ML19340D244

Forwards Revised 10CFR50.48 & App R to 10CFR50 Re Five Protection Features of Nuclear Power Plants.Rules Take Effect 810217.Summary Listing of Open Items Re Fire Protection Features of Facility Encl

ML19340D244
Person / Time
Site:	Fort Calhoun
Issue date:	11/24/1980
From:	Eisenhut D Office of Nuclear Reactor Regulation
To:	OMAHA PUBLIC POWER DISTRICT
References
NUDOCS 8012290418
Download: ML19340D244 (21)

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UNITED STATES

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i NUCLEAR REGULATORY COMMISSION j

WASNNGTON. D C. 20555

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TO ALL POWER REACTOR LICENSEES WITH PLANTS 4

LICENSED PRIOR TO JANUARY 1,1979 Q

3 The Cocmission published on November 19,1980 (45 FR 76602), a revisec Section 10 CFR 50.48 and a new Appendix R to 10 CFR 50 regarding fire protection features of nuclear power plants.

The _ revised Section 50.48 and Appendix R will become effective February 17, 1981, wnich is 90 days after publication.

A copy of the Federal Register Notice-is enclosed (Enclosure 1).

The provisions of Appendix R that are applicable to the fire protection features of your facility can be divided into two categories. The firs.

category consists of those provisions of the Appendix that are required to be backfit in their entirety by the new rule, regardless of whether or not alternatives to the specific requirements of these Sections have been previously approved by the NRC staff. These requirements are set forth in Sections III.G, Fire Protection of Safe Shutdown Capability; III-J, Emergency Lighting;-and III-0, Oil Collection Systems for Reactor Coolan Pump. The fire protection features of your facility must satisfy the specific requirements of these three Sections by the dates established by Paragraph 50.48(c), unless an exemption from the Appendix R requirements is approved by the Comission.

You should note the provisions for tolling the time for conpleting the modifications required by these three Sections of Appendix R set forth in Paragraph 50.48(c)(6).

The second category of Appendix R provisions applicable to the fire protection features of your facility consists of requirements concerning the "open" items of previous NRC staff fire protection reviews of your facility. An cocn item is defined as a fire protection feature that has not been previously approved by the NRC staff as satisfying the provisions of Appendix A to Branch Technical Position BTP PCSB 9.5-1, as reflected in a staff fire l

protection safety evaluation report.

The fire protection features of your f acility that are in this category must satisfy the specific recuirements cr Appendix R by the dates established by Paragraph 50.48(c), unless an exemp-tion f rom the Appendix R requirements on those features. is approved by the Cocmi s sion.

i nclosure 2 is a summary listing of the open items concerning the fire e

protection features of your f acility based on a review of our records.

Alsa j

included is our position on the specific requirements that cust be satisfied in order to resolve these open items.

If you have any questions or disagree-l ments with this enclosure, please advise us within 30 days of your receipt of this letter.

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• With regard to the fire protection modifications that have been previously approved by the NRC staff, Paragraph 50.48(d) specifies a new schedule for their completion. This paragraph, when it becomes effective, will supersede the currently affective section of the regulations that temporarily suspends co pletion dates for previously approved fire protection modifications that are given in facility license conoitions (45 FR 71569, October 29,1980).

The Comission expects that all such modifications will be completed in aCCordance with this new schedule, unless an extension has been requested and granted by the Director of the Office of Nuclear Reactor Regulation

[see Paragraph 50.48(d)], or an exemotion has been requested and granted by the Cocmission pursuant to Section 50.12 of the Comission's regulations.

If you have previously requested extensions of dates for completion of modifications that are required by license conditions for your facility which were not approved, and you have determined that these extensions are still necessary and-justifiable, it will be necessary for you to reapply for any such extensions in accordance with the provisions of Paragraph 50.4S(d).

All requests for Commission action resulting from this rule are subject to the schedule of fees specified in 10 CFR 170.21.

If you have any questions concerning the subject matters of this letter, please contact the NP.C Project Manager for your facility.

Sincerely,

'Oxuac m ew f Darrell G. Eisenhut, Director C'

sion of Licensing t'

i of Nuclear Reactor Regulation

Enclosures:

1.

Notice - Fire Protection Rule 2.

