ML20127N379
| ML20127N379 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 03/20/1985 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | Advisory Committee on Reactor Safeguards |
| References | |
| ACRS-2277, NUDOCS 8505230507 | |
| Download: ML20127N379 (16) | |
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} j rr jh0 DATE ISSUED: March 20,1985 E 8 MINUTES OF THE AD HOC FIRE PROTECTION SUBCOMMITTEE, FEBRUARY 5, 1985 WASHINGTON, D.C.
A meeting was held by the ACRS Ad Hoc Fire Protection Subcommittee on February 5, 1985. The purpose of the meeting was to discuss the status of Appendix R compliance, Calvert Cliffs compliance with Appendix R, and the status of fire protection research at Sandia. Notice of the meeting was published in the Federal Register on January 18,1985(Attachment
)
A). The schedule of items cevered in the meeting is in Attachment B.
The list of attendees is in Attachment C. A list of handouts is included in Attachment D. The handouts are filed with the office copy.
H. Alderman was the cognizant staff member for this meeting.
Opening Statement Mr. Michelson convened the meeting at 8:30 a.m. He noted that he was the Chairman of the Subcommittee, and the other ACRS members in atten-dance were Messrs. Ebersole, Reed and Wylie. Mr. R. Patton was in-troduced as an invited Fire Protection expert for this meeting.
In response to a request for comments from the Chairman, Mr. Reed noted that he was concerned that some of the invited participants dropped out of the meeting. H. Alderman noted that the stated reasons for the fire insurance group and the utilities dropping out were, that the fire insurance group were involved in litigation that concerned Appendix R
'and were advised by their legal department to withdraw from the meeting.
The utilities fire protection group stated that they were in the process of reviewing the NRC steering connittee report and were not prepared to -
discuss Appendix R until the conclusion of that review.
Mr. Ebersole noted that he would like the staff to address the topic of 50-3/7 Sp- 3 T the characterization of the intrusion fire in the context of whether P r&S 7'*: ..
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they can be reasonably and administratively modified to diminish their potential and what are the risks involved.
V. Benaroya, Chief, Chemical Engineering, NRR Mr. Benaroya noted the impetus for the current fire protection regu-lations and positions was the Browns Ferry fire in March 1975. The recommendation related to the Browns Ferry fire were issued under NUREG-0050 in February 1976. Based on these recommendations, the branch technical position on fire protection was issued in March 1976. The branch technical position was for new plants.
Appendix A was an outgrowth of the branch technical position and succes-sive regulatory guide, and was a backfit to all operating plants and
- plants under construction.
. With Appendix' A in force, the staff visited every plant and looked at the fire protection systems and saw how well they were performing. As a result of these inspections, a Safety Evaluation Report (SER) was issued for every plant. Some of the plants had open items in the SER's. The mechanism chosen to resolve the_open items was to issue a rule. In November 1980, the fire protection rule was issued (10 CFR 50 Appendix R). The rule also includes 10 CFR 50.48 which states that all operating ;
nuclear power plants shall have a fire protection plan. Appendix R establishes the required fire protection features for certain items which were unresolved in the SER issues in 1978 and 1979.
Three of the sections of Appendix R,Section III.g which covers sepa-ration and alternative shutdown systems, III.J lighting requirements and III.0, the oil collection system were determined to be backfit items by the Commission. This is irregardless of whether they were approved or agreed on previously. .
Mr. Benaroya stated that the biggest problem in Appendix R compliance has been interpratation by non-professionals. He noted that fire protection is not an exact science but relies on judgments that should
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. Minutes / Fire Protection 3 February 5, 1985 Mtg.
. be made by professionals in the fire protection discipline. The second protest problem in Mr. Benaroys's view, is the failure in communication between the licensees and the NRC.
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Mr. Reed remarked that the notion of consistency and uaiformity in the fire protection act bothered him because the fire protection systems vary considerably from plant to plant.
