ML20151K383
| ML20151K383 | |
| Person / Time | |
|---|---|
| Site: | Haddam Neck, 05000000 |
| Issue date: | 09/21/1984 |
| From: | Harold Denton Office of Nuclear Reactor Regulation |
| To: | Ferguson R Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20151H089 | List:
|
| References | |
| FOIA-88-92 NUDOCS 8410040113 | |
| Download: ML20151K383 (3) | |
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% # September 21, 1984 MEMORANDUM FOR: Robert L. Ferguson Chemical Engineering Branch Division of Engineering )
1 FROM: fHarold R. Denton, Director '
Office of Nuclear Reactor Regulation
SUBJECT:
DIFFERING PROFESSIONAL OPINION REGARDING HADDAM NECK FIRE PROTECTION l
This memorandum responds to your differing professional opinion (DPO) dated l February 24, 1984. As you know, I assigned Mr. Faust Rosa to provide an ;
independent assessment of your views. He concluded that no modifications to !
the pending safety evaluation by Messrs. Fioravante and Kubicki were justified by your DPO. I subsequently met with you on several occasion:: to discuss the issues you had raised. On September 4,1984, you accompanied me and l Messrs. Rosa, Fioravante, and Kubicki on a site visit to Haddam Neck, where we reviewed the utility's overall approach to fire protection and specifically
-\ examined the utility's proposals for the control room.
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/ The areas reviewed at the site included: existing and proposed fire detection systems, and manual and automatic fire suppression systems; the design of a new instrument panel and a safety system lockout display panel; procedures to limit transient combustibles; installation of ramps and seals to mitigate flammable liquid spills; smoke removal capability and self-contained breathing apparatus; and operator actions in the event of a control room fire.
Bas.ed on your written opinion and our discussions, I understand your concerns to be as follows:
- 1. The alternate shutdown capability proposed by the licensee for control room fires is not adequate to assure that the plant can reach and maintain hot shutdown from outside the control room for a prolonged time period.
- 2. The licensee does not have procedures to close the reactor coolant system power-operated relief valves (PORVs) and the main steam isolation valves (PSIVs) from outside the control room.
- 3. Any exemption granted to the licensee should be from the
}y requirements of Section III.G.3 rather than III.G.2.
s N(In Ir. reaching Rosa, and athe decision in this information matter, I obtained I have during theconsidered your views, thos site visit. I have cuncluded that the licensee has provided adequate justification for en ex t4on-from-the-specific requirements of Appendix R for the control room.
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Robert L. Ferguson My reasoning is as follows. First, I believe that the fire detection, and suppression measures taken (or comitted to) prevention, b the licensee substantially reduce the likelihood of a major fire in the control room capable of damaging redundant circuits or rendering the room uninhabitable.
- Second, the licensee has taken, or comitted to, procedures to reduce the possibility of transient combustible fires in the control room. Third, the licensee has comitted to providing a smoke removal system and breathing air sys't ems for the control room which give assurance that, even in the event of a substantial fire, the control room would remain inhabitable or would be uninhabitable for a very brief period. Fourth, the licensee has comitted to provide substantial instrumentation and control capability independent of the control room, and the capability within the control room but independent of the main or auxiliary control boards for assuring the isolation of PORVs and MSIVs. Fifth, the licensee has described a safe shutdown method which does not assume use of the control room (except for manual scram and isolation of PORVs and MSIVs) and has comitted to providing detailed procedures for this method. These procedures achieve safe shutdown with loss of the main control board or the auxiliary control cabinet. In regard to this point, at my.
instruction the Division of Human Factors Safety reviewed the feasibility of this method and found it to be acceptable. The final procedures will also be subject to NRC approval.
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I recognize that the licensee's approach for control room fires at Haddam Neck represents a mixture of III.G.2 fire protection measures and III.G.3
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alternative shutdown measures, while not meeting either provision in totality.
The proposed outside-of-control-room shutdown method does rely more heavily on operator actions, as opposed to hardware additions and modifications (relays, switches, cable rerouting, etc.), than we have accepted at other facilities.
As you are aware, however, the Haddam Neck plant is a comparatively small, simple facility where manual procedures are more feasible, and may be taken more rapidly, than in recent-vintage, complex plants. In my view the approach taken by the licensee in this instance provides an adequate level of fire protection for control room fires while not introducing needless additional hardware which could reduce overall plant safety or reliability.
I am therefore able to conclude that, while the licensee does not meet either II.G.2 or III.G.3 in their entirety for the control room, the licensee does meet the fundamental design objective set out in III.G.I.a. which is to assure that one train of systems necessary to achieve and maintain hot shutdown is free of fire damage and thus available to perform its shutdown functions.
After consulting with OELD, I am instructing that the exemption be from both III.G.2 and III.G.3, accompanied by an explanation of the measures proposed by the licensee and the basis for our conclusion that such measures provide an adequate level of fire protection. As a condition to the exemption, the licensee will be required to provide a human factors review, after completion of modifications, demonstrating that operators can perfom the necessary actions outside of the control room in a timely and effective manner.
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Robert L. Ferguson I want to comend you, Mr. Rosa, and the others involved in'this issue for your dedication and professionalism. Pursuant to the procedures for resolving a Differing Professional Opinion, Manual Chapter 4125, I consider the DP0 resolved.
/ w Harold R. Denton, Director Office of Nuclear Reactor Regulation
Enclosure:
As stated -
cc: W. Dircks E. Case R. Bernero R. Vollmer D. Eisenhut T. Speis B. Snyder H. Thompson
'( W. Johnston F. Rota V. Benaroya
/ 0. Parr D. Kubicki N. Fioravante J. Funches G. Edison P. B. Cotter, ASLBP A. S. Rosenthal, ASLAP e
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MEMORANDUM FOR: Fire Protection Policy Steering Comittee l FROM: Richard H. Vollmer, Chairman l
Fire Protection Policy Steering Comittee i l
SUBJECT:
AGENDA FOR SECOND MEETING l
l The second meeting of the Fire Protection Policy Steering Comittee will be I held at 9:00 a.m. on September 27, 1984 in Room P-202 A. At this meeting we l
will be briefed on the Working Group activities and on current inspection content and schedules and have the benefit of the IE and NRR Office Director's i views on our activities. Our tentative schedule is as follows: 1 9:00 a.m. Executive Session 9:30 Harold Denton and Ed Case l 10:00 Dick DeYoung and Jim Taylor l 10:30 Faust Rosa will discuss Working Group activities 1:00 p.m. Steve Richardson will discuss Appendix R inspections l 2:00 Comittee work l In addition to our consideration of issues raised by the above agenda items, I we need to consider policy approaches to deal wit'h technical and schedular ,
l exemptions which put implementation of Appendix Ji into the distant future.
Any approaches you have to deal with this issue will be welcomed.
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Richard H. Vollmer, Chairman Fire Protection Policy Steering Comittee cc: W. Dircks V. Stello H. Denton ,
R. DeYoung T. Murley R. Minogue J. O'Reilly J. Keppler J. Collins J. Martin G. Cunningham E. Case J. Taylor D. Eisenhut R. Bernero -
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MEMORANDUM FOR: Harold R. Denton, Director, ONRR l Richard C. DeYoung, Director, OIE l Thomas E. Murley, Regional Administrator, R-I '
James P. O'Reilly, Regional Administrator, R-II James G. Keppler, Regional Administrator, R-III John T. Collins, Regional Administrator, R-IV John B. Martin, Regional Adninistrator, R-V FROM: Richard H. Vollmer, Chairman Fire Protection Policy Steering Comittee
SUBJECT:
NRC FIRE PROTECTION MEETING j
The Fire Protection Policy Steering Comittee requests that the fire protection engineers in your organization attend a meeting in Bethesda on October 2, 1984, to give their views on licensing and inspection fire protection issues. ,
This is an information gathering session to help the l Comittee formulate its policy recommendations. A candid discussion of how these issues are viewed by the fire protection reviewers and inspectors, and recomendations they may have, would be welcome. A meeting agenda 1 is enclosed. '
ichard H. Vollmer, Chairman Fire Protection Policy Steering Conunittee
Enclosure:
Agenda cc: W. Dircks V. Stello R. Minogue G. Cunningham E. Case J. Taylor, IE
- 0. Eisenhut R. Bernero G. Arlotto, RES F. Rosa N. Grace, IE L. Spessard, R-III W. Olmstead, ELO J. Olshinski, R-II T. Wambach
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l NRC Fire Protection Meeting Date: October 2, 1984 at l
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Location: P-422 Phillips Building l l
1 9:00 a.m. Opening Remarks - R. Vollmer 9:10 Region I Remarks l 9:40 Region II Remarks 10:10 Region 111 Remarks 10:40 Region IV Remarks 11:40 Brookhaven Remarks 1:00 p.m. NRR Remarks 2:00 I&E Remarks 2:30 to 4:00 Group Discussion 4:00 to 5:00 Each group given opportunity to provide any additional comments. !
5:00 Adjourn 1
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f.6 MEMORANDUM FOR: Faust Rosa, Chairman Fire Protection Working Group FROM: Richard H. Vollmer, Chairman Fire Protection Policy Steering Committee
SUBJECT:
ASSIGNMENTS FOR FIRE PROTECTION WORKING GROUP At the first meeting of the Fire Protection Policy Steering Comittee, the Comittee assigned action tasks to the Working Group. The purpose of this memo is to provide better focus a the Working Group assignments as a result of the second and third Committee meetings.
The Working Group's first priority should be the revision of the enclosure to the Generic Letter discussed at the fire protection workshops. This package should include answers to the questions posed by industry and revision of the "interpretations" section to utilize clarifying aspects of the DP0 and to emphasize the level.of fire protection expected by staff guidance, e.g.,
Generic Letter 83-33, and the documentation necessary to dernonstrate ecuiva"-
lence to staff guidance. This package should not contain any new guidance
(' and should be internally' consistent and consistent with the Comittee's proposed policy on the "interpretations." To the extent possible criteria acceptable to the staff should be clearly identified. This package should be available for Comittee review by October 12 and whatever efforts are necessary to meet this date should be expended.
Bill Shields will. prepare a draf t of the Generic Letter in whicn he will lay out the elements for expediting Appendix R implementation. It will discuss the proposed polic9 on schedular exemptions, the proposed augmentation of plant inspections, and indicate generally what is expected of licensees and what enforcement action may occur. In additio.n, it was agreed that the 50.48 schedule expirattun for each. plant would be indicated.
The item of next priority is the development of an inspection plan which would accomplish the objectives of a "helpful" inspection. That is, in a one week, four-man inspection, we need to find out how the licensee is approaching his Appendix R implementation, the status of the plant with respect to compliance, and plans and schedules for complete implementation.
This inspection should identify improper paths being taken by the lice e, and allow the staff to assess current fire protection safety and need t..- any plant specific enforcement action.
Finally, the Working Group should compare fire protection requirements for ors and NTOLs and work on any outstanding technical issues. The outline
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. Faust Rosa - 2-you provided of the Working Group's program review appears f ar too ambitious in view of current time and resource constraints. We should discuss this further, at our October 10 meeting in Atlanth.
r-Richard H. Vollmer, Chairman Fire Protection Policy Steering Committee cc: Steering Committee W. Dircks H. Denton R. DeYoung E. Case ,
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l MEMORANDUM FOR: Harold R. Denton, Director, ONRR U _
l Richard C. DeYoung, Director, IE -
FROM: Richard H. Vollmer, Chairman sr// /y Fire Protection. Policy Steering Committee ,
SUBJECT:
FIRST COMMITTEEMEETING OF FIRE PROTECTION POLICY S Sumary At its first meeting, the Fire Protection Policy Steering Committee (SC) discussed the issues identified in the EDO memo of Septe'mber 13, 1984 The SC made the following recomendations and assignments:
. the SC recommended that Appendix R implementation policy follow the "Interpretations" discussed at the Regional Workshops, as modified by details discussed below, rather than requiring prior staff review or exemptions for deviations from Generic Letter 83-33;
. . the SC recommended that the issuance of the fire protection enforcement policy and enforcement actions be expedited;
. the SC recommended that QA for fire protection be clearly defined as that required by GDC-1; and
. the SC assigned to the Working Group tasks dealing with the adequacy of available guidance, comparison of fire protection requirements for ors and NT0Ls, the adequacy of current inspection practices, and identification of outstat ding
- technical issues. l Introduction l l
As a result of the ED0 memo of September 13, 1984, regarding a review of I NRC fire protection policy and programs, the SC held its first meeting
- on September 13 and 14 The objectives of this meeting were to:
"Attended by: i. Martin, J. Olshinski, L. Spessard, N. Grace, ! Rosa, i S. Richardson, W. Shields, W. Little, T. Wambach, W. Olmstead, t. Cyr l and R. Vollmer. l l
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. discuss the background leading to the formation of the SC;
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. establish a general charter, objectives, schedule, and working arrangements; and
. discuss issues currently in hand and make decisions for resolution if appropriate.