Surrmary of Staff Require-ments to Resolve Open Items cc w/ enclosures:

See next page

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Omaha Public Power District CC:

Marilyn A. Tebor LeBoeuf, Land, Leiby & MacRae Alan H. Kirshen, Esq.

1333 New Hampshire Avenue. NW.

Fellman, Ramsey a Kirshen Washington, D. C.

20036 1166 Woodmen Tower Omaha, Nebraska 68102 Mr. Emmett Rogert Chairman, Washington County Board of Supervisors Mr. Charles S. Brinkman Blair, Nebraska 68023 Manager - Wasnington Nuclear Operations Omaha Public Power District C-E Power Syr.tems ATTN: Mt. Spencer Stevens Combustion Engineering, Inc.

Plant Manager 4853 Cordell Ave., Suite A-1 Fort Calhoun Plant Bethesda, Maryland 20014 1623 Harney Stree Omaha, Nebraska 68102 Mr. Dennis Kelley Director, Criteria and Standards Divisic:

USNRC Resident Inspector Office cf Radiation Preg ams (ALM 60)

P.O. Box 68 U.S. E.Trircr. mental Prctection Agency Fort Calhoun, Nebraska 68023 Washington, D.C.

20L60 U. S. Environmental Protection Agency Region VII ATTN:

EIS COORDINATOR 324 East lith Street Kansas City, Missouri 64106 Mr. Frank Gibson W. Dale Clark Library 215 South 15th Street Omaha, Nebraska 68102 Director, Nebraska Department of Environmental Control Post Of fice Box 94877, State House Station Lincoln, Nebraska 68509

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O Part 11 Nuclear Regulatory Commission j L'".".', '!!% "T.K'"""' "*"""'

76602 Federal Register / Vol. 45. No. 225 / Wednesday November 19.1980 / Ruies and Regulatior.s NUCLEAR REGULATORY inaf tae comment twriou snould nave are already set fortn m Genera l Desigr.

COMMISSION been extended.

C:itenon 3 of Appenda A to to CFR The Commission does not agree. 'Ihe Part 50 and in the NRC guidance 10 CFR Part 50 NRC has been developmg fire protection documents These general provisions requirements since 1975. The NRC une rise to a number of disputes over Fire Protection Program for Operating published comprehensive fire protection whether specific methods adequately Nuclear Power Plants guidelmes. Branch Techmcal Positior:

accomphshed the intended goal. The AGENCY: Nuclear Regulators HTP APCSB 9.5-1, and its Appendix A in pr3 posed rule is intended to provide 1976. Licensees have compared their hre sufficient specific guidance to ensure Commission.

pr lection programs against these satisfactory resolution of these issues.

ActiO*c Final rule.

guidelines and have discussed their Trus. reverting to generalized guidance

SUMMARY

The Nuclear Regulatory deviations from these guidelines with would not accomplish the intended Commission is amending its regulations the NRC staff for the past four years purpose of the proposed rule.

to require certain provisions for fire dunng the NRC's fire protection reviews The second issue involved some protection in operating nuclear power of operatmg reactors. A Safety instances in which the specific wording plants. This action is being taken to Evaluation Report and,in most cases, used resulted in unnecessary and upgrade fire protection at nuclear power supplements to the Safety Evaluation unintended restrictions. For example.

plants licensed to operate prior to Report, have been issued for each the proposed rule called for a " fresh January 1.1979< by requirmg resolution operating reactor. These reports water" supply. For firefighting purposes, of certain contested generic issues in describe fire protection alternatives that brackish w ater is satisfactorv and a fire protection safety evaluation reports.

have been proposed by the licensee and

" fresh" water supply is unnecessary.

EFTECTIVE DATE: February 19,1981.

found acceptable by the staff as well as Similarly, the proposed rule called for Note.-The Nuclear Regulatory unresolved fire protection issues an " underground" yard fire main loop.

Commission has submitted this rule to remaining between the staff and the Of ten portions of a fire main loop run the Comptroller Ceneral for review as licensee. Proposed Appendix R provided above ground in and as they enter structures. The Commission had not may be appropriate under the Federal the Commission's requirements for Reports Act, as amended (44 U.S C.

resolving those issues. Thus, it concerns mtended to prohibit running portions of 3512).The date on which the reporting only a limited number of issues derived a fire main loop above ground. Other requirement of this rule becomes from the use of the earlier guides. The sinilar changes are discussed in Section effective, unless advised to the contrary, Commission believes that a 30-day

!!!. " Specific Requirements," of this reflects inclusion of the 45. day period comment period was adequate under preamble.

