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. '5 UN.TED STATES NUCLEAR REGULATORY

COMMISSION

OFFICE OF NUCLEAR REACTOR REGULATION

WASHINGTON, D.C. 20555-0001 July 9, 1997 NRC INFORMATION

NOTICE 97-48: INADEQUATE

OR INAPPROPRIATE

INTERIM FIRE PROTECTION

COMPENSATORY

MEASURES All 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 alert addressees

to potential

problems associated

with the Implementation

of interim compensatory

measures for degraded or Inoperable

plant fire protection

features or degraded or Inoperable

conditions

associated

with post-fire

safe-shutdown

capability.

It is expected that recipients

will review the informatioit

for applicability

to their facilities

and consider actions, as appropriate, to avoid similar problems.

However, suggestions

contained

In this information

notice are not NRC requiremnents;

therefore, no specific action or wdtten response is required.Description

of Circumstances

The NRC foresaw cases in which fire protection

features would be inoperable

and allowed licensees, through plant technical

specifications (TS) or approved fire protection

plans controlled

by license conditions, to implement

alternative

actions to compensate

for the inoperable

condition

or component

until permanent

corrective

actions are implemented.

In general, the combination

of appropriate

compensatory

measures and the defense-in-depth

fire protection

features provides an adequate level of fire protection

until the licensees complete the corrective

actions, For common types of deficiencies (e.g., an Inoperable

fire suppression

system), the specific compensatory

measures are generally

noted in either the TS 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 the licensee 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

conditions

associated

with a plant's abilities

to achieve and maintain post-fire

safe shutdown have noted some weaknesses

in the interim compensatory

measures.

For example, some licensees have relied exclusivoly

on the 1-hour roving fire watch as an interim compensatory

measure for deficiencies

that affect their abilities

to achieve and maintain post-fire

safe shutdown and have not considered

or Implemented

other appropriate

interim compensatory

measures, such as briefing operators

on degraded post-fire, safe-shutdown-system

conditions;

temporary repair procedures;

temporary

fire barriers;

or detection

or suppression

systems. In addition,____ ?DE q=TE 91-011 911o(A (9707020308 dQV 11111111111111111011 IN 07.48 July 9, 197o MC kIspectlons

of fire protection

programs have found weaknesses

In kliensees'

fle watch t'Org programs and In the conduct of fire watch dutiee. Specific examples documented

In NRC Inspection

reports Include the following:

ODutig a November 1996 Inspection

at Waterford

Generating

Station (Inspection

Report W0-382/95-020, Accession

No. 9603260040), NRC Inspectors

found that the licensee's

procedures

redefined

the

Intent

of a continuous

fire watch. The licensees'

procedure required a 15-minute

roving fire watch, with a margin of 5 minutes, In lieu of a continuous

fir watch. In addition, required fire watches were not performed

in areas In which fire detection

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 on fire watches as compensatory

measures for a number of post-fire, safe-shutdown-design

deficiencies

Identified

by the licensee pursuant to Appendix R to Part 50 of T ", 10 of the Code f Federal Regulations

(10 CFR Part 50) while long-term

corrective

actlukns were being evaluated.

The licensee did not alert the operators

to these deficient

conditions

nor did It provide interim shutdown strategies

to operators

on how to ouccossfully

deal with potential

fire damage to required safe-shutdown

components.

The potential

conse-quences could have been extensive

since placing and maintaining

the plant in post-fire hot standby could only have bean achieved by significant

operator actions, trouble-shooting, and repair activities

to compensate

for the post-fire, safe-shutdown-design

deficiencies.

The sole use of a fire watch for a safe shutdown function which Is not adequately

protected

against fire damage is an Inappropriate

application

of a compensatory

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 reactor coolant 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 giving additional

guidance to the operators

when responding

to the RCP smoke detector alarm.However, the licensee did not propose Interim plant operational

measures which would help operators

identify and mitigate the consequence

of potential

oil leakage from the RCP oil system sites not protected

by the RCP oil collection

system. This problem resulted in a Severity Level III Violation.

