Information Notice 1997-48, Inadequate or Inappropriate Interim Fire Protection Compensatory Measures

Inadequate or Inappropriate Interim Fire Protection Compensatory Measures

ML070180068
Person / Time
Site:	Beaver Valley, Millstone, Hatch, Monticello, Calvert Cliffs, Dresden, Davis Besse, Peach Bottom, Browns Ferry, Salem, Oconee, Mcguire, Nine Mile Point, Palisades, Palo Verde, Perry, Indian Point, Fermi, Kewaunee, Catawba, Harris, Wolf Creek, Saint Lucie, Point Beach, Oyster Creek, Watts Bar, Hope Creek, Grand Gulf, Cooper, Sequoyah, Byron, Pilgrim, Arkansas Nuclear, Three Mile Island, Braidwood, Susquehanna, Summer, Prairie Island, Columbia, Seabrook, Brunswick, Surry, Limerick, North Anna, Turkey Point, River Bend, Vermont Yankee, Crystal River, Haddam Neck, Ginna, Diablo Canyon, Callaway, Vogtle, Waterford, Duane Arnold, Farley, Robinson, Clinton, South Texas, San Onofre, Cook, Comanche Peak, Yankee Rowe, Maine Yankee, Quad Cities, Humboldt Bay, La Crosse, Big Rock Point, Rancho Seco, Zion, Midland, Bellefonte, Fort Calhoun, FitzPatrick, McGuire, LaSalle, Fort Saint Vrain, Shoreham, Satsop, Trojan, Atlantic Nuclear Power Plant
Issue date:	07/09/1997
From:	Slosson M M Office of Nuclear Reactor Regulation
To:
References
IN-97-048, NUDOCS 9707020308
Download: ML070180068 (11)

9. '5UN.TED STATESNUCLEAR REGULATORY COMMISSIONOFFICE OF NUCLEAR REACTOR REGULATIONWASHINGTON, D.C. 20555-0001July 9, 1997NRC INFORMATION NOTICE 97-48:INADEQUATE OR INAPPROPRIATE INTERIM FIREPROTECTION COMPENSATORY MEASURESAll holders of operating licenses or construction permits for nuclear power reactors.

Purpose

The U.S. Nuclear Regulatory Commission (NRC) Is Issuing this Information notice to alertaddressees to potential problems associated with the Implementation of interim compensatorymeasures for degraded or Inoperable plant fire protection features or degraded or Inoperableconditions associated with post-fire safe-shutdown capability. It is expected that recipientswill review the informatioit for applicability to their facilities and consider actions, asappropriate, to avoid similar problems. However, suggestions contained In this informationnotice are not NRC requiremnents; therefore, no specific action or wdtten response isrequired.

Description of Circumstances

The NRC foresaw cases in which fire protection features would be inoperable and allowedlicensees, through plant technical specifications (TS) or approved fire protection planscontrolled by license conditions, to implement alternative actions to compensate for theinoperable condition or component until permanent corrective actions are implemented. Ingeneral, the combination of appropriate compensatory measures and the defense-in-depthfire protection features provides an adequate level of fire protection until the licenseescomplete the corrective actions, For common types of deficiencies (e.g., an Inoperable firesuppression system), the specific compensatory measures are generally noted in either theTS or in the NRC-approved fire protection program. For unique plant-specific situations (e.g.,Inadequate cable separation), the appropriate compensatory measures are determined by thelicensee on a case-by-case basis. (This is discussed further later in the information notice.)NRC reviews of licensees' corrective actions to address degraded or Inoperable conditionsassociated with a plant's abilities to achieve and maintain post-fire safe shutdown have notedsome weaknesses in the interim compensatory measures. For example, some licenseeshave relied exclusivoly on the 1-hour roving fire watch as an interim compensatory measurefor deficiencies that affect their abilities to achieve and maintain post-fire safe shutdown andhave not considered or Implemented other appropriate interim compensatory measures, suchas briefing operators on degraded post-fire, safe-shutdown-system conditions; temporaryrepair procedures; temporary fire barriers; or detection or suppression systems. In addition,____ ?DE q=TE 91-011 911o(A(9707020308 dQV11111111111111111011 IN 07.48July 9, 197o MC kIspectlons of fire protection programs have found weaknesses In kliensees' fle watcht'Org programs and In the conduct of fire watch dutiee. Specific examples documented InNRC Inspection reports Include the following:ODutig a November 1996 Inspection at Waterford Generating Station (Inspection ReportW0-382/95-020, Accession No. 9603260040), NRC Inspectors found that the licensee'sprocedures redefined the