The third issue relates to imposition of that statute allows for such review (44 these circumstances.

re4uirements n plants with presently U.S.C. 3512(c)(2)).

2. Many licensees questioned the need installed or with existing commitments FOR FURTHER INFORMATION CONTACT:

for backfitting all the requirements of t install fire protection features David P. Notley. Office of Standards Appendiy R.They commented that they previ usly determined by the staff to Development, U.S. Nuclear Regulatory had previously complied with staff fire satisfy the guidance of Appendix A to Commission. Washington, D.C. 20555, protection recommendations in " good BTP APCSB 9.5-1.The Commission phone 301-443-5921 or Robert L faith" and have committed to or Ferguson, Office of Nuclear Reactor completed certain modifications.They f,fc"t n that will f tt d Regulation, U.S. Nuclear Regulatory contend that the staff has properly Appendix R should not be retro $ictively Commission, Washmgton, D.C. 20555.

determmed that these modifications applied to features that have been phone 301-492-7096.

provide at least the level of fire previously approved by the NRC staff as sUPPt.ESSENTARY INFORMATION: On May protection described by the guidance satisfying the provisions of Appendix A 29,19ao, the Nuclear Regulatory contamed m, Appendix A to Branch to BTP APCSB 9.5-1.

Commission published in the Federal Technical Position BTP APCSB 9.5-1.

The NRC staff had intended. in its Register (45 FR 30082) a notice of They also contend that these original proposal for Appendix R. that proposed rulemaking inviting written modifications provide a level of the requirements be applicable only for suggestions or comments on the protection at least equivalent to that the resolution of unresolved disputed proposed rule by June 30,1980. The contained in the proposed rule. They fire protection features. Thus, the staff notice concerned proposed amendments express the concern that the proposed had not intended the provisions of to 10 CFR Part 50, " Domestic Licensing rule was written in such specific Appendix R to require modification of of Prmluction and Utilization Facilities,"

language that fire protection issues that previously approved features.This was which would require certain minimum were thought closed would be reopened not clearly described in the proposed provisions for fire protection in nuclear and new, but not necessarily better, rule as published for comment. In fact, power plants operating prior to January modifications would be required.These the Supplementary Information 1,1979. Fifty-one comment letters were modifications could be accomplished published with the proposed arule received regarding the proposed only by the expenditure of considerable explic tly indicated that "[ajlllicensees amendments. A number of comments engineering. design, and construction will be expected to meet the pertained to specific requirements in the effort and at great undue expense. The requirements of this rule. in its effective proposed Appendix R. and these will be commenters request that the form. including whatever changes result dealt with below. Ilowever, there were requirements in the proposed rule be from public comments."

three substantive contentions which rewritten to specify only the general in determining whether the specific n

were raised by many of the commenters. requirements of what needs to be requirements of Appendix R should be These three comments are summarized accomplished.

imposed on licensees with presently as follows:

These comments raise three related installed or existing commitments to

1. Most commenters stated that the 30 issues. The first relates to the need for install fire protection features previously day c6mment period was too short to specific requirements. The general determined to satisfy Appendix A to permit adequate detailed response and requirements relating to fire protection Branch Technical Position BTP APCSB

t i

Federal Register i Vol. 45. No. 225 / Wednesday, November 19, 1980 / Rules and Regulations 76603 9 5-1. it is important to recogmze that arrangements were accepted in some permitted either an oil collection system 3j Appendix R addresses only a portion of early fire protection reviews. As a result or a fire suppression system.The staff the specific items contained in the more of some separate effects tests, the staff has also accepted an automatic fire comprehensn e document. Branch changed its position on this suppression system as an acceptable Techmcal Position BTP APCSB 951 configuration. and subsequent plans method of fire protection for this 4

and su Appendix A. Appendix A to BTP have been required to provide

' application The Commission has j

APCSB 9 S-1 has been the basic fire additional protection m the form of fire concluded that fire suppression systems protect on guidance used by the staffin barriers or substantial physical do not give adequate protection for fires their fire protection reviews conducted separation for safe shutdown systems.

that may be induced by seismic events.

for all operating plants during the past No credit for such coatmgs as fire The Commission therefore believes that several years. For many plants, barriers is allowM by Section Ill G of previously approved suppression licensees proposed systems and features Appendix R. Appendix A to Branch systems should be replaced with oil that satisfactortly achieved the fire Technica! Position BTP APCSB 9.5.1 and collection systems that can withstand protection criteria set forth in Appendix the proposed Appendix R recognized seismic events.

