ML20203D799
| ML20203D799 | |
| Person / Time | |
|---|---|
| Issue date: | 02/09/1999 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| References | |
| REF-10CFR9.7 NUDOCS 9902160375 | |
| Download: ML20203D799 (140) | |
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iJ 0110 i'AL UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
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Title:
BRIEFING ON FIRE PROTECTION ISSUES PUBLIC MEETING i
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Location: Rockville, Maryland i
1 KJ Date: Tuesday, February 9,1999 i
1 Pages: 1 - 140 ll 9902160375 990209 PDR 10CFR PDR PT9.7 ANN RILEY & ASSOCIATES, LTD.
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DISCLAIMER i This is an unofficial transcript of a meeting of i
the United States Nuclear Regulatory Commission held on.
February 9, 1999, in the Commission's office at One White l
Flint North, Rockville, Maryland. The meeting was open to public attendance and observation. This transcript has not been reviewed, corrected or edited, and it may contain inaccuracies.
The transcript is intended solely for general informational. purposes. As provided by 10 CFR 9.103, it is not part of the formal or informal record of decision of the matters discussed. Expressions of opinion in this transcript do not necessarily reflect final determination or beliefs. No pleading or other paper may be filed with the Commission in any proceeding as the result of, or addressed to, any statement or argument contained herein, except as the Commission may authorize.
e o S- 1 1 UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION 3 ***
4 BRIEFING ON FIRE PROTECTION ISSUES 5 ***
6 PUBLIC MEETING 7
8 Nuclear Regulatory Commission 9 One White Flint North 10 Building 1, Room 1F-16 11 11555 Rockville Pike l
12 Rockville, Maryland 13 14 Tuesday, February 9, 1999 16 The Commission met in open session, pursuant to 17 notice, at 9:10 a.m., Shirley A. Jackson, Chairman, 18 presiding.
19 20 COMMISSIONERS PRESENT:
21 SHIRLEY A. JACKSON, Chairman of the Commission 22 NILS J. DIAZ, Member of the Commission 23 EDWARD McGAFFIGAN, JR., Member of the Commission 24 GRETA J. DICUS, Member of the Commission 25 JEFFREY S. MERRIFIELD, Member of the Commission 1
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n 6 S- 2 j 1 STAFF PRESENT:
2 JOHN C. HOYLE, Secretary 3 KAREN D. CYR, General Counsel ,
l 4 ANNETTE L. VIETTI-COOK, Assistant Secretary 5
6 PRESENTERS:
7 WILLIAM TRAVERS, Executive Director for Operations 8 LEDYARD B. (TAD) MARSH, NRR 9 BRIAN SHERON, NRR 10 STEVEN WEST, NRR 11 STEVE REYNOLDS, NRC Region III 12 ED CONNELL, NRR 13 I ALAN RUBIN, RES 14 RALPH BEEDLE, NEI 15 ANTHONY O'NEILL, NFPA 16 DAVID MODEEN, NEI l
17 PAUL GUNTER, Reactor Watchdog Project, Nuclear l
18
- Information and Resource Service 39 DAVID LOCHBAUM, Union of Coilcerned Scientists 20 21 f 22
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1 PROCEEDINGS i
2 [9:10 a.m.] ;
3 CHAIRMAN JACKSON: Good morning, ladies and ,
4 gentlemen. I am pleased to welcome you today for a briefing l 5 on fire protection issues for nuclear power plants. The !
6 Commission will be briefed by the NRC Staff,'who are at the 7 table, the Nuclear Energy Institute, the National Fire ,
i 8 Protection Association, the Union of Concerned Scientists 9 and the Nuclear Information and Resource Service.
10 In October, 1996 the Commission directed the Staff 11 to revise 10 CFR 50.4o and to modify or remove Appendix R.
12 The last Commission briefing on these efforts was in March 13 of 1998, which focused on the Staff's proposal, as discussed 14 in SECY 98-058, for development of a risk-informed 15 performance-based regulation for fire protection at nuclear 36 power plants. In the Staff Requirements Memorandum dated 17 June 30th, 1998 the Commission approved the Staff 18 recommendation to defer development of a risk-informed, 19 performance-based fire protection rule and instead pursue 20 with the National Fire Protection Association and the 21 nuclear industry the development of a risk-informad and 22 ultimately performance-based consensus standard for fire 23 protection at nuclear power plants.
24 The Commission could then endorse the standard if 25 successfully developed in a future rulemaking which would ANN RILEY & ASSOCIATES, LTD.
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i 6 S- 4 1 serve as an alternative method to meet NRC fire protection 2 requirements.
3 Since that March, 1998 Commission meeting the 4 Staff has forwarded several information papers to the 5 Commission on fire protection issues such as status reports 6 on the Fire Protection Functional Inspection Program and 7 progress made in the development of fire protection 8 consensus standard, and insights from Research on fire 9 protection.
10 Today's briefing will cover this information and 11 in particular revisions to Appendix R and 10 CFR 50.48, 12 development of the Fire Protection Regulatory Guide, the 13 National Fire Protection Agency Standard 805, and Fire 14 Protection Functional Inspection Program, Individual Plant 15 Examinations of External Events -- the IPEEE Program, the 16 Fire Risk Assessment Research Program, and the Quad Cities 17 IPEEE fire results.
18 As we progress through today's briefing I as'k in l 19 particular that each presenter focus on any significant 20 issues that have developed or been identified since the 21 March, 1998 Commission meeting. Now I understand that 22 copies of the briefing materials are available at r:le 2, entrances to the room, so unless my colleagues have opening 24 or additional comments, Dr. Travers, please proceed.
25 MR. TRAVERS: Goed morning, Chairman and ANN RILEY & ASSOCIATES, LTD.
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t e S- 5 1 Commissioners. Chairman, as you mentioned, we are here to
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2 brief you on the status of a number of high priority reactor 3 fire protection activities and rather than list them again I 4 will mention that at the table, joining me, is Dr. Brian 5 Sheron, who is the Associate Director for Project Licensing 6 and Technical Assessment in NRR; Tad Marsh, who is the Chief 7 of Events Assessment, Generic Communications and Non-Power 8 Reactors Branch in NRR; Ed Connell is a Senior Fire 9 Protection Engineer in NRR; Alan Rubin, down here, who is a 10 Section Chief in the Office of Nuclear Regulatory Research; 11 Steve Reynolds, who is the Deputy Director of the Division 12 of Reactor Safety in Region III; and also Steve West, who is
- a Section Chief in NRR.
14 We would like to begin with Dr. Sheron, who iL I
/"'s k ) l N s' 15 going to provide you a brief summary of the subjects, 16 Chairman, that you mentioned at the outset of this meeting.
17 Following that, we intend to have the principal Staff 18- representatives give you a short but more detailed 1
19 presentation on each of those issues.
20 CHAIRMAN JACKSON: Thank you.
21 MR. SHERON: Good morning. Could I have the first 22 slide, please. f 23 As Bill said, I will walk through very quickly the l 24 major topics that we plan to present. I understand we have 25 about 30 minutes of presentation time, so I was only going ANN RILEY & ASSOCIATES, LTD.
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S- 6 1 to take about five minutes, hit the high points and then 2 turn it over to the Staff and let them walk you through some 3 of the details.
4 With regard to SECY 98-058, which you mentioned, 5 Chairman, we are in the process right now of revising 6 Appendix R and 50.48 to remove the requirement for 7 non-combustible penetration seals. We are also implementing 8 the removal of the Schedule 1 footnote to the guidance 9 document which has been superseded, and we are right now on 10 schedule to complete that in April of 2000.
11 The comprehensive Fire Protection Regulatory 12 Guide, if you remember, we said that most of our guidance is 13 kind of scattered in various documents and guidance, generic 14 letters and information notices. Our intent was to try to 15 pull that all together into one comprehensive document and 16 to consolidate it. That is on schedule and we are planning 17 on issuing a draft for public comment in September of this 18 year.
19 For the National Fire Projection Association 20 Standard 805, again that was supposed to provide a 21 comprehensive, as you said a risk-informed, 22 performance-based method for addressing fire protection 23 requirements that would be an alternative to the current 24 rules and regulations. We are participating on that 25 committee in the development of that standard and right now l ANN RILEY & ASSOCIATES, LTD.
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1 that is on schedule for completion in May of 2000. ,
2 On the Fire Protection Functional Inspection l 3 Program, as you know, that was to assess licensee 4 implementation of the fire protection rules and regulations. l 5 We completed four pilot inspections. We are currently 6 assessing the results. We have had workshops with the i
7 industry on this. We also have received a proposal from NEI l 8 with regard to future inspections in which they propose that 9 basically the industry do self-assessments and the Staff 10 basically oversee the self-assessment process.
11 We are in the process of evaluating that proposal 12 as well, and our plan is to provide a Commission paper with 13 our recommendations for how we proceed in the future in l 14 April of this year, so that's about two months.
15 CHAIRMAN JACKSON: Let me ask you, how does the 16 National Fire Protection Standard 805 play off against the 17 development of the Comprehensive Fire Protection Regulatory 18 Guide and will that comprehensive guide have to be revised l 19 or will any type of regulatory guidance be necessary for 20 that fire protection standard?
21 MR. SHERON: My initial reaction is that hopefully 22 they will be complementary but the NFPA. Guide is supposed to (
23 be risk-informed, whereas the Reg Guide is pulling together
! 24 guidance for the existing rules and regulations, which again 25 will be an alternative, so I am not sure that the Reg Guide l
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S- 8 1 will be in any sort of a conflict with the NFPA Guide 2 because the Reg Guide is basically for implementing the 3 current Appendix R and 50.48 and the NFPA Standard would be 4 an alternative.
5 Is that right, Ed?
6 MR. CONNELL: Right.
7 MR. SHERON: Okay.
8 CHAIRMAN JACKSON: Okay.
9 MR. SHERON: On the IPEEE Program, as you know, 10 that's the external events assessment, the purpose is to 11 examine potential severe accident vulnerabilities and to 12 resolve some generic safety issues. I understand there are 13 about 12 right now that are related to fire concerns.
14 The preliminary review of the submittals has been 15 completed by our Office of Research, and we are using these 16 results right now as insights to support the Fire Protection 17 Functional Exams and our interaction and work on the NFPA 18 805 Standard and also to feed into further fire research 19 efforts.
20 We also have the ongoing Fire Risk Assessment 21 Program in the Office of Research, and the purpose there is 1
22 to improve our understanding of fire risk, to support our 23 fire protection activities including our participation on 24 the NFPA Standard as well as our inspections, and to improve 25 analytical methods and tools, and the major results from ANN RILEY & ASSOCIATES, LTD.
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4 e S- 9 1 that program are expected in September of the year two, 2 2000.
3 COMMISSIONER MERRIFIELD: Madam Chairman?
4 CHAIRMAN JACKSON: Please.
5 COMMISSIONER MERRIFIELD: I have a question 6 regarding that last point. You expect that results from 7 that assessment to be in September of 2000, but right now we 8 are working with NFPA and we have already got a draft 9 standard out, which will go final in May of 2000 and I am ,
i 10 wondering are we out of synch?
11 Here we have a research program, the results of 12 which you are not going to have until September of 2000, and l l 13 yet we have action we are taking which will be effectuated 14 in May of 2000.
s- Y 15 MR. RUBIN: Let me comment on that. Although most 16 of the results will be expected by 2000 or certainly the l 17 significant results, there will be interim products along 18 the way. In fact, we have some results already from the 19 Fire Risk Assessment Research Program that are being used by 20 the agency in terms of the IPEEE reviews.
21 The NFPA Standard itself will have an appendix on 22 risk assessment analyses and the insights from the IPEEE 23 program and the Fire Research Program will be fed into that.
24 That appendix has not yet been written but there are l
l 25 products that are being developed that will feed directly i
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i 6 S- 10 1 into that activity.
2 CHAIRMAN JACKSON: Why don't you go ahead.
3 MR. SHERON: The last item is Quad Cities. As you 4 know, on February '97 they submitted their IPEEE results, 5 which showed a fire CDF of five times 10 to the minus 3.
6 The licensee took the initiative to shut the plant down due 7 to deficient safe shutdown analysis. They did a revised 8 analysis and concluded that the fire CDF was 6.6 times 10 to 9 the minus 5th. This analysis will be submitted in about two 10 months in April.
11 Basically the reason that the number went down so 12 much is they went more to looking at the plant-specific 13 design. They made, as I understand it, a number of 14 conservative assumptions in their risk assessment, for 15 example that they would lose all of the 125 volt DC.
16 When they went back and they looked at the actual 17 cable routing they realized they would not lose all of that 18 and so when they took into account the details of the 19 design, it is my understanding that you would not lose all 20 of that, for example, the way they assumed, and therefore 21 the risk went down.
CHAIRMAN JACKSON: So we haven't -- I mean the 22 23 analysis hasn't come to NRC formally yet, is that correct?
24 MR. SHERON: That is my understanding.
CHAIRMAN JACKSON: And so we haven't accepted that 25 ANN RILEY & ASSOCIATES, LTD.
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j S- 11 1 analysis as such -- what you are reporting is what they
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( 2 reported to you, is that correct?
3 MR. SHERON: Yes, that is correct.
4 CHAIRMAN JACKSON: And as far as you know, that 5 there were no specific plant changes to have brought the 6 core damage frequency down by two orders of magnitude? All 7 pencil sharpening?
8 MR. REYNOLDS: Most of it has been. They did a 9 few modifications that may have got them 10 percent, 15 10 percent better, but the bulk of the risk reduction was 11 understanding the plant better and doing some analysis 12 better. ;
13 CHAIRMAN JACKSON: What does that say then about f- s 14 the other IPEEE submittals if, you know, if understanding
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\m / 15 their plant better gave a two order of magnitude change in 16 the core damage risk from fires? I don't know who is 17 responsible for reviewing those but --
18 MR. RUBIN: I will get into this a little bit in 19 my presentation but the Staff's reviews of the IPEEEs are 20 not intended to assess or evaluate all.the assumptions that 21 go into the licensee's assessment, IPEEE's. We just don't i l
22 have the resources to do that. l 23 Here is a case where the licensee made some very 24 conservative assumptions, as Brian Sheron has said. That is 25 one thing we would not necessarily review. The licensee has p
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S- 12 chosen to do that. This is obviously a significant ,
1 2 difference that can result if the input assumptions vary.
3 I don't know -- we haven't looked in detail at 4 every other licensee, IPEEE, whether to see if that is the 5 case or not, but we don't think it is.
6 This is, I think, a unique situation with Quad 7 Cities, certain in terms of ;uch a high core damage 8 frequency. We hadn't seen that at any other plant.
CHAIRMAN JACKSON: Is this going to -- I mean the 9
10 real issue has to do with the basis for Commission 11 decision-making and all that will go into that basis. I 12 mean it somewhat relates to Commissioner Merrifield's 13 question of having Research Program results that -- I 14 understand the point about modular products along the way --
15 but in the absence of those, you know, you are talking about 16 getting results but the Commission is supposed to make a 17 decision on the National Fire Protection Association 18 standard before then, and so the issue is what are we 19 supposed to make of the IPEEE program results vis-a-vis fire 20 vulnerabilities, be they on the positive or the negative 21 side, relative to a comfort in stepping through a 22 decision-making process.
23 MR. RUBIN: Well, the IPEEE reviews are focused on 24 looking at each individual licensee's analysis, looking at 25 plant vulnerabilities, see whether the licensee's done an ANN RILEY & ASSOCIATES, LTD.
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l S- 13 l 1 adequate job. In regards to the completeness of their 2 reviews, have they overlooked significant parts of their 3 analysis. It's --
4 CHAIRMAN JACKSON: That review didn't look at then 5 something that could make a two-order-of-magnitude change in 6 the core damage.
7 MR. RUBIN: Well, if we saw things missing -- in 8 fact, for example, results of IPEEE and Quad Cities where 9 turbine building fires were a significant risk contributor, 10 we took that into account in looking at reviews of other 11 licensee submittals, and if there was not sufficient 12 information in the turbine building, we've asked questions 13 and --
'N 14 CHAIRMAN JACKSON: So as long as it's overly 15 conservative, we don't look anymore. Is that the point?
16 MR. RUBIN: I'd say --
17 CHAIRMAN JACKSON: But how do you know it's overly 18 conservative if you don't look? l 19 MR. RUBIN: Unless we do, you know, followup l I
20 audits or onsite inspections, we probably would not.
21 CHAIRMAN JACKSON: Okay.
1 22 MR. SHERON: I'll turn it over now to Ed Connell.
23 MR. CONNELL: Good morning. Thanks, Brian.
24 I'm just going to briefly touch on things that NRR 1
25 was assigned out of 98-058, and that was the revision of fs j
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S- 14 1 Appendix R, deleting the noncombustible requirement from 2 section III.M, developing the comprehensive reg guide and 3 working with NFPA and industry to develop NFPA 805. And I 4 just want to point out that industry supports the current 5 path concerning the reg guide and the NFPA 805 process. And 6 then we provided an update to the Commission this past 7 October on the status of the NFPA activities and the 8 resolution of the issues, the 12 issues that were in 97-127.
9 CHAIRMAN JACKSON: Let me take you up on 10 something.
11 MR. CONNELL: Sure.
12 CHAIRMAN JACKSON: This has to do with the You know, if I look ahead to Mr. Lochbaum's 13 SECY-98-058.
14 presentation, I note that he disputes the staff's conclusion 1 15 that there is no technical basis for the noncombustibility l 16 requirement. Can you elaborate on this issue?
17 MR. CONNELL: I think so. The purpose of a l
18 penetration seal was to prevent fire propagation from one 19 side of the barrier to the other side of the barrier. What 20 that material -- how that material does that we've left 21 flexibility to the designers and the plants to choose 22 whatever material best suits their purpose.
23 The fact that a material is combustible as silicon I
24 foam is does not prevent it from performing its function.
25 The doors to this room are made of wood. Eood's a ANN RILEY & ASSOCIATES, LTD.
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6 4 S- 15 1 combustible material. They are also rated fire doors. So 2 you can have a combustible material that serves its function 3 as a fire-barrier material. What it does is it delays 4 propagation of the fire from one side of the barrier to the 5 other. In' fact, wood is actually more combustible than the l 6 silicon foam that's used in the penetration seal in the 7 plant.
8 CHAIRMAN JACKSON: So in laying out or in ,
1 9 proposing to delete the requirement for noncombustible 10 penetration seals, you then are going to replace it with i
11 what the performance requirements have to be? !
12 MR. CONNELL: Yes.
13 CHAIRMAN JACKSON: For such seals?
14 MR. CONNELL: Yes. We've established those in 15 previous -- in the rule, the requirements are there, and 16 also in previous generic communications we've established 17 those requirements.
18 CHAIRMAN JACKSON: And when you've done the fire 19 protection functional inspections, you've verified that the 20 penetration seals satisfy --
21 MR. CONNELL: Part of -- of course, they don't --
22 CHAIRMAN JACKSON: Or you --
23 MR. CONNELL: There are thousands of penetration 24 seals.
25 CHAIRMAN JACKSON: Of course.
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- o S- 16 1 MR. CONNELL: They look at, you know, a sample and 2 they look at the licensee's program to how they design, 3 install, and maintain the penetration seals that are in 4 their plant.
5 CHAIRMAN JACKSON: How do you get to the 6 performance issue of combustible seals in terms of whether 7 they can perform their intended functions vis-a-vis the 8 requirements?
9 MR. CONNELL: Right. Well, a qualification test 10 is performed to qualify the seals as a 1, 2, or 3-hour-rated 11 barrier. There's a standardized test that's performed -- l 12 CHAIRMAN JACKSON: By the vendor.
13 MR. CONNELL: No. No , by an independent testing 14 laboratory such as Underwriters Laboratories or Factory 15 Mutual, some other independent testing laboratory. And 16 you'll -- Underwriters Laboratories, for example, publishes 17 a directory of rated assemblies annually published -- a l l
l 18 directory of rated assemblies that can be used, basic 19 designs that could be used by licensees to use it. And it's 20 used not just in nuclear plants, it's used throughout the 21 construction industry.
CHAIRMAN JACKSON: And the licensees have good 22 23 documentary records that such tests have been performed and 24 you've verified that the seals they have in the plants in 25 fact conform?
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S- 17 i 1 MR. CONNELL: Well, that's one of the things that 2 we look at. Of course I wouldn't say that all -- well, I I
3 couldn't make the statement that all plants have great 4 documentation. The documentation varies. But you do look 5 at that, and if there are gaps, we ask the licensees to 6 address those.
7 CRAIRMAN JACKSON: Okay.
8 MR. CONNELL: Okay? !
I 9 Next slide, please, Tanya.
f 10 And regarding the penetration seal issue, I just 11 wanted to note that the ACRS has also addressed this issue, !
and they concur with the staff's position and the Commission 1
12 13 direction regarding the noncombustible requirement.
14 And then last October we sent the Commission a 15 memo updating the status of the rulemaking. We guesstimate 16 about one-and-a-half pages will come out of 50.48 17 altogether, deleting the schedule or stuff, and the material 18 related to the obsolete guidance documents. You get a 4
13 little Otduction.
4 20 I'll move on to the next one now, talk a little 21 bit about the comprehensive reg guide.
22 As you're aware, the guidance is contained in i 23 numerous documents spanning a period of about 25 years.
24 We'd like to clean that up a little bit. There's some 25 conflicts in the guidance, as would be expected over such a s
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o S- 10 l 1 long period of time. We'd like to replace that with the 2 comprehensive guide. have it all in one place. I think 3 right now the guidance takes about five volumes on my desk, 4 so we'd like to if we can shrink that down a little bit.
5 The guidance will allow, although not prescribe, 6 performance-based methods as they are developed, consistent 7 with the research program and some efforts from NFPA 805.
8 The reg guide is, the way we view it, is to be applicable to 9 plants that elect to maintain their existing fire protection i 10 license condition, such as Appendix R. It is a parallel 11 effort with the 805 effort. It will include some additional 12 areas for guidance that we have not addressed in the past 13 such as compensatory measures. We think we could do a 14 little better job on the guidance there is out there on 15 compensatory measures.
16 CHAIRMAN JACKSON: Speaking of that, you know, 17 what does the guidance entail regarding the use, extent, and 18 duration of fire watches?
19 MR. CONNELL: We don't have guidance that l
l 20 expressly addresses that. That's why.we think the reg guide 21 is necessary -- one of the reasons why we think the reg 22 guide is going to sort of fill that hole.
23 CHAIRMAN JACKSON: So you' re goi 19 to explicitly i
j 24 address that?
25 MR. CONNELL- Yes.
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S- 19 1 CHAIRMAN JACKSON: In the new reg guide.
O2 MR. CONNELL: Um-hum. Um-hum.
3 And just to note we have a meeting later on this 4 month to address the feedback for the draft outline that we 5 issued December of last year.
6 COMMISSIONER DICUS: Madam Chairman?
7 CHAIRMAN JACKSON: Let me ask one more question.
8 You mentioned the circuit analysis, you know, you 9 said this is an area where additional or revised guidance is 10 needed. Now what's the staff's position relative to the 11 need to protect circuits versus performing detailed circuit 12 analysis to resolve issues?
13 MR. CONNELL: Well, I don't think it's going to
g 14 one or the other. I think what's going to come out is going
] 15 to be a combination. Some circuits are going to require 16 protection. Some circuits maybe we can address analytically l
17 so they do not require protection. But I don't think it's I 18 going to be an either/or --
19 CHAIRMAN JACKSON: Well, have you worked out the 20 kind of an approach or criteria for when you go down one 21 path or --
22 MR. CONNELL: Well, that's still under 23 dev.elopment. I think you're aware that NEI and the BWR 24 Owners Group are working on a circuit analysis resolution 25 plan. NEI has an issue task force working on that. And n'v ANN RILEY & ASSOCIATES, LTD.
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. o S- 20 1 we're involved with their efforts.
2 CHAIRMAN JACKSON: What does our involvement 3 entail?
4 MR. CONNELL: Well, we have meetings. They have 5 some proposed positions that we've looked at, we've provided 6 some feedback on, and we're continuing that discussion.
7 CHAIRMAN JACKSON: But the NRC staff does not have 8 any position on the issues. We're reviewing their 9 positions. Is that what you're saying?
10 MR. CONNELL: We are not developing right now an 11 independent path for the resolution of this at this time.
12 CHAIRMAN JACKSON: No, I don't mean that. I mean l 13 we haven't laid out any, you know, specific basic 1
14 requirements that whatever is developed must satisfy --
15 MR. WEST: I'll try to address your question.
16 Steven West, j 17 The staff does have existing positions on 18 - protection of circuits and circuit analysis, and the 19 positions at the highest level are built into the regulation 20 and Appendix R, and we've issued a number cf guidance 21 documents over the year to try to clarify or interpret those 22 requirements. Generic Letter 86-10 is one that's frequently 23 mentioned. But based on interactions with industry and 24 issues that have come up during inspections and that have 25 been reported through LERs have convinced us that we need to ANN RILEY & ASSOCIATES, LTD.