Discussion]

In accordance

with 10 CFR 50.48, "Fire protection," each operating

nuclear power plant must have 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 the provisions

of Appendix R to 10 CFR Part 50, Section Ill.G, "Fire protection

of safe shutdown I' .

IN 97-48 July 9, 1997 capability;" Section Ill.J, "Emergency

lighting;" and Section 111.0, "Oil collection

system for reactor coolant pump;" and the provisions

of Appendix A to the Branch Technical

Position of the Auxiliary

Power Conversion

Systems Branch (BTP APCSB) 9.5-1, "Guidelines

for Fire Protection

for Nuclear Power Plants Docketed Prior to July 1, 1978." Licensees

of plants licensed to operate after January 1, 1979, are required to satisfy the fire protection

provisions

of their operating

licenses.

Generally, these plants have fire protection

programs that satisfy the provisions

of NUREG-0800, "Standard

Review Plan (SRP)," Section 9.5.1; "Fire Protection

Program," July 1981.Appendix A to BTP APCSB 9.5-1 specifies

that licensees

should establish

administrative

controls for normal and abnormal conditions

or such other anticipated

operations

as modifications (e.g., breaking fire stops/penetration

seals, Impairment

of fire dete,'tion

and suppression

systems) and refueling

activities.

The controls should be reviewed by appropriate

levels of licensee management, and appropriate

special actions and procedures, such as fire watches or temporary

fire barriers, should be implemented

to ensure adequate fire protection

and reactor safety.On November 7, 1991, the NRC issued Generic Letter 91-18, "Information

to Licensees Regarding

Two NRC Inspection

Manual Sections on Resolution

of Degraded and Nonconforming

Conditions

and on Operability" (Accession

No. 9111040293).

This generic letter contained

two sections, "Resolution

of Degraded and Nonconforming

Conditions" and"Operable/Operability:

Ensuring the Functional

Capability

of a System or Component," to be included in Part 9900, "Technical

Guidance," of the NRC Inspection

Manual. These additions are based upon previously

issued guidance.With respect to fire protection

and post-fire, safe-shutdown

capability, the licensee may discover a previously

unanalyzed

condition.

Under these conditions, Part 9900, "Technical

Guidance:

Resolution

of Degraded and Nonconforming

Conditions," Section 4.4, "Discovery

of an Existing But Previously

Unanalyzed

Condition

or Accident," notes that the licensee, upon discovering

an existing but previously

unanalyzed

condition

that significantly

compromises

plant safety, shall report that condition

in accordance

with 10 CFR 50.72 and shall place the plant in a safe condition.

Once a degraded or nonconforming

condition

of specific structures, systems, or components (SSCs) is Identified, an operability

determination

should be made as soon as possible, consistent

with the safety Importance

of the SSC affected.

For SSCs that are outside plant TS, engineering

judgment must be used to determine

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 expressly subject to TS and which are determined

to be Inoperable, the licensee should assess the reasonable

assurance

of safety. If the assessment

assures safety, then the facility may continue to operate while prompt corrective

action is taken. As stated in Part 9900, the following

items are to be considered

for such assessments:

the availability

of redundant

or backup equipment, compensatory

measures (including

limited administrative

controls), and the conservatism

and margins.

U IN 97-48 July 9, 1997 This Information

notice requires no specific action or written response.

If you have any questions

about the Information

In this notice, please contact one of the technical

contacts listed below or the appropriate

Office of Nuclear Reactor Regulation (NRR) project manager."Mi ee M. solosson, Acting Director Division of Reactor Program Management

Office of Nuclear Reactor Regulation

Technical

contacts:

Darrell Schrum, Rill (630) 828-9741 E-mail: dls3@nrc.gov

Rogello Mendez, Rill (630) 829-9745 E-mail: rxm@nrc.gov

Patrick Madden, NRR 301-415-2854 E-mail: pmmMnrc.gov

Attachment:

List of Recently Issued NRC Information

Notices

Attachment

IN 97-48 July 9, 1997 LIST OF RECENTLY ISSUED NRC INFORMATION

NOTICES Information

Notice No.Date of Issuance Subject Issued to 97-47 97-46 96-44, Supp. 1 97-45 97-44 97-43 97-42 Inadequate

Puncture Tests for Type B Packages Under 10 CFR 71.73(c)(3)

Unisolable

Crack in High-Pressure

Injection

Piping Failure of Reactor Trip Breaker from Cracking of Phenolic Material In Secondary Contact Assembly Environmental

Qualification

Deficiency

for Cables and Contain-ment Penetration

Pigtails Failures of Gamma Metrics Wide-Range

Linear Neutron Flux Channels License Condition Compliance

Management

Weaknesses

Resulting

In Failure to Comply with Shipping Requirements

for Special Nuclear Material 06/27/97 07/09/97 07/02/97 07/02/97 07/01/97 07/01/97 06/27/97 All "users and fabricators" of type B transportation

packages [as defined In 10 CFR 171.11(60)(8)]

All holders of OLs or CPs for nuclear power reactors All holders of OL permits for nuclear power reactors All holders of OLs or CPs for nuclear power reactors All holders of OLs or CPs for test and research reactors All holders of OLs or CPs for nuclear power reactors All fuel cycle conversion, enrichment, and fabrication

facilities

OL -Operating

License CP -Construction

Permit

IN 97-48 July 9, 1997 This information

notice requires no specific action or written response.

If you have any questions

about the Information

In this notice, please contact one of the technical

contacts listed below or the appropriate

Office of Nuclear Reactor Regulation (NRR) project manager.original signed by S.H. Weiss for Marylee M. Slosson, Acting Director Division of Reactor Program Management

Office of Nuclear Reactor Regulation

Technical

contacts: Darrell Schrum, RIIl (630) 828-9741 E-mail: dis3@nrc.gov

Rogelio Mendez, RIIl (630) 829-9745 E-mail: rxmonrc.gov

Patrick Madden, NRR 301-415-2854 E-mail: pmm@nrc.gov

Attachment:

List of Recently Issued NRC Information

Notices Tech Editor has reviewed and concurred

on 01/28/97* -See pervious concurrence

DOCUMENT NAME: 97-48.1N To Ituveasm pof Agocufm k ot s Inb am born T, a Copy W~o utischment/.ncioswe

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Z "II UNI!LIAL KLLUXU LUPY

IN 97-June ,1997 This information

notice requires no specific action or written response.

If you have any questions

about the Information

in this notice, please contact one of the technical

contacts listed below or the appropriate

Office of Nuclear Reactor Regulation (NRR) project manager.Marylee M. Slosson, Acting Director Division of Reactor Program Management

Office of Nuclear Reactor Regulation

Technical

contacts: Darrell Schrum, Rill (630) 828-9741 E-mail: dls3@nrc.gov

Rogello Mendez, Rill (630) 829-9745 E-mail: rxm@nrc.gov

Patrick Madden, NRR 301-415-2854 E-mail: pmm@nrc.gov

Attachment:

List of Recently Issued NRC Information

Notices'- See pervious concurrence

LOFC PECB:DRPM

SPLB:DSSA

DIDSSA C/PECB:DRPM

NAME T. Greene* P. Madden* G. Holahan' Chaffee C4 DATE 2/03/97 2/04/97 5/25/97 "97 I, OFC D/DRPM NAME M. Slosson DATE 6/ 197 I'll --) (0/0? W

IN 97-June ,1997 This Information

notice requires no specific action or written response.

