Removal of Fire Protection Requirements from Technical Specifications
August 2, 1988
TO ALL POWER REACTOR LICENSEES AND APPLICANTS
SUBJECT: REMOVAL OF FIRE PROTECTION REQUIREMENTS FROM TECHNICAL
SPECIFICATIONS (Generic Letter 86-12)
Generic Letter 86-10 requested that licensees incorporate the NRC-approved
Fire Protection Program in their Final Safety Analysis Reports. Generic
Letter 86-10 encouraged licensees, upon completion of this program, to apply
for an amendment to their operating licenses (1) to replace current license
conditions regarding fire protection with a new standard condition and (2)
to remove unnecessary fire protection Technical Specifications (TS).
During the past two years, the staff has gained experience with
implementation of Generic Letter 86-10 for new operating licenses. In
addition, lead-plant proposals for this license change were submitted with
the endorsement of the Westinghouse Owners Group and approved for Callaway
and Wolf Creek. On the basis of this combined experience, the staff
developed the enclosed guidance for the preparation of a license amendment
request to implement Generic Letter 86-10.
A conforming amendment would remove fire protection requirements from TS in
four major areas: fire detection systems, fire suppression systems, fire
barriers, and fire brigade staffing requirements. The existing
administrative control requirements related to fire protection audits would
be retained. Additional programmatic requirements have been included in the
administrative controls to address the Fire Protection Program consistent
with the requirements for other programs.
Licensees and applicants are encouraged to propose changes to TS that are
consistent with the guidance provided in the enclosures. Proposed license
amendments conforming to this guidance will be expeditiously reviewed by the
NRC Project Manager for the facility. Proposed amendments that deviate from
this guidance will require a longer, more detailed review. Please contact
the Project Manager if you have questions on this matter.
Sincerely,
Frank J. Miraglia
Associate Director for Projects
Office of Nuclear Reactor Regulation
Enclosures:
As stated
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Enclosure 1
GUIDANCE FOR REMOVAL OF FIRE PROTECTION REQUIREMENTS
FROM TECHNICAL SPECIFICATIONS
INTRODUCTION
This enclosure provides guidance for the preparation of a license amendment
request to implement Generic Letter 86-10. Such an amendment (1) institutes
the standard license condition for a Fire Protection Program. (2) removes
requirements for fire protection systems from Technical Specifications (TS),
(3) removes fire brigade staffing requirements from TS, and (4) adds
administrative controls to TS that are consistent with those for other
programs implemented by license condition. The submittal must also include
the update of the Final Safety Analysis Report (FSAR) to include the Fire
Protection Program, if this has not been completed as requested by Generic
Letter 86-10.
The staff's intent in Generic Letter 86-10 of recommending that fire
protection requirements be removed from the TS was to further the goal of
Technical Specification improvement as delineated in other NRC policy
statements. It is not the staff's intent to reduce the level of fire safety.
This guidance was developed on the basis of the review of lead-plant
proposals for Callaway and Wolf Creek and from staff experience in
implementing Generic Letter 86-10 for recent operating licenses.
DISCUSSION
This section addresses the elements a licensee should include in a license
amendment request to remove fire protection requirements from TS.
First, the NRC-approved Fire Protection Program(1) must be incorporated into
the FSAR and submitted with the certification required by 10 CFR
50.71(e)(2). as requested by Generic Letter 86-10. The FSAR update includes
the incorporation of the Fire Protection Program, including the fire hazards
analysis and major commitments that form the basis for the NRC-approved Fire
Protection Program. This clay be accomplished by referencing the documents
which define the licensee's Fire Protection Program as identified in the
NRC's Safety Evaluation Reports.
The staff does not intend to repeat its review of the approved Fire
Protection Program incorporated in the updated FSAR. The staff may audit the
updated FSARs to assure that they have incorporated the approved Fire
Protection Program. Licensees should not use this FSAR incorporation as an
opportunity to make changes in the approved Fire Protection Program.
Licensees should
(1) The NRC-approved Fire Protection Program includes the fire
protection and post-fire safe shutdown systems necessary to satisfy NRC
guidelines and requirements; administrative and technical controls; the fire
brigade and fire protection related technical staff; and other related plant
features which have been described by the licensee in the FSAR, fire hazards
analysis, responses to staff requests for additional information,
comparisons of plant designs to applicable NRC fire protection guidelines
and requirements, and descriptions of the methodology for assuring safe
plant shutdown following a fire.