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S- 21 l
, s 1 relook at that guidance, principally because there appears ss 2 to have been in some cases differing interpretations still 1
3 of what it meant and how it was implemented.
l 4 And we've had findings that licensees have l 5 disputed based on interpretation of regulation or guidance, 6 and the effort that we're undertaking now is to come up with 7 a clarification of guidance or maybe the final word on 8 guidance, what the circuit analysis should be. And the 9 staff originally was undertaking that effort internally, and 10 the BWR Owners Group and NEI expressed an interest in 11 cooperating with us to give us their insights and feedback, 12 and we've agreed to do that. But we are working directly 13 with them. It's expected that sometime this year the owners 14 group will submit a topical report for staff review that 15 would contain -- would specify a method for doing circuit 16 analysis and identifying the circuits that should be 17 protected and those that maybe could be addressed 18 analytically.
19 In parallel, NEI is working ora a method that would 20 take the next step and apply risk information to the 21 analysis. So there would be -- first you would go through 22 the deterministic analysis identified by the owners group l 23 method, and then you may apply the NEI method to get a finer 24 cut. But as Ed said, we still expect --
and I'm sure 25 industry does also -- that there still will be circuits, l
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r 0 4 S- 22 cables that will require protection. It's not a question of 1
2 analyzing away all circuits. That's --
3 CHAIRMAN JACKSON: Well, that's not the nature of 4 the question. The real question is how much of a position 5 or thought in terms of what is fundamental from the 6 regulatory point of view vis-a-vis safety in terms of how 7 much you go down one path or, you know, how you go about 8 making an analysis in a given situation of how much you go 9 down one path or another.
10 And I guess I just want to have some sense that 11 the NRC staff has thought about this and has, you know, I 12 think -- I mean, I applaud in fact the efforts that you're 13 making with the owners groups and with NEI, but it is very 14 important that as part of that that, you Know, we have some l
15 clarity ourselves as to, you know, what, you know, the l
16 safety regulator, what we feel is important.
i l
17 MR. WEST: Yes, ma'am, we agree, and in fact we do 18 have a firm position in the regulatory record, and we are i
i 19 today inspecting to the requirements and the criteria that 20 are in place. And we haven't stopped inspecting or 21 overseeing --
CHAIRMAN JACKSON: No, no, no. You miss my point.
22 23 See, for instance., we are migrating the oversight paradigm, l 24 right?
25 MR. WEST: Right.
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l S- 23 l
,_s 1 CHAIRMAN JACKSON: And there are some fundamentals 1 x ,/ 2 that were part of that, i.e., cornerstones of safety.
3 MR. WEST: Yes, ma'am.
4 CHAIRMAN JACKSON: You can then -- that does not 5 step you from working with others, refining them, fleshing 6 them out, revising your regulatory framework. But you have 7 to be clear on what you think is important from the point of 8 view of protecting public health and safety, going in.
I 9 MR. WEST: Yes, ma'am, I agree, and I'm not 10 communicating well. I apologize. But we have j 11 established --
12 CHAIRMAN JACKSON: Maybe I'm not communicating.
13 MR. WEST: No, you are, but we have established
(N 14 through our work with the owners group and NEI what our
'- 15 requirements are and what our expectations are.
16 CHAIRMAN JACKSON: Okay.
17 MR. WEST: So it's clear, we're all working from a 18 - common baseline, I believe.
19 CHAIRMAN JACKSON: Commissioner Dicus.
20 COMMISSIONER DICUS: Yes. When you do the revised 21 guidance, I'm assuming it does take out the conflicts that 22 we currently have in our guidance.
23 MR. CONNELL: Yes.
24 COMMISSIONER DICUS: I want to be clear.
25 MR. CONNELL: Yes.
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S- 24 1 COMMISSIONER DICUS: Now in the process of doing 2 this, have you identified any policy issues?
3 MR. CONFELL: Not so far. Most of the conflicts i
I 4 are detailed technical requirements, how long hose needs to 5 be, how far you have between fire hydrants, what kind of 6 separation you have as far as vertical separation between l 1
7 cable trays, things like that.
8 COMMISSIONER DICUS: Thank you. )
i 9 CHAIRMAN JACKSON: Okay. Go on. l 10 MR. CONNELL: Okay. I'd like to cover 805 now.
11 The next slide, please, Tanya.
12 Followed by performance objectives which are more
- 13 specific, can be -- some are more qualitative, some are more 1
14 quantitative, depending upon the specif4.c objectives. Then 15 that follows to the performance criteria, which are 1 l
16 quantitative and are expressed in engineering terms and are I
i 17 measurable.
t 18 The use of the terms in the standard right now is 19 consistent with the way the staff's draft positions or draft 20 definitions were in SECY-98-144. They are consistent with 21 the National Fire Protection Association's Report on 22 Performance-Based Codes and Standards which was issued in 23 1995, and the Society of Fire Protection Engineers Draft
! 24 Engineering Guide, which was issued last year.
I 25 I just wanted to note that we had a meeting with ANN RILEY & ASSOCIATES, LTD. l Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
S- 25 1 the ACRS Fire Protection Subcommittee a few weeks ago and 2 one with the full Committee last week and we have extensive 3 feedback from the ACRS on the 805 process.
l 4 The next slide, please. Here is kind of a graphic 5 overview of the fire protection pyramid. Here, where you ,
i l 6 have a baseline fire protection program under 805, l 7 basically, you use minimal deterministic requirements that 8 we believe are essential for all plants, things like a water i
9 supply, a fire brigade, administrative controls, procedures l 10 that we do not be lieve lend themselves to performance-based, 11 risk-informed methods, just good industrial fire protection l l
12 requirements. That makes up the baseline part of the j l
13 program.
/ 14 That follows up to the additional requirements, ;
i k
15 performance requirements, and here, the way the standard is i i
16 structured is licensees are given the option of pursuing a 17 deterministic similar to the existing Appendix R approach, 18 or they are given the flexibility of adopting a f 19 performance-based approach that could be based upon risk ,
1 20 information, it could be based on engineering evaluations, 21 fire modelings, or any other analytical tool that 22 demonstrated they still meet the performance criteria.
23 This is topped off with a site-wide risk 24 evaluation, similar, but we believe an enhancement to the 25 existing IPEEE to provide some additional information and a i
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8 O S- 26 1 larger overview of the fire protection program to look at 2 the risk insights that might be gained, and if there are any 3 additional improvements that need to be made to the fire 4 protection program as a result of that risk information.
5 CHAIRMAN JACKSON: Now, are you saying this is 6 where NRC is going, or you are proposing to go?
7 MP CONNELL: This is the way the standard is 8 structured, the draft standard is structured today.
9 CH. RMAN JACKSON: Okay.
10 MR. CONNELL: Each one of these will be part of 11 the overall fire protection program if a licensee elects to 12 adopt 805.
13 CHAIRMAN JACKSON: Okay. Now, there was a recent 14 Commission paper on fire protection functional inspection, 15 and the staff indicated, and I quote, "that the tools to l
l 16 measure the risk significance of specific fire protection l
! 17 inspection findings are not mature." Now, as such, then, 18 how would you say that they are suitable to do this pyramid, 19 but, in particular, the site-wide risk examination?
20 MR. CONNELL: Well, consistent with that, I think 21 a lot of the things in the baseline fire protection program, 22 we believe that the risk tools are not mature to assess 23 those. That is why we are prescribing them.
l 24 CHAIRMAN JACKSON: So that is why you are going to 25 review those? These are the very prescriptive.
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S- 27 1 MR. CONNELL: That's right. But this is a minimal f
\ 2 level. This is -- and most of the plants have this already.
i 3 I mean this is not going to be a change. They already have 4 a fire brigade, they already have a water supply. They have 5 manual suppression capability. They have administrative 6 controls, they have procedures. So this is not going to be t
7 change from they currently have. .
8 CHAIRMAN JACKSON: But I am ta2 king about the top 9 of the pyramid.
10 MR. CONNELL: The top of the pyramid is the risk -
11 tools can't address everything, okay, but they do provide 12 additional insights, and that is what the site-wide risk ;
13 evaluation is for, is to provide additional insights in case i 14 something may have been missed by the baseline program or 15 the additional performance requirements, whether they be 16 deterministic or performance-based. That's where we get the 17 risk in.t'ormrtion into the overall fire protection program, 18 which we currently only have limited with the IPEEE, because 19 we will address things beyond core damage frequency. We 20 will address LERF, we will address shutdown risk.
21 CHAIRFUJJ JACKSON: Okay.
22 MR. CONNELL: My next slide, please. Just a 23 status of where we are and where we are going to be. We did 24 issue the -- or made available to the public the draft )
25 standard this past November. We had a meeting three weeks s
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i O S- 28 l
1 ago to discuss some of the internal Committee comments and 2 some public comments that have been received.
3 The public proposal period for the draft that was 4 issued in November closes next week. We are going to have a 5 meeting on those public proposals next month. The standard 6 will be issued for public comment at the endlof July this 7 year, and the public comments will be due for that October, 8 and then the final draft will be published in March and will 9 be voted on by the NFP membership in May of 2000. l 10 CHAIRMAN JACKSON: Does this schedule stay within 1
11 the Commission's expectations or has it --
12 MR. CONNELL: This is what we reported in 98-058 13 and in 92-47.
14 COMMISSIONER McGAFFIGAN: Madame Chairman.
15 MR. CONNELL: That concludes my material. ,
16 CHAIRMAN JACKSON: Thank you. J 17 COMMISSIONER McGAFFIGAN: On 805, NEI is later 18 going to testify that they have a concern with regard to the 19 staff's intention that 805 be all or nothing. Can you 20 respond to that concern?
21 MR. CONNELL: I can tell you what our plan was 22 regarding it. We believe that in order to simplify our 23 approach and our oversight of the reactor fire protection 24 program, it would be preferred if licensees either maintain 25 their existing license condition or adopt a risk-informed, ANN RILEY & ASSOCIATES, LTD.
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S- 29 1 performance-based alternative in its entirety. Okay.
( 2 However, there is nothing that prevents, if they 3 elect to maintain their existing license condition, there is 4 nothing that prevents them from using the analytical tools 5 that will be available in 805 as a basis for {uture 6 exemptions or future deviations. There is nothing that 7 prohibits that. We would prefer them to adopt 805 in its 8 entirely. That would eliminate the need for the exemptions 9 and the deviations, but 10 CFR 50.12 is still going to be 10 available for them as an alternative.
11 COMMISSIONER McGAFFIGAN: Madame Chairman, can I 12 follow up?
13 CHAIRMAN JACKSON: Please.
f- g 14 COMMISSIONER McGAFFIGAN: At the moment we have t \
\msl 15 Appendix R, we have pre-Appendix R. My assumption is that 16 this new rule endorsing this new standard, which has both 17 prescriptive, deterministic and performance-based options in 18 it will have to be -- it will have to be voluntary because 19 of backfit rule. So you are going to have a new system 20 which itself has multiple options in it, right?
21 MR. CONNELL: Yes.
22 COMMISSIONER McGAFFIGAN: So, will you -- I mean I 23 count four at a minimum. You have got pre-Appendix R, if 24 they stay with pre-Appendix R, Appendix R, and then Option A 25 and Option B under the new standard. You are going to ANN RILEY & ASSOCIATES, LTD.
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S- 30 1 simultaneously have four plus --
2 MR. CONNELL: There will be three.
3 COMMISSIONER McGAFFIGAN: Okay.
4 MR. CONNELL: If they adopt 805, that will be 5 their license condition. Okay. Within 805, there are 6 dete-rministic and performance, but it is still the same 7 license conditions.
8 COMMISSIONER McGAFFIGAN: Okay.
9 MR. CONNELL: So they will have sufficient 10 flexibility, I believe,, that it would be desirable.
11 COMMISSIONER McGAFFIGAN: Okay.
12 MR. CONNELL: The additional burden is going to be 13 on the site-wide risk evaluation. We see that as an 14 expansion of the existing IPEEE. So if they want to elect 15 to adopt that burden, they will get better risk information.
16 COMMISSIONER McGAFFIGAN: Okay.
17 CHAIRMAN JACKSON: Okay. Commissioner.
18 COMMISSIONER DICUS: Do you plan to have any pilot 19 plants or have any plants come forward and want to be a 20 pilot plant?
21 MR. CONNELL: I think, if you notice, NEI, I think
(
22 is going to cover it in their presentation, but some plants 23 have expressed an interest in piloting the 805 standard, 24 yes.
25 CHAIRMAN JACKSON: Why don't you go on?
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.- . _.__ ___._ _ ___ . _ _.._ _ . _ . - . _ . . _ . _ _ _ _ = _ _ _ . . _ . _ - _ . _ . _
t . .
S- 31 y 1 MR. CONNELL: I'm finished. I will turn it over 2 to Steve now to talk about the FPFI.
3 CHAIRMAN JACKSON: Okay.
l 4 MR. WEST: Good morning, I am Steve West, the 5 Chief of the Fire Protection Engineering Section. I am l i I
l 6 going to give you a briefing on the fire protection l
l 7 functional inspection program, and I will try to be brief.
8 But, basically, the program came out of two staff ,
9 activities. One was thermo-lag and a commitment we made to l 10 inspect the thermo-log corrective actions at all plants, and 11 I think about 80 plants use thermo-lag, so it was a 12 significant inspection activity. ,
i 13 And the other was a fire protection program 14 reassessment that came out of the thermo-lag issue itself,
\
15 and in that reassessment, there were recommendations that we 16 relook at the scope and depth of inspections we were doing 17 and maybe make changes to try to preclude problems 18 thermo-lag coming up in the future.
19 So, basically, the objectives were to --
20 CHAIRMAN JACKSON: Can you give the timeline for 21 this program?
22 MR. WEST: Yes, ma'am. We originally identified 23 the need to do the inspections of thermo-lag corrective 24 actions in the thermo-lag action plan which we -- the first l
revision, or original version we issued in August of 1992 to l .
25 i
i !
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4 m --v
l l
S- 32 1 the Commission. The fire protection program reassessment 2 was completed in February of 1993, and that was actually a 3 thermo-lag action plan task. I i
4 Later, in SECY-93-143, May '93 timeframe, we 5 reported to the Commission our plans to address the l 6 recommendations from the reassessment, and in there we 7 identified the need to look at the fire protection --
8 reactor fire protection inspection program. ,
l 9 It was finally in December of 1996 in SECY-96-267 l 10 that we presented to the Commission our final plan for the 11 FPFI program, identifying the scope and objectives of the 12 program. And in a SRM of February 1997, the Commission 13 indicated that they had no objection to the staff going 14 forward with the FPFI pilot program.
15 Since February of 1997, we have issued at least 16 one interim status report late last year, and there was 17 another one which you may or may not have, it was on its way 18 to you last time I checked. It may be there.
19 MS. VIETTI-COOK: They have it.
20 MR. WEST: They have it.
21 MS. VIETTI-COOK: They got it yesterday.
22 MR. WEST: Okay. Great. So that is kind of the ch.ronology of where we are. But, basically, four 23 24 objectives, as I said, to inspect thermo-lag corrective 25 actions. We were also trying to determine if the licensees 7JRI RILEY & ASSOCIATES, LTD.
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S- 33 1 were maintaining the licensing and design bases and 2 complying with the fire protection requirements and their 3 commitments to meet those requirements or fire pro.-ction 4 guidance.
5 We also wanted to continue in the vein of the 6 reassessment to assess the NRC reactor fire protection 7 program to determine if it had appropriately addressed all l 8 fire safety issues and, kind of along those lines, to assess 9 the strengths and weaknesses of our program, our regulatory l 1
l 10 process for fire protection.
11 Another objective was, again, as I said, to 12 reevaluate the scope and depth of the NRC reactor inspection 13 program and to develop a coordinated approach to reactor l
14 fire protection and post-fire safe shutdown inspections, and l- 15 by doing so, to determine the appropriate level of future i
16 fire protection inspections.
j 17 And another objective which we explicitly 18 identified in our paper was to attempt to renew industry I 19 attention to fire safety. There was a feeling in the l 20 thermo-log era that the interest in -- or attention to fire l .
j 21 safety had dropped off within industry, and I think, to some l l 22 extent, within the NRC staff also.
l 23 CHAIRMAN JACKSON: Steve, how do you foresee fire 24 protection inspections in the new NRC reactor oversight 25 program? I mean is there a need for a level of baseline i
l
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S- 34 1 inspection? l l
2 MR. WEST: That's a good question and it is one 3 that actually we are trying to come up with an answer to !
l 4 right now. That is one of the reasons we have delayed our 5 final report. As you know, when we started this process, l 6 there was no concept that there would be a new performance 7 assessment inspection program, and it is come along right at 8 about the -- you know, they have kind of hit head-on with 9 the end of the FPFI pilots. And we are trying to assess the 10 lessons learned from the FPFI pilot inspections, and a 11 couple of other FPFI-like inspections that we have done, and 12 make a decision on whether or not we should just develop a 13 program that fits nicely into the new process, or whether 14 fire protection for at least some period of time needs to be 15 treated as a special case.
16 And I think actually if you ask the inspectors 17 that did the inspections, they have ideas. I developed a 18 program, I have ideas. I know my management has ideas in 19 the EDO. So we are really -- I was going to mention later, 20 there is a significant challenge to us right now to try to 1 21 come up with a recommendation for you that addresses that 22 very question.
CHAIRMAN JACKSON: Okay. Well, I think it 23 24 requires some specific thought and effort. I mean I l
I 25 encourage you very strongly.
l J
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S- 35 l fs 1 MR. WEST: Yes, ma'am.
As, 2 CHAIRMAN JACKSON: Because it is an opportunity 3 and coming -- you know, you have the insights coming out of 4 your FPFI.
5 MR. WEST: Yes, ma'am.
6 CHAIRMAN JACKSON: So I think it is very important 7 to give some specific thought to it, difficult though it may I
8 be.
9 MR. WEST: Yes, ma'am. And I will talk a little 10 bit about what we are doing now, and kind of they all feed 11 into that, trying to answer that question.
12 I am on slide number 11. So, anyway, so we can 13 get through this quickly, I will cover what the scope of the
/\g 14 program was and what our accomplishments were together, b 15 because, basically, we have completed the program, 16 essentially, as we laid it out originally in 1996. We did 17 develop new inspection procedures for FPFIs, and it was a 18 comprehensive fire protection and safe shutdown procedure.
19 And I should make it clear that when we talk about 20 fire protection functional inspections, we are normally 21 talking about what you would normally think of as a fire 22 protection feature that may be installed in a plant, like a 23 sprinkler system, or the fire extinguishers, or the fire 24 hoses or the fire brigade.
25 We are also talking about the capability of the ANN RILEY & ASSOCIATES, LTD.
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r 4 A S- 36 I
1 plant being able to achieve and maintain post-fire safe 2 shutdown. So if they have a fire, they are going to have 3 the systems available to achieve shutdown. So it is also 4 classical fire protection, and it is also the safe shutdown 5 capability itself, the plant systems and other features that 6 are used by the reactors to shut the plant down. So it is a 7 very complicated, complex area.
8 And the scope and depth of this new inspection 9 procedure went -- I will just characterize it way beyond any 10 previous NRC inspection procedure for fire protection. And 11 another thing that we factored into the program right from 12 the beginning was the use of risk insights to help focus on 13 areas of inspection.
14 That worked very well. We did conduct four pilot 15 inspections. As we specified in the SECY paper, we went to 16 River Bend, Susquehanna and St. Lucie and did full FPFIs.
17 The fourth one we deviated a bit from what we told you we 18 would do in the Commission paper and we went to Prairie l 1
19 Island, but instead of doing a full-scope FPFI, we did what l l
l 20 we are calling a reduced-scope FPFI where we basically 21 inspected a licensee's self-assessment that was based on the 22 FPFI procedure and also Prairie Island, when they did their 23 self-assessment, took into consideration the lessons learned .
1 24 from the previous FPFIs and another difference with that 25 inspection is the first three were led by Headquarters with
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l' S- 37 1 regional support. The Prairie Island was led by the region 2 with Headquarters support, so it was a little bit different 3 focus there and we're trying to get information on how well l ~
4 a licensee's self-assessment program may fit into the future 5 of fire protection inspections.
6 CHAIRMAN JACKSON: Well, see, that's also -- that 7 takes me back to the question I had raised with you 8 vis-a-vis the new Reactor Oversight Program, because, you 9 know, the role of baseline inspections by self-assessments, 10 by special inspections being addressed -- I'm listening.
11 MR. WEST: You just reminded me I never really did 12 answer your question. You did ask did we think that 13 baseline --
14 CHAIRMAN JACKSON: Yes, I did. That's right.
{
15 I thought you were just being smooth and avoiding 16 my question.
17 [ Laughter.] i 1
18 MR. WEST: I think whatever we do there will be 19 some NRC baseline inspection involved and that is currently 20 -built into the process. What exactly that inspection would 21 look like is up in the air, but I will talk to you a little 22 bit about the current baseline or core inspection on the next slide.
24 CHAIRMAN JACKSON: Okay.
25 MR. WEST: In addition to the four pilot FPFIs ANN RILEY & ASSOCIATES, LTD.
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1 S- 38 1 that we did, we also did a couple of other inspections. We 2 did inspections at Quad Cities and Clinton, and they were 3 not FPFIs but we used FPFI techniques during those 4 inspections so we are also considering the lessons learned 5 from those two inspections in our process now to assess 6 where to go in the future.
7 Finally, we had a one-day workshop with industry 8 and the other stakeholders and we did this in November of 9 1998. It was a very worthwhile exercise. We got a lot of 10 good information out of the workshop from licensees and from 11 industry and from others. We basically discussed the 12 results of the program, got input from the stakeholders.
13 We learned in the workshop that one of our 14 obj ectives., to increase industry awareness of fire 15 protection, to refocus industry, we accomplished. For 16 example, a lot of licensees that were not subject to the 17 pilot program had gone out and done self-assessments on 18 their own initiative. I think NEI -- I don't know if they 19 were going to dover FPFIs in their presentation, but they 20 acknowledged in the workshop and in a later meeting with the 21 Staff that we had been very effective in doing that.
22 The inspection procedures were I think by 23 everybody that talked about them thought they were 24 outstanding inspection procedures and in fact we will talk 25 in a second about NEI's proposal, but they believe those IdHJ RILEY & ASSOCIATES, LTD.
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. , 1 S- 39 1 procedures could be used in an industry initiative later.
2 One interesting thing that came up -- well, 3 actually we raised it and industry agreed, licensees agreed, 4 was the use of risk -- risk assessment in fire protection 5 and the need to come up with tools and methods to assess 6 fire protection deficiencies like those that you find during 7 an inspection.
8 Again, that is something that we are working on 9 now. We have had some internal meetings with our fire 10 protection staff and our risk staff from NRR and Research.
11 We have a meeting in a couple of weeks with the same people 12 plus we are bringing in all the SRAs from the regions and 13 others within the agency that are interested and are
(
'~
14 responsible for risk assessment.
The real problem is not that it can't be done. We 15 16 have had some experience in looking at some of the FPFI l
17 procedures where we have different groups looking at the
- 18 same issue, and.they come up with different answers. To get l 19 the answers we are spending a lot of time and effort and 20 resources. We want to come up with a way to assess fire 21 protection deficiencies, kind of a standardized approach 22 where everybody is looking at it in the same way and you can 23 expect fairly consistent results by somebody that is 24 knowledgeable and experienced and trained in using the 25 method, and it has got to be a method that can be done O ANN RILEY & ASSOCIATES, LTD.
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S- 40 l
1 easily.
2 You can't spend two weeks looking at each fire 3 protection deficiency that we find, and industry, NEI in 4 particular, also recognizes the shortcomings and the need to 5 overcome those, and there are some industry efforts underway 6 to develop techniques, and I expect that -- we are going to 7 be having a meeting with NEI shortly, but I expect that 8 sometime we'll come together again with industry and try to 9 continue to cooperate in this area.
10 Okay, next slide please -- Slide 12.
11 Some of our preliminary observations -- we have 12 discussed, I think we have discussed these in the interim 13 reports that we have forwarded to the Commission, but some 14 licensees expended more resources to prepare for FPFIs than 15 we had expected when we set up the program.
CHAIRMAN JACKSON: So that was a surprise?
16 17 MR. WEST: Yes, that was a surprise.
18 CHAIRMAN JACKSON: And I mean why are licensees 19 not already ready? I mean I guess that is what is 20 confusing.
MR. WEST: That is another good question.
21 Some licensees - I don't want to give the 22 23 impression that no licensees are ready --
CHAIRMAN JACKSON: No , I am talking about any 24 l
25 specific cases.
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S- 41 l
-- 1 MR. WEST: Well, one specific example I can give (s,) 2 you where we have some letters from the licensee. It was i l
3 St. Lucie -- and they asked us to postpone the FPFI that we 4 had scheduled there and in their letter they stated that it 5 was going to take them basically 24,000 staff hours to
~
6 prepare for the inspection, and when you see a number like 7 that, that is a huge surprise.
8 It turns out in their case we believe that they 9 weren't preparing for the inspection -- just in other words 10 getting the documents ready --
11 CHAIRMAN JACKSON: They were getting the plant --
12 MR. WEST: -- for the Staff. They were fixing 13 their program, and it turns out they had some significant
/ 14 problems with their fire protection program itself.
MR. MARSH: Let me add a comment, if I can. To be 15 16 fair, this is a new inspection procedure, a new inspection 17 process, and there was in my opinion growing in terms of the 18 industry looking at what they needed to do to prepare for l 19 it, so there was certainly some getting the plant, getting 20 the procedures ready but it was also where is the agency 21 looking, what does this procedure look like.