If you have any question about the Information

In this notice, please contact one of the technical

contacts listed below or the appropriate

Office of Nuclear Reactor Regulation (NRR) project manager.Marylee M. Slosson, Director Division of Reactor Program Management

Office of Nuclear Reactor Regulation

Technical

contacts: Darrell Schrum, Rill (630) 828-9741 E-mail: dls3@nrc.gov

Rogello Mendez, Rill (630) 829-9745 E-mail: rxmanrc.gov

Patrick Madden, NRR (301) 415-2854 E-mail: pmm@nrc.gov

Attachment:

List of Recently Issued NRC Information

Notices-See pervious concurrence

OFC PECB:DRPM

SPLB:DSSA

DIDSSA C/PECB:DRPM

NAME T. Greene* P. Madden* G. Holahan* A. Chaffee DATE 2/03/97 2/04/97 5/25/97 61 /97 01ýOFC D/DRPM NAME M. Slosson DATE 8/ /97 (OFFICIAL

RECORD COPY)DOCUMENT NAME: G:\TAGYINFIRE.TAG

IN 97-May ,1997 This Information

notice requires no specific action or written response.

If you have any question about the Information

In this notice, please contact one of the technical

contacts listed below or the appropriate

Office of Nuclear Reactor Regulation (NRR) project manager.Marylee M. Slosson, Director Division of Reactor Program Management

Mece of Nuclear Reactor Regulation

Technical

contacts: Darrell Schrum, Rill (630) 828-9741 E-mail: dls3@nrc.gov

Rogelio Mendez, RIII (630) 829-9745 E-mail: rxm@nrc.gov

Patrick Madden, NRR (301) 415-2854 E-mail: pmm@nrc.gov

Attachment:

List of Recently Issued NRC Information

Notices-See pervious concurrence

OFC PECB:DRPM

SPLB:DSSA

D/DSSA C/PECB:DRPM

NAM T. Greene* P. Madden* G. Holahan* A. Chaffee E DATE 2/03/97 2/04/97 4125197 5/ /97 ,n I OFC D/DRPM NAM M. Slosson E DATE 5/ 197 4q 4 , //'3V,7[OFFICIAL

RECORD COPY)DOCUMENT NAME: G:\TAG\INFIRE.TAG

IN 97-April .1997 This Information

notice requires no specific action or written response.

If you have any question about the information

In this notice, please contact one of the technical

contacts listed below or the appropriate

Office of Nuclear Reactor Regulation (NRR) project manager.Thomas T. Martin, Director Division of Reactor Program Management

Office of Nuclear Reactor Regulation

Technical

contacts: Darrell Schrum, Rill (630) 828-9741 E-mail: dls3@nrc.gov

Rogello Mendez, Rill (630) 829-9745 E-mail: rxm~nrc.gov

Patrick Madden, NRR (301) 415-2854 E-mail: pmm@nrc.gov

Attachment:

List of Recently Issued NRC Information

Notlc as* -See pervious concurrence

OFC PECB:DRPM

SPLB:DSSA

DqW ' ' C/PECB:DRPM

NAM T. Greene* P. Madden* lahan A. Chaffee E -__-DATE 2/03/97 2104/97 1 7 2/ /97 OFC D/DRPM NAM -rh~n E DATE 2/ /97[OFFICIAL

RECORD DOCUMENT NAME: COPY)G:ATAG\INFIRETAG

IN 97-febre , 1997 This Information

notice requires no specific action or wdtten response.

If you have any question about the Information

In this notice, please contact one of the technical

contacts listed below or the appropriate

Office of Nuclear Reactor Regulation (NRR) project manager.Thomas T. Martin, Director Division of Reactor Program Management

Office of Nuclear Reactor Regulation

Technical

contacts: Darrell Schrum, Rill (630) 828-9741 E-mail: dls3@nrc.gov

Rogelio Mendez, Rill (630) 829-9745 E-mail: rxm@nrc.gov

Patrick Madden, NRR (301) 415-2854 E-mail: pmm@nrc.gov

Attachment:

List of Recently Issued NRC Information

Notices OFC PECB:DRPM

SPLB:DSSA

DIDSSA CIPECB:DRPM

NAT. Green@ P en .Holahan', A. Chaffee E DATE 12/3/97 F/1197 21 /97 j2/ /97 OFC D/DRPM NAM T. Martin E 7 DATE 12/ /97[OFFICIAL

RECORD COPY]DOCUMENT NAME: G:\TAG\INFIRE.TAG