Intent

of a continuous fire watch. The licensees' procedurerequired a 15-minute roving fire watch, with a margin of 5 minutes, In lieu of a continuousfir watch. In addition, required fire watches were not performed in areas In which firedetection equipment was out of service and In areas In which fire barriers were degraded.This Issue Is currently under review by the NRC for disposition.* During an April 1996 Inspection at Palisades Nuclear Plant (Inspection Report 60-255/96-004, Accession No. 9805290105). the NRC Inspector noted that the licensee relied onfire watches as compensatory measures for a number of post-fire, safe-shutdown-designdeficiencies Identified by the licensee pursuant to Appendix R to Part 50 of T ", 10 of theCode f Federal Regulations (10 CFR Part 50) while long-term corrective actlukns werebeing evaluated. The licensee did not alert the operators to these deficient conditions nordid It provide interim shutdown strategies to operators on how to ouccossfully deal withpotential fire damage to required safe-shutdown components. The potential conse-quences could have been extensive since placing and maintaining the plant in post-firehot standby could only have bean achieved by significant operator actions, trouble-shooting, and repair activities to compensate for the post-fire, safe-shutdown-designdeficiencies. The sole use of a fire watch for a safe shutdown function which Is notadequately protected against fire damage is an Inappropriate application of acompensatory measure. This problem resulted in a Severity Level III Violation.* On October 17, 1998, Arkansas Nuclear One had an event involving a fire in a reactorcoolant pump (RCP) and inadequacies associated with the RCP oil collection system.The licensee's initial compensatory measures placed the lift olK pumps in the "stop"condition. This action enhanced the fire protection annunciator procedures by givingadditional guidance to the operators when responding to the RCP smoke detector alarm.However, the licensee did not propose Interim plant operational measures which wouldhelp operators identify and mitigate the consequence of potential oil leakage from theRCP oil system sites not protected by the RCP oil collection system. This problemresulted in a Severity Level III Violation.Discussion]In accordance with 10 CFR 50.48, "Fire protection," each operating nuclear power plant musthave a fire protection plan that satisfies Criterion 3 of Appendix A to 10 CFR Part 50.Licensees of plants licensed to operate before January 1, 1979, are required to satisfy theprovisions of Appendix R to 10 CFR Part 50, Section Ill.G, "Fire protection of safe shutdownI' .

IN 97-48July 9, 1997 capability;" Section Ill.J, "Emergency lighting;" and Section 111.0, "Oil collection system forreactor coolant pump;" and the provisions of Appendix A to the Branch Technical Position ofthe Auxiliary Power Conversion Systems Branch (BTP APCSB) 9.5-1, "Guidelines for FireProtection for Nuclear Power Plants Docketed Prior to July 1, 1978." Licensees of plantslicensed to operate after January 1, 1979, are required to satisfy the fire protection provisionsof their operating licenses. Generally, these plants have fire protection programs that satisfythe provisions of NUREG-0800, "Standard Review Plan (SRP)," Section 9.5.1; "FireProtection Program," July 1981.Appendix A to BTP APCSB 9.5-1 specifies that licensees should establish administrativecontrols for normal and abnormal conditions or such other anticipated operations asmodifications (e.g., breaking fire stops/penetration seals, Impairment of fire dete,'tion andsuppression systems) and refueling activities. The controls should be reviewed byappropriate levels of licensee management, and appropriate special actions and procedures,such as fire watches or temporary fire barriers, should be implemented to ensure adequatefire protection and reactor safety.On November 7, 1991, the NRC issued Generic Letter 91-18, "Information to LicenseesRegarding Two NRC Inspection Manual Sections on Resolution of Degraded andNonconforming Conditions and on Operability" (Accession No. 9111040293). This genericletter contained two sections, "Resolution of Degraded and Nonconforming Conditions" and"Operable/Operability: Ensuring the Functional Capability of a System or Component," to beincluded in Part 9900, "Technical Guidance," of the NRC Inspection Manual. These additionsare based upon previously issued guidance.With respect to fire protection and post-fire, safe-shutdown capability, the licensee maydiscover a previously unanalyzed condition. Under these conditions, Part 9900, "TechnicalGuidance: Resolution of Degraded and Nonconforming Conditions," Section 4.4, "Discoveryof an Existing But Previously Unanalyzed Condition or Accident," notes that the licensee,upon discovering an existing but previously unanalyzed condition that significantlycompromises plant safety, shall report that condition in accordance with 10 CFR 50.72 andshall place the plant in a safe condition. Once a degraded or nonconforming condition ofspecific structures, systems, or components (SSCs) is Identified, an operability determinationshould be made as soon as possible, consistent with the safety Importance of the SSCaffected. For SSCs that are outside plant TS, engineering judgment must be used todetermine safety significance.Part 9900, "Technical Guidance: Resolution of Degraded and Nonconforming Conditions,"Section 4.8, "Reasonable Assurance of Safety," states that for SSCs which are not expresslysubject to TS and which are determined to be Inoperable, the licensee should assess thereasonable assurance of safety. If the assessment assures safety, then the facility maycontinue to operate while prompt corrective action is taken. As stated in Part 9900, thefollowing items are to be considered for such assessments: the availability of redundant orbackup equipment, compensatory measures (including limited administrative controls), andthe conservatism and margins.