22 There was growth on both sides in this endeavor, I 23 would say.
COMMISSIONER MERRIFIELD: Chairman, I just -- you 24 25 know, I seized upon the same sense you did, and I am I
l
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i S- 42 1 reminded of the discussions we went through when we had our 2 reanalysis of the OSPRI program --
3 CHAIRMAN JACKSON: OSPRI --
COMMISSIONER MERRIFIELD: -- where we had spent 4
5 significant resources to get ready and I think that is a 6 concern. That is a concern, particularly since from a 7 risk-based analysis fire issues are one of the most 8 significant things we have to deal with.
9 If people have to expend resources at these plants 10 to get ready to do this, and I understand that it is a new 11 program, a new way of doing things --
CHAIRMAN JACKSON: With all the people working 12 13 every hour for a year, that is a lot.
i 14 COMMISSIONER MERRIFIELD: And what does that 15 indicate to us for the other plants that were not doing this 16 kind of an assessment?
17 CHAIRMAN JACKSON: That's right.
18 MR. WEST: Again, that is a part of 19 CHAIRMAN JACKSON: Speak to the microphone.
20 MR. WEST: That is part of something we are taking 21 a look at. We touched on the --
COMMISSIONER MERRIFIELD: Well, does it concern l 22 23 you?
l 24 [ Laughter.)
25 MR. WEST: Yes, it does. Very much. Very much.
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S- 43
~ 1 COMMISSIONER MERRIFIELD: Okay.
,/ ss I
(
N ,/ 2 MR. WEST: And I think comments during the 3 workshop we received from industry for example, they were -
4 also quite surprised about this and acknowledged that it was 5 a matter of having a program that needed to be repaired in 6 advance of an inspection, or that was the attempt.
7 MR. MARSH: During the workshop there was 8 acknowledgement on the part of the industry that there was a 9 great deal of effort they had to go through to get ready for 10 these inspections, and in the sense that there was some 11 housecleaning that needed to be done on their part to 12 gain -- regain assurance of fire protection programs.
13 We didn't hear in the workshop the fire protection
/N 14 functional inspections were on the wrong track. They were
('
15 not finding things that were not important, that the 16 programs were all ready to go. We didn't hear that. We 17 heard an acknowledgement that there was a need for this 18 program and an acknowledgement that fire protection programs 19 needed to improve, and that through many endeavors through 20 either their self-assessment process or through an 21 inspection process they believed that improvements have been 22 made, and that was one of the objectives of this program was 23 to. regain the sensitivity to fire programs.
24 CHAIRMAN JACKSON: Well, again, I mean I sound 1
25 like -- I will call myself "the broken CD" -- you know, n) k ANN RILEY & ASSOCIATES, LTD.
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S- 44 1 " record" -- the " broken CD" from now on. I hope you all 2 took notes relative to the new Reactor Oversight Program 3 because you have got to kind of grapple with what at a 4 fundamental level we need to be looking at and what at a 5 fundamental level licensees need to be doing and looking at, 6 because this kind of thing is an eye-catcher.
7 MR. WEST: Yes, ma'am -- we have been --
8 CHAIRMAN JACKSON: And when you tell us the 9 numbers, you know, 24,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br />, that is a lot --
10 MR. WEST: Right.
11 CHAIRMAN JACKSON: -- and, you know, there can be 12 a knee-jerk reaction, "Oh, there's the onerous NRC" but if 13 people, if it is a risk-informed look, and folks are not 14 telling you you are barking up the wrong tree, then that 15 says something, that that is an area that we have to ensure 16 that we give attention to, as the regulatory program has 17 migrated.
18 MR. WEST: In addition, and I am probably getting 19 ahead of you, but the next bullet, the fact that we are 20 finding things that wouldn't have been found through the 21 core inspection --
22 CHAIRMAN JACKSON: By the core inspection, that's 23 right.
MR. WEST: -- that underscores even more, I 24 25 believe --
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S- 45 j- s 1 CHAIRMAN JACKSON: I understand. That's the
(
\s_-) 2 point. That's why I raised the issue about the baseline.
3 What is the baseline?
4 MR. WEST: Yes, Chairman.
5 I don't think we really thought about the core 6 inspection program too much before we started the FPFIs but 7 once we got into doing a couple pilots it became obvious 8 that there were problems out there that were not found by 9 our core inspection or licensee self-assessments that were 1
10 based on the core inspection, and in hindsight when we l
11 thought about it, we said that that really shouldn't be too 12 surprising because the core program is set up more along 13 looking at classical fire protection lines and it wasn't looking at the engineering issues. It wasn't looking at
(N 14
\s_ 15 design issues. It wasn't looking at configuration control.
16 Our theory is that there was a feeling, not a l 17 feeling but we had done Appendix R inspections after plants 18 originally complied with Appendix R in the early to mid '80s 19 and during those inspections we verified that the barriers 20 were there, the seals were there, the sprinkler systems were 21 there, and there may have been a feeling that once that was 22 done it was treated more as a milestone, and all we needed 23 to.do in the future was go back and just make sure the 24 barrier was still there.
25 So the inspector might say, just see a barrier and ANN RILEY & ASSOCIATES, LTD.
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l S- 46 1 say, you know, they're done when in fact no one had really 2 looked at the document base behind the barrier or whether 3 plant mods have made that could have invalidated the safe 4 shutdown capability, so --
5 CHAIRMAN JACKSON: Well, the key is the second "F" 6 in FPFI -- you know the " functional" inspection.
7 MR. WEST: Yes, ma'am. Absolutely.
8 CHAIRMAN JACKSON: And -- okay, I am going to stop 9 talking. You have got the message. I'm sure.
I think I have gone over my time. I'll 10 MR. WEST:
11 try to hurry up.
12 I think in the -- I am not sure if we have 13 reported it but if you just go through the six inspections 14 that I '.nentioned earlier and you just do a simple count of 15 anything tilat was identified as a problem or a weakness or a 16 finding or an unresolved item, we had 140 separate items and 17 obviously they had varied safety significance.
18 Some were little to no safety significance and 19 some were of more safety significance. To cover those could 20 be another whole briefing.
21 We did find through Prairie Island we believe that 1
l 22 the licensee self-assessments that would be based on an FPFI 23 techniques could be beneficial as a way to continuing to 24 achieve a good level of fire safety within industry.
COMMISSIONER McGAFFIGAN: Madam Chairman?
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S- 47 s 1 CHAIRMAN JACKSON: Yes, please.
Un 2 COMMISSIONER McGAFFIGAN: He flew past the 140 3 times and said it would take a whole briefing, but could you 4 describe the single most safety significant item you found, 5 just to give a ballpark?
6 MR. WEST: That's really going to be a judgment 7 call. I mean I'll tell you some that we --
8 COMMISSIONER McGAFFIGAN: A significant --
9 CHAIRMAN JACKSON: "A" --
10 COMMISSIONER McGAFFIGAN: A significant.
11 MR. WEST: Well, for example, an issue that, a 12 fincing that we believe was significant we found during our 13 first FPFI at River Bend and it was a situation where they 14 had a cable that if there was a fire involving that cable 15 and they had a certain type of fire-induced fault all of the 16 safety release valves could inadvertently open, so that 17 would be an example of a significant, what we believe to be 18 a significant finding. The licensee has corrected that 19 problem.
20 Something that would be less significant may be an 21 isolated example of combustible controls procedures not 22 being followed -- maybe a little too much combustibles in an 23 area that that shouldn't be there, so there really is a 24 large range, and different people will place things in t
l 25 different bins -- high, medium, or low.
l
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S- 48 1 CHAIRMAN JACKSON: Did you ever take a look at 2 where combustible gases are stored?
3 MR. WEST: Yes, ma'am. We did it as part of the 4 FPFIs and it has also been something the agency has looked 5 at several times. There were generic safety issues 6 involving combustible gases, and there is guidance on 7 combustible gases --
8 CHAIRMAN JACKSON: But things come up from time to 9 time.
10 MR. WEST: Yes, ma'am. Just quickly, to finish up 11 Slide 12, as I have mentioned, we do think we did renew 12 industry attention on reactor fire safety and in the 13 workshops NEI and others did say that we should take some 14 steps to ensure that we stay there. We shouldn't just back 15 off completely and let things backslide.
16 We didn't find any significant problems with our 17 Reactor Fire Protection Program, looking at Appendix R and l 18- IPEEE and the various guidance documents. We didn't find 19 any gaping holes where there was a fire safety issue that 20 had not been adequately addressed.
21 Again, there may have been some problems in l l
22 implementation but it appears that the regulatory 23 framework's health is sound.
24 CHAIRMAN JACKSON: So you are saying that as long 25 as licensees implement the regulatory framework ANN RILEY & ASSOCIATES, LTD.
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~ . -
S- 49 '
i 1 appropriately, then there is not a problem?
2 MR. WEST: Some may say as long as they implement l i
3 it the way we think it should be implemented -- l 4 CRAIRMAN JACKSON: As you define it -- ;
5 MR. WEST: As we define it -- there is not always j l
6 total agreement, and that has been one of the problems. As
! 7 we said, circuit analysis in an area where we think the '
8 basic requirements are sound, but there could be confusion :
l 9 in the implementation and we are taking action to address 10 that.
11 My last slide is Slide 13, before we move into l 12 IPEEE, but what do we have left to do? I think we have 13 touched on all of these. I won't go over them again, but we 14 are looking at developing a method for assessing the risk 15 -significance of fire protection deficiencies.
16 We have this big meeting in a couple of weeks.
l 17 Hopefully we will come out of that with something we can use. We do want to actually assess the risk significance so l
l 18 19 we can come up with a consensus on the FPFI findings or at 20 least the important ones, so we can report those to you in j 21 our final report.
22 Continuing our assessment of the lessons learned, l 23 we do have from NEI a proposal for an industry initiative 24 that would continue some level of fire protection l inspections in industry. Basically they are proposing a l
25 b ANN RILEY & ASSOCIATES, LTD.
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S- 50 phase-out of FPFIs as a routine type of inspection, to be 1
2 replaced with licensee-managed self-assessments.
3 We would have oversight of those self-assessments 4 through the new performance assessment and inspection 5 program. We would still have some level of baseline 6 inspection and if a plant gets into a certain range -- you 7 know, the green, yellow, white -- then we may warrant a 8 FPFI.
9 But we are looking at the NEI proposal.
CHAIRMAN JACKSON: Commissioner McGaffigan?
10 COMMISSIONER McGAFFIGAN: Part of the NEI proposal 11 12 is to develop fire-protection performance indicators, and, 13 you know, the notion generally in this assessment process is 14 where there are indicators we will inspect less, and where 15 there aren't indicators, we'll inspect more.
16 How difficult is it going to be to come up with 17 indicators? I mean, I can count combustibles lying around ,
18 on the floor or whatever, but, you know, the one you cited, l 19 the cable -- the analysis which leads to the conclusion 20 that, you know, if our induced faults could have all the 21 safety valves - relief valves open, that doesn't sound like 22 something that you're going to have a performance indicator l
I 23 on very readily.
24 MR. WEST: We in the industry have acknowledged 25 that it would be very difficult, it would be challenging.
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S- 51 1 We had, when we met with the ACRS subcommittee and full 2 committee last week, they also agreed that it would be 3 difficult, but they seemed to believe it could be done. We 4 really need to think about that before I could give you 5 specific examples.
6 I mean, you've given some examples, and certainly 7 those could be performance indicators. It may not be -- it 8 may end up that it's not very discrete items like, you know, 9 how well is your surveillances or maintenance of sprinkler 10 systems. It may be a more general type of indicator like if 11 you do a self-assessment, you need to look at the results of 12 the self-assessment and consider what that means to the 13 health of your fire-protection program.
14 CHAIRMAN JACKSON: Okay. I think we'd be ss 15 interested in -- the Commissioner wants to hear NEI's, you 16 know, commentary in this area. But I just wanted to mention 17 to Commissioner McGaffigan, the baseline inspection program 18 . is meant to cover areas where there are no --
19 COMMISSIONER McGAFFIGAN: Right.
20 CHAIRMAN JACKSON: Indicators, and to validate --
21 COMMISSIONER McGAFFIGAN: Validate. I understand. ,
22 CHAIRMAN JACKSON: So that would help --
23 COMMISSIONER McGAFFIGAN: More --
24 CHAIRMAN JACKSON: Right, but that would help 25 in --
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S- 52 1 COMMISSIONER McGAFFIGAN: But the thrust of this 2 briefing so far has been that maybe a larger part of the 3 baseline inspection program than perhaps is currently 4 planned needs to be focused on fire.
5 CHAIRMAN JACKSON: Right. That's an interesting 6 point, or at least fire needs to be squarely addressed as 7 part of that.
8 MR. TRAVERS: It could be viewed as similar to 9 some of the issues that have been raised on design basis and 10 how you get to a comfort and confidence level, you know, 11 because of the lack of good performance indicators.
12 CHAIRMAN JACKSON: Right. Right.
13 COMMISSIONER DICUS: Do you think that this 14 self-assessment program would keep the licensees focused on 15 fire protection? Because apparently they've wandered off 16 from being focused on that, which is part of what we're 17 doing here.
18 MR. WEST: Well, at this point we're really still 19 considering that. It's not clear, and we need to have 20 additional interaction with NEI as to exactly whether this 21 would be a voluntary initiative or whether NEI is going to 22 recommend or make a stronger recommendation that licensees 23 do .it. And we would imagine if we bought into this type of 24 approach there would be some period of maybe a higher level 25 of oversight to really try to gauge that licensee's --
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S- 53 1 CHAIRMAN JACKSON: Commitment to the --
2- MR. WEST: Commitment to the program.
3 I think in the -- just to make one other comment 4 about performance indicators -- I believe in the development 5 of the oversight, the new oversight process, the team looked 6 at performance indicators for fire, and basically they said 7 the only one that made sense was the number of fires, but 8 then they concluded that that really -- that's a good 9 performance indicator, but you can't do that.
10 Anyway, we're going to -- we have this work to 11 complete. We have a lot to think about. We have a lot to 12 work out. And in the end we will give you a final report in 13 April which will lay out, you know, what we've done, why we 14 did it, what we believe the viable options are for the Ik 15 future and what our recommendation will be. l 16 CHAIRMAN JACKSON: And you are looking to factor j 17 it into the new oversight.
18 MR WEST: Yes, ma'am, we definitely are.
19 CHAIRMAN JACKSON: Okay. This is 7pril? ;
20 MR. WEST: Yes, ma'am.
21 CHAIRMAN JACKSON: The final report?
22 MR. WEST: Yes, ma'am.
23 CHAIRMAN JACKSON: Okay. All right.
24 MR. WEST: That concludes my presentation. If 25 there are no more questions --
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S- 54 1 CHAIRMAN JACKSON: Counting the number of fires is 2 like going down the highway at 100 miles an hour and when 3 you've passed a red barn, you've gone too far.
4 MR. WEST: Alan Rubin will be the next --
5 MR. RUBIN: Good morning. My name is Alan Rubin.
6 I'm section chief for the PRA Branch of the Office of 7 Research.
8 And in the interest of time, I'm going to be 9 covering two topics with three slides total, try to be 10 concise. However, there are additional backup slides which 11 are provided in your package to provide some additional 12 information.
13 I'm going to talk about the IPEEE program and the 14 fire risk assessment research program.
15 First, in the IPEEE program, that's on slide 14, 16 we originally anticipated that there would be 74 submittals 17 from licensees. However, four plants have permanently shut 18 down, and we've completed the preliminary reviews of all 70 19 submittals to date. We have also completed final reviews 20 and issued staff evaluation reports for 11 library i
21 submittals. And the reviews are being conducted in a 22 similar fashion to the way the IPE program was done.
23 It involves quite a significant number of steps I 24 along the way. I won't get into them in this meeting. But 25 just to again focus what the attention of the reviews are, l
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S- 55 1 we're looking to see whether the licensee submittals are f
2 complete, whether they're reasonable, whether they have 3 significant gaps, whether they have significant problems in 4 the assumptions or the analysis or the methods in the ;
5 program. We're particularly focusing to see if the i
6 assessments can address plant-specific severe accident '
7 vulnerabilities, which is really to meet the overall I 8 objectives of the IPEEE program.
9 In addition to that, we're also looking to see how i I i l 10 specific generic safety issues that relate to IPEEEs are :
11 being addressed and resolved, and I'll talk a little bit l 12 about that on the next slide.
13 In January of last year we provided a report to 14 the Commission that included preliminary perspectives from l
l 15 the review of the submittals that were conducted up to that i
16 time which were about a third to one-half of the submittals.
17 And let me just highlight some of the major conclusions from 18 that, and they really haven't changed since then. But I 19 think they're important to just go over again.
20 First we've seen that many licensees have 21 implemented improvements at their plants, made modifications 22 to improve plant safety. They include both procedural l 23 - modifications such as improving fire protection, fire l
24 response procedures, improving administrative procedures for 25 transient combustibles, and they've made some hardware l
t l0 l
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S- 56 1 improvements as well, such as relocating cables out of fire 2 areas, made improvements to their fire-suppression systems, 3 and several others. There's a backup slide that provides 4 some more examples in your package.
5 In the fire area, about half the plants' licensees 6 have made improvements to their plant. That's a substantial 7 number. And overall in the IPEEE program about 80 percent 8 of licensees have made some improvements, which is either 9 fire, in the seismic area, or high winds, floods, and other 10 external events.
11 We've seen from results in the submittals that 12 fire events can be a significant and in fact a dominant 13 contributor to core damage frequency, to the total core 14 camage frequency at the plant. The range of core damage 15 frequencies reported by licensees is from 10 to the minus 7 16 to on the order of 10 to the minus 4 per reactor year.
17 We make an important point about I'd say the 18 comparing of core damage frequencies between plants or even 19 between IPE's and IPEEE's. Anyone who's got a number is 20 going to make a comparison, but it's got to be done with 21 caution. There are some significant things I want to point 22 out to demonstrate where a comparison is not really 23 straightforward.
24 Similar conclusions were drawn from the IPE 25 program. First, there were differences in the modeling ANN RILEY & ASSOCIATES, LTD.
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S- 57 1 assumptions that analysts have made. And you've seen the O- 2 significant difference in the example already at Quad Cities 3 what that can do. There are differences in methods that are 4 used. These were approved methods that were put out in 5 guidance for doing IPEEE's. And there are acceptable 6 methods that differ from submittal to submittal. And 7 there's also a difference in the level of detail themselves 8 in the submittals from one plant to another.
9 COMMISSIONER McGAFFIGAN: Madam Chairman? l 10 CHAIRMAN JACKSON: Yes, please.
11 COMMISSIONER McGAFFIGAN: We had ACRS in last week 12 and we were talking about elevating core damage frequency to 13 a safety goal, and it strikes me that we've just been warned
[h 14 by the staff that, you knou, not to trust these overall l
\ 17 15 numbers, which is a conversaticn we also have had with ACRS. l l
16 But how could we get -- I mean, if we ever do go down the 17 line of making core damage frequency a safety goal, do we 18 have to standardize these methods and have a standard 19 method, a standard level of detail, you know, in order to 20 get the comparability across?
21 MR. RUBIN: Simple answer, in my view, yes, I 22 think so. I mean, we were looking at the, you know, reviews 23 not so much focusing on the quantitative number --
COMMISSIONER McGAFFIGAN: Looking at relative --
24 25 MR. RUBIN: We're looking at relative risk at the s
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S- 58 1 plant to see whether the licensee has done that.
2 COMMISSIONER McGAFFIGAN: Right.
3 MR. RUBIN: But for the objective that you're 4 talking about, yes, I think you would need some kind of a 5 standard. And a standard is being developed for the 6 internal events PRA, and you're aware of that, and certainly 7 in the IPEEE that could be as well.
8 CHAIRMAN JACKSON: But when you get to the 9 IPEEE's, your uncertainties --
10 MR. RUBIN: State of the art is different.
11 CHAIRMAN JACKSON: But nonetheless, your point is 12 well taken.
13 MR. RUBIN: Okay. Going on to the next slide, I 14 just wanted to focus on areas in addition to the 15 plant-specific reviews where the staff and industry is using 16 risk information from the IPEEE program. First, as I 17 mentioned, the licenses have made improvements to their 18 plants in a number of areas. In addition to that, the staff 19 has used the IPEEE program to identify or to help identify 20 and prioritize the fire risk research program. For example, 21 at Quad Cities we saw that the area of turbine building 22 fires can be a significant contributor, and that's part of 23 the fire risk assessment research program.
24 We're also looking at how the submittals can 25 address and resolve specific IPEEE-related generic safety ANN RILEY & ASSOCIATES, LTD.
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I S- 59 1 issues. Brian Sheron mentioned there are about a dozen of J
) 2 those in the fire area.
3 CHAIRMAN JACKSON: Could you give us one, using 4 Mr. McGaffigan's technique, give us one example?
l 5 MR. RUBIN: Yes, the effects of smoke on manual 6 fire suppression is one example. It's a fire' risk coping 7 study issue. Seismic fire interaction is another issue.
8 Okay. There are again twelve in the fire area.
j 9 CHAIRMAN JACKSON: Are you doing this yourselves?
10 Are you doing it with international cooperation? How is it l 11 working?
12 MR. RUBIN: No , this is not being done -- the l 13 reviews are not being done --
l i 14 CHAIRMAN JACKSON: No , I'm talking about the
! \
15 research program.
16 MR. RUBIN: The research program, yes. I will get 17 into that. It's done in a collaborative, cooperative i
18 program with both international participants as well as
- 19 industry and economic.
20 CHAIRMAN JACKSON: Okay. ;
i 21 MR. RUBIN: Yes. You're at the conclusion of my 22 last bullet.
l 23 CHAIRMAN JACKSON: Oh, I'm so sorry.
l 24 MR. RUBIN: There are 25 issues that are being 25 addressed in the IPEEE program, including one unresolved t
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r S- 60 1 safety issue, one shutdown decay heat removal requirements, 2 seven generic issues of which some have nine to seven to ten 3 subparts in them as well as fire-risk scoping study issues.
4 And the resolution of each of those issues is documented in 5 each plant's staff evaluation report.
6 Of the reports we've completed to date, we've seen 7 that not all issues were resolved in each plant, and for 8 those cases, there will be followup by the staff, either on 9 a generic basis or a plant-specific bases if an issue is not 10 resolved.
11 However, in large part we are finding that the 12 issues are being addressed and the IPEEE's are adequate to 13 resolve a number of issues.
14 The fourth area that we're using risk information 15 is to provide input to NRR and prioritization of areas for 16 fire plant inspections. Which areas, for example, in the 17 IPEEEs are showing up as dominant risk contributors? And 18 that's very useful information that's input to where fire 19 protection inspections can focus their activities.
20 CHAIRMAN JACKSON: Doesn't that help you get at 21 the issue of the risk significance of inspection findings 22 themselves?
23 MR. RUBIN: That's the other side of the coin.
24 This is an input to the --
25 CHAIRMAN JACKSON: Right.
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S- 61 1 MR. RUBIN: Risk program. The other side, as 02 3 we've probably -- I'll talk a little bit -- may need some new tools or additional tools, to help assess what the risk 4 significance is of the findings.
5 CHAIRMAN JACKSON: Were you going to talk about 6 that?
7 MR. RUBIN: I'll talk about that when I get into 8 the --
9 CHAIRMAN JACKSON: Okay.
10 MR. RUBIN: Fire risk assessment.
11 CHAIRMAN JACKSON: Fine. I'll wait.
12 Commissioner Merrifield has a question, I think.
13 COMMISSIONER MERRIFIELD: I was going to wait till 14 his next point and ask my question.
\ 15 MR. RUBIN: Okay. Next point I'm certain is of j l
16 interest to the Commission. In fact, in response to a 17 Commission SRM that was issued in June of last year, we're 18 - assessing the effect of exemptions to Appendix R on fire 19 risk, and this stemmed initially from Quad Cities, and there 20 are other overall significant impacts on exemptions.
21 CHAIRMAN JACKSON: Do you have any preliminary 22 results?
You knew I was going to ask that. l 23 24 MR. RUBIN: I knew you were going to ask that.
25 And I was going to tell you we are on schedule for n
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S- 62 l 1 providing a report to the Commission in May of this year, 2 which is consistent with the SRM. l 3 It's a challenging and difficult activity, as 4 we've seen. It depends on the level of detail we need to 5 get into. Is there enough information in the IPEEE's 6 themselves? Do we have the event trees and fault trees to 7 do an adequate assessment? And let me just tell you the 8 methodology of the approach that we're doing, see if that satisfied you temporarily. You'll still be here in May.
9 10 CHAIRMAN JACKSON: I'm looking forward to your --
11 [ Laughter.]
12 And I'll even be around a little while after that.
13 MR. RUBIN: We don't have the time or resources to 14 look at all 70 submittals, but we've picked ten plants, 15 those which have reported the higher core damage 16 frequencies, on the order of about 10 to the minus 4th. And 17 the range of exemptions for those plants is from three to j 18 more than 20 per plant, typically nine or ten exemptions for 19 each plant that we're looking at.
20 To assist the risk significance, we're asking !
21 three questions. The first one is do the exemptions, can 22 they contribute to a significant increase in the total core 23 damage frequency at the plant. That's an obvious question.