Mr.-Ferguson, NRR, responded that there are different levels of consis-tency. One level of consistency is that there will not be any core damage due to a fire. The mechanism for achieving this goal varies from plant to plant. Individual plant situations can be accommodated by means of the exemption process. One basis for exemption would be if meeting the letter of the rule provided no significant increase in. fire-safety, then the rule would not have to be met.
Mr. Benaroya briefly discussed the differir.g professional opinions in fire protection. Basically some members of the staff believe that the utilities are allowed to perform their interpretations and analysis without staff concurrence. - The staff is unaware of any changes until the utility fire protection is reviewed.
At this point in time, the utility has incurred large expenditures and sometimes has installed equipment. It is difficult to make any changes in'this, after the fact case.
Mr. Kubicki stated that the DP0 is based upon the interpretation of Appendix R. He noted that a concern was the potential of prolonging the process of Appendix R compliance. He also noted a concern of allowing the utilities to subvert the rule by virtue of doing in house analyses concerning the validity of fire boundaries.
Warren Minners, Chief, Safety Program Evaluation Branch Mr. Minners discussed generic issue 57 " Effects of Fire Protr. tion System Actuation on Safety Related Equipment." He noted that their job
Minutes / Fire Protection .4 February 5,.1985 Mtg.
is to take generic issues and try to make an evaluation of them. The-
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evaluation is based upon somewhat quantitative objectives. .Following the evaluation, the generic issues are arranged in a priority listing to efficiently use the NRC resources, f
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Mr. Minners introduced Mr. Vandermolen who discussed the prioritization of generic. issue 57. This. issue was. approached on a probabalistic
- basis.-. Plant data was compiled to determine the number of spurious 4 actuation events. Based upon the data, the number of actuations where; ,
suppresent was released was determined to be about 0.00 33 per reactor year. -This series;of' estimates was extrapolated to consider the availability of various safety systems as needed. The bottom line was the estimate of 3.4x107 core melts per reactor year due to spurious fire protection system actuation.
The next scenario that was considered was a large fire near the site boundary that creates a large quantity of smoke that drifts into the plant area. The first probability estimate was the chance that smoke would not be detected by the plant personnel. The second estimate is 4 the probability that the smoke will enter the plant ventilation system.'
The third calculation concerns the probability that the smoke would
.. actuate a fire protection detector. The fourth probability calculation is that the sprays damage a sr.fety system. The bottom line of this scenario is an increase in core melt frequency of about 3x10-9 per L reactor year.
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! Generic issue 57 has not been prioritized as yet but the indications
.were that it would be given a medium priority.
Ralph Thompson, Risk Manager, TVA Nuclear Power Program
. Mr. Thompson wasn't a scheduled speaker, but was in the audience, and .
responded to Mr. Ebersole's question on CO2 incidents. Mr. Thompson noted that TVA had two failures with carbon dioxide systems. In one case, the fire door wasn't latched and the door came open during test-l- .ing. The second' case involved a panel above a door. The panel didn't ,
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have the structural. requirements to withstand.a full scale pressure
- test.
'Mr. Thompson-said they use large capacity storage tanks in conjunction with a low pressure system. During the pressure test a transducer is placed in the area-to be tested and the pressure rise is observed. If
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it appears a serious problem will arise due to pressure, then dampers are installed in that room. Mr. Thompson noted that the delivery pipe
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is sized based on friction loss, to keep the flow to fairly low levels.
Peter Katz, Project Engineer, Baltimore Gas and Electric Company Mr. Katz noted that he was the project engineer for the fire protection modifications. He remarked that lie believed the reason Calvert Cliffs did s'o well on their Appendix R reviews was the use of a systems ap-proach to the problem. The fire protection engineer was~part of the team but the emphasis remained on the system approach with electrical
. work being one of the major efforts. The major issue, in his view,.was the protection of safe shutdown capability from fire. Mr. Katz noted the-b'asic philosophy is not to save the capital investment but to maintain safe operation and shutdown of the plan.
-Calvert Cliffs investigated alternate shutdown and issued a report called " Report on Alternate Safe Shutdown. This investigation considered conventional and non-conventional means of shutdown and considered the sequence of operations i.e., which valves, trains, equipment-had to remain open or closed and what alternate means can be employed.