UIN 97-48July 9, 1997 This Information notice requires no specific action or written response. If you have anyquestions about the Information In this notice, please contact one of the technical contactslisted below or the appropriate Office of Nuclear Reactor Regulation (NRR) project manager."Mi ee M. solosson, Acting DirectorDivision of Reactor Program ManagementOffice of Nuclear Reactor RegulationTechnical contacts: Darrell Schrum, Rill(630) 828-9741E-mail: dls3@nrc.govRogello Mendez, Rill(630) 829-9745E-mail: rxm@nrc.govPatrick Madden, NRR301-415-2854E-mail: pmmMnrc.govAttachment: List of Recently Issued NRC Information Notices

AttachmentIN 97-48July 9, 1997 LIST OF RECENTLY ISSUEDNRC INFORMATION NOTICESInformationNotice No.Date ofIssuanceSubjectIssued to97-4797-4696-44,Supp. 197-4597-4497-4397-42Inadequate PunctureTests for Type BPackages Under 10 CFR71.73(c)(3)Unisolable Crack inHigh-PressureInjection PipingFailure of ReactorTrip Breaker fromCracking of PhenolicMaterial In SecondaryContact AssemblyEnvironmentalQualificationDeficiency forCables and Contain-ment PenetrationPigtailsFailures of GammaMetrics Wide-RangeLinear Neutron FluxChannelsLicense ConditionComplianceManagement WeaknessesResulting In Failureto Comply with ShippingRequirements for SpecialNuclear Material06/27/9707/09/9707/02/9707/02/9707/01/9707/01/9706/27/97All "users and fabricators"of type B transportationpackages [as defined In10 CFR 171.11(60)(8)]All holders of OLs or CPsfor nuclear power reactorsAll holders of OL permitsfor nuclear power reactorsAll holders of OLs or CPsfor nuclear power reactorsAll holders of OLs or CPsfor test and researchreactorsAll holders of OLs or CPsfor nuclear power reactorsAll fuel cycle conversion,enrichment, and fabricationfacilitiesOL -Operating LicenseCP -Construction Permit

IN 97-48July 9, 1997 This information notice requires no specific action or written response. If you have anyquestions about the Information In this notice, please contact one of the technical contactslisted below or the appropriate Office of Nuclear Reactor Regulation (NRR) project manager.original signed by S.H. Weiss forMarylee M. Slosson, Acting DirectorDivision of Reactor Program ManagementOffice of Nuclear Reactor RegulationTechnical contacts:Darrell Schrum, RIIl(630) 828-9741E-mail: dis3@nrc.govRogelio Mendez, RIIl(630) 829-9745E-mail: rxmonrc.govPatrick Madden, NRR301-415-2854E-mail: pmm@nrc.govAttachment: List of Recently Issued NRC Information NoticesTech Editor has reviewed and concurred on 01/28/97* -See pervious concurrenceDOCUMENT NAME: 97-48.1NTo Ituveasm pof Agocufm k ot s Inb am born T, a Copy W~outischment/.ncioswe *I a Copy w/o I Ichment/ancdoeure N" a No CopyOFFICE TECH CONTS IC/PECB:DRPM AD:DRPMI NAME TGreen* AChaffee* MSIosson*PMadden*DTF 02/03/97 062397 0/ 9702/04/97 ................. Z "IIUNI!LIAL KLLUXU LUPY

IN 97-June ,1997 This information notice requires no specific action or written response. If you have anyquestions about the Information in this notice, please contact one of the technical contactslisted below or the appropriate Office of Nuclear Reactor Regulation (NRR) project manager.Marylee M. Slosson, Acting DirectorDivision of Reactor Program ManagementOffice of Nuclear Reactor RegulationTechnical contacts:Darrell Schrum, Rill(630) 828-9741E-mail: dls3@nrc.govRogello Mendez, Rill(630) 829-9745E-mail: rxm@nrc.govPatrick Madden, NRR301-415-2854E-mail: pmm@nrc.govAttachment: List of Recently Issued NRC Information Notices'- See pervious concurrenceLOFC PECB:DRPM SPLB:DSSA DIDSSA C/PECB:DRPMNAME T. Greene* P. Madden* G. Holahan' Chaffee C4DATE 2/03/97 2/04/97 5/25/97 "97I,OFC D/DRPMNAME M. SlossonDATE 6/ 197I'll --) (0/0? W

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IN 97-April .1997 This Information notice requires no specific action or written response. If you have anyquestion about the information In this notice, please contact one of the technical contactslisted below or the appropriate Office of Nuclear Reactor Regulation (NRR) project manager.Thomas T. Martin, DirectorDivision of Reactor Program ManagementOffice of Nuclear Reactor RegulationTechnical contacts:Darrell Schrum, Rill(630) 828-9741E-mail: dls3@nrc.govRogello Mendez, Rill(630) 829-9745E-mail: rxm~nrc.govPatrick Madden, NRR(301) 415-2854E-mail: pmm@nrc.govAttachment: List of Recently Issued NRC Information Notlcas* -See pervious concurrenceOFC PECB:DRPM SPLB:DSSA DqW ' ' C/PECB:DRPMNAM T. Greene* P. Madden* lahan A. ChaffeeE -__-DATE 2/03/97 2104/97 1 7 2/ /97OFC D/DRPMNAM -rh~nEDATE 2/ /97[OFFICIAL RECORDDOCUMENT NAME:COPY)G:ATAG\INFIRETAG

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