24 The second question is can the exemptions contribute to a 25 change in the dominant risk contributors or profile of risk ANN RILEY & ASSOCIATES, LTD.
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A 4 S- 63 1 at the plant. And, thirdly, can the exemptions contribute 2 to a change in plants' reliance on various fire protection 3 functions.
4 So I think with those three questions in mind, you 5 can see it's a challenging issue. We're in the midst of 6 doing that review. We have some contractor support to help 7 us in that area. And we're working actively to get the job 8 done.
9 CHAIRMAN JACKSON: Commissioner Merrifield I think 10 had a question.
11 COMMISSIONER McGAFFIGAN: Yes, mine goes to sort 12 of the cumulative effect of the exemptions. I mean, we do 13 have a number of exemptions out there, and many of them --
14 at individual plants. And do we have a good safety valve, a
\m 15 good safety check to make sure that that one additional 16 exemption does not have in combination with all the other 17 exemptions we've given --
18 CHAIRMAN JACKSON: That's part of what you're 19 looking at --
20 MR. RUBIN: We're trying to assess for each 21 exemption is there a contributor, is an exemption -- does it 22 affect an area that's a high-risk contributor, a dominant 23 risk contributor for the plant. And we're trying to bin 24 those -- to answer your question that, you know, the 25 incremental or the marginal increase in risk, that's going ANN RILEY & ASSOCIATES, LTD.
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S- 64 1 to be a tough one.
2 CHAIRMAN JACKSON: But wasn't it true -- well, 3 before this analysis exercise -- that at least in a certain 4 instance at Quad Cities that you had exemptions that 5 overlaid with each other in terms of their net effect on the 6 plant?
7 I mean, that was my understanding in at least one 8 instance with Quad Cities specifically.
9 Mr. West.
10 MR. WEST: I'll try to address that.
11 When we originally went to Quad Cities after they 12 submitted the IPEEE, we thought that that may be the case.
13 And we v i find one exemption where we thought it 14 contribt .ed to a vulnerability, and the licensee took action l
15 to correct that problem, although they've indicated that in 16 risk space it really was not significant, but in practical 17 terms it could create a problem for plant shutdown.
18 We met with the licensee again in December of this I l 19 year, and they have gone through and did a detailed 1
20 assessment of their exemptions including the cumulative i
21 effects of exemptions. And they stated in the meeting that i 22 none of the exemptions where the cumulative effect was not a i
23 significant contributor to fire risk.
i 24 We didn't have a chance in that meeting to get
- 25 into the details of their analysis, but we're scheduling a ANN RILEY & ASSOCIATES, LTD.
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S- 65 '
1 followup meeting at the site in March where we're going to l 2 meet with them and go through in detail the assessments and i !
3 analyses that they did to reach those conclusions, because 4 we're -- you know, we're interested to find out how they did ,
5 it and how they got to the conclusions they got. So we j 6 would know more in March.
7 CHAIRMAN JACKSON: Commissioner, you were asking 8 the question relative to cumulative effect at a plant or i l
9 cumulative effect across the industry?
10 COMMISSIONER MERRIFIELD: I was looking at the ,
11 cumulative effect at a plant, an individual plant. l 12 CHAIRMAN JACKSON: Right.
13 COMMISSIONER MERRIFIELD: Do we have the right 14 assessment mechanism to be able to gauge that as we had 15 additional exemptions?
16 CHAIRMAN JACKSON: Why can't that analysis --
17 MR. RUDIN: We'll keep that it mind, that is a 18 valid point, as we do this. We are in the midst of doing l 19 that, and we will keep that in mind.
l 20 CHAIRMAN JACKSON: But I thought I had already 21 asked you to do that sometime ago. No , I had. That was 22 exactly the point at Quad Cities, was whether there was a 23 cumulative effect of the exemptions. And so if you can't 24 answer that for us, then we have no ability to answer the 25 question.
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S- 66 MR. RUBIN: No, that is part of it. We are doing 1
2 them separately, but we will combine each of the exemptions 3 to see what the cumulative effect is.
4 CHAIRMAN JACKSON: Okay.
5 MR. RUBIN: The last point on the slide is just to 6 point out that both -- another use of risk information from 7 the IPEEE program, both by.the staff and industry, is to 8 incorporate lessons learned from the risk insights from 9 IPEEE into the NFPA standard. And I mentioned a little 10 earlier where the appendix being developed for that 11 standard, which focuses on the site risk evaluation, will 12 provide guidance for NFP 805.
13 Just to conclude that final statement, that we 14 will issue a final IPEEE report after all the individual 15 plant evaluations are completed.
16 Let me move on to the next slide on the fire risk assessment research program. I would like to acknowledge 17 18 Dr. Nathan Siu, sitting in the audience, who has got the lead for this program. He is raising his hand right over 19 20 there. And just make a couple of points with regard to this 21 program.
22 As the agency and the Commission has moved towards 23 more risk-informed, performance-based regulation, there j 24 certainly is a need for robust fire risk assessment methods, l 25 tools and data to support those activities. We know there l
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c S- 67 l
1 .are some weaknesses in the' current state of the art in FRA, l s 2- fire risk assessment, and, in fact, we have seen how that 3 can contribute to variability in the IPEEEs in other. plant l 4 assessments.
5 There have been weaknesses that have been 6 identified in fire risk assessments, and improvements, work i i
7 has started -- was initiated to address ' ame of those 8 weaknesses. For example, analyses or da for fire 9 frequencies, fire modeling, looking at thermal fragilities l
l 10 of cables, looking at circuit failures, which was brought up l l
! 11 earlier, are some of the areas that are in the program.
12 And then SECY-98-30, which was provided to the i 13 Commission in October '98, summarizes the key research 14 findings from the fire research program, as well as needs l 15 for improvements.
16 And the last point goes to your question, Chairman 17 Jackson, in order to leverage our resources, the fire risk 18 program involves collaboration with industry, that includes 19 NEI and EPRI, with academic, with universities, with 20 government, for example, NIST, and wi.th international 21 organizations. And, as I said earlier, that program will have significant improvements by the end of 2000, but there 22 l 23 are products that have been developed and will be developed l
i 24 before that time period.
t 25 CHAIRMAN JACKSON: Okay.
)4 4
i i
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S- 68 )
MR. REYNOLDS: Good morning. Let me pull this l 1
over. Okay, there we go. In the interest of time, I will 2
3 just stick to my prepared remarks, and we will start with 4 slide 17.
5 As you may recall, Quad Cities shut down both Quad 6 Cities' units in the fall of 1997 due to significant 7 discrepancies between the safe shutdown analysis and the 8 safe shutdown implementing procedures, and the resultant potential increased risk of damage from fire. Commonwealth 9
10 Edison then undertook a number of corrective actions to deal 11 with the identified fire-related safe shutdown deficiencies 12 and to support plant restart.
13 The licensee revised and validated the safe 14 shutdown analysis for each unit. They revised and validated 15 and approved their safe shutdown implementing procedures.
16 Additionally, the licensee implemented a number of enhanced 17 fire protection compensatory measures in the high risk plant 18 areas. These included fire watches, enhanced controls over 19 combustible materials, enhanced controls over activities 20 than represented increased fire risk like welding and 21 grinding.
22 The licensee also augmented the additional 23 operating shift crews with one additional staff member per 24 shift to ensure they had sufficient personnel to be 25 available to perform safe shutdown activities.
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S- 69 s 1 Additionally, the licensee provided training to the 2 operational personnel and all other personnel required to 3 implement the new safe shutdown actions.
4 And in May of 1998, the NRC reconducted a 5 comprehensive inspection of their safe shutdown corrective 6 actions, and at that end of that inspection, the staff 7 concluded that the Quad Cities' safe shutdown analysis, and 8 their implementing procedures, along with the compensatory 9 measures I just mentioned above, were acceptable to support 10 plant restart for both units. And subsequent to the 11 inspection in late May, both units restarted.
12 Moving on to slide 18. Since plant restart, the 13 licensee has continued to take actions to reduce the Quad 14 Cities' fire risk and to improve the safe shutdown
[)
U 15 capabilities. In November of 1998, the licensee completed a 16 revised core damage frequency assessment for Quad Cities' 17 Unit 1. This improved risk assessment resulted in a core 18 damage frequency of 6 times 10 to the minus 5 per reactor 19 year. As you have earlier, this is a significant 20 improvement over the core damage frequency of 5 times 10 to 21 the minus third, which was included in the Quad Cities' 22 IPEEE which was submitted to us in 1997.
23 CHAIRMAN JACKSON: So the 6 10 minus 5 is a Unit 1 24 number?
25 MR. REYNOLDS: Right.
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r l
S- 70 l 1 CHAIRMAN JACKSON: What about Unit 2?
2 MR. REYNOLDS: They haven't finished that 3 analysis. Based on discussions with them, they think it is 4 going to be about the same.
CHAIRMAN JACKSON: The 5 10 minus 3, that was for 5
6 both reactors?
7 MR. REYNOLDS: Yes, ma'am.
CHAIRMAN JACKSON: So it wasn't done on a per 8
9 reactor basis?
10 MR. REYNOLDS: Right. ,
l 11 CHAIRMAN JACKSON: Okay.
12 MR. REYNOLDS: The two major factors in reducing 13 the risk between the 1997 and the IPEEE and the one they 14 just finished in November was a more accurate understanding 15 and determination of actual cable routings, where the cables 16 are, and a reduction in the conservatism of the fire 17 modeling. Knowing the actual cable routings allowed the 18 licensee to identify a number of additional components that 19 would be available to achieve safe shutdown. These pieces 20 of equipment had been previously assumed to be unavailable 21 due to fire damage.
22 The licensee is still continuing to implement a 23 number of actions to improve their safe shutdown 24 capabilities. These include a better safe shutdown system 25 optimization, a reduced unit interdependent study, and a ANN RILEY & ASSOCIATES, LTD.
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S- 71 l 1 cable separation study. Additionally, the licensee has ,
2 implemented a number of plant modifications which have 3 resulted in 3mproved safe shutdown and performance..
i 4 CHAIRMAN JACKSON: Now, is that part of 6 10 minus l
5 5, of is that above and beyond that?
l 6 MR. REYNOLDS: A little of both. They have 7 completed insulation of some pathway fire barriers, that was ;
8 included in the change. And then they have relocated some ;
9 critical cables. And they are going to plan additional l l 10 changes. Some of those include they are going to have 11 modification to the safe shutdown makeup pumps, the station 12 blackout diesel generator control circuit, and they have 13 changes to the reactor -- excuse me, the high pressure :
14 coolant injection system, and they are going to do
. 15 modifications to the fire protection features in the reactor 16 feedpump areas.
17 CHAIRMAN JACKSON: Are you able to include the 18 effect of fire watches on the mitigation of core damage 19 frequency due to fire, can you model that in a PRA? ?
20 MR. REYNOLDS: I'll let you try to answer that 21 one.
22 MR. RUBIN: The question is, can you model the 23 effect of fire watches in the PRA?
24 CHAIRMAN JACKSON: Correct.
25 MR. RUBIN: Our expert is shaking his head no.
i
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1 S- 72 l 1 Dr. Siu is our fire PRA cxpert. Do you want to expand on 2 that?
3 DR. SIU: Chairman, at this moment, fire l 4 frequencies are estimated based on statistical data, and 5 those data generally don't include whether or not a watch 6 was available. You can sometimes infer that the fire was 7 started by people who by there, and you can say, well, 8 there's -- you know, obviously, it was detected quickly.
9 But as far as fire frequency effects go, we don't have a way 10 to measure that.
11 CHAIRMAN JACKSON: Is that an issue, when one 12 thinks about compensatory measures that involve fire 13 watches?
14 DR. SIU: It is certainly an issue. Whether it is 1
15 one that we can really deal with in research space, I am not 16 sure.
17 CHAIRMAN JACKSON: Okay. Thank you.
I 18 MR. RUBIN: Is that it?
19 MR. REYNOLDS: Just the last point I wanted to 20 make is the NRC staff, both NRR and Region III, is going to 21 continue interact closely with the licensee as they continue 22 to make improvements.
23 CHAIRMAN JACKSON: Are there other plants with 24 similar issues, if not the same core damage frequency 25 numbers as Quad Cities? There were some ques' ons about ANN RILEY & ASSOCIATES, LTD.
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e .a S- 73 1 Salem and the Salem resta.rt. I mean that is not in your ps k, m 2 region, but --
I 3 MR. REYNOLDS: I will tell you the next one we are l 1
4 worried about is Dresden. Dresden has a 10 to the minus 4 !
5 number and they are basically in the same spot where Quad 6 Cities was. They didn't do a good job of understanding 7 where all their cables are, so they are in process.
8 MR. TRAVERS: They are in the midst of a 9 reanalysis?
10 MR. REYNOLDS: Right. And they are right behind 11 Quad Cities. I don't know if you wanted to speak to Salem.
12 MR. RUBIN: Salem doesn't come to mind as a real 13 plant that had a significant problem, but there was no plant 14 that had 10 to the minus third core damage frequencies.
15 There were a number of plants, approximately 10, that had on 16 the order of 1 to 4 times to the minus fourth core damage 17 frequency, and Dresden was among those 10.
18 CHAIRMAN JACKSON: I think Salem had an issue 19 having to do with fire penetration seals. Anyone want to 20 speak to the fire penetration seal issue?
21 MR. TRAVERS: Do you know, Steve, about Salem?
Yes, ma'am, I can address that. Salem, 22 MR. WEST:
23 prior to the restart of Salem, NRR assisted Region I in a 24 fire -- a couple of fire protection inspections there, and 25 the inspectors did identify a minor problem with the fire rx I )
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S- 74 1 barrier penetration seals. It was basically a documentation problem, which I understand has been resolved. The more 2
3 significant problem was the fire barriers themselves that 4 i were installed at Salem to protect electrical raceways.
5 There were questions about the qualifications of 6 those barriers and the licensee, prior to restart, committed 7 to a program to correct that, and they are into that 8 program. They have done some testing and there's meetings 9 between Region I and NRR and the licensee to review 10 progress.
11 CHAIRMAN JACKSON: Okay. Thank you very much.
12 MR. TRAVERS: That completes our presentation.
13 CHAIRMAN JACKSON: We will now hear from our 14 second panel, Mr. Ralph Beedle, a Senior VP of NEI, Mr.
15 David Modeen from NEI and Mr. Anthony O'Neill, who is Vice 16 President of Government Affairs for NFPA, National Fire 17 Protection Association.
18 MR. O'NEILL: Good morning, Madame Chairman.
19 Would you like the NFPA, National Fire Protection 20 Association, to go first? You had introduced us in that order, and that is fine with us. It is up -- it is your 21 22 choice.
23 CHAIRMAN JACKSON: Actually, I introduced you in 24 opposite order, but it's okay. You all decide.
MR. O'NEILL: Okay. We will do it that way, and )
25 !
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S- 75 1 perhaps the projectionist can come to the NFPA logo slides k 2 and we will start there.
3 Good morning and my name is Tony O'Neill, and I am l
4 Vice President of Government Affairs at the National Fire 5 Protection Association. We are certainly pleased to be here 6 We -- NFPA has appeared a couple of times in front of the 7 ACRS, but this is the first time we have had an opportunity 8 to appear before the full Commission. ;
1 9 As a way of introduction, over the years the NRC, l 10 the Department of Energy, the nuclear industry have used 11 NFPA codes and standards regularly as a part of their 12 program for assuring safety in the use of atomic energy. Of 13 course, last year, as was mentioned by Chairman Jackson, we
14 entered a new era of cooperation with the NRC, and with the 15 support of NRC, the nuclear industry, insurance, specialists 16 in a number of different fields, we started the development 17 of NFPA 805, which has already been described.
18 Today, what I will do is give you a brief overview 19 of NFPA and how we develop codes and standards through a 20 national consensus process. And before I do that, though, I 21 want to apologize for not having our Chairman of the 22 Committee, Len Hathaway, here and Rich Belon, who is our 23 Senior Engineer who is assigned to the project. Both of 24 them are in Europe at this time and, in fact, are looking at 25 methods and methodologies that are used in Europe for i
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S- 76 l 1 accomplishing the task at hand.
2 I would like to move to slide number 3, which goes 3 past the introductory items, and start with just a brief 4 overview of what NFPA is all about. The National Fire ,
5 Protection Association was founded over a hundred years ago, 6 and its purpose was to develop national consensus codes and 7 standards and, over the years, that has been our primary 8 purpose, although the Association has also evolved into a 9 public safety advocate organization in a very general sense, 10 including public education activities. We are a private, 11 non-profit, voluntary codes and standards developer, and the 12 Association's standards making activities are accredited by 13 the American National Standards Institute.
14 What does that mean? It means that we, in our 15 process, invite all effected and interested parties to 16 participate in the codes and standards making activity, not 17 only on the Committee, but in any way, shape, form in which 18 those people, individuals would want to be involved in that 19 process, and I will get into that a little bit more.
20 The process also is completely transparent, so 21 that anyone can participate, and we will talk about that.
22 And the process involves adequate due process to make sure 23 that the standards are arrived at in a fair and equitable 24 manner. We have members, close to 70,000 members in the 25 United States and some 79 nations around the world.
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S- 77 i
-s 1 I would like to move to the next slide, slide
(_s/ 2 number 4, and you will see that NFPA has been involved in 3 providing codes and standards for the federal government use 4 as we have with states, counties, cities, towns. The codes 5 and standards are used by architects, engineers, designers.
6 Many of them are adopted and referenced in building codes 7 and they are widely used as a basis for underwriting and I
8 insurance, and, of course, they are used by industry.
9 In the federal government area, just to mention 10 one or two of those that are listed on the slides, all 11 Medicare, Medicaid funding eligibility to some 35,000 12 healthcare institutions in the United States has as a 13 prerequisite the compliance with the Association's life
} 14 safety code, as an example.
(~'/
\
15 Federal Aviation Administration, all the ground 16 servicing, fueling and aircraft rescue, fire-fighting 17 activities are governed by the NFPA codes and standards that 18 deal with that.
19 Next slide, please. Starting in 1983, the Office 20 of Management and Budget, through OMB.A-119, required that 21 federal government staff participate in the development of 22 private sector standards and that the OMB circular urged the 23 adoption of these standards in carrying out public policy.
24 In 1996, that was codified into Public Law 104-113, the It 25 Technology Transfer Act, and I will quote from that.
l
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7-x
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S- 78 l
1 directs, "All federal agencies and departments shall use 2 technical standards that are developed or adopted by 3 voluntary consensus standards bodies using such technical 4 standards as a means to carry out policy objectives."
5 Moving to the next slide, and I am going to move 6 quickly because I know time is of essence here, but please 7 stop me at any time in the presentation if you have any 8 questions. Some of the more recent projects that have been 9 requested by the federal government, in addition to the NRC 10 project to develop 805, includes electrical safety 11 requirements for work place, employee work places.
12 In the Environmental Protection Agency, we work 13 very closely with them to develop a new clean agent fire 14 extinguishing system to replace system -- and agents to 15 replace the halogenated agents that were affecting the ozone 16 layer. That is, of course, an extremely important milestone 17 for the nuclear industry also, in that those agents are used 18 in this industry as well.
19 Recently, the Coast Guard has, and we have just 20 published a Merchant Vessel Fire Protection Life Safety Code 21 for merchant vessels, or popularly known as cruise ships, 22 and you know from the media that there have been major 23 problems in those cruise ships in terms of fires at sea.
24 COMMISSIONER MERRIFIELD: If I may interrupt for a 25 second.
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l S- 79 l 1 MR. O'NEILL: Sure. ]
l fg s, 2 COMMISSIONER MERRIFIELD: And this raises this 3 one. Of the types of projects you have done here recently 4 for other federal agencies and departments, have any of 5 those been risk-informed, performance-based approaches?
6 MR. O'NEILL: None of these that I have mentioned 7 have risk-informed, risk-based approaches. However, the 8 Life Safety Code, which I mentioned earlier, for Medicare, 9 Medicaid, is developing alternatives which would include 10 risk-based, and we have a couple of other documents in which l 11 our committees are also providing a separate parallel potential use of risk-based approaches. Lut this, the NRC 12 13 project on 805, is the first project created from scratch in 14 which we are developing risk-based.
UN 15 CHAIRMAN JACKSON: How challenging is this proving 16 to be for you?
It is quite challenging. However, 17 MR. O'NEILL:
18' as I mentioned earlier, we are on schedule. Your staff has 19 been very heavily involved with us, as has the nuclear 20 industry that will be represented here. And we are very 21 confident, as a result of the meeting that occurred two 22 weeks ago, that Mr. Connell mentioned, and I am being told 23 this by our Committee and by our staff, that we will achieve 24 the objective of bringing the project in on time, and that 25 it will address the issues that are important to NRC.
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S- 80 1 CHAIRMAN JACKSON: Do you have experts that you 2 are able to draw upon independently of the industry or NRC?
3 MR. O'NEILL: Yes. Yes, we are --
4 CHAIRMAN JACKSON: You have capabilities in these 5 areas?
6 MR. O'NEILL: Yes, we are.
7 CHAIRMAN JACKSON: Risk assessments and the like.
8 MR. O'NEILL: Yes, we have. And I would be glad 9 to supply the names of the Committee to the Commission. We 10 have also had ACRS involvement, as I said, formally, a 11 couple of times here, plus they have been involved at the 12 Committee meetings and the meeting that occurred a couple of 13 weeks ago. And from then, we have received quite a bit of l
l 14 advice on how to achieve the input of experts.
15 Let me just mention two others that are not on 16 here. This past year we were asked by the Department of 17 Housing and Urban Development not a risk-based standard but 18 to update the standards on the preemptive manufactured 19 housing standard, which incidentally covers one-third of all 20 new single-family dwelling construction in the United 21 States. So in addition to the traditional State and local 22 government adoption and Federal Government uacption, there 23 have been a number of new projects.
24 The next slide, just to briefly talk about the 25 process, as I mentioned earlier, the association standards ANN RILEY & ASSOCIATES, LTD.
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! S- 81 1 are accredited through the American National Standards Institute and do become American national standards. The
\m 2 3 process includes the involvement of some 5,400 committee 4 members who volunteer their time for the various committees.
! 5 We have over 200 committees working on various aspects of l 6 fire protection and some 290 -- I believe it's up to 300 7 now -- documents, those would be code standards, recommended 8 practices, and so forth.
9 A key ingredient of arriving at a consensus is
! 10 that no more than one-third of the committee members may l
11 represent any one interest category, and it takes a 12 two-thirds consensus to change the document, and that is the 13 basis of our approach to developing a consensus document.
l On the next page, as I mentioned earlier, our f 14 activities are hopefully completely transparent. This shows l 15 16 how any individual, any member of the public, any interested i
17 party or affected party can access the activities 18 association, look at the draft standards and so forth, which 19 were explained earlier, will be coming out this year.
I 20 The other thing that's --
l CHAIRMAN JACKSON: Let me ask a question relative 21 l 22 to the specific standards you're working to develop here.
(
23 MR. O'NEILL: Sure.
CHAIRMAN JACKSON: To what extent do organizations 24 25# like the Union of Concerned Scientists and the Nuclear i,
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S- 82 1 Information Resource Service have access to the process?
2 MR. O'NEILL: They have complete access to this 4
3 process in several ways. They can apply and become members 4 of the committee, and we would welcome that, the actual 5 technical committee that's putting together documents. They 6 can access the committee reports on how they react to public 7 proposals or committee proposals, all of which is published 8 and is available on our Web site. And then there's a third 9 step, and that is after the draft standards are published, 10 then the committee must justify what they're -- how t:ey're 11 reacting to and whether accepting, rejecting, or what have 12 you, each proposal.
13 That is then sent out again for a second review, 14 and that second review, which is our review which is 15 outlined in the schedule here, would also be available. We 16 welcome and urge again all affected and interested parties 17 to become fully active in the process. We however cannot 18 demand or require them to become active in the process or 19 access it. But we provide the facilities for that.
20 The only other thing I would make on that last l 1
1 21 slide was that we are the only private-sector 22 standards-developing organization who puts notices in the 23 Federal Register at our cost as to the status of each 24 document. So it's another attempt to get widespread use and 25 accessibility to the standard.
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S- 83 ,
1 Now Mr. Connell earlier had gone through the last 2 three slides that I have here, namely the status of the 3 document, and to answer your question-further, Chairman 4 Jackson, after that February 19 date on the next -- that is 5 due next week, after that the committee will meet on March 6 16 and 18, and then the results of that activity will be i l'
7 published in what we call a report on -- the committee 8 report on proposals. And then if you fast-forward then 9 there's a public comment period where the public can review 10 that and make comments back to the committee, and that would 11 be that October 8 deadline, and then the final report will 12 come out after December 27, 1999, and be available for 13 public review and consideration.
14 Then in May of the year 2000 the NFPA 15 membership -- the committee will present its report to the 16 membership, in this case in Denver, Colorado, and at that 17 meeting anyone who has made a proposal before or commented 18 on the document has the ability to advance their proposal or 19 their comment for consideration by the entire NFPA 20 membership that are attending that meeting.
21 Then as indicated here the summer of the year 2000 22 we -- by the way in these processes between the publishing 23 of the standard there's also an opportunity for someone to 24 appeal if they were not comfortable with the methods used by 25 the committee and that type of thing. And then the ANN RILEY & ASSOCIATES, LTD.