A to BTP APCSB 9.5-1 and began to that there were plantuique The technical basis on which these promptly implement such features and configurations that required fire three sections are based are further i

systems.

protection features that are not identical discussed in Section 111. " Specific Satisfactory features and systems are to those listed in Secthn Ill.G of Requirements," of this preamble.

already in place and in operation in Appendix R. For these cases, fire

3. Most commenters stated that the many plants There is a reasonable protection features were developed by implementation schedule contained in degree of uniformity among most of the bcensee and described in a fire the proposed rule is impossible to meet 1

these approved features for all facilities hazards analysis. Some of these for any of the operating plants. The since they were reviewed against the arrangements were accepted by the staff commenters further stated that if the j

same criteria of Appendix A to BTP as providing equivalent protection to the implementation schedule in the effective APCSB 9 5-1. In general, the features requirements of Section lit.G to rule is the same as that in the proposed i

previously approved by the NRC staff in Appendix R.

rule, the Commission must be prepared d

6ts reviews of fire protection using the Requirements that account for all of to either shutdown each operating critena of Appendix A to BTP APCSB the parameters that are important to fire nuclear power plant, or process 9.5-1 provide an equivalent level of fire protection and consistent with safety exemption requests.

The commenters then concluded that i

protection safety to that provided under requirements for all plant-unique the specific provisions of Appendix R.

configurations have not been developed. the implementation schedule should be Thus. the further benefit that might be in light of the experience gained in fire rewritten to allow an adequate time provided by requiring that previously protection evaluations over the past four priod for compliance. The proposed rule stated that all fire protection and approsed features be modified to years. the Commission believes that the m difications identified by the staff as conform to the specific language set licensees should reexamine those necessary to satisfy Criterion 3 of forth in Appendix R is outweighed by previously approved configurations of Appendix A to this part, whether the overall benefit of the early fire protection that do not meet the contamed in Appendix R to this part or Implementation of such previously requirements as specified in Section in ther staff fire proiection guidance l

approved features which in many cases Ill.G to Appendix R. Based on this (except for alternat or dedicated are currently being installed.

reexamination the licensee must either P

sa completed l

Nevertheless. as a result of-its meet the requirements of Section !!!.G of f. ""b r n

9, continuing review of fire protection Appendix R or apply for an exemption cause shown, the Commission approves matters, the NRC staff has mdicated to that justifies alternatives by a fire an extension,"(proposed paragraph the Commission that there are hazard analysis. However. based on 50.481.(c)).The Commission went on to requirements in three sections in which present information, the Commission state its intention in the Statement of the protection afforded by Appendix R does not expect to be able to approve Consideration to the rule that "... no l

over and above tht previously exemptions for fire. retardant coatmgs plant would be allowed to continue to accepted. may be deirable. The used as fire barriers.

operate after November 1.1980. or Commission has decided that these The second relates to emergency beyond an extended date approved by j

requirements should be retroactively lighting. Section 111.] of Appendix R calls the Comission. unless all modifications applied to all facilities.This decision is for 8-hour emergency lighting, whereas (except for alternate or dedicated j

not meant to reflect adversely on in some cases less than 8-hour shutdown capability) have been previous hcensee or staff evaluations:

emergency lighting has been accepted as implemented."

rather its purpose is to take fully into satisfying Appendix A to BTP APCSB The Commission has reconsidered the account the increased knowledge and 9.5-1. While an adequate level of safety implementation schedule and has experience developed on fire protection may be provided by less than an 8-hour determined that it should be modified -

matters over the last several years.

supply, an 8-hour system would provide for the following reasons:

The first of these sections is related to added protection and would generally

• After reviewing the comments and il, fire protection features for ensuring that involve only a small cost. The the information developed as a result of systems and associated circuits used to Commission therefore believes that completion of fire reviews over the past 3

a'chieve and maintain safe shutdown are licensees should upgrade the previously 6 months. the staff has informed the i

l free from fire damage. Appendix A to approved facilities to satisfy the 8. hour Commission that the date of November 8

DTP APCSB 9.51 permits a combination lighting requirement of Appendix R.