Mr. Michelson asked if there were any cases where changes in fire-protection philosophy had to be reversed because of Appendix R. Specif-ically Mr. Michelson referred to things that were done and had to be. .
changed because of Appendix R. Mr. Katz responded that they didn't have to reverse any changes because of Appendix R.
- Minutes / Fire Protection 6 February 5,1985 Mtg.
Mr. Katz noted that a complete cable analysis was performed to determine exactly where each cable runs throughout the plant.- This was in prepa- !
ration to determining where the fire areas should be located.
Mr.- Katz noted that the only walls erected during the Appendix R process were to. separate charging pumps and to turn them into areas. Each charging pump now occupies its own area.
The approach used for the alternate shutdown system was to determine which paths could be used utilizing normally operating equipment. The benefits would be the operators were familiar with the systems and would not have to learn new procedures and techniques. An additional advan-tage would be that the normally operating systems would be maintained on a regular basis.
A flow charting analyses was performed listing primary flow paths and secondary flow paths, if the normal flow paths were unavailable. Where a singular functionality was indicated in the flow path, divergent means of actuation were assured, which in some cases relied on manual ac-tuation.
A fire protection engineer working in conjunction with an electrical engineer took the cable. analysis and did a "three tier analyses."
First, all cables were evaluated by room locations. All rooms touching on any one elevation along with elevations above or below that over-lapped, were analyzed for separation.
The next~ series of analyses considered was separation by function. All rooms that contained the same functional equipment were checked for separation requirements.
The last series of evaluations checked all the hot shutdown reactor heat -
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removal rooms in the plant to see what had to be separate.
The end result was 59 bounded fire areas.
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February 5,'1985 Mtg.
v Mr. R. J. Tourtellotte, Executive Legal Department Mr. Tortellotte stated that he was concerned about backfitting in its
+- ; broadest scope rather than fire protection specifically. He.noted he was concerned about:
1 o The regulatory culture that-considers it is appropriate to have post hoc development and imposition of requirements.
-o . A regulatory culture that believes that it is_ appropriate to impose requirements without prior analysis, o A regulatory culture that believes its appropriate to not make
- a distinction between what is fundamental to safe operation as opposed to what is only a marginal safety improvement.
-o A regulatory culture that thinks its appropriate that no cost benefit analysis of marginal safety improvement need to be
- made.
o A regulatory culture where there seems to be an inability of the staff to reconcile the question of why an operating plant with a certain system, component, or structure is considered safe while a near-term OL with substantially the identical system, structure, or component is considered unsafe.
o A regulatory culture that thinks it's appropriate for the staff to use regulatory leverage to impose requirements with no legitimate basis and without analysis, o A regulatory culture that seems to approve a wiring around CRGR.
o A regulatory culture that has the " fair game" mentality; that is, whenever there ' '
oss on an appealed issue at one plant it does not preclude taff from trying again with, or w-m--,w pww - w w y- 4 rw-v- -
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continuing to press another plant if-that plant is vulnerable-by reason of its licensing posture.
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Mr. Tourtellotte remarked that fire protection does not exist for the sake of fire protection alone, fire protection only exists to assure the safe operation of the plan.
David Notley, Fire Protection Engineer, Office of Research Mr. Notley requested time to express his personal views.
Mr. Notley noted that fire protection for nuclear power plants is not different in kind from fire-protection at any complex industrial plant.
The consequences of a fire at a nuclear plant can be worse but the fire protection itself, the fire hazards and the protection as provided is not different in kind.
Regarding previous discussion about lack of quality assurance and quality control, he remarked that the fire protection community had quality assurance long before the Nuclear Regulatory Commission existed.
Mr. Notley remarked that it was dangerous to estimate the prcbability of a fire in a specific area as being very small and then ignoring it. If there is any. possibility, at al, it should be included in the consid-era tion.
