is not a rule and thus is not subject to the SmallBusiness Regulatory Enforcement Fairness Act of 1996.
PAPERWORK REDUCTION ACT STATEMENT
This RIS does not contain information collections and, therefore, is not subject to therequirements of the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.).