The discussion of background included the events leading up to and includ-ing the fire protection regional workshops, the May 30, 1984 meeting with the Commission, the August 27 meeting with the EDO, and the events surrounding the DP0 signed by three fire protection reviewers and two inspectors. As part of this background, ELD representatives discussed the Rule and the distinction between its legally enforceable requirements and staff guidance issued subsequent to the Rule. The background dis- l cussion also focussed on the issues identified in the ED0 memo of Septemoer 13.
Charter and Schedule The charter of the SC is the review of NRC fire protection policy and programs leading to policy recommendations which would expedite compliance with Appendix R at older plants and assure consistent levels of fi.c protection safety at all plants. To implement this Charter the SC agreed
( that current licensing, inspection, legal, and technical issues needed to be examined. The SC's objective wo.ld be to make specific recommenda-tior.s to the EDO which could be carried out (1) within the existing framework of 50.48 and Appendix R, and (2) without making a disruption in the effort already underway to implement fire protection requirements.
The SC wculd attempt to make recc=mendations that could be immediately l effective. However, we recognize that there may be some instances in which further study was needed. In such cases, we agreed to recommend a specific assignment and end date for such study. Finally, the SC agreed that its work would be completed through issuance of its report to the EDO by October 26, 1984.
Working Arrangements The SC discussed how it cou'd use the available resources most effectively.
It was d?cided that the SC would not need to meet at this time with HQ and Regional people since their views have been expressed extensively in written and transcribed material. The SC did not feel the need to meet with industry for the same reason. However, the SC does wish to meet with Vic Stello and hereby of*ers the opportunity of a meeting with the recipients of this memo. ,
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The SC will take advantage of the Working Group chaired by Faust Rosa
-and make assignments to that group and to certain individuals. It was our belief that use of currently available resources, including the Working Group, would be sufficient to achieve our objectives and schedule.
Issues
- 1. Adequacy of current guidance to industry.
The SC felt that enough guidance has been generated but that it needed to be made consistent with our recommendations and cleared up technically in some areas. The mechanism for this would be a generic letter, super-ceding previous guidance, to be sent to all licensees 2.s promised at the regionat workshops. This generic letter would be sent to the Commission, as requested at the Commission's May 30 meeting, before being issued to industry. The SC agreed that it would be best to utilize guidance already available, to the extent possible, to minimize possible confusion both within industry and the NRC. It was also agreed that we should utilize either Generic Letter 83-33 or the "Interpretations" rather than a third option for dealing with the exemption issue. This is discussed below.
The Working Group was tasked with reviewing all current guidance and outstanding technical questions and to revise the Regional Workshop
( package to incorp:wate in one place a comprehensive set of guidance that is consistent with the SC's policy recommendations and the approved technical recommendations of the Working Group. ;
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- 2. Interpretation of the Appendix R requirements vice staff l guidance.
l The basic issue is whether industry can deviate frem the contents of !
Generic Letter 83-33 without prior staff review and approval. This l issue is fully developed by the current Staff DPO. The SC had the benefit i of ELD's views and Faust Rosa's recommendations resulting from=his assign-ment by Mr. Denton to make an independent assessment of this DPO. The SC decided that it could only support the contents of 83-33 as guidance l to industry, consistent with the "Interpretations" drafted for the Regional Workshops since ELD advised that Generic Letter 83-33 stated requirements which went beyond the terms of Appendix R itself.
However, the SC also felt that some of the clarifying language contained in the DP0 should be utilized and that specific guidance should be supplied to clearly indicate the level of fire protection to be achieved and the documentation necessary to demonstrate it. In 6ddition, the SC felt that, at an appropriate time prior to the Appendix R inspection, the licensee should be requested to provide information necessary to
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- support the inspection for HQ and regional review. In addition, the licensees should be encouraged to meet with the staff to discuss plans
-before extensive hardware modifications are initiated.
The Working Group was tasked to work on language to support this recom-mendation.as part of its work on item 1.
- 3. Treatment of expected future technical and schedular exemptions into late 1980s and early 1990s.
This item was discussed extensively and tabled when no clear direction was apparent. The concern is that some licensees may unduly request staff reconsideration of technical findings and/or implementation schedules which would in effect defer compliance. This item will receive priority consideration.at the next meeting and no assignments were made. However, the SC felt strongly that the fire protection enforcement policy and current enforcement packages consistent with that policy should be issued promptly to aemonstrate NRC resolve in this area and that the backlog in NRR be processed expeditiously.
- 4. Comparison of Appendix R and current NT0L plants for fire protection safety.
Based on statements made at the May 30 Commission meeting and correspond-
/ ence from the Regions, there may be differences in the licensing evaluation
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and inspection prectices for Appendix R plants and NT0Ls. The Working Group was tasked with investigating if such differences do exist and how the goal of consistent levels of fire protection safety at all plants might be achieved. In pursuing this, it was suggested that the Working Group meet with representatives from HQ and the Regions active in fire protection reviews and inspections. It was also acknowledged that the existing Temporary Instruction for Appendix R safe shutdown inspections must be revised to be consistent with the new interpretations. The Working Group must also verify that the guidance documents referenced in I the Temporary Instruction for use by the inspectors have been officially I sent to all licensees and applicants.
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- 5. Acequacy of current inspection practices.
The SC was informed that consistent inspection practices and schedules have been set up for Appendix R plants but that the NT0Ls have been handled on a somewhat ad hoc basis. Some regions have instituted a fa rly extensive review of the capability to achieve a safe shutdown l following a fire and others look mcre at SER-specific hardware items.
Steve Richardson of IE was tasked with reporting to the SC, at the next l neeeting, on current inspection content and schedules for all classes of plants, suggestions for modifying current practices, and, specifically, when the NTOL's should be inspected to assure effective compliance with NRC's fire protection requirements.
- 6. Identification and resolution plan for outstanding technical issues.
The Working Group was requested to identify any outstanding technical issues that impede Appendix R compliance. These will t'e discussed with the SC and a plan and schedule for resolution will be developed. One issue that was discussed is the QA standard to be applied to fire protection compliance. The SC felt strongly that the requirements of GDC-1 apply to fire protection features, recognizing that the activities are underway to resolve the GDC-1/ Appendix B and safety-related/
important-to-safety issues. Without trying to muddy the water in these areas, the SC felt that, at minimum, licensees be made aware that the fire protection. program falls under GDC-1. The Working Group should look into this also and review the QA commitments made by some licensees in their pre-Appendix R SERs.
The next meeting of the Fire Protection Steering Committee will be held on September 27 at 9:00 a.m. in F-202A.
Richard H. Vollner, Chairman Fire Protection Policy Steering Committee cc: W. Dircks V. Stello R. Minogue T. Murley J. O'Reilly J. Martin E. Case J. Taylor
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R. Bernero G. Arlotto F. Rosa (10) 1 SC Members l l
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, m MEMORANDUM FOR: Fire Protection Policy Steering Comittee FROM: Richard H. Vollmer, Chairman Fire Protection Policy Steering Comittee
SUBJECT:
AGENDA FCR THE FOURTH MEETING The fourth meeting of the Fire Protection Policy Steering comittee will be held at 9:00 a.m. on October 10, 1984 in the Region II offices in Atlanta. At this meeting we need to reach agreement on the enforcement policy guidance and develop our decision, reached at the second meeting and fortified in the third meeting, on a FY 85 inspection for most plant types. I request that John prepare a rewrite of the enforcement policy and Nelson a general plan for inspections for Comittee consideration.
Other items we need to discuss are:
. Focus of inspections relative to fire protection and safe shutdown;
. Working group assignments; What should be included in technical specifications;
. Resolution of licensee / inspection team disputes; and
. Disputes of issues raised at third meeting. l I hope at this meeting we can agree on our overall approach to make our recomendations to Dircks coherent and consistent so that we can begin writing to have a draft report ready at our fifth meeting.
l Richard H. Vollmer, Chair an Fire Protection Policy teering Comittee cc: See next page
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October 12, 1984 MEMORANDUM FOR: Harold R. Denton, Director, NRR Richard C. DeYoung, Director, OIE FROM: Richard H. Vollmer, Chairman -
Fire Protection Policy Steering Committee
SUBJECT:
SECOND MEETING OF THE FIRE PROTECTION POLICY STEERING COMMITTEE HELD ON SEPTEMBER 27, 1984 Summary At its second meeting, the Fire Protection Steering Committee (SC) con-sidered policy approaches to deal with technical and schedular exemptions which threaten to put Appendix R implementation into the distant future, discussed SC activities with the IE and NRR Office Directors and Deputies, and was briefed on Working Group activities. As a result of this meeting, the SC made the following decisions:
the SC decided to hold a meeting with all HQ and Regional fire protection engineers, as a body, to candidly discuss their views
.on fire protection issues, problems, and possible future actions; the SC decided that the most promising way to expedite Appendix R compliance is to initiate an aggressive inspection program which would steer and promote licensee compliance, assess the degree of fire safety, and exercise enforcement policy where appropriate; and the SC decided that no further schedular exemptions should be granted.
Discussion
- 1. Meeting with Office Directors and Deputies.
The SC met with Messrs. Denton, DeYoung, Case and Taylor to discuss their views on the fire protection problems, potential solutions, and SC activities. They. viewed the problem as a lack of staff cohesiveness in a highly judgemental area exacerbated by industry reluctance to meet Appendix R '
requirements. They felt that a meeting between the HQ and Regional fire protection staff to air any problems, issues, and possible solutions, would benefit the SC's work. We agreed and set up such a meeting for October 2nd.
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- 3. Technical issues.
Two technical issues were identified to be pursued by the Working Group:
(1) the Dow Corning ascertion that penetration material was not being properly installed; and (2) whether our criteria on control room fires are appropriate and consistent.
- 4. Working Group discussion. ..
Faust Rosa discussed the Working Group activities, in particular, the out-line of the Working Group report. All items of interest to the SC were covered in the outline of this report. However, it appeared that com- -
pletion of the work as outlined was too ambit.ious for the time and resources provided. The SC indicated that priority attention be given to the completion of the generic letter package. The SC also indicated in its first meeting that the Woi king Group should compare fire protection requirements for ors and NTOLs, review the adequacy of' current inspection practices, and identify outstanding technical issues. These tasks should proceed except for the review of inspection practices which is superceded by the development of the program described in item 2 above.
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ichard H. Vollmer, Chairman Fire Protection Policy Steering Comittee cc: W. Dircks -
V. Stello H. Denton R. DeYoung R. Minogue T. Murley, R-I J. O'Reilly, R-II ,
J. Keppler, R-III J. Collins, R-IV J. Martin, R-V G. Cunningham E. Case J. Taylor D. Eisenhut R. Bernero G. Arlotto - -
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MEMORANDUM FOR: Fire Protection Policy Steering Comittee )
l FROM: Richard H. Vollmer, Chairman Fire Protection Policy Steering Comittee '
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SUBJECT:
AGENDA FOR THE FIFTH MEETING l The fifth meeting of the Fire Protection Policy Steering Comittee will be l held at 9:00 a.m. on October 17, 1984 in Room P-202A. At this meeting you I should be prepared to discuss the generic letter and its attachments relative to the ability of these documerits to satisfy Steering Comittes decisions. We should also be prepared to settle on the enforcement policy 1 guidance and the inspection module revision if these are available. Finally we will need to discuss format, content, and writing assignments for our October 26 report to the EDO.