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l
' S- 84 1 Standards Council, which is a body appointed by our board of 2 directors, will issue the standard on July 20, year 2000.
3 And conclusions, the project is on schedule, and 4 we'd be glad to answer any other questions that you might 5 have.
6 COMMISSIONER McGAFFIGAN: Madam Chairman?
l 7 CHAIRMAN JACKSON: Yes, please.
8 COMMISSIONER McGAFFIGAN: Last year we had a 9 meeting on codes and standards, and the main theme that came 10 across from ASME and IEEE and others was the need for us on l
11 a concurrent basis if we're going to endorse a rule, endorse 12 a standard through a rule, that we get that rulemaking done 13 in parallel to the extent that it's practical rather than 14 waiting for this process to complete and then start a 15 rulemaking.
16 Looking at your schedule, it sounds like the final 17 document's available -- is it's going to go to your members 18 to vote in March of 2000. Is that the time frame we should 19 be thinking about starting our proposed rulemaking so that, 20 you know, sometime reasonably after the standard is 1
l 21 finalized, if it's finalized, we could endorse it formally?
l 22 MR. O'NEILL: That is really your decision.
23 COMMISSIONER McGAFFIGAN: Right.
24 MR. O'NEILL: Agencies -- our experience has been 25 that agencies -- some agencies use a parallel track, other l
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S- 85 1 agencies will wait until the document is published, an 1 2 official American national standard, then go into 3 rulemaking. And I can give you examples of both of those. j t
4 But it is your decision. ,
5 I would certainly, given the history of the r
6 process and your decision making up to this point, would 7 assume, and from talking to your staff and so forth, that t 8 you may wish to parallel the two and get moving on the l 9 rulemaking.
10 COMMISSIONER McGAFFIGAN: But March of 2000 wodld 11 be about the time we could realistically start the process.
12 MR. O'NEILL: You will see the final draft i
13 standard that will be presented to the NFPA annual meeting 14- and to our membership at the end of March 2000; correct.
15 CHAIRMAN JACKSON: Okay. Yes?
16 Oh, I'm sorry. Commissioner.
No , I was just going to l 17 COMMISSIONER MERRIFIELD:
18 say it's certainly a deliberative process you use. There's 19 plenty of opportunities for public comment. And there's a 20 reason for that.
Do you take a position at all l
21 COMMISSIONER DICUS:
22 on whether or not the implementation of the standard should 23 be an all-or-nothing situation?
24 MR. O'NEILL: No, we do not have a position on 1
25 that.
i i
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CHAIRMAN JACKSON: Let's see if we can move along. ;
f 1 2 Mr. Beedle.
l 3 MR. BEEDLE: Commissioners, we appreciate the 4 opportunity to discuss with you today some of our views on 5 this risk-informing of the fire-protection standards.
6 Dave Modeen in a moment will discuss in some 7 detail our views and involvement with this process.
8 First I'd like to mention that Jim O'Hanlon is the 9 chairman of our working group. He's the senior 10 vice-president of Virginia Power, very active in this I
11 process, and regrets that he was unable to be here today.
12 Before I turn to Dave, I'd like to make an 13 observation concerning the previous panel's discussion with 14 you and presentation. Clearly the NEI and the industry has 15 been involved in this fire-protection effort, and we're certainly committed to it. And I would like to point out 16 17 that the industry as a whole is very concerned about fire 18' protection.
19 It's an economic issue. Insurance rates are 20 predicated on keeping the plants free of fire hazards and 21 ensuring that systems work properly, and to develop a notion 22 that because we have a fire-protection functional :.nspection 23 is.the only reason that the industry really focuses on fire 24 protection is an absolute mistake.
l 25 So I just want to make sure that we understand l
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[I S- 87 1 that that's -- that the staff is not the reason that we're l O2 focused on fire protection.
Now, I think that when we talk about doing a l
l 3
4- functional fire-protection inspection and we spend money l 5 trying to prepare for it, I'm reminded of the time that I 6 went through an inspection some years ago, and I do not 7 recall ever having to worry about smart fires. But that's a
{ 8 problem that we have to deal with today. So as we go from l
1 l 9 on and on in this process, we develop more and more i l f 10 interpretations of the existing rules, and the plant staff 11 have to deal with that. And it costs you money to do that.
l 12 Now I'm not suggesting for a moment that there 13 aren't things that need to be remedied in the process of
,(% 14 preparing for an inspection, but we have to address an awful Ib 15 lot of new issues as we go about dealing with this t
16 fire-protection process. And it just seems like it's a l
l
- 17 never-ending ordeal as we try and come to grips with it. l l 18 I think the most heartening things about this l i i 19 whole process this morning is the question that Commissioner
! 20 McGaffigan raised when he said what's the most significant 21 thing that you found in all this process. So with that I'd 22 turn to David and ask him to --
23 COMMISSIONER McGAFFIGAN: But before I let him 24 go --
CHAIRMAN JACKSON: I was waiting to see if you 25 if ANN RILEY & ASSOCIATES, LTD.
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S- 88 l 1 were going to --
2 COMMISSIONER McGAFFIGAN: Just on the issue, you
! 3 say the insurance industry, you know, monitors this area.
4 Do insurance rates differ from plant to plant based on 5 performance indicators the insurance industry uses, or do 6 they use these core damage -- conditional core damage i
7 frequency numbers for fire that come out of the IPE's? What !
8 is --
9 MR. BEEDLE: They do their inspections and they 10 find -- they look at the fire-loading issues, whether or not 11 you're complying with the rules and regulations that you've 12 set down. And it affects the rates.
13 COMMISSIONER McGAFFIGAN: So rates do vary --
14 MR. BEEDLE: Absolutely.
15 COM:- 1IONER McGAFFIGAN: Rates do vary --
16 MR. BEEDLE: That's right.
17 COMMISSIONER McGAFFIGAN: Within the industry.
18 MR. BEEDLE: Right. l 19 COMMISSIONER McGAFFIGAN: So a performance 20 indicator would be what your insurance rate is.
21 MR. BEEDLE: Uhhh --
22 [ Laughter.]
23 CHAIRMAN JACKSON: That's good.
24 COMMISSIONER McGAFFIGAN: I mean, I don't know. I 25 mean --
I l
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S- 89 1 MR. BEEDLE: It's certainly a performance I
(,,/ 2 indicator when I pay the bill. Yes.
3 MR. MODEEN: I think a better indicator might be ..
4 what are the findings from your insurance regulator and the 5 followup activities actually.
6 Let me turn my attention also to NFPA 805. Slide '
7 number 2, please.
8 NEI has been represented specifically on the 9 committee by two utility fire-protection experts since the '
10 initiation of this project, but clearly it is an NFPA show, 11 I think, as Tony had indicated, or just part of the process.
12 We did, however, have -- probably the most significant ;
i 13 meeting so far for the industry was in October of '98 where 14 the standard, the draft standard had gotten to the point
' that we could have a fairly good discussion at the 15 16 semiannual fire-protection information forum where we had 17 over 100 industry peers that are -- and the lead members of 18* the committee were able to explain the process, the 19 thoughts, the structure, et cetera, so we could one, start j
20 warming our peers to the idea as well as make them aware 21 that there was going to be a draft issued the end of 22 ,
November that they could then comment on, and I think again 23 as Ed Connell had indicated, those comments or proposals are 24 due back February 19.
25 NEI will be commenting along with other members of l
l T
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S- 90 l 1 the public and the committee on that. And we heard quite a 2 bit of discussion at the meeting. I think that's -- and 3 I'll come to this later -- as to at least some of our 4 perspectives on the all-or-nothing and what that might mean l 5 and how the standard might be embraced by the industry.
6 And also related to the question of pilot plants, l
! 7 though, we don't have plants identified yet, but it's our 8 intention between the time frame that the next draft is l
9 issued, that is, after these current proposals are dealt 10 with in February, so that puts us into the late March, early 11 April time frame. And prior to the publication of what l 12 would really be the ready-to-go standard, I think in the l 13 October '99 time frame, that we'd be able to shake it down a 14 little bit and actually have some users use it and tell us 15 how it really works.
16 CHAIRMAN JACKSON: I think it's important if you 17 really do that that you not only get " good plants" but 18 plants that have, you know, a history of having had some 19 issues.
20 MR. MODEEN: Yes, ma'am, I understand.
21 COMMISSIONER McGAFFIGAN: Madam Chairman?
22 CHAIRMAN JACKSON: Please.
23 COMMISSIONER McGAFFIGAN: The other point seems to l
l 24 be, if I understood the standard from earlier, there are two l
l 25 options within the standard, one more deterministic and one ANN RILLY & ASSOCIATES, LTD.
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S- 91 .
1 more performance-based. I don't know whether when you get 2 the pilot demonstration whether you'd want to pilot both 3 options, if I'm understanding the standard right. I have 4 not ever seen the standard.
5 MR. MODEEN: Yes, and in fact I think we may even 6 cut it a little finer than that, that when finding pilots 7 and to spend resources on this activity, there has to be an
'f 8 incentive for that, and my sense is we would be most likely 9 to find candidates that really want to try to shift more to 10 this probabilistic risk-informed, use those elements, and 11 probably the more traditional prescriptive deterministic, 12 they already know where they sit there.
13 There's not a whole lot of -- my impression 14 reading the standards, not a whole lot of difference 15 compared to current practices today and maybe what the 16 standard might require, I'm not so sure I'm going to find 17 too many volunteers that really want to work through that 18 part of it. I mean, that's a difficulty we're wrestling 19 with, trying to offer incentives there for the licensee.
20 CHAIRMAN JACKSON: Okay.
. 21 MR. MODEEN: Slide 3, please.
22 Again, my observation, but at a distance, is that 23 there has been a tremendous amount of activity on this 24 standard. I think the draft's a good first cut, but it does 25 need much work. I had heard at the ACRS meeting that up to ANN RILEY & ASSOCIATES, LTD.
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S- 92 1 as many as 51 people had been at a committee meeting at a 2 time, and only about a third of those really are from the l 3 utility industry. Looking at this thing, I think when you 4 get a lot of cooks working on that thing, undoubtedly it 5 needs additional work.
6 CHAIRMAN JACKSON: That's the nature of developing 7 consensus.
8 MR. MODEEN: Yes. Our view is that we need to see 9 this through to the end. I know we had gotten some feedback 10 from the industry and other I'd say doubters and otherwise 11 as to at least looking at the current standard and the state 12 that it's in, but it's really our sense is this is the best 13 avenue in town to really bring in all those stakeholders, 14 work through the process, do the pilots, and see where that 15 puts us. I think also we were I guess heartened by the 1C Commission direction last summer to really pursue this 17 process as opposed to any other immediate rulemaking on that 18 activity.
19 At this point I'd like to turn my attention to the 20 opportunities as well as what the concerns are, and I think 21 that's related to what in our sense would be impediments to 22 really having licenses use the standard in the future.
i 23 Slide 4, please.
24 First of all, the opportunities. Again, yes, this 25 standard has a little bit of everything in it, whether you ANN RILEY & ASSOCIATES, LTD.
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S- 93 1 want a more deterministic approach or a probabilistic one, 2 and using performance-based ideas, and the flexibility is 3 built into the guidelines so that the licensee can try to 4 take advantage of that.
5 I think it clearly supports the application of j 6 risk-informed insights, which, down the road, I believe will 7 help us focus NRC and industry resources. I have observed 8 in my time at the utility, as well as in Washington, that we 9 continue to work on potential risk significant issues in 10 fire protection. Some were noted this morning that have 11 been on the table since the Sandia fire scoping study, and 12 it provides a framework by which I think the regulator and 13 the licensee can kind of communicate on where does this fit
/'~ 14 relative to my overall fire protection program.
t 15 Next slide, please. Shifting attention to 16 concerns, clearly, what we are hearing from our members is 17 that, obviously, a lot of work, a lot of effort to ensure 18 that they comply with the current regulations, the licensing 19 basis they do have, the long litany of changes that may had 20 occurred there, and exemption processes and relooks and 21 things like that. So, for those plants, it is relatively 22 late in a plant life cycle to forego that licensing basis 23 and adopt the new standard in totality. What does that 24 really mean? I think that is probably the number one 25 concern, what would be the expense involved there?
' 5 ANN RILEY & ASSOCIATES, LTD.
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i S- 94 1 I think that leads me to the next point, is that 2 -- or at least it is our sense that an all or nothing 3 adoption is really too restrictive and, in fact, there can l 4 be ways to incrementally adopt pieces of the standard where 5 you see some benefit. I think oftentimes one looks at fire l l
6 and fire risk, and we all recognize that inherently -- and 7 the PRAs tell us this, our own intuition tells us this, 8 there are pinch-points and areas of concern that one really 9 needs to pay attention to, and then there are other areas in 10 the plant that just one exposure fire in and of itself 11 doesn't make a whole lot of sense to protect to the same 12 level.
13 CHAIRMAN JACKSON: Well, I mean, presumably, I 14 mean that is your challenge. I mean I don't view that -- I 15 wouldn't call that under incrementalism. If you have 16 appropriately developed a risk-informed standard and an 17 approach that goes along with that, by definition, that 18 should cover those issues. If not, then you have failed in 19 developing a risk-informed approach. I mean that is what I 20 would say.
21 MR. MODEEN: I see, I understand the point, 22 Chairman. I would agree with you, and I think, at this 23 point, perhaps we might be failing because if one looks at 24 the first -- or Section 3 of the standard, when you define 25 that minimal fire protection program, many of the elements, ANN RILEY & ASSOCIATES, LTD.
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S- 95 1 I would agree with Ed Connell, belong in a minimum-base l
2 program. I believe there are some elements in there, 3 however, that if I took a risk-informed approach, I would 4 not address all those elements to the equal degree in all my 1
5 fire areas. And, again, I understand your challenge, that
! 6 is back to the Committee and those of us providing comments 7 into the process.
8 CHAIRMAN JACKSON: That's right. I mean because 9 -- I mean that, to me, is not something that comes here. It 1
10 is something that is back with where you all are in terms of )
11 working through and making the standard really .
12 risk-informed. And if you don't, then there is not a lot 13 that we can do, if you go through this two year deliberative
/\ 14 consensus development process, and you don't come out.
U 15 Because when you talk incrementalism, you have to be careful 16 with your language, because, in point of fact, -- I will 17 make two comments to you.
18 One, that sends a message that you want to pick 19 and choose where, you know, as opposed to having a comprehensive risk-informed approach. And I think, you 20 21 know, a comprehensive risk-informed approach is what you 22 want, not cherry-picking. And the second comment is that at 23 an, earlier stage, NEI was on the record as being against l l
l 24 incremental improvements to the fire protection rule. I l
25 mean that was -- had come through. You were not in the ]
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S- 96 1 particular Commission meeting.
2 But I am just -- so, you know, we can say that 3 incrementalism is okay when we are taking a voluntary 4 approach, but incrementalism is not okay when we are doing a 5 rulemaking. But incrementalism, as opposed to a 6 comprehensive risk-informed approach, is the wrong way to 7 talk about it.
8 MR. MODEEN: Chairman, I understand the point.
9 CRAIRMAN JACKSON: Yes.
10 MR. MODEEN: Oh, I am trying -- the last point on 11 slide 5 is that --
12 COMMISSIONER MERRIFIELD: No, no, please finish 13 your thought.
14 MR. MODEEN: Is that I believe there is a strong 15 nexus between what we are doing in this area, and also the 16 industry activities with the Office of Research and NRR in 17 trying to define what some of that criteria is and to what 18 level, the degree of rigor. Some of these issues -- I heard 19 earlier today about IPEEE, and I had significant involvement 20 in that. I relate back to -- what are the figures of merit?
21 Where do you stop your analysis? When you are satisfied 22 with the answer, you are no longer satisfied, or someone 1
23 else isn't, so we go analyze some more, and we obviously 24 need to work through that.
25 CHAIRMAN JACKSON: Well, the question I have, ANN RILEY & ASSOCIATES, LTD.
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S- 97 1 since we still have a year-and-a-half to go on the MPFA 2 schedule -- NFPA schedule, is that enough time? When you 3 say time to develop?
4 MR. MODEEN: Yes, I think it is. Yes. We have 5 had a lot of interactions. In fact, a sideline to this has 6 been I think a very profitable effort between industry and _
l 7 NRC responding to the generic request for additional l
l 8 information on IPEEE fire modeling, on the EPRI fire PRA 9 model. It probably gave us a jump start on a lot of what
! 10 those issues are.
l 11 CHAIRMAN JACKSON: Okay. Thank you. l 12 Commissioner.
13 COMMISSIONER MERRIFIELD: Mr. Beedle, at the very l 14 beginning of your presentation, you made I think a very l
~s 15 rigorous and fair defense of where NEI and its members are 16 in terms of the degree of seriousness _that they take fire l 17 protection. One of the problems, it seems to me, is 18 partially an NRC problem, as was described, we have got five i
19 binders, comprising 125 different guidance documents, 20 overlapping, confusing, and that obviously causes a problem f
21 for licensees, and that is something that we are having to 22 address and we should address.
l 23 However, in the earlier presentation, it was also l
i 24 pointed out that there was one licensee that spent 24,000 25 man-hours getting ready for the inspection. And so, I am l
l
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l S- 98 l 1 wondering, is that reflective of the NRC problem? Is that 2 reflective of the licensee not being where they should be 3 relative to their baseline? Or is it both? And what are 4 the lessons that we have to learn from that as it relates to 5 other licensees?
6 MR. BEEDLE: Well, I think it is probably 7 attributed to both the NRC and the utility. I mean I would 8 be hard-pressed to tell you that it wasn't. On the part of 9 the NRC, I think it is a continuing changes in 10 interpretation of some of the requirements, and as those go 11 from one plant to the other, every time you have an 12 inspection, you hire some consultants and they go find out 13 all the problems in the previous plants. We correct those 14 in preparation for the inspection this time around.
15 Also, as you go through and you look with fresh 16 eyes at your program, you might find the need to replace and 17 remedy some situations that exist in order to make sure that 18 you do, in fact, meet the standards that are expected'today.
19 So I think it is both.
20 CHAIRMAN JACKSON: Do you feel that this 21 consolidation of the guidance and eliminating -- you know, 22 where the guidance conflicts with itself, is a helpful --
23 will be helpful?
l MR. BEEDLE: I think eliminating ambiguity is a l 24 25 good thing in any sector of regulation, including the ANN RILEY & ASSOCIATES, LTD.
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S- 99 1 Appendix R fire protection area. So if we can consolidate 2 and get clear, concise identifiable requirements, I think 3 that is both to our advantage, from the utility point of 4 view, and to the regulator's point of view.
5 CHAIRMAN JACKSON: Okay.
6 MR. MODEEN: If I could also follow up on Ralph's 7 answer. Relative to the FPFI, I think it is important to 8 realize that the very first plant that was looked at, 9 supported by a larger utility with other -- more than one 10 unit, did no significant preparation for the FPFI. I have 11 confirmed that with the licensee. And then, of course, this 12 is a rather significant team inspection, issues get raised.
13 We were sharing all those issues with the industry, and then 14 you go, in sequence, to smaller licensees that don't have 7-s k-s 15 the large staffs, can't pull people from other staffs. They !
16 get a little concerned about things, and what is their bases 17 and stuff.
18 Again, I am not trying to say that there weren't 19 issues and maybe lose the bubble here or there, but it is 20 not everyone at 20,000 man-hours.
21 CHAIRMAN JACKSON: No, I think that was clear from 22 what Mr. West said. He was not implying that it was every 23 licensee who expended that kind of effort.
24 COMMISSIONER MERRIFIELD: Chairman, just as a 25 follow up, I mean I guess that raises the question then, we ANN RILEY & ASSOCIATES, LTD.
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S- 100 1 have had a series of these inspections and there were 2 various responses of the licensees to those.
3 Where are you as an industry now? I mean has 4 there been some generic follow up across industry? Say, 5 okay, this is what we have found from these analyses, how 6 can we apply that industry-wide?
7 MR. MODEEN: Yes. There are several things. One, 8 both by e-mail and also by semi-annual information forms, we 9 have been sharing all the insights from these inspections 10 with all the other plants. We did a survey -- don't hold me 11 to the date, but about six months ago, wondering if other 12 people looked and did their own self-assessment as a result 13 of these things. We had about two-thirds, I think, of the 14 industry that had already started in var c.as levels. I 15 think one of the issues on the part of the staff is, you 16 know, are you as self-critical on yourself as the NRC might 17 be?
18 The part in the proposal that we put forth to the 19 staff, and understanding where the inspection and core 20 baseline program oversight was heading, that it seemed to be 21 a natural thing to take the FPFI insights, mesh it also with 22 the staff role in the licensee rule for self-assessment, 23 say, hey, this ought to be where the follow-on is across the 24 board, because, let's face it, four FPFIs a year, you are 25 not going to get to every plant in twenty-comething years, ANN RILEY & ASSOCIATES, LTD.
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S- 101 1 and we will all -- you know, they won't be there. So some i
2 other approach probably makes more sense.
3 CHAIRMAN JACKSON: Okay. Commissioner McGaffigan.
4 COMMISSIONER McGAFFIGAN: I am going to pi.:.t on 5 the Chairman's question just to try to be clear. The 5 regulatory acceptance criteria, I assume is our Reg. Guide 7 for how the new standard would be -- you know, how the staff 8 would deal with the new standard. Looking back at the 9 staff's p.esentation, the comprehensive Reg. Guide that 10 Commiosioner Merrifield just referred to is going to keep 31 them busy until September getting -- issuing a draft, and 12 then, presumably, working on the final.
13 When, realistically, could they begin the work of
("'N 14 developing the regulatory acceptance criteria for this U 15 evolving new standard? It sounds like it is needed to 16 provide some clarity to the industry as to how we would 17 actually carry out the endorsement. Is it -- I am still in 18 this technical issue of how much parallelism is possible 19 here.
20 MR. MODEEN: I believe, and I don't know if the 21 staff would quite agree with this, but I see the new 22 standard is very much akin to a new Regulatory Guide, so, in 23 fact, as you are developing the standard, most of what is
, 24 satisfactory in the criteria is in that standard itself.
25 Okay.
O ANN RILEY & ASSOCIATES, LTD.
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S- 102 1 The second piece, and what I was referring to in 2 criteria, is more in agreement along the ways in the f 3 probabilistic models and the figures of merit, and what is 4 acceptable in that area. It is a little bit different 1
5 than --
6 COMMISSIONER McGAFFIGAN: So on this SRE that the 7 Chairman pointed to earlier, what the acceptable way to 8 carry -- to do an SRE?
9 MR. MODEEN: Yes. Yes 10 COMMISSIONER McGAFFIGP';. Will that be in the 11 Guide or would that be in the acceptance criteria? Or is 12 that something to be worked out?
13 MR. MODEEN: I don't know that it is totally 14 worked out there. There is an appendix to the standard that 15 addresses the use of probabilistic tools and the site-wide 16 risk evaluation. I don't believe I have seen it yet. I 17 think it is still being worked. And to some degree that 18 will have criteria, but I think we were trying to mesh both 19 criteria, as we understand it, in big picture, 20 risk-informed, performance-based regulation, the NRC 21 oversight process, the performance indicators, that type of 22 criteria -- How does all that fit together? -- which I think 23 would go beyond where the standard would end up.
24 COMMISSIONER McGAFFIGAN: But do you need that?
25 If we are going to be endorsing a rule -- the standard by ANN RILEY & ASSOCIATES, LTD.
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S- 103 i
1 rulemaking, does that have to be part of the published i 1
O- 2 package, in your view, what you are describing, in order for 3 people to comment on whether we are on the right track or 4 not?
5 MR. MODEEN: Yes, I think we would, and I think we 6 ought to be able to have it there. I don't see a disconnect 7 timing-wise, or for a way of going on.
8 CHAIRMAN JACKSON: Okay. Mr. McGaffigan -- I mean 9 Merrifield, please, Commissioner.
10 COMMISSIONER MERRIFIELD: One final question.
11 Assuming we were to endorse the NFPA standard, how many 12 plants do you think would come around that direction to want 13 to participate in that, if we had a two track program? And 14 layered on top of that, there are some questions -- we have 15 plants that are coming in for license renewal, and, so, what 16 would the reaction of the industry be if we said that plants 17 that are coming in for renewal would have to go that 18 direction?
19 I mean you raise the question, wanting to have two 20 track. But you have some plants that are not going to be 21 going for license renewal, they are only going to be 22 operating for a while longer and they don't want to switch 23 over. But what about the plants that are going to renew for 24 20 years?
25 MR. BEEDLE: The answer is whether or not ANN RILEY & ASSOCIATES, LTD.
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S- 104 l 1 implementing that new standard would overall reduce the cost 2 of operating the plant. Is it going to be economics.
3 CHAIRMAN JACKSON: Okay.
l 4 COMMISSIONER MERRIFIELD: Okay. But the other l 5 part of my question was, how many plants do you think would 6 go that direction?
7 MR. BEEDLE: It depends on how much money they have got. It is hard to say, Commissioner. And until you 8
9 see it and you do some analysis of it, and determine what it 10 is going to cost you to implement it, you know, if you can 11 -- if it is going to cost you $12 million to implement this 12 new program, if you are going to operate for three years, 13 you may not want to do it. If you are going to operate 14 licensee renewal and operate for an additional 23 years, it l 15 would make a difference in how you approached it.