1,1980. is not possible because the i

of fire. retardant coatings and fire The third relates to protection against effective date of the rule will be after j

detection and supression systems fires in noninerted containments that date.

j without specifymg a physical separation involving reactor coolant pump

. The staff has informed the distance to protection redundant lubrication oil (Section !!!.O of Commission that it would expect systems (Appendix A. D.1(2)), and such Appendix R). The proposed rule virtually alllicensees to request i

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766M Federal Register / Vol. 45. No. 225 / Wednesday. November 19, 1980 / Rules and Regulations exemptions if the new implementation Section III we provide a summary of the automatic water suppression system dates do not provide an appropriate Technical Basis for each requirement, throughout the plant.

period of time for complying with the followed by a summary of the public An ensured minimum volume of water requirements of Appendix R. 'Ite time comments and a statement of the staff's is set aside and dedicated for fire and manpower resources needed by the disposition of those comments.

protection uses to be available at all licensees to prepare such requests and times regardless of other simultaneous Section 1. Intmductwa and Scope water uses in the plant. This water by the staff to formulate recommendations on these requests is This section has been revised as a volume is dedicated for fire service by not warranted from the standpoint of result of comments to include a means of separate storage tanks or timely fire protection improvement.

discussion of the importance of safe separate pump suctions from a large

+ The revised implementation shutdown capability and the distinction body of water. When common tankage schedule provides a careful balance of between requirements for " safety-is employed for fire service needs and these considerations. calling for the related" equipment and equipment other water services. the fire pump remaining fire protection modifications needed for " safe shutdown."

suctions must be at the bottom of the tank and other water supply suctions to be implemented and installed on a Section ll. Cenero/ Requirements phased schedule that is as prompt as must be located at a higher level to can be reascnably achieved.

This section has been substantially ensure that the micimum dedicated The revised schedules distinguish rewritten as a result of comments to water volume is set aside for fire between requirements imposed for the provide a concise summary of general protection needs. Administrative first time on the licensee by Appendix R requirements. The specific requirements controls by themselves, such as locked and those requirements already imposed were consolidated with the appropriate valves to ensure adequate water supply in license conditions or Technical parts of Section Ill" Specific for fire fighting needs, are deemed Specifications issued prior to the Requirements." except that the credit unacceptable at nuclear power plants.

effective date of the rule. For given for 50. foot separation has been Comment Resolution requirements imposed by Appendix R.

dropped.

were bem,commenters stated that we Many including the items "backfit" to all Section ll/. Specific Requirements g too restrictive by stipulating plants. the schedule provides a reasonable time after publication of the The requirements m. this rule are an underground yard fire main loop and rule for completion of required based upon principles long accepted fre A wa,. uoolies. Our intent was modifications. For requirements already within that portion of American industry only that a yard fire main loop be imposed by license conditions providing that has been classified by their furnished. We have deleted the for implemention after November 1.

insurance carriers as ' Improved Risk,,

specification for an underground loop 1980. the Commission has reviewed or" Highly Protected Risk". In each of since special conditions may dictate that these schedules and has found that in these cases. the Commission has part of the loop be above ground or some instances the allotted time for decided that the overallinterest of inside safety-related buildings. Such completion of the required modifications public safety is best served by arrangements are acceptable.

may be excessive. Thus. for fire establishing some conservative level of With regard to the specification for a protection features other than those fire protection and ensuring that level of fresh water supply. the staff was covered by Appendix R. although the compliance exists at all plants. The attempting to avoid potential plant Commission has extended the following is a list of the specific problems that are not associated with compliance dates beyond the November technical bases and resolution of public fire protection. From a fire protection 1.1980. date in the proposed rule the comments for each of the specific standpoint. salt or brackish water is Commission has added a requirement requirements in Appendix R.

acceptable for fire suppression provided that limits the compliance schedule in A. WoterSupplies for Fire the fire protection system is designed existing licenses if such schedules Suppression Systems Technica/ Bosis.