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ichard H. Vollmer, Director Fire Protection Policy Steering Comittee cc: W. Dircks V. Stello H. Denton R. DeYoung i R. Minogue l T. Murley, R-1 l J. O'Reilly, R-II i J. Keppler, R-III !
J. Collins, R-IV J. Martin, R-V G. Cunningham E. Case J. Taylor D. Eisenhut R. Bernero )
G. Arlotto l F. Rosa . 1 I
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, AT L Ast A.cLORGI A 30m 00116 54 MEMORANDUM FOR: Files -
FROM: W. H. Miller, Jr. , Reactor Inspector (Fire Protection)
P. M. Madden, Reactor Inspector (Fire Protection)
G. R. Wiseman, Reactor Inspector (Fire Protection)
SUBJECT:
NRC OCTOBER 2, 1984 FIRE PROTECTION MEETING On October 2, 1984, the NRC Fire Protection Policy Steering Committee conducted a meeting with the NRC Fire Protection Engineers to obtain views on fire protection licensing and inspection issues. An outline of the general topics discussed by the various participants is enclosed. Region II's briefing notes are also enclosed. .
This meeting was informative and the open discussion should be beneficial to help the Committee formulate policy recommendations, i t s~
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Dis'cussion Topics NRC Fire Protection l Meeting, October 2, 1984 1 cc w/ encl: i R. Vollmer, NRR l
J. Olshinski, RII '
T. Conlon, RII S. Pullani, RI J. Ulie, RIII M. Murphy, RIV W. Miller, RII P. Madden, RII l G. Wiseman, RII l A- g^,
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ENCLOSURE DISCUSSION TOPICS NRC FIRE PROTECTION MEETING OCTOBER 2, 1984 I. Region I (S. Pullani)
A. Reported on results of Appendix R inspections conducted within Region I. ..
B. Licensee's Appendix R evaluation and Fire Hazards Analysis Reports were normally available at plant sites for review by the NRC inspections.
C. Exemption request for Salem were submitted to NRC just prior to Appendix R inspection.
D. ' Region I requested that the NRC/ Utility workshop Appendix R interpretations be issued as soon as possible in order to resolve the I
level of NRC and licensee confusion.
II. Region II (W. Miller, P. Madden and G. Wiseman)
.t NOTE: Refer to Attachment A - Region II briefing notes.
III. Region III (C. Ramsey and J. Ulfe) .
A. Supported Region II comments.
B. Fire Protection QA Program deficiencies and appropriate enforcement actions should be established.
C. Technical Specifications should be revised to include fire protection features presently omitted (i.e., fire damper inspection and operability testing).
D. An inspection module should be developed for Appendix R items at NT0L plants.
E. Three improvements which should be made in existing fire protectior. I program are:
- 1. Issue fire protection enforcement policy. !
- 2. Establish minimum fi re protection requirements (i.e., NFPA standards).
- 3. Consistent inspections:
s (a) Adequate inspection procedures. ;
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we (b) Qualified inspectors.
(c) Training program for inspectors.
F. Three undesirable features in current program:
- 1. Inadecuate fire prote: tion a.alysis by the licer. sees.
- 2. Unclear regulatory requirements.
- 3. Inadequate SERs based 'on reviews of the license's inadequate analysis.
IV. Region IV (M. Murply)
A. Provided inspection history of two NTOLS and two pre-1979 plants.
B. Suggested areas of improvement:
- 1. Fire protection enforcement policy.
- 2. Improved inspectors, acceptance criteria.
-s 3. Revised Technical Specifications. -
. . , V. Brookhaven National Laboratory (H. Thomas and A. Coppula)
A. Appendix R requirements for NTOL plants should be clearly defined.
B. Criteria on loss of control room by fire should be established.
C. Actions required by licensee prior to evacuation of Control Room should be established.
D. Criteria should be established for required actions in fire involving multi-units combined control rooms.
E. Criteria should be developed on spurious valve operations during a fire.
F. Formal written evaluation procedures for ASB review of control room fires do not exist.
VI. I&E A. Fire Protection Enforcement Policy (J. Axelrad)
- 1. Provided background information on the development of current
. draft fire protection enforcement policy.
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- 2. Enforcement policy was not issued due to current misunderstanding of Appendix R Rule. -
- 3. Committee is to review, revise and attempt to issue an enforcement policy.
B. Appendix R interpretations (L. Wnitney).
Note: Refer to Attachment B.
VII. NRR - Fire Protection Rev.iewers (,R. Eberly, D. Kubicki and J. Stang)
A. Existing guidelines (NUREG 0800) and Generic Letter 83-33 are adequate.
B. Licensee should evaluate and identify to the NRC all Appendix R deviations and exemptions prior to the Appendix R inspection.
C. Fi.nal Committee Report should be reviewed by NRC Fire Protection
~ Engineers prior to issuance.
D. NRR staff should be consistent in fire protection reviews.
E. Good plant operational procedures are essential to assure safe plant
,_ ,, shutdown. .
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Attachments:
- 1. Attachment A - Region II Briefing Notes NRC Fire Protection Meeting, October 2, 1984
- 2. Attachment B - Appendix R Task Force .
Presentation By Leon E. Whitney IE/0QASIP/ORPB i
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L' ATTACHMENT A REGION II BRIEFING NOTES NRC FIRE PROTECTION MEETING OCTOBER 2, 1984 I. NRC's Fire Protection Program began following Browns Ferry Fire.
II. Post Browns Ferry Actions A. NRC issued BTP 9.5-l and Appendix A.
B. NRC issued Fire Protection Technical Specifications.
C. Region II plants implemented NRC guidelines and made major fire protection and prevention improvements.
D. 'NRC issued 10 CFR 50 Appendix R in February 1981.
E. Enthusiasm and cooperation of licensees within Region II towards continued fire protection improvements is decreased due to the licensee's belief that:
,'S s 1. Modifications required by Appendix A were sufficient.
- 2. Appendix R modifications are not justified.
- 3. Fire protection guidelines, requirements and interpretations are constantly changing.
- 4. NRC management has placed fire protection as a low priority item. :
III. Recommended Improvements A. Develop a consolidated NRC fire protection program. The present program is fragmented due to the assignment of fire protection l functions to a number of different management organizations.
- 1. ASB - Safe plant shutdown following a fire l
- 2. CHEB - Fire protection features I
- 3. EPLB - Offsite fire protection organization and plant fire brigade organization
- 4. LQB - Fire brigade training
Atta:hment A 2 l 7#\ .;
- 6. Licensing Guidance Branch - Fire protection system Technical Specifications
- 7. Licensing Project Manager - Fire protection modification schedule Note: Total fire protection program shoulc be uncer the sare manage. tent organization.
B. Develop and issue criteria to assure consistency in implementation of fire protection program.
- 1. Fire protection review (ASB/CHEB)
- a. Revise fire protection guidelines to include only the minimum items required.
- b. Revise NUREG 0800 to adequately address all items presently listed by BTP 9.5-1, Appendix A and 10 CFR 50, Appendix R.
- 2. Licensing Project Manager
- a. Operating licenses for all plants should contain similar fire
,_s protection requirements.
~'.. b. Technical Specifications for all plants.should be similar and contain sufficient operability and surveillance requirements for Appendix R shutdown components.
- 3. Regional Inspectors
- a. Develop inspection modules for ors and NT0Ls which cover the entire fire protection program.
(1) Permanent plant fire protection features being provided at plants under construction should be included in the inspection program.
(2) More detailed inspection criteria for operating plants to include both basic fire protection items and Appendix R fire protection features should be included in the inspection program.
- b. Provide only qualified fire protection personnel tc conduct fire protection inspections, {
- c. Develop fire protection enforcement policy that includes {
general fire protection and Appendix R violations.
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C. Program Goals
- 1. Consistency in the review of licensee's fire protection evaluations and preparation of NRC's SERs such that both of these documents match the actual "As Built" plant conditions.
- 2. Irprovec :c . u .ications bet een the NRR staf f reviewers and the Regional inspectors anc licensee invciving fire protection issues.
IV. Specific Recommendations A. Issue generic lette[81-12 and 1982 supplemental letter to all NT0Ls and plants under construction.
B. Revise generic letter 83-33 to more clearly reflect the NRC's regulations and guidelines.
1, Detection and suppression systems should be adequate to assure that one train of shutdown equipment remains free of fire damage.
In conjunction with the nuclear industry, develop minimum standards for systems which do not provide total fire area coverage.
,, 2. Fire areas must be provided to divide the plant structures into 3 compartments to restrict fire damage and to provide protection for
~, at least one safety train by passive fire barriers. If passive barriers cannot be provided, active fire protection features such as fire detection and suppression systems must be utilized.
Minimum standards should be developed for these active fire protection features.
- 3. Fixed supression systems provided at nuclear power plants often do not meet the requirements of NFPA codes and standards due to the numerous obstructions provided between the system and the floor below. Minimum design and installation standards should be developed.
Guidance should be provided for the minimum acceptable suppression system required to meet the requirements of 10 CFR 50, Appendix R, Section III.G.3.
- 4. Intervening combustibles in the form of cable insulation are often provided between redundant sa fety train components. Guidance should be provided as to acceptable means of protecting these combustibles (cable tray covers, etc.).
- 5. Transient combustibles should also be considered as an intervening combustible.
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C. Revise temporary inspection procedure TI 2515 for inspection of Appencix R shutdown components to: -
- 1. Provide minimum acceptable criteria for all items which require Regional review and approval.
- 2. I.rc rea se present inspe:tfon sample size for components and pro:ecures.
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r ATTACHMENT B APPENDIX R TASK FORCE PRESENTATION BY LEON E. WHITNEY IE/DQASIP/0RPB The Commission Memorar.dum and Order which issued 10 CFR 50.48 and Appendix R cuoted the issuing supplemental information as follows:
"It is not possible to predict the specific conditions under which fires occur and propagate."
The Memorandum and Order also stated, in part, that the uncertainties regarding fire hazards led the Commission to endorse the rule.
Interpretation Number 3 states that licensees must show equipment to be "free of fire damage" before, during, and after a fire.
Although "free of fire damace" is not explicitly defined,Section III.G.2. says that any of the three features of Section III.G.2. will maintain redundant trains free of fire damage (without further analysis). The fire protection rule allows only two other paths to compliance: The alternative or dedicated shutdown features of Section III.G.3., or an exemption based on a plant specific fire hazards analysis. 10 CFR 50.48 states that exemptions can have only one of two
-s purposes: to show that the three modifications of Section III.G.2. would not enhance fire protection safety, or would be detrimental to overall plant safety.
,_ The plant configurations described in an exemption request must, therefore, lead to equivalent (or lower) levels of fire damage as would occur given the existence of any one of the three features of Section III.G.2. I feel that this high standard (recognized to be conservative on the issuing supplemental information) should be reflected in the interpretations.
Currently, interpretation Number 3 could ea'sily be construed to approve blackened, scorched, and severely heated equipment and components which survive the fire and are barely sufficient (yet adequate) to perform their intended functions. Fire Hazards Analyses developed to support this use of the interpretations would involve non-conservative predictions of fire propagation.
These Fire Hazards Analyses would also involve non-equivalent levels of fire damage to those levels resulting had the features of Section III.G.2. been implemented. The interpretations should be worded to prevent non-conservative, mechanistic analyses.
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NUCLEAR REGULATORY COMMISSION numNorow. o. c. rosss s.7..w.*<*/ GOT 191984 MEMORANDUM FOR: Fire Protection Policy Steering Committee FROM: Richard H. Vollmer, Chairman Fire Protection Policy Steering Comittee SUBJECT : AGENDA FOR SIXTH MEETING The sixth meeting of the Fire Protection Policy Steering Comittee will be held at 9:00 a.m. on October 22, 1984 in the Region III offices. At this meeting you should be prepared to discuss and finalize versions of:
. Generic Letter and Interpretations ,
. Technical Issues Package !
. Standard License Condition !
. Inspection Module i In addition, we need to prepare our final report to the EDO. I will FAX an outline to you for your consideration today. In addition, there are a number of issues and suggestions still left hanging. For example:
the central point of contact for fire protection issue; the status of NFPA codes; what to do about Tech Specs; and the format of the workshop in advance of the expedited inspections.