16 CHAIRMAN JACKSON: Presumably, the pilot, if 17 well-structured, could help you to address those questions.
1 18- MR. BEEDLE: It would certainly help us determine 19 the economics of it.
I 20 CHAIRMAN JACKSON: Right.
21 MR. MODEEN: I would say, bas?d on a preliminary 1
22 look, very reticent acceptance by the licensee.
l 23 MR. BEEDLE: By the very fact that we are working l
24 on it, there is a presumption that it would cause us to 25 f ocus .cm the things that are more important and, thereby, ANN RILEY & ASSOCIATES, LTD.
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S- 105 1 avoid spending money on things that aren't important and, 2 therefore, save money overall. So I mean that's --
3 CHAIRMAN JACKSON: That's the risk-informed and 4 performance-based approach, right?
5 MR. BEEDLE: That's the assumption. Absolutely.
6 CHAIRMAN JACKSON: Okay. I think we --
7 MR. BEEDLE: And maintain safety at the same time.
8 CHAIRMAN JACKSON: Well, risk-inforred being 9 safety is at the heart of it, by definition.
10 MR. BEEDLE: Yes, ma'am.
11 CHAIRMAN JACKSON: Do you have any final comments?
l 12 I think we have covered it all.
13 MR. MODEEN: No, I think the last slide is pretty 14 self-evident.
f
15 CHAIRMAN JACKSON: Mr. Beedle, did you have any 16 further comments?
17 MR. BEEDLE: No. Thank you very much.
18 CHAIRMAN JACKSON: Okay. Thank you. We will move 19 on to the third panel. I would ask Mr. David Lochbaum from 20 the Union of Concerned Scientists and Mr. Paul Gunter, 21 Director of the Reactor Watchdog Project at the Nuclear 22 Information and Resource Service, to please come forward.
l Thank you. And we'll begin with Mr. Lochbaum.
j 23 24 MR. LOCHBAUM: Good morning.
25 CHAIRMAN JACKSON: Good morning.
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S- 106 1 MR. LOCHBAUM: Slide 2, please. l 2 If a moving target is difficult to hit, then fire 3 protection problems must be one of the easiest targets to 4 hit. The Appendix R regulations went into effect in January 5 1980, yet the majority of nuclear plants are still not in 6 compliance with these regulations.
7 COMMISSIONER McGAFFIGAN: Madam Chairman?
8 CHAIRMAN JACKSON: Please.
9 COMMISSIONER McGAFFIGAN: Could I clarify, what do 10 you mean by not in compliance? They have an exemption?
11 MR. LOCHBAUM: Well, exemption is a form of 12 compliance, so it's --
13 COMMISSIONER McGAFFIGAN: Yes, I agree.
14 MR. LOCHBAUM: So it's not the exemptions, it's 15 the fire watches and these surprises that we keep finding.
16 This industry is too old to be constantly surprised like it 17 is.
18 COMMISSIONER McGAFFIGAN: Okay. So it's not the 19 10, 15 exemptions per plant that were granted after Appendix 20 R went into effect.
21 MR. LOCHBAUM: That wouldn't be the optimum form l 22 of compliance, but that is a form of compliance.
l l 23 COMMISSIONER McGAFFIGAN: So that's not your 24 concern.
25 MR. LUCHBAUM: That's not our issue, no.
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S- 107 r~s 1 If compliance -- we feel if compliance were needed k 2 to generate electricity, we feel confident that the 3 situation would be very different.
4 To be fair, this regulatory stagnation has been 5 very helpful to me. Today's presentation is basically the 6 same one I made to the ACRS Fire Protection Subcommittee in 7 1997. All I had to do was revise the date and reorder the 8 slides to make it look like a brand new presentation.
9 Unfortunately, it looks like I'll be able to recycle this 10 presentation for many more years.
11 Last week, you proudly informed the United States 12 Senate that the Calvert Cliffs license renewal process was i
13 ahead of its aggressive schedule and should be completed 14 during the first half of next year, or 25 months after it i 15 was first submitted.
l 16 Ironically, the first half of next year also marks l
17 the 25th anniversary of the Browns Ferry fire that praapted 18* the Appendix R regulations. Perhaps you can understand why 19 people think that this agency places economic viability of 20 the industry ahead of health and safety of the American 21 public when you place design certifications and license 22 renewals at the top of your priority list and resolution of 23 fire safety issues on the back burner.
I j 24 Slide 3.
! 25 On March 22nd, 1975, a worker using a candle to i
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S- 108 1 check for air leaks ignited combustible material and a 2 penetration in a cable spreading room at the Browns Ferry 3 nuclear plant. Workers responded by trying to extinguish 4 the fire that they ignited. The fire burned out of control 5 before anybody reported it to the control room or anyone 6 else.
- The local fire department arrived within an hour.
8 The fire chief advised the plant manager to use water to put 9 the fire out. The plant manager, concerned that this water 10 would further damage electrical equipment in the fire area, 11 refused that suggestion. The fire blazed for over six 12 hours, disabling most of the emergency core cooling systems 13 on both of the operating caits.
14 When the use of water was finally allowed, the 15 fire was put out within ten minutes.
16 Slide 4.
17 More than 20 years later, a worker at the 18 Waterford Nuclear Plant reported heavy smoke in the turbine 19 building following a turbine trip. The plant's fire alarm 20 was not sounded for 29 minutes, as workers searched through 21 the heavy smoke looking for the source of the flames.
22 During this period, fire detector alarms in the 23 control room were ignored by operators, who were busy 24 directing fire workers in their search for the flames.
25 When the plant's fire brigade finally responded, i
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! S- 109 t l 1 the fire brigade leader did not allow water to be used, l
\ 2 again because of the energized electrical equipment. As a 3 result, the fire blazed for over an hout. When the use of :
l \
4 water was finally allowed, the fire was put out within four 5 minutes.
6 CHAIRMAN JACKSON: Let me ask you two questions.
1 l
7 I mean, you're aware of the fact that the NRC did put out l 8 after the Browns Ferry fire an information notice that --
9 MR. LOCHBAUM: Yes.
10 CHAIRMAN JACKSON: -- does allow the use of water.
l 11 MR. LOCHBAUM: Yes, I am. In fact, I worked at 12 Browns Ferry after the fire, and we were trained to use it.
13 CHAIRMAN JACKSON: Okay. And so this -- so what 14 I'm interested in understanding is to what extent these as 15 examples, particularly the later one, relate to what you 16 feel is a failure in the regulatory framework, a failure in 17 performance by a licensee, and to what extent they're 18 connected, if they are. And secondly, I'm interested in the 19 Waterford fire, what you feel the significance of -- the 20 safety significance of the event was.
21 MR. LOCHBAUM: Working backwards through those f l
l
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l 22 issues, I think the significance of that issue wasn't too i 1
It was a turbine building, there was no direct threat I
l 23 bad.
l It 24 to safety Oguipment based on the location of that fire.
25 wasn't a swatch-gear area, but the equipment that was o
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f S- 110 l
l 1 actually lost or could have been lost posed no direct threat 2 to the reactor core or associated cooling.
3 However, the fact that the fire brigade leader, 4 with the benefit of 20 years of hindsight and this knowledge 5 that the Browns Ferry should have put out, didn't use the 1 6 best thing he had available to put out that fire, which was I
l 7 l water, would have put it out within four minutes, suggests 1 8 that if that same fire had been somewhere else that was a l 9 more significant risk, that water still would not have been 10 used because of the reluctance to use it for causing -- the 11 reason he didn't use it wasn't because --
12 CHAIRMAN JACKSON: So is the implication of his i 13 behavior, if -- in the -- given the information notice, l 14 given the Browns Ferry experience, the implication of having l
15 the same response as the workers in the Browns Ferry l
16 situation, and they got away with it, you're saying, because 17 it wasn't in a safety significant area, but if that is l 18 characteristic of the behavior, that's the problem. l l i l
MR. LOCHBAUM: Right. Exactly. And they didn't 19 1
20 get away with it; the NRC wasn't real happy with what i
l 21 happened down at Waterford. l 1
CHAIRMAN JACKSON: Absolutely. I was going to j
22 f 23 point that out next.
l 24 [ Laughter.)
25 MR. LOCHBAUM: Still I think those two events 20 i
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S- 111 1
-~ 1 years apart, the fact that the -- Browns Ferry, one of the
\ss/ 2 things we learned was, report the fire to the control room 3 right away.
4 CHAIRMAN JACKSON: Right.
5 MR. LOCHBAUM: You don't wait to figure out what 6 it is, how bad it is, whatever; you report it right away.
7 That didn't happen at Waterford. The second thing was to 8 put the fire out. Use whatever you have to put it out.
9 That wasn't done.
10 So there's a lot of lessons that were clearly 11 learned from Browns Ferry that weren't captured.
12 CHAIRMAN JACKSON: This is 20 years later, one 13 licensee. I mean, do you have reason to believe that this is characteristic of the nuclear industry? I mean, it is 20
(["'N 14 L 15 years later, one licensee. ,
l l
l 16 MR. LOCHBAUM: I think I could go through -- I 17 didn't do that -- I think I could go through and look and 18 find more than this one example. I don't think this is the l
l 19 sole example of the time. It just happened to work out good 20 for the timing --
21 COMMISSIONER McGAFFIGAN: May I ask, you said NRC 22 wasn't happy. What is the problem with the regulation? I l
- 23 mean, you know, --
i 24 CHAIRMAN JACKSON: Or the regulatory
{ 25 implementation of the regulation.
1 I
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r S- 112 I l l 1 COMMISSIONER McGAFFIGAN: The regulatory ,
l 2 implementation. The regulatory implementation by the i 3 licensee I understand, but what is it that NRC could have 4 done to make sure that that person had learned a lesson of 5 20 years ago? Isn't it the licensee's responsibility to 6 make sure that their control room follow presumably their 7 procedures that said to do exactly what you said to do?
8 What is it that we would have done differently?
9 MR. LOCHBAUM: I think some things you did do that 10 I thought were good, was after the Waterford fire, you 11 clearly indicated that this was unacceptable performance, so 12 that sends a message to everybody else: try not to do this 13 again.
14 But I think when -- you can't wait for a fire all 15 the time to learn these things. They are very expensive and l
l 16 they can be very costly.
1 17 COMMISSIONER McGAFFIGAN: But how do you not learn 18 them? If the problem is a response to a fire, how do you 19 learn -- I guess we could give everybody a test, you know.
20 Maybe -- I don't know whether -here are testing requirements l
f 21 and whatever that you feel are inadequate. But I'm trying to i
22 figure out what is the regulatory thing that the NFC could 23 have done to prevent the second fire?
24 MR. LOCHBAUM: Well, you couldn't prevent the 25 second fire -- prevent the performance problems in the ANN RILEY & ASSOCIATES, LTD.
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S- 113 1 second fire.
I 2 COMMISSIONER McGAFFIGAN: Right. Right.
3 MR. LOCHBAUM: You can't just be in a fire 4 brigade. There is training and qualifications to do that.
5 In the inspections conducted by the NRC to look at the 6 licensee's fire brigade training and qualifications issues, 7 the reluctance -- or the knowledge of the most significant 8 fire in the industry should be a part of what the NRC does 9 to look at the licensee program.
10 If, you know, it's not stressed both to the fire 11 brigade and to other workers at the plant, because at Browns l 12 Ferry we were taught if we got hurt at the plant to yell 13 fire because that got people there real quick because
/"' 14 everybody was so trained to respond. So you've got to look 15 at those kind of things.
16 COMMISSIONER McGAFFIGAN: In our inspection module 17 for the core inspection program, this revised core 18 inspection program, you're suggesting that our. residents 19 look for this exact -- look at how the fire brigade training 20 is carried out and whether people have knowledge of now two 21 events, Waterford and Browns Ferry?
22 CHAIRMAN JACKSON: Let me piggyback onto that
! 23 because I --
24 COMMISSIONER McGAFFIGAN: I just want to 25 understand.
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S- 114 1 CHAIRMAN JACKSON: -- noted that you have as your j 2 third bullet on the Waterford fire that the fire detector 3 alarms in the control room were ignored by the operators, 4 who were directing the search for the flames, and therefore 5 the fire was out of control before a fire alarm was sounded.
6 The question becomes, I mean in addition to what 7 Commissioner McGaffigan has raised, is it a training issue, 8 you know, or something in the simulator with a crew? That's 9 the kind of thing we need to understand. Is it something 10 that can be accounted for in an inspection program? Is it 11 something that's a training issue that we need to adjust?
12 Is it something in the regulations or in some guidance we 13 put out?
14 MR. LOCHBAUM: Well, I think it harkens back to 15 some of the questions asked of the previous panels, the l
l 16 sensitivity or awareness of the industry to these problems.
)
17 I think this demonstrates that awareness or emphasic in this 18- area, at least at Waterford, was dropping off and people 19 weren't responding.
20 As far as the bullet that you mentioned, what l
21 concerned me -- us about that issue is the control room I
22 operators -- those alarms that were going off in the control 23 room told the cperators where the fire was. That's why they 24 put them in. Instead of looking at that and finding out 25 where the fire was, he sent three more people into heavy 7JUJ RILEY & ASSOCIATES, LTD.
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S- 115 cm. 1 smoke to look for the flames, ignoring information available 2 to him in the control room that told him where they were. l l
3 So he was jeopardizing those people and slowing down the 4 response overall..
5 To me, that was the lesson of TMI. You had the t
6 back-up information; it was not used for a while. So again, 7 it's a training awarenes* issue. ;
8 CHAIRMAN JACKSON: Okay.
9 Mr. West, you were going to make a comment?
10 MR. WEST: If you'd like, I could provide a little 11 insight into the specifics or the event. I went to 12 Waterford after their fire and helped supervise the NRC 13 inspection team, and the real problem at Waterford was a 14 problem with their procedure for fire notification. The 15 licensee had had a problem with false alarms, false fire l
16 alarms based on operators or other plant personnel observing 17 smoke and sounding the fire alarm, which would dispatch the 18 entire fire brigade.
19 They addressed that problem by revising their 20 procedure to say, don't sound the fire alarm unless you 21 actually see flames. You have to see flame, it can't be a l 22 smoking motor. So they had an inadequate procedure, which j 23 we -- and they had inadequate fire brigade training because 24 they did not use water on the fire. We took appropriate 25 enforcement action and the licensee has corrected those i
1 i
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1 problems.
2 We have factored, of course, the lessons learned 3 from that event into our inspection program -- specifically 4 the FPFI -- and we have looked at thove issues during FPFI 5 inspections, and we think it's a -- 1 don't know if it's an 6 anomaly but it's a unique case.
7 AEOD did do a study which they completed in 1997 8 of all fire experience in commercial U.S. reactors, and they 9 looked at the fire experience from -- I believe it was 1965 10 through 1994, and there are some rare cases like this, but 11 it's not common. In most cases, the fire brigades and the 12 plant operators take appropriate action. There have never 13 been any deaths or injuries as a result of fire in a nuclear 14 power plant.
CHAIRMAN JACKSON: Well, that one you could --
15 16 that one is less of -- that doesn't give me comfort. All 17 you need is one. But you're saying that there was some 18 fallout for us in terms of normalization vis-a-vis 19 inspection against procedures in this area.
20 MR. WEST: Yes, ma'am.
1 CHAIRMAN JACKSON: And the second having to do 21 l 22 with training vis-a-vis the fire brigade.
MR. WEST: Yes, ma'am. The fira bligade should 23 24 all be trained, classroom training and practical training in 25 using water on fires.
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S- 117 i s 1 COMMISSIONER McGAFFIGAN: Madam Chair?
, 2 MR. WEST: It's specific in the regulation.
3 COMMISSIONER McGAFFIGAN: Before we let him go, 4 how -- I mean, the root cause, a root cause was they had the 5 false alarm issue, which they dealt with in an inappropriate i 6 way. How common are false alarms in the industry? Do you 7 know at a given plant how many false alarms are there per 8 year or per month? Do you know?
9 MR. WEST: I couldn't say off the top of my head.
10 I know they occur. I'm sure we don't even have data on 11 that. The false alarms can occur in any --
12 COMMISSIONER McGAFFIGAN: I'm just trying to 13 understand whether there's a big generic -- I mean, a lot of 14 folks were facing thie, and maybe a lot of folks developed
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15 inappropriate procedures to deal with fals alarms.
16 MR. WEST: We don't believe so.
17 COMMISSIONER McGAFFIGAN: Okay.
l 18 - MR. TRAVERS: Just a clarification. I don't 19 believe that this is as much the false alarms at it is 20 over-conservatism in response --
21 CHAIRMAN JACKSON: To an alarm.
22 MR. TRAVERS: - to a perceived fire where you may 23 or may not have an alarm.
I COMMISSIONER McGAFFIGAN: Right. Well, Mr. West l
24 25 said that they had developed a procedure because they had i
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S- 118 1 had lots of false alarms, and the procedure said see the 2 fire, and I was just trying to understand whether false 3 alarms were a general issue.
4 MR. WEST: Could I clarify that just a little bit?
5 If I said false alarm, I didn't mean a situation where the 6 detection system alarms falsely; I meant a situation where a 7 plant operator or some other plant person would sound an 8 alarm that would dispatch the fire brigade when, in fact, 9 there was not a fire. They may see smoke, a smoking motor ,
10 or some other condition where you would not need the full 11 fire brigade, but by sounding that alarm, the procedure 12 required the licensee to dispatch the fire brigade.
13 CHAIRMAN JACKSON: Thank you.
14 MR. LOCHBAUM: Slide 5, please.
15 Another Browns Ferry lesson that seems to have 16 fallen by the wayside is the need for noncombustible 17 fire-barrier penetration seals. In an October 16, 1980 18 meeting, the Commission explicitly refused the industry's 19 position that penetration seals only need to have the same 20 fire rating as the wall, floor, or ceiling that they are 21 sealing.
22 The Commission pointed out that the penetration 23 seals are more likely to be challenged during a fire because 'l 24 combustible material, i.e., the cable insulation, will bring.
25 the flames to the fire-penetration seals, whereas the walls, I
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S- 119 f-~g i floors, and ceilings may or may not be exposed to direct x, 2 flames. The Commission therefore concluded that the 3 fire-barrier penetration seals needed to be noncombustible.
4 The staff's current position on penetration seals is in 5 direct opposition to the position taken by the Commission in 6 1980 and as promulgated in the Appendix R regulations and 7 associated guidance documentation.
8 However, having said that, we don't care if people 9 use kerosene in those penetration seals, as long as they 10 pass the fire test. The problem we have and that we 11 constantly find out is that these things are installed 12 without tests or documentation to support them. Maine 13 Yankee had one test that backed up 90 percent of their
/N 14 seals, and it didn't bound hardly any of those 15 installations. At Salem that FS-195 product is hard to tell 16 what the test is because there's no dimensions given on the 17 drawing. So we don't know if it bounds one or none or all.
18 So that's why that licensee is now doing some tests, because 19 the documentation doesn't give you that answer.
20 CHAIRMAN JACKSON: So let me make sure I 21 understand. So the issue is really not the combustibility 22 versus not combustibility, it's the actual performance 23 verification against the performance, the requirement or l 24 the, you know, and one aspect of that is installation with 25 the appropriate testing and documentation. Is that right?
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S- 120 1 MR. LOCHBAUM: Right. The staff in responding to 2 us and to Representative Markey says things like, you know, 3 if properly designed and installed fire barrier provides 4 adequate protection. And we would -- if that's the 5 condition we were at, we probably wouldn't be here today.
6 We don't have properly designed and installed fire barriers 7 or assurance of that.
8 CHAIRMAN JACKSON: Right.
MR. LOCHBAUM: That's the issue. Like I said, 9
10 they could be kerosene as long as they meet the one- or 11 three-hour test. I doubt that they would, if they were 12 kerosene, but --
Slide 7?
13 We recognize that things change, and the position 14 taken in 1980 may not be valid today. We fully recognize 15 that. But we feel that the staff is corrupting the 16 regulatory process by essentially ignoring the portions of 17 fire-protection regulations that they unilaterally feel are 18 meaningless. The proper and legal course of acticn would be 19 for the staff to change the regulations to whatever it is 20 they feel is right. Until that time, the staff should I
21 enforce the regulations that are on the books, even those 22 that they don't care for.
COMMISSIONER McGAFFIGAN: Madam Chairman, I think 23 that's exactly what we're going to do. This rulemaking i 24 25 package is going to be out for comment on combustible versus ANN RILEY & ASSOCIATES, LTD. ,
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S- 121 j 1 noncombustible, but, you know, one of the fundamental
,7 s s
(_) 2 problems with Appendix R, and I went and read a court case 3 in which a liberal group of judges on the U.S. appeals court l
4 panel, a panel of judges on the U.S. appeals court, you 5 know, listened to a challenge to Appendix R and ruled in l
6 March of 1982, and I wich I had it in front of me, but they l
7 basically only supported the rule because in trying to 8 defend ourselves at that time the Commission said we're 1 9 going to use exemptions, we're going to use exemptions.
10 And --
11 MR. LOCHBAUM: And you did.
12 COMMISSIONER McGAFFIGAN: And we did. We did.
13 But otherwise the court probably would have tossed the rule
/'"% 14 out, because as I understand Appendix R the way it was put
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\- 15 together, I mean, the complaint that was made was we 16 basically stapled together every best practice that anybody 17 brought forward and said okay, here's our rule, but here's 18 our exemption process. And come one, come all, to use our 19 exemption process, because we realize stapling together all 20 of these -- it's exactly how you don't do rulemaking, I 21 would posit.
22 So now the piece of the rule that -- I think we've 23 almost exempted everybody from the combustible versus i
noncombustible over the years. So now we're going to bring 24 25 that into fact. But we are going to do it by rulemaking, l'
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S- 122 1 and we are going to justify it as we've already done in the 2 correspondence with Senator Biden and Representative Markey 3 that you're citing, and we'll see how the discussion goes.
4 But the frustration I have with this whole area is 5 there was a really flawed rulemaking; the reason you can 6 shoot at this target so easily is the Appendix R rule is 7 probably the epitome of how not to rulemake. If you do a 8 rule and say, you know, with a big sign saying, "See our 9 exemption process" --
CHAIRMAN JACKSON: Right. Go this way.
10 COMMISSIONER McGAFFIGAN: This way to the 11 12 exemptions. It's a hell of.a rule.
l 13 MR. LOCHBAUM: What position are we in today 14 though with adopting an NFPA standard that perhaps nobody 15 will embrace? You know, it will be an awful --
16 COMMISSIONER McGAFFIGAN: I think that's a fair 17 issue too.
18 MR. LOCHBAUM: So whether you point to exemptions 19 or point to a standard that nobody follows, that's semantics 20 largely. So we're concerned that we can go through this 21 rule and develop a new standard, but nobody will follow it.
22 Slide 8, very briefly. Last month at a Commission 23 meeting I told you that plant risk assessments are 24 nonconservative because they unrealistically assume that fire barriers are 100-percent effective. Regarding the 25 ANN RILEY & ASSOCIATES, LTD.
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i S- 123 1 information that was discussed earlier from the earlier i
s_s/ 2 panel, the Quad Cities situation, with the .
3 two-orders-of-magnitude pencil whipping that was done, the 4 point I tried to make at last month's meeting was that if I 5 was going to make a change to my plant to put kerosene in 6 the fire spray headers, that it would increase the risk by 7 two orders of magnitude.
8 I could pencil whip it, because this can be done, 9 and it would show that my balance was net zero, and that 10 would allow me to do that. That would be one of the dumbest 1 11 things I've done, but technically I could do it. There's no 12 provision against it, other than common sense. But the fact 13 that you can do this allows those kind of abuses to occur,
[ 14 and we're very concerned about those kind of abuses. Not 15 that people will be using kerosene.
16 CHAIRMAN JACKSON: Let me ask you this question.
17 Would the development of the PRA standard help to address 18 this issue?
19 MR. LOCHBAUM: Definitely. I was encouraged by 20 Mr. Rubin's comments about standardization and things like 21 that. We would advocate that needs to be done before we 22 really proceed much further towards risk-informed i
23 regulation.
24 Slide 9. There's been a lot of talk about 25 focusing both industry and NRC efforts on the right areas.
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S- 124 1 I would argue that that can't be done until plant risk 2 assessments accurately account for fire-barrier problems.
3 For example, in plants that have 10,000 penetration seals, 4 if it took one hour to inspect the penetration seals, then 5 it would take five man-years to examine all 10,000.
6 If you had a realistic PRA that accounted for 7 possible nonperforming or nonfunctional fire barriers, then 8 you could use the results from those realistic risk 9 assessments and expend 100 inspection hours and cover the 10 100 highest-ranked penetration seals, which would probably 11 comprise the bulk of the fire-risk profile. So on one hand 12 the industry is arguing about risk-informed regulation and 13 focusing the priorities in the right area, and this is an 14 area that they definitely could do that. ,
l 15 CHAIRMAN JACKSON: Let me ask you a question, 16 because this is an interesting area for me. Are you l 17 implying that the PRA's have to be able to deal with 18 degraded performance?
r 19 MR. LOCHBAUM: I think the record shows that there 20 is degraded performance. Penetration seals are typically l l
21 nine inches for fires and walls. If you only have seven 22 inches of foam due to some installation error, then that 23 affords you less than the three- or one-hour rating, 24 whatever it's designed for. PRA would account for those 25 kind of things on a statistical basis and would say where if J
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. 4 S- 125 7-s. 1 you only have an hour's worth of combustibles in a region, I
(s,/] 2 then that might exclude some areas from concern.