Mr. Notley took exception to Mr. Patton's remarks about the membership of NFPA committees being self serving to promote manufacturers products.
He noted that membership is open to all interests and parties and there is total public review and comments on all proposed standards.
V. Benaroye, NRC, Diesel Fuel Oil Storage Areas Mr. Bensroya stated that the Hope Creek Plant has diesel oil storage, right under the diesels. There are four storage tank rooms with two
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' tanks to a room. Each room is separated from the others by three hour barriers. There are three hour barriers between the rooms and the
~ diesels above. Fire suppression is provided by an automatic carbon dioxide system and a fixed water protection system.
Mr. Michelson noted his concern was that the B&P states that these types of tanks ought not to be in buildings containing vital equipment.
Mr. Benaroya stated that the plant was built this way without the prior knowledge of the NRC, and the end result was to try to see how adequate fire protection would be achieved under the circumstances.
Mr. D. Berry, Sandia National Laboratories, Fire Protection Research at Sandia
- Mr. Berry pointed out that one of the major insights received from the testing is that fire retardant insulations do actually reduce the fire severity, but even qualified cable does burn and can be damaged.
In'the case of gaseous suppression agents, they do eventually put out the fires but they allow the temperatures to remain high and this could cause damage.to some components.
The use of water produces severe moisture environments which spray shielding does not always alleviate.
Penetration seals will fail if they have cracks in them.
Hot gas layers can cause damage to spatially separated components.
Mr. Berry pointed out that one thing that is disturbing to him is PRA's have ignored damage to components due to things other than just burning, .
things such as spray suppression effects, manual fire fighting effects on redundant systems and things like smoke migrating throughout the plant. The effects of these phenomena on the overall core melt frequen-cy are unknown.
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Regarding a separate redundant remote shutdown system, Mr. Berry noted
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that it is not clear that the millions of dollars that were spent were justified from the >tandpoint of fire protection. In a number of cases.
-improvements-in the suppression systems, protection within a given room--
and reduction of fire frequencies would be a more cost-effective ap-proach.
Mr. Berry discussed the fire characterization tests. The objective of
'these tests is: "For transient and in-situ fuels found in nuclear power plants,' determine the rates of heat and combustion product release during open burning." This information is used for source terms for room environmental models. The available fire environmental models are unable to accurately predict the burning characteristics of source fires.
- Mr. Berry discussed a cable tray fire analyses performed at Sandia. The rate of burning for a particular array versus the tray surface area was determined. .This was based upon tests performed by Factory Mutual. The objective of the analysis is to determine whether or not redundant systems would be vulnerable to the same fire due to the magnitude of the fire.
Mr. Berry pointed out a concern regarding cabinet fires. The concern here is that control rooms and remote shutdown areas and other places in the plant where cabinets are located are single points where redundant systems are concentrated. There is a need to look at the design ap-proaches on cabinets to see whether or not cabinets are vulnerable and whether or not the rates of fire development in cabinets are fast enough so that they cannot be coped with by the operators or whether these transfer things can be done in a timely fashion.
The last major discussion by Mr. Berry concerned component damage. This .
is related to failure of equipment by conditions of burning and associ-ated effects. Tests are being planned on the combination of the
. heating, water sprays, high humidities, smoke, particulates and
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corrosive vapors. .The approach is to determine whether or not the equipment can be damaged by the fire environment.
The meeting was adjourned at 7:05 p.m.
NOTE: A complete transcript of the meeting is on file at the NRC Public Document Room at 1717 H St. NW., Washington, D.C. or can be obtained from ACE-Federal Reporters, Inc., 44 N.
Capitol Street, Washington, D.C. 2001, (202) 347-3700.
ATTACHMENT A 18, 1965 / N:tices Federal Register / Vol. 50, No.13 / Fridry, JInutry 2742 with representatives of the NRC Staff.