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ichard H. Vollmer, Chairman Fire Protection Policy Steering Comittee cc: See next page.
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October 19, 1984 MEMORANDUM FOR: Harold R. Denton, Director, NRR Richard C. DeYoung, Director. OIE FROM: Richard H. Vollmer, Chairaan Fire Protection Policy Steering Committee -
SUBJECT:
FOURTH MEETING OF THE FIRE PROTECTION POLICY STEERING COMMITTEE Sumary At its fourth meeting, the Fire Protection Policy Steering Comittee (SC) again considered the generic letter to licensees, the enforcement policy guidance and the scope, timing and resources for the expedited fire protection inspections. The SC focussed on some of the peripheral issues which would be important to the success of the expedited inspections and other SC initiatives. At this meeting, the SC decided that:
Prior to the fire protection inspectiorrs, a workshop would be held with IE, NRR, and Regional partici' pants in the inspections to assure understanding in the objectivesy scope, and technical issues and to help provide consistency between inspection teams; A team would be established to promptly handle disputes between licensees and the inspection teams; and That a standard condition should be incorporated into all licenses, requiring maintenance of the fire protection comitments but allowing change under 50.59 which do not decrease the level of fire protection with annual reporting to the Commission of such changes.
1 Discussion l l
- 1. Expedited inspections.
The SC di. ssed the scope, timing, and resources for the expedited inspections.
or an inspection.
There was a discussion of whether this should be a review I The SC felt that the concept was one of an inspection ~
rather than a review and that the availability of enforcement was im-portant to the process. l The SC discussed resources and concluded that an adequate pool existed; however it was not clear if or how the expedited
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Harold R. Denton October 19, 1984 Richard C. DeYoung ,
cc: W. Dircks V. Stello R. Minogue T. Murley', R-1 J. 0Reilly, R-Il J. Keppler, R-III R. Martin, R-IV '
J. Martin, R-V G. Cunningham E. Case J. Taylor D.' Eisenhut R. Bernero G. Arlotto F. Rosa SC Comittee 7
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l MEMORANDUM FOR: Harold R. Denton, Director, ONRR Richard C. DeYoung, Director, OIE FROM: Richard H. Vollmer, Chairman Fire Protection Policy Steering Comittee
SUBJECT:
THIRD MEETING OF THE FIRE PROTECTION POLICY STEERING COMMITTEE, HELD ON OCTOBER 2, 1984 Sumary At its third meeting the Fire Protection Policy Steering Comittee (SC) met with the fire protection engineers from HQ and the Regional Offices to obtain their candid views on licensing and inspection fire protection issues. Coments were presented by fire protection engineers from NRR, IE, and Regions I, II, III, and IV. In addition, Jane Axelrad discussed l
' the proposed fire protection enforcement policy with the SC. Highlights of these coments and ensuing discussions are as follows:
The responsibility for fire protection was viewed as fragmented since CNEB, ASB, LQB, and QUAB in HQ are involved in addition to Regions. Comentors believed a central point of contact is needed in HQ; The fire protection guidelines and scope of Tech Specs were l considered by some to be inconsistent and inadequate, and a l list of "minimum requirements" for fire protection was requested; Regional inspectors indicated need for an enforcement policy l and for policy on QA for fire protection; ,
Need for control room electrical review policy was indicated; and Coments were voiced for and against use of the "interpretations."
This meeting was very helpful to the SC in better defining the issues and clarifying where action was most needed. However, the SC indicated it would not be able to resolve or even address all of the issues raised.
Of particular note was the attitude expressed by the fire protection engineers of a desire to resolve the issues promptly and of a willingness to support the recomendations of the SC. A list of attendees is provided in the enclosure.
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OCT 191984 4
The SC believes that its previous decision on expediting plant inspections was reinforced by the comments in this meeting. The SC indicated its view that inspections should go forward rapidly to get on with the identi-fication and resolution of problems. To require more documentation in areas not specifically required by the Rule would slow compliance down.
Discussion
- 1. Views expressed by fire protection engineers.
Region I discussed the inspections of Vermont Yankee, Salem and Calvert Cliffs. It was indicated that confusion generated was caused by differ-ences between Generic Letter 83-33 and "interpretations" but that the Regien endorsed the interpretations because they would expedite the proces, and not create inspection problems. The implementation of Appenoix R at Calvert Cliffs was successful because the licensee did a very thorough evaluation of his alternate shutdown needs, had substantial connunication with the licensing staff, had some unit-specific features which benefitted shutdown, and had support of licensee management.
Other comments made by Region I were that: (a) Vermont Yankee was con-fused by the Appendix R implementation letter, (b) at Salem the inspection was complicated because many exemptions were needed just prior to the inspection as a result of 83-33, and (c) all Region I licensees appear to be taking Appendix R seriously and making good faith efforts.
Region II discussed their experience with Appendix A and Appendix R.
They saw Appendix R and fire protection as a moving target in particular since different utilities take different approaches and when these are accepted in licensing, confusion in the inspection process results.
They also noted that utilities were concerned that NRC was going beyond reactor safety and getting into loss prevention. Region II raised an issue, generally endorsed by others in the meeting, that the responsi-bility for fire protection is fragmented because of all the disciplines responsible. In particular, in NRR responsibility lies in engineering, systems interaction and human factors safety. Licensing work also resides in the Quality Assurance Branch in IE. This, along with differ- '
ent Regional views and inspector approaches, results in confusion and inconsistency. It was suggested that a central contact was needed at HQ to provide central authority for fire protection. It was also indicated that reviewers and inspectors need additional guidelines, in particular, minimum acceptance criteria. Region Il also pointed out differences in license requirements and Tech Specs dealing with fire protection. A discussion evolved concernino the need for augnenting Tech Specs in relation to other safety significant items. The general concensus of the fire protection engineers was that Tech Specs needed to be expanded in this area.
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. ~ l OCT I S 1984 l Region II' also indicated that guidance for inspectors needed revising and expansion and that an inspection module was needed for NT0Ls. It was also pointed out that the fire protection inspection must be done early in the inspection phase when the licensee has the opportunity to make changes. It was suggested that Regional inspectors accompany NRR reviewers in their site visits and that a general improvement in com-munication and understanding of SER commitments was needed. Finally, Region II voiced the view that the definition of fire areas in 83-33 must be retained, that guidance is needed for suppression systems and intervening combustibles, reiterated that the inspection module needs improvement by supplying minimum acceptance criteria, and stressed the need for an enforcement policy in this area.
Region III generally endorsed the comments of Region I and II. In addition, they pointed out the need for QA guidance in the area of fire protection. They stated that deficiencies in Tech Specs resulted from omission of fire damper surveillance, and inconsistancies of Code require-ments. It was suggested that the present inspection modules be cortined into one for all plants. Region III indicated that they felt the need-to explain the rule requirements to industry; for example, 20 feet separa-tion. They requested that RES be tasked to supply the technical basis.
They felt that inspectors needed such information to guide them in making judgments and evaluations. The SC pointed out that the items in the rule were based on the best information at the time and that inspectors needed not feel obligated to explain rule obligations to licencees. If there are areas where the inspector feels safety is not well served by meeting rule provisions, such concerns should be elevated to management but that the rule, including its defense indepth provisions, seemed adequate. Finally, Region III indicated that the three things most needed were: (1) enforcement policy, (2) minimum requirements, and (3) consistent levels of irispection. To take care of (3), a training program would be needed. When asked, Region III cited the following as their three biggest frustrations: (1) the adequacy of licensee analyses, (2) the adequacy of regulatory requirements, and (3) the inconsistent reviews and inspection criteria.
Region IV has inspected Fort Calhoun, Fort St. Vrain and some NTOLs.
They endorsed most of the coments of the previous Regions. In particular, they felt the need for acceptance criteria, enforcement policy, and-up-to-date Tech Specs.
Brookhaven National Laboratory (BNL) comented on problems with specific compliance vice meeting the "intent" of Appendix R. In particular, NTOLs allege that they meet the intent of Appendix R through a number of
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different ways. BNL indicated that there were serious problems with consistency and interpretation of control room fires and that we lack the rationale or basis for these views. They question in particular how long is the.contril room habitable, what action can be taken, where two units share a con .rol risom are both units affected, and must both units i shut down outside the control room. BNL also stated that we needed !
specific guidelines for associated circuit analysis and indicated that the SER was not always a reliable indicator of licensing comitments for inspection. i A representative of ASB indicated the scope of review for alternate shutdowns and that the criteria used were consistent and had been in use l for most plant reviews. The criteria were not well documented however.
He expanded on the systems used for safe shutdown, the requirements for physical separation and electrical separation for safe shutdown. With respect to the associated circuits analysis it was indicated that the evaluation assured, assuming offsite power loss, that safety could be I cemonu rated assuming one spurious signal, a loss of all automatic l signals, and spurious operation of motor-operated valves in the high/ low pressure interface. {
It was indicated that this included review of :
licensee's sumary of operator actions and that, during inspection, the ;
actual procedures are wilked down.
IE's discussion focused on item 3 of the "interpretations" which states that licensees must show equipment must be "free of fire damage" before, during and after a fire. He was concerned that although Section III.G.2 specifies free of fire damage, the interpretation would allow less than l i
this, in particular, scorched and severely heated equipment which are still barely sufficient to perform their intended functions. He said l that the rule language would not allow this and that it is not appro-priate and conservative.
In many of the above coments from Region and HQ representatives the SC !
detected a belief of bad faith by the licensees and practices which would subvert the spirit and the technical intent of the Commission's requirements. The SC pursued this to some exter;t but noted that there seemed to be a lack of specifics. Since the importance and safety significance of each requirement was somewhat judgmental the SC felt that the NRC needed to shoulder some responsibility for lack of com-pliance because of the evolution of Appendix R. ,
)
NRR representatives indicated their belief that the NRC should stick with the Generic Letter 83-33 approach, which in their view has been working, and issue enforcement policy. They felt that if the licensees l
were required to submit for review their entire program, both how they l
J OCT 191984 meet Appendix R as well as deviations or exemptions, there would be fewer inspection and enforcement problems, fewer citations and a better overall fire protection image. They pointed out that, if the licensee's evaluation is kept in house and not docketed under oath, it could be inaccurate.
The NRR representatives stated that the practical effect of the interpre-tations would be to relax requirements becaur. $n additional burden is placed on reviewers and inspectors that c b nget
- licensee fixes are needed. They also asked for the agency 4 chav b :1rize the priority of fire protection in plant safety.
- 2. Views of IE enforcement staff.
Jane Axelrad discussed the current policy ano indicated that it has not yet been issued because of a lack of general policy on what constitutes compliance with the rule.
She gave backgrcund on the enforcement policy and comments on efforts to apply policy consistently across the regions.
The SC indic6ted that it would provide its revision of the enforcement policy guidance for EDO 6pproval.
- Richard H. Vollmer, Chairman Fire Protection Policy Steering Comittee
Enclosure:
As stated cc: W. Dircks V. Stello R. Minogue T. Murley, R-I J. O'Reilly, R-II J. Keppler, R-III R. Martin, R-IV J. Martin, R-V G. Cunningham E. Case J. Taylor D. Eisenhut )
i R. Bernero G. Arlotto F. Rosa j SC Comittee l
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,,... OCT 2 61984 MEMORANDUM FOR: Harold R. Denton, Director, ONRR Richard C. DeYoung, Director, 0IE FROM: Pictard H. Vollner, Chairman Fire Protection Policy Steering Conmittee SbBJECT:
FIFTH AND SIXTH MEETINGS OF THE FIRE rROTECTION POLICY STEERING COMMITTEE
'At the fifth and sixth meetings of the Fire Protectiv Policy Steering Connittee (SC), held in Bethesda on October 17 and the Region III offices _
1 on October 22, respectively, the final version of (1) enforcement policy Suid-ance, (2) Generic Letter, (3) standard license condition, (4) temporary instruction for fire protection inspections, and (5) technical issues package of questions and answers were discussed, edited, and put into final l form. No new initiatives were discussed but the impact and consistency of i l all initiatives developed by the SC were reviewe k The SC also assured l that all issues included in the E00 memo of Septeruber 13 had bean fully I addressed and that all issues raised to the SC's attention by other parties I had been fully considered.
