Multiple Addressees " 5 May 29, 1984 The fire protection engineers believe that the definition of free from fire damage" must also explicitly require the alternative structure, system or component to be undamaged by the fire suppression agent. When Part 50 was promulgated, the Commission was concerned that fire suppression agents should not disable shutdown equipment. The proposed interpretation does not share that concern. The Commission should ask the staff to explain why It appears to believe that the potential disabling effects of fire suppression agents are no longer a significant safety concern.. d. Automatic Detection and Suppression An integral component of an overall fire protection plan is the use of automatic detection and suppression systems, e.g., fire and smoke alarms and automatic sprinklers or gas systems. To be effective, these systems usual rust cover the entire fire area. The interpretation wo ::rmit licensees to use less than full area coverac:d on an evaluation subject only to subsequent NRC aud. The fire protection staff is concerned that this varian procedure suffers from the same problems of delay and in:: sistencies as the variance procedure for deviations from .. requirement for uniformly rated fire boundaries. The Commission should ask the staff to explain why the special exemption procedure for fire protection requirements should not be applied to requests for less than f. coverage automatic detection and suppression system. e. Alternative or Dedicated Shutdow Appendix R requires an alternative or dedicated shutdown capability if existing shutdown equipment cannot be separated or otherwise protected from damage by one fire to satisfy requirements for redundancy. An alternative or dedicated shutdown capability has beer. generally understood to mean a separate system. The new interpretation of Appendix R would permit licensees to locate alternative or dedicated Shutdown equipment in the same fire area containing the inadequately redundant equipment as long as that new equipment is independent of the room or zone. No guidance is provided for determining the acceptability of an alternative or dedicated shutdown system so placed. Members of the fire protection staff noted that this interpretation may release licensees from previous commitments to provide a physically separated alternatives or dedicated shutdown Multiple Addressees 6 May 29, 1984 capability. At the very least, these members of the fire protection staff would require a detailed fire hazards analysis showing that a single fire would not disable both trains of redundant equipment and the alternative or dedicated shutdown capability. An alternative or dedicated shutdown capability can be expensive. However, some licensees have installed them and others have committed to them because they were apparently required. By now permitting those licensees who have delayed their compliance with this requirement to avoid it, the Commission will be sending a signal that defiance pays. It was just to avoid this penalization of licensees who complied with regulations that the Commission sought to avoid in setting the compliance schedules in 10 C.F.R. 50.48. Accordingly, the Commission should ask the staff to explain its change of position as a matter of safety and policy. f. Minor Issues 1. Seismic Events An The reactor coolant pump (RCP) lube oil system contains up to 235 gallons of lubricating oil per pump. Appendix R requires a seismically qualified oil collection system. exemption can be granted for a collection system which is not seismically qualified if the lube oil system itself is designed to with stand a safe shutdown earthquake (SSE). Under those circumstances, the exemption analysis needs to consider only random leaks from the joints and need not assume that random leaks will occur simultaneously with an earthquake. In my view, the proposed exemption analysis is incomplete because it does require consideration of an accumulation of randomly leaked lube oil which could be discharged from a seismically unqualified leak collection system by a subsequent earthquake. Staff should be requested to explain why this possible scenario has not been included in the analysis. An alternative to using a fire barrier to protect redundant equipment from damage by a single fire is to locate the equipment so as to be physically separated by a large space with no intervening combustibles. Staff would now interpret "no" intervening combustibles to be "no significant quantities "of intervening combustibles. Such an interpretation Multiple Addressees.... 7 May 29, 1984 reduces the effectiveness of physical separation and may render it a less effective alternative to a fire barrier. Staff should be asked to explain how this interpretation is consistent with the use of physical separation as a substitute for a fire barrier. 3. Oil Cans Oil in closed cans is not considered as an intervening combustible. But a fire in the vicinity of an oil filled can could heat that oil causing it to vaporize, burst the containing can and then ignite. Staff should be asked to explain why oil in closed cans need not be considered to be an intervening combustible. Mr. ASSELSTINE. Right. Dated May 29, 1984. It talks about the six major areas where there were fundamental changes really being proposed to the current interpretation of the regulation, interpretation that had been formally reviewed and approved within the Agency management. I think that memorandum really spells out the kind of fundamental changes that were being talked about here in such essential elements of fire protection as fire boundaries, fire areas, fire damage, really some of the key elements in the rule and its interpretation. Mr. DEFAZIO. Yes. In fact, I have that memorandum and I certainly share he talks here about the Browns Ferry fire lessons, and he goes on, saying: Therefore, to now interpret appendix R so as to not incorporate a fundamental lesson learned at Browns Ferry would appear to directly contradict the Commission's intent in promulgating appendix R. That is in response to just one of the changes that was made, and it certainly will be tragic if we find that we didn't learn a lesson at Browns Ferry; or, as often happens in America, we get a few years away from something and we don't retain our sense of history. He certainly seems to have taken strong exception and he certainly is an individual, intimately familiar, having had to defend these regulations with these changes. So I would say, Mr. Chairman, it is certainly the opinion of Mr. Trubatch and some others that it was not just sort of a discussion in Mr. Stello's office that resulted in a renewed understanding and going forward either with the exception process or perhaps a new rulemaking, but actually a significant modification of rules that had been found to withstand a legal test that happened at this point. Mr. ZECH. May I, Mr. DeFazio, in order to complete the record on this issue, request that a memorandum dated October 24, 1985, NRC Memorandum, subject, Staff Interpretations of appendix R, also be included in the record? Mr. GEJDENSON. Without objection. [EDITOR'S NOTE.-Memo for Palladino, Roberts, Asselstine, Bernthal, and Zech from Martin Malsch on staff interpretations of Appendix R-October 24, 1985.] On May 29, 1984, Sheldon Trubatch, then of the Office of the On June 8, 1984, in a Memorandum from Samuel Chilk to William Dircks, the Commission requested that the staff comment on the May 1984 Memorandum. SECY-85-306 and Enclosure 8 thereto, submitted by the staff to the Commission on September 17, 1985, contain the staff's comments on five of the eight interpretations discussed by Mr. Trubatch, the five he had argued constituted significant changes in the rules. OELD prepared the staff's comments on three of the five, concluding that only those three raised legal issues. See SECY-85-306, Enclosure 8 at 1. 1The Nuclear Utility Fire Protection Group (NUFPG) also [Footnote Continued] Contact: Steven Crockett, OGC X41465 |