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wait until the standard license condition is in place and then use the
procedures described in the license condition to make any necessary changes
in the Fire Protection Program.
Second, the Limiting Conditions for Operation (LCO) and Surveillance
Requirements associated with fire detection systems, fire suppression
systems, fire barriers, and the administrative controls that address fire
brigade staffing would be relocated from the TS. An index of these
specifications is provided in Enclosure 2. The existing administrative
controls related to fire protection audits are to be retained in TS. Also,
any specifications related to the capability for safe shutdown following a
fire, e.g., see Item 8(j) in Enclosure 1 to Generic Letter 61-12, are to be
retained in TS.
Third, all operational conditions, remedial actions, and test requirements
presently included in the TS for these systems, as well as the fire brigade
staffing requirements, shall be incorporated into the Fire Protection
Program. In this manner, the former TS requirements will become an integral
part of the Fire Protection Program and changes subsequent to this amendment
will be subject to the standard license condition. These remedial actions
include shutdowns currently required by TS 3.0.3 when an LCO and its
associated Action Requirements cannot be met. An example of such a
requirement is the shutdown required for the loss of the fire suppression
water system and failure to establish a backup water supply within 24 hours.
Fourth, the standard fire protection license condition in Generic Letter
86-10 must be included in the license. Any other current fire protection
license conditions shall be removed. This license condition precludes
changes to the approved Fire Protection Program without prior Commission
approval if those changes would adversely affect the ability to achieve and
maintain safe shutdown conditions in the event of a fire. The shutdown
requirement that applies because of a failure to establish a backup water
supply within 24 hours after a loss of the fire suppression water system is
an example of a Fire Protection Program requirement that would be subject to
the license condition and could be changed in accordance with the standard
license condition. However, the staff believes that any change to the
shutdown requirement would also require the implementation of extraordinary
compensatory measures. Absent such extraordinary measures, changes to this
requirement are likely to have an adverse effect on the ability to achieve
and maintain safe shutdown in the event of a fire and, therefore, could not
be made without prior Commission approval.
Finally, the Administrative Controls section of the TS shall be augmented to
support the Fire Protection Program. This shall be accomplished by additions
to two specifications. First, the Unit Review Group (Onsite Review Group)
shall be given responsibility for the review of the Fire Protection Program
and implementing procedures and the submittal of recommended changes to the
Company Nuclear Review and Audit Group (Offsite or Corporate Review Group).
Second, Fire Protection Program implementation shall be added to the list of
elements for which written procedures shall be established, implemented, and
maintained.
The Emergency Plan and the Security Plan were used as models to determine
the appropriate administrative control for the Fire Protection Program.
These additions will provide administrative controls for the Fire Protection
Program that are equivalent to those for other programs that are implemented
by license condition. The enclosed marked pages of the Westinghouse Standard
Technical
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Specifications (STS) serve as a model for the changes to the administrative
controls. If the plant's TS differ from the STS, additions to the
administrative controls for the Fire Protection Program should be proposed
that are consistent with the administrative controls for the Emergency and
Security Plans.
In Generic Letter 86-10, licensees were reminded of their responsibilities
to report deficiencies in the Fire Protection Program which meet the
criteria of 10 CFR 50.72 and 10 CFR 50.73. Other conditions which represent
deficiencies of this program and are not encompassed by the above reporting
criteria should be evaluated by the licensees to determine appropriate
corrective action.
Summary
The implementation of Generic Letter 86-10 to remove fire protection TS will
entail (1) a revision to the FSAR to incorporate the approved Fire
Protection Program, (2) incorporation into the Fire Protection Program of
the operational conditions, remedial actions, tests, and fire brigade
staffing requirements for fire protection removed from the TS, and (3) a
license amendment. The license amendment will (1) institute the standard
fire protection license condition, (2) remove the fire protection systems
and fire brigade staffing TS, and (3) add administrative controls to support
the Fire Protection Program.
Any questions on this matter should be directed to the NRC Project Manager
for your facility.
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