3 But that kind of information would tell you based 4 on the evidence that's out there where your weak spots are, 5 and that's where you would focus -- both yours and the 6 ir.Justry -- would focus their resources, inspection 7 resources.
8 CHAIRMAN JACKSON: Okay. ;
9 MR. LOCHBAUM: Slide 10. In summary, we feel that 10 Browns Ferry's lessons have not been fully captured by the 11 industry or the staff. We feel that plant risk assessments 12 are invalid because they do not reflect reality. If this 13 problem were fixed, the plant risk assessment results would
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14 allow properly focused safety inspections.
15 This Friday is Abraham Lincoln's birthday. If 16 Lincoln were alive today and working for the NRC, perhaps 17 not so far-fetched that the rail-splitter might become an i
18 atom-splitter, he might say we can enforce some of the 19 regulations all the time, all of the regulations some of the 20 time, but we cannot enforce .C2 the regulations all the 21 time. I would agree with Abe, even if he wasn't carrying 22 that ax of his. All we are asking for is for the NRC to 23 enforce the fire-protection regulations now.
24 Thank you.
25 CHAIRMAN JACKSON: Thank you, David. A historical l
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F S- 126 1 perspective is always instructive.
2 [ Laughter.]
3 MR. LOCHBAUM: It gets easy with this issue.
4 CHAIRMAN JACKSON: Mr. Gunter.
5 MR. GUNTER: Thank you.
6 My name is Paul Gunter. I'm director of the 7 Reactor Watchdog Project with Nuclear Information Resource 8 Service. I'm going to go through these slides very quickly here in order to proceed. But I would like to say that I 9
10 was involved in the per.ition writing on the Thermo-Lag issue 11 back in 1991 and '92, and it's from my perspective and 12 organization's perspective that we recognize that the 13 resolution of this issue still lags.
14 Just go to slide 3.
15 I think that we can quickly recognize, and I'm 16 sure we're all aware of how Thermo-Lag has demonstrated 17 failure. The Office of the Inspector General reported as 18 early as 1982 NRC had a warning that Thermo-Lag didn't work.
19 These were the fire tests over at Susquehanna, I believe.
20 Yet a replication of those fire tests was used to qualify 21 the barriers at other nuclear power stations.
22 It was a safety-conscious file protection 23 consultant frustrated by the lack of NRC enforcement who ,
l i
24 reported his concerns to the NIRS in 1991 that began to put 25 some public profile on this issue.
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S- 127 l l 1 Finally, on June 24 Information Bulletin 92-01 l 2 came out declaring Thermo-Lag barriers inoperable. NIRS l
3 filed its 2.206 petition shortly thereafter, which was j 4 rejected by NRC on August 12, 1992. I would point out that l 5 six years later one of our contentions in that 2.206 l
6 petition with regard to new information on seismic l 7 qualification of Thermo-Lag that it could actually shear 8 fall off and break or damage cables was in fact a bona fide 9 issue in an information notice in '98. But by the end of 10 1993 in this chronology the nuclear industry through the l
11 guidance of NUMARC sets up a special task force as we see to i
12 scrimmage with NRC over this very expensive item, and they 13 establish it as a priority item to reestablish the technical 14 and licensing basis to qualify Thermo-Lag material for use 15 in one- to three-hour barriers as required by Appendix R.
16 There's a long gap here of where we attended a lot 17 of meetings, a lot of staff time involved, a lot of 18 information notices, but from our perspective essentially 19 the industry was successful in dragging out a resolution to 20 1997 when we finally began to see confirmatory action orders 21 issued during 1998 to noncompliant utilities, most of whom 22 are the licensees with extensive applications of the 23 material. We've seen to date some resolution in minor or, 24 you know, the moderate users of the material, but still the j 25 outliers here are those who are extensively reliant upon 1
i f
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S- 128 1 Thermo-Lag.
2 It's our concern and our frustration that rather 3 than move towards enforcement of a prescriptive regulation i 4 which these fire barriers were intended to represent, we now 5 see the potential for another extensive delay as NRC and 6 industry begin to approach another layer of regulation, but 7 not to take the Thermo-Lag issue out of isolation, but the 8 same kind of problem that's involved with Thermo-Lag we see 9 reoccurring in the Salem nuclear power station with regard 10 to the FS-195 barrier, the E-50 inner ram barrier, and the 11 Kale-Wool barrier.
12 Again here's a chronology that basically goes 13 through an identification of the problem. In 1992 we 14 proceed through a 2-1/2 to 3-year outage for Salem unit 3 15 and -- yes, Salem unit 2 -- and still the issue's not really 16 addressed as a restart issue where these inoperable fire 17 barriers are still in place. This was also identified in a NUMARC industrywide workshop. So it's not that the industry 18 19 didn't know about these III.M barriers and the problems 20 associated with it.
CHAIRMAN JACKSON: Let me ask you a question. To 21 22 what extent do you feel that a let's say for the lack of 23 other terminology a fire-protection defense-in-depth 24 approach should play a role, where you have this combination 25 of fire prevention, detection, and suppression along with a ANN RILEY & ASSOCIATES, LTD.
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S- 129 l
1 safe-shutdown capability, that it's really the balancing of l ]
i 2 those in the face of any one given issue which may include l 3 degraded barriers? I mean, to what extent is that kind of l 4 approach valid? I mean --
5 MR. GUNTER: We believe that to be a valid l
l 6 approach. And frankly I believe that that's why the 7 noncombustibility factor is in the penetration seal 8 regulation, that in fact we know the derated barriers are 9 out there in the industry. They are turning them up all the 10 time. That's why we believe that it's appropriate to leave 11 the noncombustible standard in there as an element of this 12 defense in depth, that you don't have the barrier itself l 13 lending as a fuel to a fire.
14 CHAIRMAN JACKSON: Well, I mean, is it true that l
' 15 all -- so your assertion is that all combustible barriers 16 are fuel -- add fuel to the fire. Is that your point?
17 MR. GUNTER: I can understand that, for example, I
l 18 Mr. Connell's earlier example of this wooden door over here i
19 being involved as a rated barrier for this room or to 20 protect this room, whichever side the fire's coming out.
21 But when inspection procedures find that the wooden door 22 itself is hollow in many cases or cracked or has gaps, and 23 that the current inspection procedures for determining 24 whether or not that barrier's degraded is extremely 25 difficult with -- there's really no nondestructive analysis
(~
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S- 130 1
l 1 available is my understanding -- to actually determine if 2 these penetration seals have voids and cracks, because 3 they're largely hidden. That's why I believe that you have 4 that noncombustible standard in that penetration seal as an 5 element of this defense in depth.
6 CHAIRMAN JACKSON: Okay. Proceed.
i 7 MR. GUNTER: But just to pick up the chronology 8 again, September 23, 1998, we finally see -- the public, at 9 least, finally sees that the Salem Nuclear Power Plant 10 Stations's fire project plans for compliance by 2002. Now, 11 this can only reflect to us a lack of resolve, both on the 12 industry's part and on the regulatory agency's part, to 13 actually bring plants into compliance and to enforce
- 14 regulations. It also constitutes an example of where NRC 15 all too often has simply accepted without verification and 16 validation the licensee's representation, and which turns 17 out not to be the case.
18 I think it is quite obvious that the industry, as 19 identified, puts economics as one of the principal issues in 20 determining resolution, and that the scrimmage in coming to 21 some kind of meaningful mitigation of this issue is based largely on economics, from our perception. And now we are 22 23 involved in this rewrite, another avenue of regulation, 24 which we believe is actually sidestepping a key and a l
problematic regulatory requirement for tested, rated l 25 ANN RILEY & ASSOCIATES, LTD.
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S- 131 1 barriers which could be part of a prescriptive regulation (s, 2 for this particular problem.
3 So I think that what that really brings us to is 4 there is no real resolution in sight from a public health 5 and safety concern. We are -- what we see is an industry 6 inching towards a goal line of closing some of these plants 7 down rather than addressing -- you know, running them to 8 their operational life without really addressing the fire 9 safety issues, basically, because the economics is a 10 hindrance to bringing some resolution and compliance to the 11 issue.
12 We believe that that strategy is at much higher 13 risk because as we move down the line, these plants are 14 getting older and age-related degradation is more and more 15 of a factor, and cost-cutting incentives only grow larger as 16 plants move towards the end of their life.
17 CHAIRMAN JACKSON: Do you believe that there can 18 be an appropriate risk-informing of fire protection 19 regulations?
20 MR. GUNTER: I think it is going to be difficult.
21 I think that there has to be -- it is like approaching 22 traffic regulation through risk-informed, performance-based.
23 There have to be stop signs. And there has to be
( 24 enforcement.
25 CHAIRMAN JACKSON: But there aren't stop signs at
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S- 132 1 every corner.
2 MR. GUNTER: There don't necessarily have to be 3 stop signs at every corner, but there are appropriate times 4 to have police enforcing speed limit, and red lights. And 5 if you run a red light, you get ticketed. So, I think my 6 concern, as we move down this avenue of risk-informed, 7 performance-based regulation, that there will be more 8 arguing when they are pulled ovre to the side, in terms of, 9 you know, violations, and that is -- I don't believe that 10 that is done at the behest of optimal public health and 11 safety. But it is concern, again, that it is an economic 12 issue that prioritizes the approach.
13 Reliance on indefinite and unreliable fire 14 watches. First of all, we believe that there is an 15 appropriate time and place for fire watch. These are 16 temporary circumstances, of course. But, as we see, the 17 current use of fire watch as a compensatory measure for 18
- long-term inoperable fire barriers, this is an obvious abuse 19 from our concern and perspective.
20 I think that Commissioner Ivan Sellin also pointed 21 this out in a statement made in testimony before the 22 Subcommittee -- or the House Subcommittee on Oversight and 23 Investigations. I think that it is really evident here that 24 even then NRC saw six to nine months as an optimal time, and 25 that when you start running into fire watches over a two l
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S- 11?
g 1 years timeframe, you are running into real problems, not l k ,-
m 2 only in terms of expense, but in terms of surveillance l
3 problems.
4 Thermo-lag fire watches have now been in place for 5 78 months at plants where there are extensive applications 6 of thermo-lag. At least two reactor sites will probably 7 close with thermo-lag fire watches in place. Again, this is 8 this whole strategy that we see of inching towards a goal 9 line without really remediating the problem.
10 CHAIRMAN JACKSON: Which plants are those?
11 MR. GUNTER: That would be -- well, certainly, 12 Oyster Creek, by confirmatory order, and their response 13 back, they are looking at 2000. I think it pretty well
(
\
14 known that they intend to close before 2000. The other 15 plant that we are suspecting would be Clinton.
16 The issue here, though, is that fire watches do 17 not constitute a compensatory level of protection for a 18 rated, passive fire barrier system. Obviously, a fire 19 barrier is what it states, it is a physical barrier used to 20 protect safe shutdown cables from fire for up to three hours 21 in the event that you can't get a fire brigade to put out 22 that fire, and that can occur either by heat or by radiation 23 in the case of nuclear power stations.
24 Obviously, that level of compensatory action cannot be taken by a fire watch. As a matter of fact, most 25 ANN RILEY & ASSOCIATES, LTD.
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- Q j
1 S- 134 1 fire watches don't even carry suppressions systems with !
2 them. *They are a more appropriate measure for a detection 1 3 system, for compensating lack of detection, from our 4 perspective. But what is most troubling is to see, time and l 5 , time and time again, where fire watches have been noted for
- 6 dereliction of duty. And there is a whole range of problems l
7 here, not only just that they get caught in an elevator and 8 can't get to watch, but that in the case of Turkey Point, l 9 the thermo-lag fire watch was found overdosed on heroin. !
10 So, and then there --
11 CHAIRMAN JACKSON: Where was this?
12 MR. GUNTER: Turkey Point. That was through a 13 -- there is a P&O on that was quite interesting to read.
14 But then, again, we also see the falsification of duty logs ,
l 15 as a problem and it broadens this range of uncertainty, just I
16 exactly how much of a measure of protection we have with 17 fire watches even in place.
18 So, in closing, I think that it is appropriate to 19 look to a recent Washington Post article dated November 8th, 20 1998, where the FAA missed a warning on insulation burn 21 tests regarding the September 2nd crash of Swiss Air Flight 22 111, which involved combustible insulation. We view this as 23 a case study of a critical safety issue being buried within i
24 a government institution subject to tight budgets and a 25 single event.
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S- 135 1 The public wouldn't tolerate fire watches for --
O(,,/ 2 on-board fire watches in its airline industry. And tnere is 3 significantly much more riding on nuclear power stations 4 operating without operable fire barrier systems and without 5 timely regulatory resolution enforcement. And why should 6 the public be any more tolerant of the nuclear power
! 7 industry and the Nuclear Regulatory Commission?
i 8 CHAIRMAN JACKSON: Thank you. Commissioner Dicus, 9 any questions? Commissioner Diaz, do you have a question or 10 comment to make? Yes, this is the end of the line, so if l
11 you are going to make a comment, make the comment.
l 12 COMMISSIONER DIAZ: This is the end of the line.
13 Okay. Since I have been so quiet, you might indulge me with 14 an integral response in here. I think this issue, which I
'-' 15 have been facing since I got to the Commission and before, 16 as everybody is saying, it requires an integral solution.
17 But it just reminds me, you know, of a story and 18 the ending of the line, a story probably everybody knows is 19 this city council meeting in which people were discussing 20 what to do about dogs that have rabies and how to take care 21 of the problem. And the mayor just feel asleep in the 22 middle of that meeting. And then the subjact changed to how l 23 they were going to take care of this epidemic of measles in l
! 24 the schools, and how they are going to try to prevent the J
l 25 measles and how they are going to help the kids and so i
1 i
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S- 136 1 forth. And then the mayor just woke up in the middle of 2 that discussion, and they asked him, mayor, what do you 3 think? And he said, shoot them all. I mean shoot them all.
1 4 Track them and shoot them all.
5 And then the gentleman came and said, but, Mr.
6 Mayor, we are talking about curing them, not shooting them.
7 He said, cure them or shoot them, but solve the problem.
8 I think that in this case, we have been arguing 9 for this for so long that it is a matter of shoot or cure 10 them. And it is obviously that the industry and the NRC put 11 such enormous resources for so long, patching these type of 12 things, that it is time that we look at realistic solutions.
13 Now, I am not an expert on fire protection. I 14 really don't know what to do with many of the things. We 15 need to trust, you know, in the staff and the industry. But 16 it is time that we realize we cannot continue to look at 17 this problem time after time, day after day, and not get a 18 rolution. Now, the solution might very well be different.
19 There are people that will be able to do risk-informed 20 regulations and tackle the ones that really need to ensure 21 that the problem is solved with some more deterministic way.
22 But whatever it is, let's shoot them or cure them, but let's 23 finish with the problem.
24 CHAIRMAN JACKSON: Thank you. Commissioner 25 McGaffigan.
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S- 137 1 COMMISSIONER McGAFFIGAN: One question I had that 2 came up with the previous panel, do either of you intend to 3 play in this NFPA standard drawing-up process, either as 4 members of the Committee or as commenters on the rule -- or 5 the standard as it comes out?
6 MR. GUNTER: NIRS has the document under review at 7 this point. .
8 COMMISSIONER McGAFFIGAN: Okay. But you didn't 9 ask to be part of the Committee itself?
10 MR. GUNTER: Not at this point.
11 COMMISSIONER McGAFFIGAN: Okay.
12 MR. LOCHBAUM: NIRS has the lead on this issue, 13 and I support Paul as he needs help but he hasn't for it :
14 yet.
15 COMMISSIONER McGAFFIGAN: Okay. And the second 1
16 question I have, I heard Oyster Creek earlier, and I 17 remember I happened to have the CEO of GPU in to see me j 18 about the time that one of Mr. Lochbaum's reports came out j l
l 19 that gave him a sort of UCS Good Housekeeping Seal of 20 Approval, in some sense, I mean he said it was a pretty good l 21 plant. How do you balance, when you make that sort of 22 assessment, fire versus everything else that GPU does at 23 Oyster Creek that went into your overall conclusion that 24 they were among the UCS good plants?
25 MR. LOCHBAUM: It is a good question. I think i
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S- 138 1 -- but the other 10 plants we had also had fire protection 2 problems. So, on a relative basis, and ours was a relative 3 basis, they looked the least evil perhaps. But a more 4 correct answer is that -- the thing, the most striking 5 performance aspect that Oyster Creek had was a good 6 percentage of their problemu were identified by looking at 7 other people's -- other plants' problems, and looking at 8 their own plant to see if they had the same thing, rather 9 than waiting for the NRC to find it, or waiting for it to be 10 self-revealing. We gave a lot of credit for that, because 11 that is very commendable. That is more than they have to 12 do. And those -- there was enough of those ones, they kind 13 of brought their score up, I think second overall.
14 And we, although we disappointed some of the 15 groups we worked with that were -- not NIRS, you just 16 happened to be happened to be sitting over there.
17 COMMISSIONER McGAFFIGAN: Right.
18 MR. LOCHBAUM: But some of local groups were upset 19 with our ranking, but we couldn't adjust the data, and that 20 is what the data showed.
21 COMMISSIONER McGAFFIGAN: Okay. Thank you.
22 CHAIRMAN JACKSON: Okay. Commissioner Merrifield.
23 COMMISSIONER MERRIFIELD: I don't know if I would 24 agree with the analogy of shoot it or cure it, but I 25 certainly would agree with Commissioner Diaz that this is ANN RILEY & ASSOCIATES, LTD.
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S- 139 i
1 one that we need to put the attention to and get it solved, i 2 because keeping it lingering longer is not helping anyone. !
l 3 CHAIRMAN JACKSON: Well, that was what we thought 1 4 we were doing in the fall of '96, and the Commission 5 switched directions in the spring of '98. But, nonetheless, 6 I feel that today's discussions have been beneficial in 7 focusing the Commission in those areas where we do need to ;
I 8 resolve and to finalize these going fire protection issues.
9 And as I stated at the recent Congressional hearing on NRC 10 oversight, fire protection issues remain a challenge, I mean ;
11 we are being honest, for the NRC to resolve. This is 12 especially significant given the risk significance of fires 1 l
13 at nuclear plants. l 14 And so I want to thank all of the participants for V 15 their input and insight and we are going to encourage the 16 staff, of course, to continue their interaction with the 17 stakeholders in developing timely and effective 18 risk-informed solutions to these problems.
19 Nonetheless, I take heed of the admonition that a 20 changing regulatory framework is no excuse for our not !
l 21 effectively and appropriately implementing existing l 22 regulatory requirements.
23 So, unless there are any other further comments, 24 we are adjourned. Thank you.
25 [Whereupon, at 12:15 p.m., the briefing was
-~
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e .I S- 140 1 concluded.)
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OVERVIEW t
- Revise Appendix R & 10 CFR 50.48
- Remove noncombustible requirement for penetration seals
- Remove implementation schedule & footnote to guidance j documents
- Schedule on track to be completed April 2000 l
- Comprehensive Fire Protection Regulatory Guide
- Consolidate & improve existing fire protection guidance
- Schedule on track for draft issued September 1999 i
- Provides for a comprehensive risk-informed & performance-based alternative to the existing fire protection requirements
- Schedule on track for completion May 2000
- Fire Protection FunctionalInspection Program
' - Assess license implementation & NRC oversight of reactor fire protection program
- Pilot inspections completed, assessment of results in progress, & NEl proposal under review
- Commission paper due April 1999 2
O O e q OVERVIEW ,
(Continued)
- IPEEE Program (Fire)
- To examine potential severe accident vulnerabilities & resohre GSis
- Preliminary review of submittals completed j
- Results used to support FPFI, NFPA 805 and fire research efforts
- Fire Risk Assessment Research Program
! - Improve understanding of fire risk, support current & future fire protection activities (e.g. NFPA 805) & improve analytical methods and tools
- Expect results September 2000 i
- Quad Cities
- February 1997 IPEEE submittal reported fire CDF of SE-03/yr j
- Plant shutdown by licensee due to deficient safe shutdown i l
analysis !
- Revised analysis concludes fire CDF 6.6E-05/yr
- Analysis will be submitted by licensee April 1999 ;
! 3 i
i
O _.._.__--_-__.__._---__________._[
O O APPENDIX R, REG GUIDE & NFPA 805 j, 1
- SECY 98-058, March 26,1998 - Staff Proposed:
- Delete Requirement from Section Ill.M of Appendix R for
" Noncombustible" Penetration Seal Material
- Develop Comprehensive Fire Protection Regulatory Guide
- Defer Rulemaking and Work with the National Fire !
Protection Association to Develop a PB/RI Consensus Standard for NPPs
- May 5,1998, Letter From R. Beedle, NEl to Chairman Jackson, Industry Supports Development of Reg Guide and NFPA Process to Develop a Consensus Standard for Perf-Based Fire Protection (NFPA 805)
- June 30,1998, SRM Approved Staff Proposals
- SECY 98-247, October 27,1998, Status of NFPA Activities, Assessment of Progress and Direction -Resolution of issues From SECY 97-127 '
4
O O O -
REVISION TO APPENDIX R e ACRS Lir to Chairman Jackson, July 20,1998, Agrees with the Commission's direction in the 6/30/98, SRM that Section Ill.M of Appendix R be amended to eliminate the requirement that penetration seals should utilize only noncombustible materials.
- October 1998 - Memo to Commission Outlining Status & Schedule
- Staff Pursuing Rulemaking to Amend Sect. Ill.M of Appendix R & Revise 10 CFR 50.48 to Delete Appendix R implementation Schedule and Footnote to Fire Protection Guidance Documents
- July 1999 - Publish Proposed Rule
- April 2000 - Final Rule 5
O O O .
COMPREHENSIVE FIRE PROTECTION !
REG GUIDE l
- Existing Fire Protection Guidance is Contained in l Numerous Documents ,
- Some Guidance Conflicts
- Additional / Revised Guidance is Needed
- Compensatory Measures '
- Circuit Analysis j
- December 1998 - Draft Outline Made Public i
l
- September 1999 - Issue Draft RG for Public Comment
0 0 0 0 NFPA 805 Scope & Structure
- Scope - Comprehensive Fire Protection Standard to Protect the Safety of the Public, Environment, and Plant Personnel, as Well as Limit the Potential for Economic Loss .
e Structure
- Goals - Overall outcome, qualitative
- Performance Objectives - More specific, qualitative / quantitative
- Performance Criteria - Engineering terms, quantitative
- Performance Requirements - Deterministic /
Performance-Based 7
O O O -
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Performance Requirements l
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8 ,
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NFPA 805 Status & Schedule
- Draft Available to Public - November 1998
- Committee Meeting - January 1999
- Public Proposals Closes - February 19,1999
- Committee Meeting on Public Proposals -
March 1999
]
- Standard issued for Public Comment - July 1999
- Public Comments Due - October 1999
- Final Draft Published - March 2000
- NFPA Membership Vote - May 2000 9
O O O .
-i FIRE PROTECTION FUNCTIONAL INSPECTION PROGRAM l
PROGRAM OBJECTIVES J
!
- Inspect Thermo-Lag corrective actions i
- Determine if licensees arc maintaining licensing and design bases
- Assess NRC reactor fire protection program (Appendix R, IPEEE)
- Determine appropriate level of future fire protection inspections
- Renew industry attention to fire safety 10
O O O -l i
t PROGRAM SCOPE AND ACCOMPLISHMENTS
- Developed new inspection procedures
- Conducted four pilot inspections using risk insights
- River Bend
- Susquehanna
- St. Lucie
- Prairie Island (inspected licensee self-assessment)
- Conducted FPF1-like inspections at two additional plants
- Quad Cities (restart)
- Clinton (SET and restart follow-up)
- 1-Day workshop 11
O O O j PRELIMINARY OBSERVATIONS j
- Some licensees expended significant resources l
l to prepare
- Many problems found during FPFis would not have been uncovered by core inspections
- Non-compliances were of varied safety significance
- Licensee self-assessments based on FPFI techniques may be beneficial
- Renewed industry attention of reactor fire safety
- No significant problems found with NRC reactor fire protection program (Appendix R)
) 12
O O O -
REMAINING WORK
- Develop method for assessing risk significance of fire protection deficiencies
- Assess risk significance of FPFI findings
- Assess lessons learned from FPFI pilot program
- Assess Nuclear Energy Institute Proposal (FPFI Backup 3?
- Factor fire protection inspection program into new oversight process
- Complete final report to the Commission 13
o o o:.
IPEEE PROGRAM
- Total of 74 IPEEE submittals originally expected
- Completed preliminary reviews of 70 submittals (4 plants shutdown)
- Completed reviews and issued SERs for 11 submittals
- " Preliminary Perspectives Gained from initial IPEEE Submittal Reviews" (Report to Commission)
- Many licensees implemented plant-specific ;
modifications (procedural and hardware) to improve plant safety.
- Fire events can be significantMominant contributor to total plant CDF
- Comparison of quantitative CDF between plants is not straightforward i
14
O O O -
~
USE OF RISK INFORMATION FROM .