Furthat information regarding topics FebruaQ539sk to be discussed. whether the meeting their consultants. and other invited A.M.-Full Committee Review and has been cancelled or rescheduled, the. persons regarding this review, s Discussion of Directorate's Management Further information regarding topics '
Chairman's ruling on requests for the to be discussed, whether tne meeting Plan opportunity to present oral statements I
- end scussion on g 19e8 hasbeencancelledof rescheduled the. s O-[Miscellfn,eous information and the time allotted therefore can be Chairman's ruling on requests for the obtained by a prepaid telephone call to -
opportunity to present oral statements P.M.-FullCommittee Review and the cognizant ACRS staff member,Mr. a Recommendauona Paul Boehnert (telephone 202/634-3267)
- and the time allotted therefore can be *'.
on Directorate Coals obtained by a prepaid telephone call to between 8:15 a.m. and 5-00 p.m. e.s.t. .
the cognizant ACRS staff member.Mr.
january 15,19s5. Persons planning to attend this meeting Herman Alderman (telephone (202/634- 3 are urged to contact the above named I M'Rebecca Wlauer' .. 1414) between 8:15 a.m. and 5:00 p.m Individual one or two days before the e.s.t. Persons planning to attend this I Committee Monosement Officer.
scheduled meeting to be advised of any a
[FR Doc. e6-14as Filed 1-17-85; 8:45 am] meeting are urged to contact the above changes in schedule, etc.,which may named individual one or two days -l enAmma coca ms.eus g have occurred. before the scheduled meeting to be c
Dated; January 15.1985. advised of any changes in schedule, etc., -
1 NUCl. EAR RECUl.ATORif Morton W.IAarun, which may have occurred.
COMMISSION Assistont becutive Directorfor Project Dated; January 15.1985.
7 Review. Morton W.taarkin.
Advisory Committee on Reactor (FR Doc. 85-1504 Filed 1-17-45,8.45 am] 1 Safeguards Subcommittee on Assistant becutive DirectorforPwject Advanced Reactoes; Meeting
' coca rose.eue Advisory Committee on Reactor **
Ad Re to 11 hold a meetin
- on February 5,1985, Room 1167.1717 H Safeguards Subcommittee on Fire Street, NW, Washington.DC. Protection; Meeting Advisory Committee on Reactor
.I The meeting will be open to public The ACRS Subcommittee on F.
ire Safeguards Subcommittee on I attendance, however, portions will be Protection willhold a meeting on Regulatory Policles and Practices; -
I closed to discuss proprietary information.
February 5.1985. Room 1046,1717 H Street, NW, Washington. DC.
"*d"8 , 1 He agenda for subject meeting shall The entire meeting will be open to The ACRS Subcommittee on be as follows: Regulatory Policies and Practices will *3
- g public attendance. hold a meeting on February 6.1985, Tuesday, February 5,1985-8:30 a.m. The agenda for subject meeting will g until the conclusion of business Room 1046,1717 H Street. NW, be as follows: Washington, DC.
g He Subcommittee will discuss the Tuest'ay, Februory 5,1985-4 JO o.m. The entire meeting will be open to 3 redirected DOE programs for LMFBR untilthe corclusion of business 3 cnd HTCR development as well as the public attendance. (
De Subcommittee will be briefed on The agenda for subject meeting will current status of NRC research programs the following:(1)The status of I on advanced reactors.* Appendix R compliance,(2)" ' .:.i be as follows: Ie Oral statements may be prese'nted by Wednesdoy, Februory 6.19G-8:30 a.m.
members of the public with concurrence Calvert Cliffs compliance with until 140p.m' -I of the Subcommittee Chairman; written Appendix R.(3) b = . ace .