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' Richard H. Vollmer, Chairman I Fire Protection Policy Steering l Committee I cc: See next page.
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1 cci W. Dircks V. Stello R. Minogue T. Murley, R-I J. O'Reilly, R-II J. Keppler, R-III R. Martin, R-IV J. Martin, R-V G. Cunningham E. Case J. Taylor D. Eisenhut R. Bernero G. Arlotto F. Rosa SC Comittee 1
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'"MEMORANDUM FOR: William J. Dircks Executive Lirector for Operations FROM: Fire Protection Policy Steering Connittee
SUBJECT:
REC 0 MENDED FIRE PROTECTION POLICY AND PROGRAM ACTIONS Introduction At an August 27, 1984 meeting on fire protection, you directed that a review of current fire protection issues be conducted and that reconnenda-tions for resolution of these issues be made within two months. This effort was to examine all current licensing, inspection, and technical issues to develop policy reconnendations aimed at expediting Appendix R compliance for older plants and assuring consistent levels of fire protection safety at all plants.
By your memorant..n dated September 13, lo" (Enclosure 1) to the NRR and IE Office Director and the Regional Admir/ . tors, you confinned this direction and approved a Steering Commite.' to provide aporopriate recom-mendations. You indicated that, amo m the issues to be considered, were: !
I adequacy of current guidance to industry; interpretation of Appendix R requirements; treatment of technical and schedular exemptions; comparison cf Appendix R and current NT0L plants for fire pro-tection safety; i adequacy of current inspection practices; and identificatica and resolution plan for any outstanding technical issues.
In response to this direction, the Fire Protection Policy Steering Comittee (SC) has considered the broad range of fire protection issues necessary tn arrive at policy reconnendations. The SC has reviewed documents which provide the basis for current fire protection policies and which discuss many of the issues that could significantly delay Appendix R N compliance and question consistency in fire protection safety at all
\ plants. The SC held six meetings. These included meetings with the Senior
\engineersfromNRR,IE,andtheRegions.NRC Managers, At the latter meeting,the NRR and IE Office the candid
' views of the individuals intimately involved in the fire protection issues
) were solicited and received. A record of the SC meetings is included as
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OCT 2 6,1384 William J. Dircks ,
- 2. Conduct fire protection 'nspections within CY 1985 at 0F s and /
NT0Ls to include at leasc one site per licensee not subkct to a previous Appendix R fire protection inspection. These inspe tions will assess the degree of fire safety, steer snd promote li nsee compliance, and take enforcement action where appropria . A Temporary Instruction for this program will be issued by 11/15/84 To make this program of inspection most effective:
(a) A workshop for the inspection teams will be conducted in mid December with SC, NRR, IE and Regional participation to assure cocrnon understanding of the objectives, scope and technical issues. Followup workshops will be held as needed; (b) The fire protection inspections will utilize ne.4 guidance for enforcement actions (Encl u ure 4);
'(c) The processing of current fire protection enforcement actions will be expedited; and (d) A referee will be established to promptly resolve significant differences between the inspection teams and licensees.
) 3. Upgrade regulatory documents and procedures to achieve an appropriate level of fire protection safety while maintaining consistency among plants. In particular:
'(a) Impose a standard firc protection condition (Enclosure 5) in each operating license (already. being implemented);
(b) Reevaluate all fire protection guidance for consistency with the SC recomendations and compare fire protection requirements for ors and NTOLs, both under the auspices of the Working Group; (c) Develop appropriate revisions to the Standard Review Plan and Standard Technical Specifications by March 31, 1985; and (d) Designate the Director, Division of Engineering, NRR as the central point of contact for interoffice / region fire protection issues.
- 4. To assure timely and on-track completion of these recomended actions, the SC will review progress at least quarterly, make mid-course corrections if appropriate, and report to the EDO.
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William J. Dircks OCT 2 61934 awareness to NRC's resolve in this area and, more importantly, would allow the teams to judge the current direction (for licensees still designing or "installing fixes) and advise the licensee on its acceptability. This should save both industry and staff resources in the long run. In the short run, that is 1985, the SC believes that adequate resources exist for the inspection teams (ane for R-I, R-!! and R-III, and one for R-IV/V) to be taken from regional staff, augmented by contractor, NRR, and IE assistance.
While this would take a modest amount of reprogranrning in the regional inspection program, we suggest that it's worth the effort to get Appendix R implementation behind us.
Prior to the 1985 inspection, a several-day inspection term workshop would be held to discuss the inspection program, the technical issues, and reach a corrrnon understanding on acceptability of various configurations and required documentation. Since this workshop cannot solve all potential problems the inspection teams will encounter, a team at HQ would be set up
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_tA promptly. resolve.significant. differences between the inspection ~p'e'r F ~
sonnel and the licensee. This referee team weeld be headed by NRR'(SES level) and would have an NRR, an IE and a regional technical member. Their decision would be issued in one week and would be sent to all teams for their information.
) The SC believes that this program of expedited inspections, airried at reaching ors and NT0Ls and to inc'ade at least one site from each licensee l not previously subject to a fire protection inspection, coupled with denial c future schedular exemptions and a fire enforcement policy will result in i a fair and uniform speed up of Appendix R compliance. Further, since the I resource cost is believed to be :nodestly above the already-progransned fire protection inspections, we believe the cost is well worth it and will even benefit industry by correcting false starts in Appendix R implementation where they are found. Althoujh we found the current inspections adequate (fif th item in your memo of September 13), this program will continue to be focussed on safe shutdown, will be implemented more expeditiously, and will byild on the resolution of other initiatives considered by the SC. A Temporary Instruction for this inspection program has oeen drafted and is undergoing final revisions. It will be in final fonn by November 15, 1984 and will include the elements discussed above, for example, the team set up to resolve inspection differences with the licensee.
Finally, the SC considered meant to assure and maintain consistent levels of fire protection safety at all plants. The Working Group researched the guidance documents currently available and how these are applied to old and new plants. The SC discussed findings of the reviewers and inspectors vho are close to the issues. As a result of this work, the SC found that the requirements for old and new plants were ger.arally the same but that discrepancies do exist. The appl'eation of guidelines, both in the review process and the inspection process, leaves room for interpretation. The SC concluded that several steps needed to be taken in addition to those
) described above some of which were to assure and maintain consistency.
I william J. Dircks .
007 2 6,1984 FIRE PROTECTION POLICY STEERING COMMITTEE
< t
. Nelson Grace Director Quality Assurance, Safeguards & Inspection, Programs Office of Inspection and Enforcement s
- Thomas T. Martin, Direc 'r Division of Engineerin and Technical Programs Region I 7-o4 : William J. Olbstead, Director and Chief Counsel Regulations Division Office of the Executive Legal Director J 'n A. Olshinski, Director N ,
ivision of Reactor Safety l
Region II Richard L. Splitssard[/ Director Division of Reactor Safety Region III Alichard H. Vollmer, Directo A l Division of Engineering l
' Office of Nuclear Reactor Regulation (Chairman) 1
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. NUCLEAR REGULATORY COMMISSION ENCLOSURE 1 WW ASM18eG TON. D. C. 20585 SEP 131984 MEMORANDUM FOR: Harold R. Denton, Director, NRR ,
Richard C. DeYoung, Director, IE . '
Thomas E. Murley, Regional Administrator, R-I James P: O'Reilly, Regional Administrator, R-II James G. Keppler, Regional Administrator, k-Ill
- John T. Collins, Regional Administrator, R-IV John B. Martin, Regional Administrator, R-V FRQ1: William J. Dircks Executive Director for Operations SUBJECT : REVIEW OF NRC FIRE PROTECTION POLICY AND PROGRAMS At our Auc_g.st 27th meeting on fire protection, I directed NRR to review and make recorrmenda,tions for resoIving current fire protection issues within two months. The objective of such an ef. fort is to examine all current licensing, inspection, and technical is. sues and, based on such a review, develop policy reconmendations aimed at expediting Appe.ndix R compliance for older slants and assuring consistent levels of fire protection safety at all plants.
Some of the current issues that should be considered are:
. adequacy of current guidance to incustry;
. interpretation of the Appendix R requirements vice staff guidance; treatment of expected future technical and schedular exemptions into late 1980s and early 1990s;
. comparison of Appendix R and current NTOL plants for fire protection safety; 1
. adequacy of current inspection practices; and j
. identification and resolution plan for any outstanding technical issues.
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To implement the above, I understand that you have set up a Staerring Canetttee composed of Messrs. Grace, IE; Martin, R-1; Olmstead, ELD;
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l 01shMJbsW, R-Ill; and Vollmer, NRR, Chairman. This Steering comittee is to decide the scope of issues to be considered, meet with hQ and regional personnel as necessary to consider these issues, make assignments as appropriate to a working group headed by Faust Rosa, NRR, for detailed consideration of certain issues, and make reconmendations for actions along with supporting bases to me by l October 26, 1984 I concur in these assignments and the general charter of the Steering Connittee.
All ongoing regulatory actions in your Offices regarding fire protection should be continued and should n:t be delayed or deferred pending the outcome of this review.
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William J. Dircks Executive Director for Operations cc: T. Stello G. Cunningham ._.
Steering Comittee :: -
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SEP 211984 MEMORANDUM FOR: Harold R. Denton, Director, ONRR Richard C. DeYoung, Director. !E I FRO 1: Richard H. Vollmer, Chairman Fire Protection Policy Steering Comittee
SUBJECT:
FIRST MEETING OF FIRE PROTECTION POLICY. STEERING COMMITTEE Sumary At its first meeting, the Fire Protection Policy Steering Comittee (SC) discussed the issues identified in the E00 memo of September 13, 1984 The SC made the following recomenda* ions and assignments: )
1
. the SC recommended that Appendix R implementation policy follow l
'he "Interpretations" discussed at the Regional Workshops, as modified by detaili discussed below, rather than requiring prior staff review or exemptions for deviations from Generic Letter l 83-33;
. the SC recommended that the issuance of the fire protection enforcement policy and enforcement actions be expedited;
. the SC recommended that QA for fire protection be clearly defined as that required by GOC-1; and
. the SC assigned to the Working Group tasks dealing with the adequacy of available guidance, comparison of fire protection requirements for ors and NTOLs, the adequacy of current inspection practices, and identification of outstanding technical issues.
Introduction As a result of the E00 memo of September 13, 1984, regarding a review of NRC fire protection policy and programs, the SC held its first meeting
- on September 13 and 14 The objectives of this meeting were to:
"Attenoeo by. T. Martin, J. 01shinski, L. Spessard, N. Grace, F. Rosa, S. Richardson, W. Shields, W. Little, T. Wambach, W. Olmstead, K. Cyr and R. Vollmer.
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Enclosure to GL 85-01, Re: Fire Protection Policy
. discuss the background leading to the formation of the SC;
. establish a general charter, objectives, schedule, and working arrangements; and
. discuss issues currently in hand and make decisions for resolution if appropriate.
The discussion of background included the events leading up to and includ-ing the fire protection regional workshops, the May 30, 1984 meeting with the Commission, the August 27 meeting with the EDO, and the events surrounding the DP0 signed by three fire protection reviewers and two inspectors. As part of this background, ELD representatives discussed the Rule and the distinction between its legally enforceable requirements and staff guid!nce issued subsequent to the Rule. The background dis-cussion aho focussed on the issues identified in the EDO memo of I Sept"mber 13.
I Charter and Schedule I l
The chartt of *te SC is the review of NRC fire protection policy and I
programt leading to policy recsunendations which would expedite compliance with Appendix R at older plants and assure consistent levels of fire protection safety at all plants. To implement this Charter the SC agreed that current licensing, inspection, legal, and technical issues needed I to be examined. The SC's objective would be to make specific reconnenda- {
tions to the EDO which could be carried out (1) within the existing I framework of 50.48 and Accendix R, and (2) without making a disruption l
- in the effort already unterway to imSlecent fire protection requirements.
The SC would attempt to make recommendations th!t could be innediately effective. However, we recognize that there may'be some instances in which further study was needed. In such cases, we agreed to reconnend a specific assignment and end date for such study. Finally, the SC agreed that its work would be completed through issuance of its report to the EDC by October 26, 1984.