- IPEEE PROGRAM
- Plant-specific improvements L
- Identify /prioritize fire research program ]
1
- Address certain generic safety issues
- Prioritize areas for fire protection plant inspections
- Assess the effect of exemptions to Appendix R on fire risk i 6 !ncorporate lesson learned into NFPA 805, i Performance Based Standard for Fire Protection E
15
O O O -!
1 FIRE RISK ASSESSMENT ,
l lMPROVEMENTS
- Robust fire risk assessment (FRA) methods, tools, and data are needed to support the move towards risk-informed, performance-based regulation. Applications include.
NFPA 805, inspection findings, " hot shorts."
l
- Important weaknesses in the current FRA state of the art allow significant variability in IPEEE and FRA qualitative l and quantitative results.
e FRA weaknesses have been identified and work on
> improvements has been initiated. SECY-98-230 summarizes key research findings and important FRA needs.
- FRA research program involves collaboration with industry, academic, government, and international organizations.
Significant improvements are expected by the end of FY 00.
16
O O O -l DUAD CITIES SAFE SHUTDOWN IMPROVEMENTS FOR RESTART
- Revised and Validated Safe Shutdown Analysis
- and Safe Shutdown implementing Procedures
- Implemented enhanced fire protection compensatory measures in high risk plant areas
- Added one person per shift to augment shift crew; trained staff
- NRC conducted extensive Safe Shutdown inspection
- Units 1 and 2 restarted in May 1998 17
O O O -i QUAD CITIES ~
RISK RE-EVALUATION AND CONTINUING SAFE SHUTDOWN IMPROVEMENTS .
e Re-evaluation of risk ll6 E-5 per reactor year) e improving Safe Shutdown Methodology Objectives e Physical Plant improvements i Planned to Date) e Continued focused NRC involvement 18
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-l FPFI BACKGROUND l
- SECY-93-143, "NRC Staff Actions to Address the Recommendations in the Report on the Reassessment of the NRC Fire Protection Program"
- SECY-95-034, Status of Recommendations Resulting from the Reassessment of the NRC Fire Protection Program"
- SECY-96-267, " Fire Protection Functional inspection ]
Program"
- SRM of February 7,1997
- SECY-98-187, " Interim Status Report - Fire Protection Functional Inspection Program"
- SECY-99-???, "Second Interim Status Report - Fire Protection FunctionalInspection Program" FPFI Backup - 1
-l COMMISSION INTEREST (SRM OF FEBRUARY 7,1997) I!,
- Strategies for shortening time for benefits of the i program to become available to all licensees ]
- Prioritize plant reviews so most vulnerable plants l
are reviewed first :
- Prioritize inspection modules so most significant parts of inspection could be included with other NRC inspections e Use licensee self-assessments 1
FPFI Backup - 2
. O O O -i i
t NEl PROPOSAL
- Rapid phaseout of FPFis in favor of self-assessments
- Approach fire protection inspections within context of
- new assessment process
- Develop fire protection performance indicators
- Baseline inspections where performance indicators l are not available
- Perform self-assessment when baseline inspection or performance indicators indicate shift in performance from green to white band
- Plants should use NRC inspection modules for self-assessments
- NRC should conduct FPFis when performance approaches unacc~eptable performance band 4
FPFI Backup - 3
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~O O O -!
IPEEE PROGRAM - BACKGROUND
- Generic Letter 88-20, Supplement 4 issued on June 28,1991
- Objectives of IPEEE
- To develop an appreciation of severe accident behavior
- To understand the most likely severe accident sequences that could occur at its plant
- To gain a qualitative understanding of the overall likelihood of core damage and fission product release :
- If necessary, to reduce the overall likelihood of core damage and fission product releases by modifying, where appropriate, hardware and procedures that would help prevent or mitigate severe accidents.
IPEEE Backup-1
O O O -
1 IPEEE PROGRAM - BACKGROUND (cont.)
- External Events included in IPEEE
- Seismic events
- Internal fires
- High winds and tornadoes
- External floods
- Transportation and nearby facility accidents IPEEE Backup-2
0 0 0 i
t IPEEE PROGRAM - BACKGROUND
- " Preliminary Perspectives Gained from initial IPEEE Submittal Reviews" i l
- Report to Commission - Jan.1998 t
- Total of 74 IPEEE submittals originally expected
- Completed preliminary reviews of 70 submittals
- Four plants permanently shut down !
- Completed reviews and issued SERs for 11 submittals IPEEE Backup-3
O O O
~
PRELIMINARY CONCLUSIONS
- Many licensees implemented plant-specific modifications (procedural and hardware) to improve plant safety.
i
- Fire events can be significant/ dominant contributor to total plant CDF
- Comparison of quantitative CDF between plants is not straightforward because of variability in: (1) methods, (2) input acid modeling assumptions by analysts, and (3) level of detail in analyses.
- Staff reviews of submittals focused on meeting intent of IPEEE program
- Examine potential severe accident vulnerabilities
- Resolution of specific generic safety issues IPEEE Backup-4
O o o .l EXAMPLES OF PLANT MODIFICATIONS i
- Hardware and Proceduralimprovements l
- Relocate cables out of fire area
- Upgrade fire barriers
- Improve fire suppression systems (e.g., install ,
additional sprinkler heads)
- Provide waterproof cabinets or splash guards for i electrical equipment
- Improve fire response procedures
- Modify procedures to control transient combustibles .
- Modify procedures to control active fire barriers i IPEEE Backup-5
O O O RISK IMPORTANT AREAS ,
- Dominant fire risk-important ereas :
- Main control room
- Cable spreading room l
- Switchgear room i
- Other frequently cited important areas ;
i
- Turbine building
- Battery room !
- DC equipment room
- Diesel generator room 1
- Cable routing areas ,
l IPEEE Backup-6 l
O O oy
-l i
INTERACTIONS WITH NEl/EPRI-IPEEE PROGRAM '
- Provide detailed methods and supporting technical information to utilities
- Reduce " conservatism" in past fire PRAs
- NRC review of guide:
- Some clarification and improvements over previous documents; some areas could mask information needed to identify potential vulnerabilities
- NRC/NEl/EPRI interacting to resolve generic requests for additional information (RAls) (e.g., low heat release rates in ,
electrical cabinets)
- Outcome - EPRI revised guidance !
IPEEE Backup-7
O O O -!
~\
l USE OF RISK INFORMATION FROM IPEEE PROGRAM e Plant-specific improvements
- About one-half of licensees have implemented or proposed plant improvements in fire area
- NRC/ industry activities -
- Identify /prioritize fire research program (e.g., importance of turbine building fires) i
- Address certain generic safety issues (e.g., Unresolved Safety issue (USI) A-45, Shutdown Decay Heat Removal Requirements)
- Prioritize areas for fire protection plant inspections
- Assess the effect of exemptions to Appendix R on fire risk
- Incorporate lesson learned into NFPA 805, Perfortnance Based Standard for Fire Protection i
IPEEE Backup-8
l i
EFFECT OF EXEMPTIONS TO APPENDIX R ON FIRE RISK i
- Has the cumulative effect of exemptions impacted fire j risk at nuclear power plants? (SRM on SECY 98-058, June 30,1998)
I e Outline
- Identify plants with high fire CDF (based on \;
IPEEE submittals)
- Review exemptions / deviations to fire protection regulations for these plants
- Review dominant fire sequences and contributors to CDF
- Identify correlations (if any) between exemptions and dominant sequences
- Report to Commission - May 1999 IPEEE Backup-9 '
.--------_--_-----__-_______---__---__--___j
-i s
Backup Slides ;
I
?
Fire Risk Assessment Program
~
t t
l l
f i
f s
t I
a s
l I
i I
~
OVERALL FRA PROGRAM OBJECTIVES
- Improve qualitative and quantitative understanding of the risk contribution due to fires in nuclear power plants.
e Support ongoing or anticipated fire protection activities, including the development of risk-informed, performance-based approaches to fire protection.
.
- Develop improved fire risk assessment methods and tools (as needed to support the preceding objectives).
Fire Risk Backup - 1
O O O -
FRAMEWORK FOR IDENTIFYING t PROBLEMS
- Fire protection defense in depth l
- Prevention
- Detection and suppression
- Mitigation
- FRA analytical framework
- Initiation frequency
- Likelihood of equipment damage l
- Likelihood of plant damage
- Work is proceeding on improvements (data, l methods, tools, understanding) for all three terms i
i Fire Risk Backup - 2 l'
O O O -!
-t CURRENT DETAILED OBJECTIVES
- Improved estimates of the frequencies of challenging fires
- Improved fire modeling tools (including guidance) e Mode-specific thermal fragilities for cables and other key components
- Identification of scenarios for which smoke effects may be
! risk significant e improved estimates of the probability of fire and fire effects containment (including active and passive barriers)
- Configuration- and condition-sensitive fire protection system reliability estimates, including guidance for application
- Improved HRA tools for fire scenarios
- Improved tools for assessing risk impact of circuit interactions .
- Improved understanding of the implications of actual fire events for FRA Fire Risk Backup - 3
, RELATIONSHIP WITH OTHER j
~ PROGRAMS AND ACTIVITIES l
- Needs identification
- National Fire Protection Association (NFPA) 805
- Industry (e.g., NEI)
- Information Exchange
- EPRl/NRC Memorandum of Understanding (MOU) t
- International Cooperative PRA Research Program (COOPRA)
- OECD/NEA/CSNI Principal Working Group 5
- Collaborative and Supporting Research
- National Institute of Standards and Technology (NIST)
- University of Maryland j
Fire Risk Backup - 4
- O cn i
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O O O -l
~i Introduction Anthony R. O'Neill Vice President, Government Affairs National Fire Protection Association 703-516-4346 (Office) / 703-516-4350 (' Fax)
Email: wdc@NFPA.org t
t
-_ ___ -----------------------------------------_---_----J
O O O -
~
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WHA-~ S NFPA?
+ National Fire Protection Association j
+ =ounded in 1896
~
i ,
+ Private, Non-Pro"it, Voluntary Codes and
~
Standards Developer 1 -
+ ANSI Accredited Organization
+ Vlembershia Organization - 69,000
+ Members in U.S. and 79 Nations i NFPA*
_ - - - - - _ . _ _ - = . --
O O O -
\ FPA Coces and Standards Adoated and Used By:
- + Federal Government
+ HHS - Health and Human Services Admin. .
+ OSHA - Occupational Safety & Health Admin.
+ GSA - General Services Administration
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+ FAA - Federal Aviation Administration i
+ States, Counties, Cities, and Towns
+ Architects, Engineers, and Designers
+ Builcing Code Orcanizations ,
- + Insurance
+ Inc ustry ,,,,.
l ._ .
O O O -
Federa Use.o" Private Sector S~:anc ards
+ O V B A-1 ~ 9 (since 1983)
. Federal Government Staff Participation in Private Sector Standards Develo3 ment and~
Urges Adoption of Standards for Carrying Out Public Policy. !
+ P.L.104-113 " Technology Transfer Act"
. Codifies OMB A-119
. Directs "All Federal Agencies and Departments Shall use Technical Standards that are Developed or Adopted by Voluntary Consensus Standards Bodies, Using such Technical Standards as a Means to Carry Out Policy O ajectives..."
NFPA*
O O O -
Pro'ects Requested by Federal Regu ators
+ OSHA .
+ NFPA 70E - Electrical Safety Requirements .
for Employee Workplaces
+ EPA
+ NFPA 2001 - Clean Agent Fire Extinguishing Systems
+ Coast Guard
+ NFPA 301 - Merchant Ve.ssel Fire Protection
+ CPSC
+ NFPA 720 - CO Detector Installation l
NFPA"
O O O
\lF-)A Codes and Standards Process
+ IVember o" ANSI - American National Standards Institute .
+ Accredited Consensus Process: .
+ ~5400 Committee Members ..
+210 Committees .'
+290 Documents kI
+ 1/3 Balance by interest Category
+2/3 Consensus to Change Document t
i i
NFPA"
O O O-i E ec~:ronic Access to NFPA
+ \l:PA's Homepage: www.NFPA.org
+ Con:ains .
. News, press releases, 3roduct information, fire investigation reports, calendar of events, staff directory and E-mail addresses, ROP's and ~10C's, membership in"ormation, hot lin m M e M. M m =
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O O O
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,i' rj' Conclusions
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i 4 is o Prelectisonschedule ,
I o CommitteestillhasROPandROCperiodto
- makechangesandaddressconcerns o AII public input [ proposals and comments)
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mustbeaddressed bycommittee ;
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l I NFPA 805: Implementation Opportunities e Provides more flexibility than cunent standard e Supports increased focus of NRC and licensee resources on risk-significant areas ,
. Provides a context to assess significance of '
emergent fire protection issues l
. V' i I NFPA 805: Implementation Concerns
,, s e Extensive changes tolong-standing fire i
[ \ protection licensing bases will be challenging k e Licensee options of allor nothing to adopt the standard are too restrictive _
e lacremental application of risk infonnation and perfonnance bases within the carent licensing basesis possible e Regulatory acceptance criteria for licensee implementation will take time to devel p g, i
l l
l I Conclusions e NE! supports the hTPA 805 development process.
e The devHyment process should be completed.
e Plants should be permitted to use insights supporting hTPA 805 to make selected changes to the existing licensing bases.
7'
(
- (
2
O I ~1 NEI Views on Fire Protection Standard Implementation Ralph Beedle, NEl ,
David Modeen, NEl NRC Commission Briefing February 9,1999
, V' I I NEl Support for NFPA 805 Development e NEl represented on NFPA committee by two ,
utility fire protection experts e Provided opportunity for extensive discussion of draft standard at a recent information forum
. Working with NFPA to arrange a plant demonstration of the draft standard this summer
, v' l f NEl Views on NFPA 805 e Considerable effort expended to develop high quality draft e Process needs to continue to completion to assure best product e implementation of NFPA 805 offers opportunities and concems V'
O 1
- O O O -!-
i 4 i UNION OF CONCERNED i SCIENTISYS Fire Protection Problems:
! Easiest Target in the World David A. Lochbaum
[
! i February 9,1999 f
UNION OF . :
CONCERNED -
sciennsrs IntrOdHCtiOH
=
i E Moving target is said to be difficult to hit.
E Fire protection problems must be the easiest target to hit since there's been no discernable movement since 1980.
l E If compliance with fire protection regulations were i needed to generate electricity, problems would have been resolved long ago. !
- O O O -;
UNION OF CONCERNED S='S'S 1975 Browns Ferry Fire E . .,
E 03/22/75: Worker using candle to check for air leaks ignites combustible materialin cable tray penetration.
E Fire alarm is not sounded for several minutes while workers attempt to extinguish flames.
E Fire is out of control before fire alarm is sounded.
E Because fire affects energized cables, management does not allow water to be used.
E Fire burns for over six hours.
E When water is finally authorized, fire is put out within 10 minutes. .
Slide 3
P UNION OF CONCERNED Sc'""=5 1995 Waterford Fire -
EE E 06/10/95: Grid disturbance caused turbine trip.
l Worker reports heavy smoke in turbine building. i E Fire alarm is not sounded for 29 minutes while workers l
search through heavy smoke for flames.
l E Fire detector alarms in control room were ignored by operators who were directing " search" for flames.
E Fire is out of control before fire alarm is sounded.
E Because fire affects energized cables, fire brigade
- leader does not allow water to be used.
E Fire burns for over an hour.
E When water is finally authorized, fire is put out within 4 minutes.
~ ~ ~ ~
_____ L _ _ . __
O O O -!
UNION OF Inadequate netermination or 'i CONCERNED Sc'"=S Technical Bases for Regulations EE. .
E In NUREG-1552,in response to Rep. Markey, and m meeting with NIRS and UCS, NRC staff stated that the ,
technical basis for the non-combustibility requirement in 10 CFR 50, App. R,Section III.M was not known.
E The technical basis is explicitly specified by the NRC Commissioners during their review of the App. R rulemaking (see transcript of 10/16/80 Commission meeting with the draft finn! rule):
- Commission specifically refused the industry's proposal to require penetration seals to meet same rating as wall.
- Commission specifically required non-combustible fire barrier penetration seal material to prevent combustible cable jackets from l propagating fire across fire wall (i.e., wick effect).
Slide 5
UNION OF nadequate eterminatiOH Of CONCERNED Sc'==S Technical Bases for Regulations E.
E App. R,Section III.N, Fire Barrier Cable Penetration Seal Qualification
" Some commenters suggested that this entire section be deleted and replaced with the following two sentences: ' Penetration seals shall provide the equivalent protection which is required of the fire barrier. Evaluation of the penetration seals based upon a design review and relevant test data or qualification tests may be made.'"
1
- "The Commission has reconsidered this issues and revised the rule to:
(a) require the us'e of only non-combustible materials in the construction of such fire barrier penetration seals; (b) require such fire barrier penetration seals to be qualified by test; and (c) require such tests to satisfy certain acceptance criteria."
E App. R Subpart III.M matches the Commission's express direction. The Commission specifically refuted the very policy which the NRC staffis now following. .!
O .
h ~
slide $ -
O O O -!
.t i
UNION OF CONCERNED Inadequate netermination or Sc'"='S Technical Bases for Regulations l .. .
j E IN NUREG-1552, the NRC staff advocates that fire barrier penetration seals need not be non-combustible but merely meet the same fire rating as the wall or floor.
- E This NRC staff position is virtually identical to that l
position specifically discarded by the Commission in 1980.
l M Recommendations: Do not issue proposed rulemaking i l for risk-informed fire protection regulations until the .
technical bases for the existing regulations are fully.
understood. Enforce the existing rule until the rule is changed.
Slide 7
UNION OF CONCERNED Sc'""=S Non-conservative Risk Studies H
E In the last decade, there have been numerous reports of missing or deficient fire barrier penetration seals.
E Within the past few years, licensees have developed plant-specific risk assessments.
E Some, if not all, of these risk assessments assume 100%
fire barrier penetration sealintegrity (i.e.,0% chance that fire-rated wall or floor will be breached by fire).
E Given documented history of fire barrier penetration seal problems, it is non-conservative to assume 100%
effectiveness in preventing fire propagation.
E Recommendaiion: Do not base risk-informed fire protection rules on d.eficient risk assessments. .
O -
..._g siia$
UNION OF -
CONCERNED S='S'S Non-conservative Risk Studies .
gl EIf risk assessments accounted for finite probability of improperly installed fire barrier penetration seals :
, - relative safety significance of penetration seals could be determined
- since plants have 2,000 to 10,000 penetration seals, prioritization would allow licensees /NRC to focus inspections on more imp.ortant areas
-ifit takes 1 man-hour to examine a penetration seal, it would take 5 man-years to examine all seals m plant with 10,000 seals
- with proper focus,100 inspection hours could cover the 100 highest ranked penetrations, or the bulk of the fire risk profile Slide 9
UNION OF CONCERNED i Sa"" = S Summary Elm i
E Browns Ferry's lessons have not been learned and those problems were repeated at Waterford.in 1995.
E The NRC staff must fully document the technical bases for existing fire protection regulations as part of the rulemaking process.
E Risk-informed fire protection regulations should not be adopted if they rely on deficient risk assessments.
E Risk assessments must reflect reality of fire barrier penetration seal problems.
E Until the final fire protection rule is implemented (some years hence), the existing fire protection regulations must be rigorously enforced. ~
- -. G . . .
-S 'e
O O O -
i NUCLEARINFORMATION AND RESOURCE SERVICE :
t COMMISSIONERS BRIEFING ON FIRE PROTECTION FEBRUARY 9,1999 i
i 1
O O o. .
l l TIME TO RESOLUTION FOR NONCOMPLIANCE OF l FIRE PROTECTION ISSUES 1
! e Thermo-Lag resolution stilllags I y
-1981 Appendix R was promulgated to protect safe shutdown power, instrumentation and control cables from fire.
-79 U.S. reactors installed Thermo-Lag fire barriers systems, many on single source contracts.
2
-Thermo-Lag failed O -
1 repeated
- 2) combustible fireand testconstitutes failures 1)fuel fo r fi re a 3) failed the standardizedesthose stream t ;
- 5) seismicallyinadequate4) reliableclaims for 6) i problematic to install
\
i
{
\
\
1982, NRC had warning that -
r y as Ther
\ ag did not work
\
by lack of NRC enforcement in 1991 ustrated repor concerns to NIRS
\
\
O O O
-Thermo-Lag failed
- 1) combustible and constitutes a fuel for fire 2? repeated fire test failures
- 3) failed the standardized hose stream test
- 4) claims for a low ampacity derating unreliable
- 5) seismicallyinadequate
- 6) problematic to install
-Office of the Inspector General reported that as early as ,
1982, NRC had warning that Thermo-Lag did not work i
i
-A safety-conscious fire protection consultant frustrated by lack of NRC enforcement reports his concerns to NIRS in 1991 3 r
_O
O O O d
-Information Bulletin 92-01, June 24,1992 declaring Thermo-Lag fire barriers " inoperable."
-XIRS files 2.206 on July 21,1992 and is rejected by NRC on August 12,1992
-By the end of 1993, the nuclear industry through the guidance of NUMARC sets up a special task force to scrimmage with NRC as a Priority Issue "to re-establish the technical and licensing basis to qualify Thermo-Lag materials for use in one and three hour fire ratings as required by Appendix R."
4 I
____ _ ___________ __- - _ _ _ - ____-_l
O O o
-1997 Industry drags out resolution, Confirmatory Action ,
and Orders ~ issued during 1998 to non-compliant utilities to set resolution dates for 1999 and 2000
. The current NRC approach to inoperable fire barrier systems at Salem nuclear power station demonstrates a carry over of this lack of resolve to enforce policy
-March 18,19811N RC acc.epts Salem fire tests for 3M fire barrier product FS-195
-February 21,1992 NRR receives " Referral of Potential Health and Safety Issue To NRR" for a failed fire test
O O O E s!
-May 28,1993, NRC issues IN 93-41 indicating deviations between tested and installed configurations, failed fire ~
tests, and hose stream tests not performed.
-December 3,1993, NUMARC industry-wide workshop focuses on inoperable cable raceway fire barriers at Salem.
-PSE&G's Salem Unit 1 is removed from service May 16, 1995 and Unit 2 on June 17 and commits not to restart ,
without permission of NRC. Units are down for over two ,
and a half years. IN 93-41 is not addressed as restart issues. .
i i
O O O q 1
September 23,1998, PSE&G presents Salem Raceway Fire Barrier Wrap Project for compliance by 2002.
?
. Examples of a licensing system that simply accepts without verification and validation the licensee representation which then turns out to be inaccurate.
- To avoid replacement ofinoperable fire barriers, industry proposes to perform a circuit analysis for alternate circuits sidestepping a key and problematic regulatory requirement for tested and rated barriers.
l 7 i l
O O O -
~
. NRC is now backing away from Appendix R altogether with a move to " risk informed" guidance for licensees despite a myriad of staff identified questions that Appendix R was intended to prescriptively address
- No resolution or compliance date within sight l
l 8
O O O .
e RELIANCE ON INDEFINITE AND UNRELIABLE FIRE WATCHES AS RESOLUTION TO NON-COMPLIANCE WITH FIRE PROTECTION REGULATIONS
. There is an appropriate role for temporary fire watch as in the case of welding operations in fire zones
- The use of fire watch as a " compensatory" measure for long term inoperable fire barriers is an abuse ofits intended role 9
H e Commissioner Ivan Selin, Fire Safety At Nuclear Power Plants, subcommittee on Oversight and Investigations
}
(March 3,1993):
" Fire watches are not new to power plants. We have always had them. If a particular system is out of repair for 6 months or 9 months, fire watches go out. People are already trained to do fire watches.
They don't expect to do them for 2 years fulltime.
That's a real strain. It's expensive, and it's something that takes surveillance."
10
~
~
O O O .
a
- Thermo'-Lag fire watches now in place for months
. At least two reactor sites will probable close with Thermo-Lag fire watches in place l
e Fire watches do not constitute a " compensatory" level of ,
protection for a rated passive fire barrier system. !
l
-A rated fire barrier is designed to physically protect safe shut down cables from fire by Appettdix R .
standards for up to 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> in the event that fire fightmg brigades maybe prevented by heat and radiation from i
i 11
o o o ,
entering an area to extinguish a fire in a safety critical area.
-A rated and tested fire barrier system is not subject to i dereliction of duty or falsification of duty logs
-More appropriately, fire watch personnel constitute a compensatory measure for inoperable detection systems u
O O o: .
CONCLUSION
. Washington Post November 8,1998 l
"FAA Missed Warning on Insulation Burn Test" regarding the September 2 crash of Swiss Air Flight 111 and combustible insulation i
e Case study of a critical safety issue buried within a government institution, subject to tight budgets and a single event
. The public would not tolerate the presence ofindefinite in-flight fire watches for inoperable aircraft insulation as an interim solution 13
o o oq
'i
. Significantly more is riding on nuclear power stations operating with inoperable fire protection systems without timely regulatory resolution and enforcement
- Why should the public be anymore tolerant of the nuclear power industry and the NRC?
. . . _ . . - . . - . _ . _ _ . _ _ _ _ _ _ _ . - . _ _ _ _ _ _ _ . _ _ . _ . . _ _ _ _ _ _ __