3,
%e Subcomm.ttee i willreflew the
- statements willbe accepted and made [2) hmr.b' a un L ps% and Commission's available to the Committee. Recordings the status of fire protection research d by g
p at Sandia. Oral statements m will be permitted only during those Oral statements may be presented liy members of the pubh,ay c with be presente concurrence. ,
portions of the meeting when a members of the public with concurrence g transcript is being kept, and questions of the Subcommittee Cha 'rman: written of the Subcommittee Chairman: written statements willbe accepted and made may be asked only by members of the statements will be accepted and made available to the Committee. Recordinga g Subcommittee. its consultants, and Staff, available to the Committee. Recordings will be permitted only during those .,
Persons desiring to make oral statments will be permitted only during those ,
should notify the ACRS staff membrr portions of the meeting,when a -
- portions of the meeting when a -
transcript is being kept, and questions ,
named below as far in advance as transcript is being kept, and questions may be asked only by members of ae ,
practicable so that appropriate may be asked only by members of the Subcommittee,its consultants, ana Staff. ,
arrangements can be made, Subcommittee. its consultants, and Staff. Persons desiring to make oral During the initial portion of the Persons desiring to make oral statements should notify the ACRS staff ,
meeting. the Subcommittee, along with statements 1thould notify the ACRS staff member as far in advance as practicable j any of its consultants who may be b .
present, may exchange preliminary member as far in advance as practicableso that appropriate ; a made.
views regarding matters to be ,
During the initial portion of the.
considered during the balance of the made. . . ,
During the initial portfori of the .
meeting. the Subcommittee members meeting.- meeting, the Subcommittee members will exchange preliminary views he Subcommittee will then hear . . will exchange preliminary views regarding matters to be considered ,
presentations by and hold discussions ; regarding matters to be considered with repiesentatives o!the Department : d. iring the balance of the meeting. during the balance of the meeting.
of Energy,'the NRC Sta!T, their - , The Subcommittee will then hear The Subcornmittee will then hear presentations by and hold discussions respective consultants, and other presentations by and hold discussions Interested persons regarding this teslew..
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- ' ATTACHMENT B REVISION #6 Feb. 4, 1985 TENTATIVE SCHEDULE FIRE PROTECTION SUBCOMMITTEE MEETING FEBRUARY 5, 1985 WASHINGTON, D.C.
8:30 - 8:35 a.m. Comments by Chairman - C. Michelson 8:35 - 12 N00N I. Staff Presentation 8:35 - 9:35 a.m. A. Appendix "R" Reviews. Discussion of the problems in achieving compliance with Appendix R 9:35 - 10:00 a.m. B. Discussion of the DP0's on Fire Protection 10:00 - 10:30 a.m. C. Discussion of Section 7.J of the Branch Technical position, " Diesel Fuel Oil Storage areas." Discussion of how justifications of deviations from this B.T.P. are documented 10:30 - 10:45 a.m. BREAK 10:45 - 11:00 a.m. D. Generic Issue 57 " Effects of Fire Protection System Actuatica on Safety
- Related Equipment." This was scheduled to be prioritized in Jan.
1985. What is thg, priority?
11:00 - 12 NOON E. Progress Report by Sandia on Fire Protection Research including budget constraints.
12:00 - 1:00 p.m. LUNCH II. Utility Experiences with Appendix "R" 1:00 - 2:00 p.m. A. Calvert Cliffs 2:00 -
2:15 p.m. IV. Toutellotte Comments on Appendix "R" Backfits e
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. Agenda / Fire Prot ction i Mtg., Feb. 5, 1985
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- 2:15 - V. Comments on Inadvertent Actuation of Fire 2:30 p.m. Protection System ,
l C. Michelson will submit a written request on this l topic to the staff, prior to the meeting. The request will ask for a written response. This time .
will be allocated for any comments by the staff at this time.
2:30 -
3:00 p.m. VI. Subcommittee Discussion and ADJOURN 9
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i FIRE PROTECTION
',ACRS SUBCOMMITTEE MEETING ON _
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ATTACHMENT C LOCATIO.1:
Roon 1046,1717 H St. NH., Washinoton. D.C.
DATE:
February 5,1985 ATTENDANCE LIST PLEASE PRINT:
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ATTACHMENT D 1
HANDOUTS l '. History and Chronology of Fire Protection V. Benaroya
- 2. Generic Issue 57 - Effects of Fire Protection System Actuation H. Vandermolen
- 3. History of Fire Protection Activities at Calver Cliffs P. Katz
- 4. Fire Protection Research at Sandia D. Berry
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