~
l Working Arrangements
- The SC discussed how it could use the available resources most effectively.
It was decided that the SC would not need to meet at this time with HQ and Regional Leople since their views have been expressed extensively in written and transcribed material. The SC did not feel the need to meet with industry for the same reason. However, the SC does wish to meet '
with Vic Stello and hereby offers the opportunity of a meeting with the recipients of this memo.
Enclosure to GL 85-01, Re: Fire Protection Policy G
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The SC will take advantage of the Working Group chaired by Faust Rosa and make assignments to that group and to certain individuals. It was our Oelief that use of currently available resources, including the Working Group, wouldebe sufficient to achieve our objectives and schedule.
Issues
- 1. Adequacy of cu'crent guidance to industry.
The SC felt that enough guidance has been generated but that it needed to be made consistent with our recommendations and cleared up technically ,
in some areas. The mechanism for this would be a generic letter, super- J ceding previous guidance, to be sent to all licensees as promised at the '
et jional workshops. This generic letter would be sent to the Comission, as requested at the Comission's May 30 meeting, before 'being issued to industry. The SC agreed that it would be best to utilize guidance already available, to the extent possible, to minimize possible confusion both within ind,stry and the NRC. It was also agreed that we should utilize either Generic Letter 83-33 or the "Interpretations" rather than a third i i
option for dealing with th'e exemption issue. This is discussed below. ;
The working Group was tasked with reviewing all current guidance and I outstand;ng technical questions and to revise the Regional Workshop I package to incorporate in one place a comprehensive set of guidance that is consistent with the SC's policy recommendations and the approved technical recomendations of the Working Group.
- 2. Interpretation of the Appendix R requirements vice staff guidance.
The basic issue is whether industry can deviate from the contents of Generic Letter 83-33 without prior staff review and approval. This issue is fully develooed by the current Staff OPO. The SC had the benefit of ELD's views and Faust Rosa's recomendations resulting from his assign-ment by Mr. Denton to make an independent assessment of this OPO. The ;
SC decided that it could only support the contents of 83-33 as guidance I to industry, consistent with the "Interpretations" drafted for the Regional Workshops since ELO advised that Generic Letter 83-33 stated requirements which went beyond the terms of Appendix R itself.
However, the SC also felt that some of the clarifying language contained in the DP0 should be utilized and that specific guidance should be ;
supplied to clearly indicate the level of fire protection to be achieved and the documentation necessary to demonstrate it. In addition, the SC felt that, at an appropriate time prior to the Appendix R inspection, the licensee should be requested to provide information necessary to Enclosure to GL 85-01, Re: Fire Protection Policy
_. . .. . . _ _ _ _ .__ _ _ _ _ . _ _ . _ _ - . . _ .- _ . ~ ..- -
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. 4 support the inspection for HQ and regional review. In addition, the licensees should be encouraged to meet with the staff to discuss plans before extensive hardware modifications are initiated.
The Working Group was tasked to work on language to support this recom- )
mendation as part of its work on item 1.
- 3. Tr3atment of expected future technical and schedular exemptions into late 1980s and early 1990s.
l This item was discussed extensively and tabled when no clear direction was apparent. The concern is that some licensees may unduly request staff reconsideration of technical findings and/or implementation. schedules which would in effect defer comoliance. This item will receive priority consideration at the next meeting and no assignments were made. However, the SC felt strongly that the fire protection enforcement policy and current enfcreement packages consistent with that policy should be issued promptly to demonstrate NRC resolve in this ares and that the backlog in NRR be processed expeditiously.
- 4. Comparison of Ap;.endix R and current h'iO( plants for fire protection safety.
Based on statements made at the May 30 Commission meeting and correspond-ence from the Regions, there may be differences in the licensing evaluation and inspection practices for Appendix R plants and NT0ls. The Working Group was tasked with investigating if such differences do exist and how the goal of consistent levels of fire protection safety at all plants might be achieved, in pursuing this, it was suggested that the Working Group meet with representatives from HQ and the Regions active in fire protection reviews and inspectic9s. It was also acknowledged that the .
existing Temporary Instruction for Appe dix R safe shutdown insoections I must be revised to be consistent with the new interpretations. The Working Group must also verify that the guidance documents referenced in the Temporary Instruction for use by the inspectors ha"e been officially i sent to all licensees and applicants.
- 5. Adequacy of current inspection practices. ,
The SC was informed that consistent inspection practices and schedules have been set up for Appendix R plants but that the NTOLs have been hanf ed on a somewhat ad hoc basis. Some regions have instituted a fairly extensive review of the capability to achieve a safe shutdown following a fire and others look more at SER-specific hardware items. 1 Steve Richardson of IE was tasked with reporting to the SC, at the next neetino on current inspection content and schedules for all classes of plants, saggestions for modifying current practices, and, specifically, when the NTOL's should be inspected to assure effective compliance with NRC's fire prctection requirements.
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- 6. Identification and resolution plan for outstanding technical issues.
The Working Group was requested to identify any outstanding technical issues that impede Appendix R compliance. These will be discussed with the SC and a plan and schedule for resolution will be developed. One issue that was discussed is the QA standard to be applied to fire protection compliance. The SC felt strongly that the requirements of GDC-1 apply to fire protection features, recognizing that the activities are underway to resolve the GOC-1/ Appendix B and safety-related/
important-to-safety issues. Without trying to muddy the water in these areas, the SC felt that, at minimum, licensees be made aware that the fire protection program falls under GDC-1. The Working Group should look into this also and review the QA commitments made by some licensees in )
i their pre-Appendix R SERs.
i
. The next meeting of the Fire Protection Steering Committee will be held on September 27 at 9:00 a.m. in P-202A.
Richard H. Vollmer, Chairman Fire Protection Policy Steering Committee ec: W. Dircks ,
V. Stello R. Minogue .
T. Murley l J. O'Reilly ,
J. Martin l E. Case J. Taylor D. Eisenhut R. Bernero G. Arlotto F. Rosa (10)
SC Members l
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l MEMORANDUM FOR: Fire Protection Policy Steering Committee FROM: Richrrd M. Vollmer, Chairman Fire Protection Policy Steering Committee j
SUBJECT:
AGENDA FOR SECONO MEETING l
The second meeting of the Fire Protection Policy Steering Comittee will be held at 9:00 a.m. on September 27, 1984 in Room P-202 A. At this meeting we i will be briefed on the Working Group activities and on current inspection 1 content and schedules and have the benefit of the IE and HRR Office Director's i views on our activities. Our tentative schedule is as follows:
9:00 a.m. Executive Session I 9:30 Harold Denton and Ed Case i 10:00 Dick Deyoung and Jim Taylor I 10:30 Faust Rosa will discuss Working Group activities '
1:00 p.m. Steve Richardson will discuss Appendix R inspections 2:00 Comhtee work 1
In addition to our consideration of issues raised by the above agenda items, we need to consider policy approaches to deal with technical and schedular exemptions which put implementation of Appendix R into the distant future.
Any approaches you have to deal with this issue will be welcomed.
r _
Richard H. Vollmer, Chairman Fire Protection Policy Steering Comittee ,
cc: W. Dircks !
V. Stello H. Denton R. DeYoung T. Murley R. Minogue J. O'Reilly J. Keppler J. Collins J. Martin G. Cunningham E. Case J. Taylor '
O. Eisenhut R. Bernero '
G. Arlotto l F. Rosa Enclosure to GL 85-01, Re: Fire Protection Policy
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- SEP 2 71984 MEMORANDUM FOR: Harold R. Denton, Director, ONRR Richard C. DeYoung, Director, OIE Thomas E. Murley, Regional Administrator, R-1 James P. O'Reilly, Regional Administrator, R-!!
James G. Keppler, Regional A ministrator, R-III l John T. Collins, Regional Administrator, R-ly l John B. Martin, Regional Administrator, R-V l 1
FROM:
Richard H. Vollmer, Chairman Fire Protection Policy Steering Ccanittee
SUBJECT:
NRC FIRE PROTECTION MEETING The Fire Protection Policy Steering Comittee requests that the fire protection engineers in your organization attend a meeting in Bethesda ,
on October 2, 1984, to give their views on licensing and inspection fire l protection issues. This is an information gathering session to help the '
Comittee formulate its policy recommendations. A candid discussion of how these issues are viewed by the fire protection reviewers and inspectors, and recomendations they may have, would be welcome. A meeting agenda is enclosed, hr ichard H. Vollmer, Chairman Fire Protection Policy Steerin'g Committee
Enclosure:
Agenda cc: W. Dircks V. Stello R. Minogue G. Cunningham E. Case J. Taylor, IE D. Eisenhut R. Bernero G. Arlotto, RES F. Rosa N. Grace, IE L. Spessard, R-III W. Olmstead, ELD J. 01shinski, R-Il T. Wambach Enclosure to GL 85-01, Re: Fire Protection Policy
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t NRC Fire Protection Meeting, Date: October 2,1984 at Location: P-422 Phillips Building 9:00 a.m. Opening Remarks - R. Vollmer 9:10 Region I Remarks j 9:40 Region !! Remarks 10:10 Region 111 Remarks 10:40 Region IV Remarks 11:40 Brookhaven Remarks 1:00 p.m. NRR Renarks l l
2:00 I&E Remarks 2:30 to 4:00 Group Discussion 4:00 to 5:00 Each group given opportunity to provide any additional coments.
5:00 Adjourn Enclosure to GL 85-01, Re: Fire Protection Policy
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\, October 3,1984 MEMORANDUM FOR: Faust Rosa, Chairman Fire Protection Working Group FROM: Richard H. Vollmer, Chairman Fire Protection Policy Steering Comittee
SUBJECT:
ASSIGNMENTS FOR FIRE PROTECTION WORKING GROUP At the first meeting of the Fire Protection Policy Steering Comittee, the Comittee assigned action tasks to the Working Group. The purpose of this memo is to provide better focus on the Working Group assignments as a result of the second and third Comittee meetings. l The Working Group's first priority should be the revision of the enclosure to )
the Generic Letter discussed at the fire p otection workshops. This package )
should include answers to the questions posed by industry and revision of the '
"interpretations" section to utilize clarifying aspects,9f the DP0 and to emphasize the level of fire protection expected by staff guidance, e.g.,
Generic Letter 83-33, and the documentation necessary to demonstrate equiva-lence to staff guidance. This package should not contain any new guidance ,
and should be internally consistent and consistent with the Comittee's '
proposed policy on the "interpretations." To the extent possible criteria acceptable to the staff should be clearly identified. This package should be available for Committee review by October 12 and whatever efforts are necessary to meet this date should be expended.
Bill Shields will prepare a draf t of the Generic Letter in which he will lay out the elements for expediting Appendix R implementation. It will discuss the proposed policy on schedular exemptions, the proposed augmentation of plant inspections, an'd indicate generally what is expected of licensees and what enforcement action may occur. In addition, it was agreed that the 50.48 schedule expiration for each plant would be indicated. )
The item uf next priority is the development of an inspection plan which I would accomplish the objectives of a "helpful" inspection. That is, in a one week, four-man inspection, we need to find out how the licensee is approaching his Appendix R implementation, the status of the plant with i respect to compliance, and plans and schedules for complete implementation. l This inspection should identify improper paths being taken by the licensee, I and allow the staff to assess current fire protection safety and need for any l plant specific enforcement action.
Finally, the Working Group should compare fire protection requirements for ors and NTOLs and work on any outstanding technical issues. The outline (y .
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.you provided of the Working Group's program review appears far too ambitious in view of current time and resource constraints. We should discuss this further at our October 10 meeting in Atlanta.
W!+e-Richard H. Vollmer, Chairman ,
Fire Protection Policy Steering Comittee cc: Steering Comittee W. Dircks H. Denton R. DeYoung E. Case J. Taylor W. Shields 1
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October 12, 1934 MEMORANDUM FOR: Fire' Protection Policy Steering Comittee FROM: Richard H. Vollmer, Chairman Fire Protection Policy Steering Comittee
SUBJECT:
AGENDA FOR THE FIFTH MEETING The fifth meeting of the Fire Protection Policy Steering Comittee will be held at 9:00 a.m. on October 17, 1984 in Room P-202A. At this meeting you should be prepared to discuss the generic letter and its attachments relative to the ability of these documents to satisfy Steering Comittee '
decisions. We should also be prepared to settle on the enforcement policy guidance and the inspection module revision if these are available. Finally we will need to discuss format, content, and writing assignments for our October 26 report to the EDO.
