ML20209D686
| ML20209D686 | |
| Person / Time | |
|---|---|
| Issue date: | 11/15/1984 |
| From: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Stello V NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| Shared Package | |
| ML20209D558 | List:
|
| References | |
| FOIA-86-274 NUDOCS 8412190351 | |
| Download: ML20209D686 (6) | |
Text
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, avis a MEMORANDUM FOR: Victor Stallo, Jr.. Deputy Executive Director for Regional Operations and Generic Requirements FROM: James P. O'Reilly, Regional Administrator
SUBJECT:
REC 0ftiENDED FIRE PROTECTION POLICY AND PROGRAM ACTIONS As requested by memorandum of November 2, 1984, from William J. Dircks, the NRC Fire Protection Policy Steering Committee's " Recommended Fire Protection Policy And Program Actions" of October 26, 1984, have been reviewed. The enclosed coments should be considered for improvements prior to promulgating the Comittee's recomendations.
Of more import, however, are issues that were not addressed by the Committee.
For example, at one Region 11 facility, over two hundred people will work fulltime for the next one and one-half years to implement Appendix R requirements at an estimated cost of about 30 million dollars. At another Region Il facility, I
a six-month delay in licensing, along with additional modification costs, have resulted because of recent Appendix R inspection findings. The issues are
. whether the staff interpretations exceed what the Commission intended when it
-G Yqdefinitive approvedguidance AppendixtoRlicensees and if we to should assure provide that the unusually extensive clear andbeing work additional done is performed efficiently and effectively. Before we progress any further with Appendix R inspections cr. enforcement I believe the issues should, in our view, be extensively discussed with the Commission.
My staff is available to discuss these consnents if you have further questions.
g [.C
- mes P. O'Reilly
Enclosure:
Region II Coments on Fire Protection cc w/ enc 1:
R. DeYoung, IE:HQ T. Murley, RI J. Keppler, RIII l R. Martin, RIV l J. Martin, RV R. Fraley, ACF.S R. Vollmer, DE F. Rosa, NRR CONTACT:
Thomas E. Conlon -
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_ ENCLOSURE REGION !! COMMENTS ON FIRE PROTECTION STEERING COMMITTEE'S OCTOBER 26, 1984 RECOMMENDED FIRE PROTECTION POLICY AND PROGRAM ACTIONS Steering Comittee Recotaendations 1.a. Concur 1.b. Concur. However, if adequate resources are available, the Region should l
conduct an Appendix R inspection of all Regional facilities during 1985.
I 1.c. Concur 1.d. Concur i 1.e. Concur. However, the " Appendix R Questions and Answers" (Enclosure 6) should be closely reviewed and revised to comply with the new "Interpreta-l tion of Appendix R" (Enclosure 3), to use standard fire protection tenni-
, nology and to provide a consistent application of positions for both OR and NTOL 11 ants. Refer to comments on " Appendix R Questions and Answers' listed below, i 2.a. Concur i
2.b. Concur 2.c. Concur 2.d. We agree with this concept to achieve resolution of NRC/ Licensee Fire Protection issues. However the section should identify the referee as a
- Fire Protection Issue Review Board in lieu of a " Referee" to resolve the differences between the inspection teams and the licensees.
i l 3.a. Concur. However, refer to the below listed 'coments on " Fire Protection License Condition".. -
3.b. A time schedule should be established for the completion of the evaluation
'j of existing fire protection Coumiittee's recommendations. guidance for consistency with the Steering 3.c. Concur 3.d. Do riot concur. Region II recomends that the entire NRC fire protection program be under the management and control of a single organization in NRR. Refer to Question 8.15 under " Appendix R Questions and Answers" for further comments.
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- 4. Concur Generic Letter on Fire Protection Do not coni.ur. A new rule or a Comission approved guidance document appears to be necessary.
Interpretations of Appendix R
, i Concur; but before these interpretation are released, the " Appendix R Questions and new Answers" document should be closely reviewed and revised to comply with the interpretations.
Guidance for Enforcement Actions Concerning Fire Protection Requirements !
Concur. The fire protection enforcement enforcement policy of 10 CFR 2 Appendix C. policy should be included in the NRC Fire Protection License Condition Concur, except item 1.
Lines 2 and 3 should be revised to read as follows: l
"... described the facility...". in the Final Safety Analysis Report or Fire Hazards Analysis for '
This change is necessary to cover those facilities in which the fire protection program is described in a document separate from the FSAR.
A_ppendix R Ouestions and Answers 4
Comments questiers. and recomended chan9es arc offered on the response to use following 3.1 The response to the question was "Yes". A history of the develop-ment of the definition was given in the response based on:
- 1. BTP APCSB 9.5-1 '
- 2. NRC supplementary guidance
- 3. Appendix A to BTP 9.5-1 However, all of the above stated " definitions" are not in-agree-ment
- 6. Thesewith the new "NRC Interpretation of Appendix RDtems 4 and definitions (i.e., fire area and fire zone) are the subject of the original Fire Protection Differing Professional Opinion written within NRC. Therefore, the new guidance proposed ;
in Items 4 and 6 of Interpretations of Appendix R should be added to the response of Question 3.1; and the "Yes" answer qualified to reflect the new interpretations. In this way, clear and useful
_ guidance the industry.based on NRC historical experience will be provided to (For editing purposes it is recossended that the order or presentation of historical definitions be chronological:
namely. BTP 9.b Appendix R, guidance (add BTP CME 8 9.5-1 as given in 3.1.2) and new Interpretations of Appendix R.)
