ML20154G960
| ML20154G960 | |
| Person / Time | |
|---|---|
| Site: | Maine Yankee |
| Issue date: | 10/05/1998 |
| From: | Zinke G Maine Yankee |
| To: | NRC OFFICE OF ADMINISTRATION (ADM) |
| References | |
| FRN-63FR40141, RTR-REGGD-01.XXX, RTR-REGGD-1.XXX, TASK-*****, TASK-RE 63FR40141-00003, 63FR40141-3, GAZ-98-53, MN-98-63, NUDOCS 9810140027 | |
| Download: ML20154G960 (5) | |
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P. .B x 4 8.wiscasset, Maine 4578.(207)882-6321 1998 0CI -7 A'l W 09 3
. . o r.u October 5,1998 MN-98-63 GAZ-98-53
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y Rules and Directives Branch Office of Administration L United States Nuclear Regulatory Commission Washington DC 20555-0001 I
Reference:
(a) License No. DPR-36 (Docket No. 50-309)
Subject:
Comments on Draft Regulatory Guide DG-1069 " Fire Protection Program for Nuclear Power Plants During Decommissioning and Permanent Shutdown"; July 1998.
E We appreciate the opportunity to offer comments on the subject dran regulatory guide. As a plant well into the decommissioning process, we are interested in the staffs position regarding the implementation of 10CFR50.48(f) and recognize this draft r;uiJe is the initial step in establishing the regulatory framework for fire protection under the new rule.
Attached are our comments on certain aspects of the draft guide. If you have any questions, please contact us.
Very truly yours, George A. Zinke, Director Nuclear Safety and Regulatory Affairs Attachment c: Mr. Hubert Miller Mr. Michael Masnik Mr. Mark Roberts Document Control Desk
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- 9810140027 981005 PDR REGOD 01.XXX C PDR E'
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-* ATTACHMENT )
SPECIFIC COMMENT.i ON J DRAFT REGULATORY GUIDE DG-1069 FIRE PROTECT!ON PROGRAM FOR NUCLEAR POWER PLANTS 1 DURING DECOMMISSIONING AND PERMANENT SHUTDOWN >
r item (1) i Section B and Section C.l.l.1 (Objectives)
Maine Yankee Comment l Section B and Section C.I.l.1 (Objectives) inappropriately expands the fire protection program objectives by leaving out key words from the regulation.10CFR50.48(f) clearly limits the scope of the objectives to those fires which could result in a radiological hazard. During the operation phase of a nuclear power plant, " radiological hazard" is related to 10CFR100 and protection of the public. Although fire protection a usually does not directly affect dose, both 10CFR50.48 and 10CFR Appendix R clearly describe fire
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- protection goals in terms its protection of systems and system redundancies which do directly mitigate accident consequences. The definition of" radiological hazard" in Appendix A of the draft regulatory guide should be revised to reflect hazards which could cause exposures exceeding 10CFR100 or other !
appropriate licensing limit,- 1 The rulemaking which added 10CFR50.48(f) [ reference 60FR37374, dated 7/20/95 and 61 FR39278, dated 4 7/29/96] specifically stated the requirement was being added to maintain a fire protection program. There is no indication that the rule was intended to increase the fire protection such that the goals were more ;
stringent than those for an operating plant. l l
l Item (2) i Section B states in part:
.....For an initial period following shutdown, accidents that can challenge the 10CFR Part 100 limits remain credible. The fire protection program should continue to provide protection against these events. Afbr a period of radionuclide decay and reduction in heat load, a determination can be made that the maximum credible accidents do not require offsite emergency protective actions. After that determination has been made, the primary fire protection concern for permanently shutdown plants is protecting the integrity of the spent fuel and preventing or minimizing the release of radioactive materials resulting from fires involving contaminated plant SSCs or radioactive wastes. The radiation dose limits specified in 10 CFR Part 20, " Standards for Protection Against Radiation," apply to plant personnel and l
members of the public for fire incidents at permanently shutdown nuclear power plants. Licensees should l make every effort to maintain exposures to radiation resulting from a fire as low as reasonably achievable."
l-10 CFR Part 20 limits are identified as controlling in Section C and Appendix B as well.
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Maine Yankee Comment There is no precedent of which we are awarejustifying the imposition of 10 CFR Part 20 limits to accident conditions or incidents such as fires on Part 50 licensees.(Maine Yankee assumes the limits referred to are those contained in sections 20.1301 and 20.1302, i.e.100 mrem / year.)
The regulatory guide position recognizes that Part 100 limits apply during operation and for some time after shutdown and proposes a change to more restrictive Part 20 limits at some later time..
We believe that 10CFR20 establishes limits for normal plant operations and effluents but is not the appropriate regulation as applied to accident scenarios including fires. The applicability of a particular regulation does not change just because a plant submits a cessation of operations letter unless the change in applicability is specified in the body of the regulation, as in the case of 10CFR50.49, Neither Part 20 nor Part 100 has been revised to indicate any change in applicability as a result of the decommissioning process. Rulemaking accompanied by backfit analysis would be necessary to legitimize this draft staff position.