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ichard H. Vollmer, Director Fire Protection Policy Steering Comittee cc: W. Dircks V. Stello H. Denton R. DeYoung R. Minogue T. Murley, R-I J. O'Reilly, R-II J. Xeppler, R-III J. Collins, R-IV J. Martin, R-V G. Cunningham E. Case J. Taylor D. Eisenhut R. Bernero G. Arlotto F. Rosa
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October 12, 1984 MEMORANDUM FOR: Harold R. Denton, Director, NRR ,
Richard C. DeYoung, Director, OIE '
FROM: Richard H. Vollmer, Chairman ;
. Fire Protection Policy Steering Comitte'
SUBJECT:
SECOND MEETING OF THE FIRE PROTECTION POLICY STEERINi COPei!TTEE HELD ON 3EPTEMBER 27, 1984 Suma ry At its second meeting, the Fire Protection ' Steering Comittee (SC) con- i sidered policy approaches to deal with technical and schedular exemptions which threaten to put Appendix R implementation into the distant future, discussed SC activities with the IE and NRR Office Directors and Deputies, and was briefed on Working Group activities. As a resuh of this me6 ting, the SC made the following decisions:
. the SC decided to hdid a meeting with all HQ and Regional fire protection engineers, as a body, to candidly discuss their views i on fire protection issues, probh,ns, and possible future actions; )
the SC decided that the most promising way to expedite Appendix R compliance is to initiate an aggressive inspection program which would steer and promote licensee compliance, assess the degree of
' fire safety, and exercise enforcement policy where appropriate; j and '
, the SC decided that no further schedular exemptions should be I granted, l Discussion
- 1. Meeting with Office Direcurs and Deputies, l
The SC met with Messrs. Denton, DeYoung, Case and Taylor to discuss their l views on the fire protection problems, potential solutions, and SC activities. They viewed the problem as a lack of staff cohesiveness in a highly judgemental area exacerbated by industry reluctance to meet Appendix R requirements. They felt that a meeting between the HQ and Regional fire 1 protection staff to air any probitas, issues, and possible solutions, would l benefit the SC's work. We agreec and set up such a meeting for October 2nd. 1 0 - f;'
l Enclosure to GL 85-01, Re: Fire Protection Policy l 1
1
~2* October 12, 1984 It was also noted that, although industry was less than enthusiastic about fire protection, many problems have been solved and there have been signif-icant improvements in fire protection of plants. To assist in defining fire protection problems and assessing safety significance, it was also suggested ,
that we sort out fire protection and safe shutdown issues. The inclusion of fire protection features in Tech Specs was also discussed; namely, that they are not currently consistent, tha.t augmenting of Tech Specs in this area has been proposed, and that such activities must be considered relative to general goals of simplifying Tech Specs. Finally, it was suggested that we need to better integrate the disciplines involved in this licensing and ;
inspection area and identify a central point of responsibility. !
- 2. Exemptions.
The SC discussed what, if anything, could be done to keep schedular and technical exemptions from dragging Appendix R implementation into the next decade. ELD stated that there was little we could do on technical 1 exemptions since, if the utility has a valid reason for requesting one, then NRC must review it. On schedular exemptions, hCwever. we can make a policy decision not to grant any more. Such a decision would have a legitimate basis since the Commission's Appendix R record viewed implementation in four ,
or five years. Further, many 50.48 schedules have or are near running out. )
The SC decided that no further, schedular exemptions should be granted.
The discussion turned to means of assuring that licensees recognized and '
could implement their responsibility for Appendix R implementation. The SC felt that the staff was taking on too mu:h of the burden and that a well defined set of technical criteria, coupled with a program of inspection, and an enforcement policy would provide the best incentives. The SC felt that about five teams each consisting of a team leader and a fire protection, electrical, and systems engineer, should be set up. Each team beginning in February 85, should go to one plant per month for a one-week inspection.
These inspections would target plants of each type, each utility, and each A/E inclucing NT0Ls. Recognizing that plants in varying degrees of com-pliance would be inspected, the inspections should focus on safe shutdown. !
Where Appendix R implementation is still being engineered, the team should steer and promote licensee compliance in a technically supportable way.
These inspections would also establish where each plant stands vis a vis Appendix R. and would use enforcement action where appropriate in a prompt fa shion- It was suggested that there should be central and prompt reso-lution of any licensee / team disputes. This cruid be handled by a team consisting of a member of hRR, IE and the appropriate Regional management.
The decision of this team would state the NRC position followed by a confir-matory letter or order as appropriate. Following such an inspection program, decisions on th long term fire protection inspections, both in extent and timing, would follow.
Enclosure to GL 85-01, Re: Fire Protection Policy
~3" October 12, 1984
- 3. Technical issues.
Two technical issues were identified to be pursued by the Working Group:
(1) the Dow Corning ascertion that penetration material was not being properly installed; and (2) whether our criteria on control room fires are appropriate and consistent.
- 4. Working Group discussion.
Faust Rosa discuised the Working Group activities, in particular, the out-line of the Working Group report. All items of interest to the SC were covered in the outline of this report. However, it appeared that com-pletion of the work as outlined was too ambitious for the ^ime and resources provided. The SC indicated that priority attention be given to the completion of the generic letter package. The SC also indicated in its first meeting that the Working Group should compare fire protection requirements for ors and NT0ls, review the adequacy of current inspection practices, and identify outstanding technical issues. These tasks should proceed except for the review of inspection practices which is superceded by the development of the program described in item 2 above.
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ichard H. Vollmer, Chairman Fire Protection Policy Steering Co,mmittee cc: W, Dircks a V. Stello !'
H. Denton R. DeYoung R. Minogue T. Mu rl ey , R-I J. O'Reilly, R-!! -
J. Keppler, R-III J. Collins, R-IV J. Martin, R-Y G. Cunningham E. Case J. Taylor D. Eisenhut R. Bernero
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.....** OCT 191984 MEMORANDUM FOR: Harold R. Denton, Director, ONRR Richard C. DeYoung, Director, OIE FROM: Richard H. Vollmer, Chairman I Fire Protection Policy Steering Connittee 1
SUBJECT:
THIRD MEETING OF THE FIRE PROTECTION POLICY STEERING I COP 94ITTEC, HELD ON OCTOBER 2; 1984 i Sumary At its third meeting the Fire Protection Policy Steering Comittee (SC) I met with the fire protection engineers from HQ and the Regional Offices to obtain their candid views on licensing and inspection fire protection I issues. Coments were presented by fire protection engineers from NRR, IE, and Regions I, II, III, and IV. In addition, Jane Axelrad discussed the proposed fire protection enforcement policy with tne SC. Highlights of these coments and ensuing discussions are as follows:
. The responsibi'.ity for fire protection was viewed as fragmented since 01EB, ASB, LQB, and QUAB in HQ are involved in addition to Regions. Comentors believed a central point of contact is needed in HQ; 1
. The fire protection guidelines and scope of Tech Specs were i considered b; some to be inconsistent and inadequate, and a <
list of "minimum requirements" for fire protection was requested; )
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. Regional inspectors indicated need for an enforcement policy l and for policy on QA for fire protection; l
. Need #or control room electrical review policy was indicated; l and
. Coments were voiced for and against use of the "interpretations."
This meeting was very helpful to the SC in better defining the issues and clarifying where action was most needed. However, the SC indicated ,
it would not be able to resolve or even address all of the issues raised. '
Of particular note was the attitude expressed by the fire protection engineers of a desire to resolve the issues promptly and of a willingness to support the recomendations of the SC. A list of attendees is provided in the enclosure.
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L I Dy l Enclosure to GL 85-01, Re: Fire Protection Policy l
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0CT 191984 The SC be.lieves that its previous decision on expediting plant inspectionf was reinforced by the comments in this meeting. The SC indicated its view thatand fication inspections should resolution go,lems. forward of prob rapidly To require to documentation more get on with the in identi-areas not specifically required by the Rule would slow compliance down.
Discussion
- 1. Views expressed by fire protection engineers.
Region I discussed the inspections of Vermont Yankee, Sales and Calvert Cliffs. It was indicated that confusion generated was caused by differ-ences between Generic Letter 83-33 and "interpretations' hut that the Region endorsed the interpretations because they would needite the process and not crecce inspection problems. The impleurentation of Appendix R at Calvert Cliffs was successful because the licensee did a very thorough evaluation of his alternate shutdown needs, had substantial communication with the licensing staff, had some unit-specific features which t;enefitted shutdown, and had support of licensee management.
Other coments made by Region I were that: (a) Vennont Yankee was con-fused by the Appendix R implementation letter, (b) at Sales the inspection was complicated because many exemptions were needed just prior to the inspection as a result of 83-33, and (c) all Region I licensee; appear to be taking Appendix R seriously and making good f aith efforts.
Region !! discussed their experience with Appeadix A and Apperdia R.
They saw Appendix A and fire protection as a moving target in narticular since differant utilities take different approaches and when these are accepted in licensing, confusion in the inspection process results.
They also noted that utilities were concerned that NRC was going beyond reactor safety and getting into loss prevention. Region Il raised an issue, generally endorsed by others 17 the meeting, that the responsi-bility for fire protection is frapnented because of all the disciplines responsible. In particular, in NRR responsibility lies in engineering, ,
systems interaction and human factors safety. Licensing work also . l resides in the Quality Assurance Branch 1.n IE. This..along with differ-ent Regional views and inspector approaches, results in confusion and incorsistency. It was suggested that a central contact was needed at HQ to provide central authority for fire protection. It was also indicated that reviewers and inspectors need additional guidelines, in particular, l minimum acceptance criteria. Region Il also pointed out differences in '
license requirements isnd Tech Specs dealing with fire protection. A discussion evolved concerning the need for augmenting Tech 5pecs in relation to other safety significant items. The general concensus of the fire protection engineers was that Tech Specs needed to be expanded in this area.
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. b elosure to GL 85-01, Re: Fire Protection Policy j l
. . OCT 19 584 Region IT also indicated that guidance for inspectors needed revising and expansion and that an inspection module was needed for NTOLs. It was also pointed out that the fire protection inspection must be done early in the inspection phase when the licensee has the opportunity to )
make changes. It was suggested that Regional inspectors accompany NRR '
reviewers in their site visits and that a general improvement in com-munication and understanding of SER commitments was needed. Finally, Region II voiced the view that the definition of fire areas in 83-33 1 must be retained, that guidance is needed for suppression systems and intervering combustibles, reiterated that the inspection module needs -
improvement by supplying minimum acceptance criteria, and stressed the need for an enforcement policy in this area.
Region III generally endorsed the comments of Region I and !!. In addition, they pointed out the need for QA guidance in the area of fire protection. They statcd that deficiencies in Tech Specs resulted from omis:; ion of fire damper surveillance, and inconsistancies of Code require-ments. It was suggested that the present inspection modules be combined into one for all plants. Region !!! indicated that they felt the need to explain the rule requirements to industry; for example, 20 feet separa-tion. They requested that RES be tasked to supply the technical basis.
They felt that inspectors needed such information to guide them in making judgments and evaluations. The SC pointed out that the items in the rule were based on the best information at the time and that inspectors needed not feel obligated o explain rule obligations to 1Jcencees. If there are areas where the inspector feels safety is not well served by meeting rule provisions, such concerns should be elevated to management but that the rule, including its defense indepth provisions, seemed
, acequate. Fint11y, Region !!! indicated tnat the three things most nvded were: (1) enforcement policy (2) minimum requirements, and (3) consistent levels of inspection. To take care of (3), a training program would De needed. When asked, Region !!! cited the following as their three biggest frustrations: (1) the adequacy of licensee analyses, (2) 1 the adequccy of regulatory requireetnts, and (3) the inconsistent reviews and inspection criteria. ;
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1 Region IV has inspected Fort Calhoun, Fort St. Vrain and some NTOLs. 4 They endorsed most of the comments of the previous Regions. In particular, l they felt the need for acceptance criteria, enforcement policy, and-up-to-date i Tech Specs.