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I 3.1.2 The definition of fire barrier presented should be that as stated in BTP APCSB 9.5-1, which was in use during the period of a 1977 fire hazards analysis. BTP CMEB 9.5-1 was not issued until 1981; namely, Rev. 3. BTF CMEB 9.5-1 (NUREG 0800). Reference should be made not only to item 4 of the " Interpretations of Appendix R",
but also response to Item 6 and response to Question 3.1.1. This will aid in fully understanding the relationship of the fire areas and the associated fire barriers. l 3.1.4 The response should add references to Items 3, 4 and 6 of the Interpretations of Appendix R. Enclosure 3. This will provide an !
i overall damage"understanding vs. resultin of the relationship of (1) " free fmm fire basis fire; and (3) gfire damage; areas (2) vs.largest firt zones. credible fire vs. design It seems that the technical terminoloty used in this response should be clearly defined in a defin< tion section and agree with that in the previous responses and interpretations. The response should be revised to present consistent use of technical terms as noted i above, and a consistent philosophy of analysis as pres,ented in the previous question responses and interpretations.
4 3.1.5
! - The requirements of Section III.G.3, as stated, are not complete.
The following requirement of !!!.G.3 should be added to the last paragraph on page 11: "For those configurations that do not satisfy the requirements of III.G.2, fire detection and fixed fire suppression system shall be installed in the area, room, or zone under consideration." Additionally. the new interpretations.
- Item 5. Automatic Detection and Suppression, and Item 6. Alternative or Dedicated Shutdown, have not been referenced in this response.
These of the response. should be referenced in the next to last and last paragraph 3.4.2 The response should include a statement that further clarification related tions to partial R.
of Appendix coverage is provided in Item 5 of Interpreta-3.4.3 The response should reference Item 5 of Interpretations 'of Appendix R.
3.4.6
- The response should reference Item 5 of Interpretations of Appendix R (Enclosure 3) of this document.
3.5.2 The response should also reference Item 4 of Interpretations of !
. Appendix R which states that "...all unsealed openings should be )
_ identified and evaluated."
3.8.2
, The basis response fire". must be expanded to clarify use of the term " design The response states that neither industry nor the staff has been able to develop criteria establishing design basis 3
fire...; however, this ters is used in the NRC response to a previous question. 3.1.1. A similar term "... largest credible fire" is used in the response to question 3.1.4. " design basis
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fires" are defined in BTP APCSB 9.5-1. Section C. which is quoted in the NRC response to Question 3.1.1. The NRC response should be revised to provide clear and consistent technical infomation.
5.3.1 The answer given to question 5.3.1 is not clear and does not provide any clear information. This response should be revised in its entirety.
5.3.2 There should be a definition 1tven for " Hot Short". A high impedence short conducts very 1ittle current. Once current flow is increased it will burn open or trip a circuit protection device. The postulation that the fire would eventually clear the '
" hot short" is secondary. The hot short would clear whether there was a fire or not.
5.3.4 The response should also refer Item 2 of Interpretations of Appendix R (Enclosure 3) for clarification of " free of fire damage".
i 5.3.11 Reference should be made to Item 6 of Interpretations of Appendix R (Enclosure 3).
7.1 The requirements for seismic design of hydrogen lines as .delineat-ed in BTP CMEB 9.5-1. C.5.d.(5) are not included in BTP APCSB 9.5-1 or Appendix A to which most early Operating Reactors (ors) are couaitted. Only NTOL plants have had a formal NRR review to BTP CHEB 9.5-1 requirements. This response, as stated, may have direct impact on early ors of the older PWR type. Early OR hydrogen system designs may need to be modified, requiring exten-sive backfitting.
7.2 It should be noted that the stated CEMB 9.5-1 requirement may not necessarily apply to those ors reviewed by NRR under BTP APCSB 9.5-1 and Appendix A.
8.8 The response should reference Section 3 of this enclosure and Item 4 of Interpretations of Appendix R.
8.10 The term " design basis fire" should not be used in this text.
8.11 The Region 11 staff does not agree that BTP CMES 9.5-1 includes the requirements of Appendix R and previous guidance documents j incorporated into the Branch Technical Position. Refer to memo-randum from Tom E. Conlon to Faust Rosa dated November 7,1984, and the statement on page 5 of the October 26, 1984 memorandum from the Fire Protection Policy Steering Consnittee . to William J. Dircks.
i B.15 The response provided clearly indicates the need for a mechanism within the agency to assure and maintain a high level of consis-tency for fire protection policy to the industry. To accomplish
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Enclosure 5 s
this, it is reccamended that the total fire protedtion responsi-bilities/ reviews presently assigned to three divisions within NRC and one in IE be reassigned to one division such that the entire MRC fire protection program will be under the management and control of a single organization at the headquarters level.
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