and maintained for salt or brackish extend beyond what we now believe One of the basic fire protection water.The requirement for fresh water should have been a reasonable schedule requirements for a modern industrial supplies is therefore dropped. Other initially. Relief from such limitation may. site in the United States is a separate operational problems unrelated to fire he granted by the Director of Nuclear water distribution system for fire protection that may result from the use Reactor Regulation upon a showing that protection with dual water supp.ies.

of salt or brackish water for fire there is good cause for extending such Duplicate water supplies are required to suppression activities are outside the date and that public health and safety is ensure uninterrupted fire suppression scope of this regulation.

not adversely affected by such capabihty allowing for single failures Several commenters took issue with extension, and periodic maintenance and repair of the requirement for two separate It should also be noted that for vital portions of the systems. Duplicate redundant suctions, stating that some licensees whose license conditions water supplies may consist of separate pla.ts use a single large intake structure imposed a schedule with a compliance auctions for fire pumps from a large on a lake or a river for all water date of November 1.1980. or other date body of water such as lake. river, or requiren.ents. The requirement for prior to the effective date of I 50.48. the pond or from two water storage tanks.

separate intake structures was not Commission has suspended such For nuclear power plants, the intended and the rule has been clarified.

compliance dates by promulgating on distribution system is required to consist Several comments called for deleting October 29.1980, a temporary rule of a loop around the plant with suitable the requirements for dedics.ad tanks or i 50.48 (45 FR 71509). which will be valves for isolating portions of the use of vertical standpipe for other water i

superseded by this rule, system for maintenance or repair services when storage tanks are used for To better understand the nature of the without interrupting the water supply to combined service-water / fire-water uses.

pubhc comments received and the staff's the various fire suppression systems in on the basis that this is overly restrictive resolution of these comments, the the plant. Thus, with dual supplies and a. and other ways are available to ensure following section will consider each loop concept. an adequate water supply. a dedicated supply such as weirs.

section of Appendix R to this part. In can be ensured to each manual or suction location. etc. Two separate but

FeEleral Register / Vol. 45. No. 225 / Wedni. day, November 19, 1980 / Rules and Regulations 76605 related issues are involved here. The hour water supply is considered by a visually indicating er key. operated first is the requirement for dedicated adequate it should also be noted that (curb) vahe." and there was an water storage tanks for fire fightmg this mimmum dedicated water volume is opportunity to comment on this purposes. The suggestion that the based on maximum flow rates. Smce document.

requirement for dedicated tanks be most fires are controlled and D.ManualFire Suppression Techmca/

deleted was rejected for the reasons extinguished with much smaller flaw Basis. Considerable reliance is placed stated in the preceding Technical Basis.

rates this requirement reahstically on automatic fire suppression systems The other pomt deals with ensuring represents a dedicated water volume far throughout a nuclear power plant.

minimum water storage capacity for fire in excess of two hours.

However, manual fire fighting activities suppression activities when storage B. Sectional /soktion Volves.

often can control and extinguish slowly tanks are used for combined service-C.HydrantIso/ation Va/ves developing fires before an automatic fire water / fire-water uses. The term Technica/ Basis. These two suppression system is actuated. In

" vertical standpipe for other water requirements are similar and can be addition, fires that are controlled or service" simply means that the suction treated together. Proper valving is extinguished by automatic systems for other water uses in common storage required to isolate portions of the water require a certain amount of manual tanks will be located sufficiently high to distribution system for maintenance or response. Also, some areas of the plant ensure the minimum water volume repair without intetrupting the water do not warrant the installation of needs for fire suppression activities,if supply to manual or automatic fire automatic fire suppression systems.

the commenters were assuming that suppression systems inside the plant.

Manual response is the only fire

" vertical standpipe" referred only to Valves are similarly required to permit suppression available for these aress:

pipes inside the tank, this is not the isolation of outside yard hydrants from thus, it is important that manual fire case. In fact a standpipe exterior to the the water distribution system for fighting capability be present in all otorage tank is more desirable since any maintenence or repair without areas of the plant, and that standpipe leakage would b e immediately evident.

mterrupting water supply to fire and hose stations be located throughout On an internal standpipe a leak in the suppression systems inside the plant.