Brookhaven National Laboratory (BNL) comumented on problems with specific compliance vice s.eeting the "intent" of Appendix R. In particular, NTOLs allege that they meet t.%e intent of Appendix R through a nusber of Enclosure to GL 85-01, Re: Fire Protection Policy
OCT 19 ay '
l different ways. BNL indicated that there were serious problems with
) consistency and interpretation of control room fires and that we lack the rationale or basis for these views. They question in particular how l long is the control room habitable, what action can be taken, where two l units share a control room are both units affected, and must both units i shut down outside the control room. BM. also stated that we needed specific guidelines for associated circuit analysis and indicated that the SER was not always a reliable indicator of licensing comitments for inspection.
A representative of ASB indicated the 3 cope of review for alternate shutdowns a.d that the criteria used were consistent and had been in use for most V 't reviews. The criteria were not well documented however.
He expanded o' the systems used for safe shutdown, the requirements for physical se] ttion and electrical separation for safe shutdown. With respect to 6..e associated circuits analysis it was indicated that the evaluation assured, assuming offsite power loss, that safety could be demonstrated assuming one spurious signal, a loss of all automatic signals, and spurious operation of motor-operated valves in the high/ low pressure interface. It was indicated that this included review of licensee's sumary of operator actions and that, during inspection, the actual procedures are walked down. .
IE's discussion focused on item 3 of the "interpretations" which states that licensees must show equipment must be "free of fire dmage" before, during and after a fire. He was concerned that although Section III.G.2 specifies free of fire damage,, the interpretation would allow less than this, in particular, scorched and severely heated equipment which are still barely sufficient to perform their intended functions. He said that the rule language would not allow this and that it is not appro-priate and conservative.
In many of the above coments from Region and HQ representatives the SC detected a belief of bad faith by the licensees and practices which would subvert the spirit and the technical intent of the Commission's requirements. The SC pursued this to some extent but noted that there seemed to be a lack of specifics. Since the importance and safety significance of each requirement was somewhat judynental the SC felt that the NRC needed to shoulder some responsibility for lack of com-pliance because of the evolution of Appendix R.
NRR representatives indicated their belief that the NRC should stick with the Generic Letter 83-33 approach, which in their view has been working, ano issue enforcement policy. They felt that if the licensees were required to submit for review their entire program, both how they Enclosure to GL 85-01, Re: Fire Protection Policy e#
, OCT I S 1984 l
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meet Appendix R as well as deviations or exemptions, there would be fewer inspection and enforcement problems, fewer citations and a better overall fire protection image. They pointed out that, if the licensee's evaluation is kept in house and not docketed under math, it could be inaccurate.
The NRR representatives stated that the practical effect of the interpre-tations would be to relax requirements because an additional burden is placed on reviewers and inspectors that changes to licensee fixes are needed. They also asked for the agency to characterize the priority of fire protection in plant safety.
- 2. Views of IE enforcement staff.
Jane Axelrad discussed the current policy and indicated that it has not yet been issued because of a lack of general policy on what constitutes compliance with the rule. She gave backgroiand on the enforcement policy and conments on efforts to apply policy consistently across the regions.
The SC indicated that it would provide its revision of the enforcement policy guidance for EDO approval.
I Richard H. Vollmer, Chairman Fire Protection Policy Steering Comittee
Enclosure:
As stated cc: W. Dircks V. Stello R. Minogue T. Murley, R-I '
J. O'Reilly, R-!! 1 J. Keppler, R-Ill l R. Martin, R-IV '
J. Martin, R-V G. Cunningham E. Case J. Taylor D. Eisenhut R. Bernero G. Arlotto F. Rosa SC Consnittee Enclosure to GL 85-01, Re: Fire Protection Policy
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l Enclosure to GL !!5-01, Re: Fire Protection Policy
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October 19, 1984 MEMORANDUM FOR: Harold R. Denton, Director, NRR Richard C. DeYoung, Director, O!E FROM: Richard H. Vollmer, Chairman Fire Protection Policy Steering Comittee
SUBJECT:
FOURTH MEETING OF THE FIRE PROTECTION POLICY STEERING COMMITTEE Sumary .
At its foJrth meeting, the Fire Protection Policy Steering Comittee (SC) again considered the generic letter to licensees, the enfo-cement policy guidance and the scope, timing and resources for the expedited fire protection inspections. The SC focussed on some of the peripheral I issues which would be important to the success of the expedited inspections )
and other SC initiatives. At this meeting, the SC decided that:
. Prior to the fire protection inspections, a workshop would be !
held with IE, NRR, and Regional partici' pants in the inspections to assure understanding in the objectives, scope, and technical issues and to help provide consistency between inspection teams; )
. A team would be established to promptl'y handle disputes between licensees and the inspection teams; ard
. That a standard condition should be incorporated into all licenses, requiring maintenance of the fire protection comitments but allowing change under 50.59 which do not decrease the level of fire protection with annual reporting to the Commission of such changes, j l
Discussion
- 1. Expedited inspections.
The SC discussed the scope, timing, and resources for the expedi:ed inspections. There was a discussion of whether this should be a review or an inspection. The SC felt that the concept was one af~an inspection rather than a review and that the availability of enfoccement was im-portant to the process. The SC discussed resources and concluded that an adequate pool existed; however it was not clear if or how the erpedited
, -,L Enclosure tn GL 85-01, Re: Fire Protection Policy
October 19, 1984 .
Harold R. Denton '
Richard C. DeYoung inspections would affect other programs. The Working Group /IE was asked to complete a module to be used in these inspections and to plan out which licensees would be inspected to best achieve the objectives. A one-year schedu.le of plants and resources was requested by the SC.
The SC also discussed how to assure a common understanding of the objectives, scope, and technical issues by all participants in these inspections.
To be effective, such inspections need to be uniform. The SC decided that a workshop would be held prior to initiation of the inspections wherein the SC would lay out the philosophy and intent, and technical and procedural issues would be discussed. The SC also decided that it would be importent to have a central authority available to promptly and uniformly resolve disputes between the licensees and inspection teams.
This was felt to be necessary so that major issues wculd not be left unsettled and so that licensees would not pursue fire protection solutions that would be unlikely to be acceptable to NRC. The Chairman of the SC was assigned to draft a charter and membership for this authority for <
SC's consideration. It was also agreed that the resolution of disputes j by this authority would be promptly published to all inspection teams, i
- 2. Generic Letter.
The need for a standard fire protection license tondition was discussed.
. Problems resulting from inconsistent license conditions have been raised during the past year. It was agreed that a standard condition, similar to that drafted by ELD and NRR for current NTOLs, should be prepared.
The SC discussed the tim ing for reporting of fire protection chan'ges conducted under 50.59 and it was decided that annual reporting was appro-priate based on other important 50.59 issues that utilize annual reporting.
A discussion ensued on how to get such a license condition applied across the board to all licensees. The use of a Generic Letter or a 50.54(f) letter was discussed. ELO was tasked with developing a recommendation.
- 3. Enforcement Policy. l The SC discussed in detail a proposed fire protection enforcement policy.
Some issues were settled and it was decided that the SC would complete this activity at its next meeting.
Finally, the SC decided to hold its next meeting on October 17 in Bethesda and to hold its final session in Chicago, for two days or more if needed, to complete activities and prepare a report to the EDO.
Richard H. Vollmer, Chairman Fire Protection Policy Steering Comittee i cc: See next page Enclosure to GL 85-01, Re: Fire Protection Policy O
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Harold R. Denton October 19, 1984 Richard C. DeYoung I I
cc: W. Dircks i
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R. Minogue 1
T. Murley', R-!
J. 0Reilly, R-II J. Keppler, R-III R. Martin, R-IV J. Martin, R-V G. Cunningham E. Case J. Taylor D. Eisenhut R. Bernero G. Arlotto F. Rosa SC Comittee l
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Enclosure to GL 85-01, Re: Fire Protection Policy ,
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OCT 191984 .
MEMORANDUM FOR: Fire Protection Policy Steering Committee FROM: Richard H. Vollmer, Chairman Fire Protection Policy Steering Committee
SUBJECT:
AGEN01. FOR SIXTH MEETING The sixtn meeting of the Fire Protectidn Policy Steering Comittee will be held at 9:00 a.m. on October 22, 1984 in the Region III offices. At this meeting p u should be prepared to discuss and finalize versions of:
. Generic Letter and Interpretations
. Technical Issues Package
. Standard License Condition
. Inspection Module In addition., we need to prepare our final report to the EDO. I will FAX an outline to you for your consideration today. In addition, there are a number of issues and suggestions still left hanging. For example:
the central point of contact for fire protection issue; the status of NFPA codes; what to do about Tech Specs; and the format of the workshop in advance of the expedited inspections, dh -
ichard H. Vollmer, Chairman Fire Protectiun Policy Steering Connittee cc: See next page, p/ , V / -
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Enclosure to GL 85-01, Re: Fire Protection Poli:y
Enc 1nsure to GL 85-01, Re: Fire Protection Policy
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...# OCT 2 61984 MEMORANDUM FOR: Harold R. Denton, Director, ONRR Richard C. DeYoung, Director, OIE FROM: Richard H. Vollmer, Chairman Fire Protection Policy Steering Consnittee
SUBJECT:
FIFTH AND SIXTH MEETINGS OF THE FIRE PROTECTION POLICY STEERING C0m!TTEE l
At the fifth and sixth meetings of the Fire Protection Policy Steering j Consnittee (SC), held in Bethesda on October 17 and the Region III offices on October 22, respectively, the final version of (1) enforcement policy guid- l ance, (2) Generic Letter, (3) standard license condition, (4) temporary l instruction for fire protection inspections, and (5) technical issues i package of questions and answers were discussed, edited, and put into final -
form. No new initiatives were discussed but the impact and consistency of all initiatives developed by the SC were reviewe b The SC also assured i that all issues included in the EDO memo of September 13 had been fully ;
addressed and that all issues raised to the SC's attention by other parties had been fully considered.
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' Richard H. Vollmer, Chairman Fire Protection Policy Steering Comittee cc: See next page.
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cc: W. Dircks V. Stello '
H. Denton
- R. DeYoung R. Minogue T. Murley, R-1 .
J. O'Reilly, R-!! 2 J. Keppler, R-!!!
J. Collins, R-IV J. Martin, R-V G. Cunningham j E. Case J. Taylor D. Eisenhut R. Bernero G. Arlotto F. Rosa 1
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Enclosure to GL 85-01, Re: Fire Prntection Policy
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cc: W. ircks V. Stello R. Minogue T. Murley, R-I J. O'Reilly, R-!!
J. Keppler, R-I!!
R. Martin, R-IV J. Martin, R-V G. Cunningham E. Case J. Taylor D. Eisenhut R. Bernero G. Arlotto F. Rosa SC Comittee l
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MEMORANDUM FOR: Fire Protection Policy Steering Committee FROM: Richard H. Vollmer, Chairman Fire Protection Policy Steering Cosnittee
SUBJECT:
AGENDA FOR THE FOURTH MEETING The fourth meeting of the Fire Protection Policy Steering connittee will be held at 9:00 a.m. on October 10, 1984 in the Region !! offices in Atlanta. At this meeting we need to reach agreement on the enforcement policy guidance and develop our decision, reached at the second meeting and fortified in the third meeting, on a FY 85 inspection for most plant types. I request that John prepare a rewrite of the enforcement policy and Nelson a general plan for inspections for Coenittee consideration.
Other items we need to discuss are: .
. Focus of inspections relative to fire protection and safe shutdown;
. Working group assign;nents; i
. What should be included in technical specifications;
. Resolution of licensee / Inspection team disputes; and
. Disputes of issues raised at third meeting.
I hope at this meeting we can agrae on our overall approach to make our recoemendations to Dircks coherent and consistent so that we can begin writing to have a draf t report ready at our fif th meeting.
Richard H. Vpilmer, Chai an Fire Protection Policy teering Comittee cc: See next page
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Enclosure to GL 85-01, Re: Fire Protection Policy
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