'Ihe regulatory guide is advocating that the limits of Part 100 be ceplaced by Part 20 after a period of radionuclide decay and reduction in heat load has deterrr.med that the " credible" accidents do not require offsite emergency protective actions. This discussion in.ippropriately mixes certain topics. Emergency Plans are required to consider " credible" accident scenarios which may be outside the design basis of a plant. However, fire protection programs, and fire protection designs in particular, are part of the design and license basis; therefore, the set of accident scenarios applicable fire protection vs. emergency plans is not identical. The staff should be clear that it is not requiring fire protection programs and designs to protect against new non-design basis scenarios.
Likewise the reference to ALARA seems out of place. Although it is certainly a practical consideration during accidents to keep exposure ALARA, that is not a design goal of the fire protection system in accordance with General Design Criteria 3 (10CFR50). ALARA (10CFR20.1003) has regulatory meaning in the context of normal operations, not accident prevention and mitigation.
The regulatory position should retain 10 CFR 100 as the appropriate limit unless the licensee establishes a different license limit. For example, if emergency plan changes establish a lower radiological limit. it is reasonable for the fire protection basis to be consistent with the new emergency plan license basis.
Item (3)
Section 1.4 states in part:
l l "As decommissioning progresses and the spent fuel is moved to an independent storage facility or l permanent repository, the fire protection requirements for the plant may be scaled down in accordance with j the radiological hazard. However, even in the absence of spent fuel in the spent fuel pool, a fire protection l program should be maintained that ensures adequate protection from the fire-induced release of radioactive j material from contaminated plant areas and combustible wastes."
Maine Yankee Comment Maine Yankee agrees with the statements in section 1.4, but would point out the context of the section more appropriate to the SAFESTORE option rather than DECON. In the year since filing a letter of permanent cessation, Maine Yankee has performed RCS decontamination, removed decontamination resins
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- e from the site as well as most resins from process systems, reconfigured the spent fuel pool into a self contained nuclear island, and have taken most of the rest of the plant to a " cold and dark" condition. Our calculations indicate that a complete loss of cooling to the spent fuel pool will no longer result in boiling or significant loss of water inventory or any radiological release..
Maine Yankee has examined the PNL analyses presented in Appendix J of NUREG\CR-0130 for the remaining fire hazards applicable to Maine Yankee, i.e. explosion of LPG leaked from front end loader, explosion of Oxyacetylene during segmenting of the reactor vessel, segmentation of RCS piping with unremoved contamination, fire in combustible waste, etc. The resulting radiological releases from these incidents have been determined to be insignificant in terms of the health and safety of the public by the authors of the NUREG.
Maine Yankee has, or will soon, reduce the fire sensitive radiological source terms to the point that a fire protection program under the purview of 10CFR50.48(f) may be difficult tojustify. Maine Yankee does recognize that State of Maine, OSHA, and other regulatory agencies sequire an industrial program for personnel and asset protection. Maine Yankee has no intention of eliminating completely the existing fire protection program even if the requirements of 10CFR50.48(f) no longer apply due to the elimination of radiological hazards .
Item (4)
Section 3 discusses in detail the Administrative Controls of a fire protection program Maine Yankee Comment Almost without exception the discussion in this section is redundant to OSilA (29 CFR 1910) and local requirements for industrial facilities as evidenced by the number of references to NFPA standards..
Consequently Maine Yankee believes this section can be limited to section 3.0 and a bibliography of NFPA standards which the staff may suggest is ofinterest to the licensees.
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l Item (5)
Section 4 discusses Physical Fire Protection Features Maine Yankee Comment l
Maine Yankee agrees with the statements and guidance presented in this section. We support the staff i position that fire detection, suppression, barriers, and manual fire fighting capabilities need to be continually reassessed in terms of the fire and radiological hazard and that the decommissioning process l will continuously reduce both the fire loading and the radiological hazard. Maine Yankee's experience to date indicates that nearly all of the Physical Fire Protection Features in the plant were designed to satisfy l the requirements of 10CFR50.48, BTP 9.2 Appendix A and Appendix R (shutdown redundant train l separation). Very few of these features appear to contribute to either personnel safety or radiological confinement. Consequently most of these systems and components fall outside the purview of !
10CFR50.48(f) which is limited to those aspects and attributes of the plant which limit radiological hazards.
Item (6)
Appendix B - Examples of Fire Protection for Selected Fire Areas, Structures, Systems, and Components ,
1 Maine Yankee Comment Fire Protection component design had specific design objectives during plant operation. Many of these objectives only pertained to plant operation such that even in refueling outages, compensatory measures for inoperable fire protection SSC's were temporarily reduced or eliminated. Statements such as " rated fire barriers should be maintained . . " must be consistent with their original design and license basis function.
Statements like " smoke detection and fire suppression capability for the spent fuel pool area should be provided" are only true if the operating plant license basis required such fire protection measures and if the reduced risk stilljustifies them; otherwise such statements constitute a backlit.