the plant. The standpips and hose pipe could actually allow depletion of p isually mdicating valves such as post stations are to be located so that at least the water otherwise to be reserved for indicator valves are preferred so that one effective hose stream can be fire uses. The rule has been clarified to the position of the valve can be readily brought to bear at any location in the allow physical alternatives for water determmed. However, key-operated plant containing or presenting a hazard cupply dedication but to preclude valves (commonly known as curb to structures, systems, or components exclusive use of administrative controls valves) are acceptable for these important to safety.They are to be purposes where plant-specific for this purpose.

supplied from the fire water supply co osw an ruse jg fyg,-Comment system except for those inside Some commenters objected to the requirement that other water systems Resolution. Many commenters stated containment, which may be connected used as a backup water supply for fire that the requirement for " approved to other reliable water supphes if a protection should be permanently visually indicating" sectional cor trol separate penetration into containment cannot be made for fire water service connected to the fire main system and valves was overly restrictive, needs.

ouggested that it would be sufficient t unnecessary, and not specific with provide a water supply capable of being respect to who should give the approval. Comment Resolution connected to the fire main system within The Commission has accepted this suggestion: the rule now requires that Several commenters suggested adding ten minutes of the loss of normal water supply or pumps. The rule does not sectional control valves shall be a sentence reading " Standpipe and hose address backup water supplies. The provided to isolate portions of the fire stations are not required if sufficient requirement means that,if another main for maintenance or repair without justification can be provided that water system is used as one of the shutting off the entire system. Post adequate fire protection features have redundant water supplies, it must satisfy indicator or key-operated valves are been provided to account for a given fire allof the requirements of the fire mentioned as two examples of area." This suggestion was rejected. The protection water supplies. Additional acceptable valves.

staff has taken the position that the backup supplies need not meet these C. Hydrant Block Valves-Comment minimum requirements are that at least requirements.

Resolution. A number of commenters one effective hose stream that will be One commenter asked why only a made suggestions for rewording this able to reach any location that contains two-hour water supply is required when section. This section has been clarified or could present an exposure fire hazard the Browns Ferry Fire lasted well over to state the requirement for capability to to the safety-related equipment. The two hours. All of the investigations of isolate hydrants from the fire main Commission concluded that no analyses the Browns Ferry Fire clearly show that without disrupting the water supply to can identify hazards so carefully that if water had been used immediately, the automatic or manual fire suppression this minimum requirement can be fire would have been extinguished much sy stems in any arra containing or further reduced.

earlier. Indeed once the manual fire presenting a fire hazard to safety-related E. Hydrostatic Hose Test Technical fighting activities were started with the or safe shutdown erioment.

Basis. Fire hoses should be us2 of only one fire hose stream, the fire One commenter suggsted that this hydrostatically tested periodically to waa extinguished within one-half hour.

requirement be di apped in its entirety ensure that they will not rupture during The staff would find unacceptable any since it "Is a new t equirement which has use.The requirement for c minimum test condition in which a postulated fire that not been subjected to the peer review pressure of 300 psi comes from NFPA could threaten safe shutdown capability process." This suggestion was rejected No.196 (National Fire Protection could not be controlled.end extinguished on the basis that Appendix A to BTP Association Standard No.194-within two hours with any combination APCSB 9.5-1 contains the following Standard for Fire Hose), a nationally of manual and automatic fire sentence: "The lateral to each hydrant recognized consensus standard.This suppression activities. Therefore. a two-from the yard main should be controlled standard contains other guidance for the

~6606 Fer4ral Register Li n No. 225 ' Wednesday. h ember 19 lono Russ and Regulatmns

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ht moder i mdu'g Technicci i F.r R a;& I-n

' w at < d e s ' 6re how w

-t sy ster" m.d! m h amas whauid be stnal plants ir dustra c t d e etu!

retained. The fue W,rds anah sis me la s caH f r a u'pa ate suppresion system with repisi ement cost s alues G

m ? hew.btw, but this wouhl be m addition to the fire awroar hms those of a modern nuclear Man) wmmrnters po nie d...t the detectmn 9 ster pw cred We( tm generatmg station base erroneoo* usaee of the tern un ic e G.rmteamn. Sam m rJ,mv a fu!i.fime fui!> equipped hre pressure r.dher than "opeanne Copabiha Th h <. / Bam T he der irtment. mcludmg motonzed hre pressure m this requirement. The obb ctne for the protection of safe apparatus. I ecause of the reduced miended meaning for this requirement is shutdown capabdih is to ensure that at seurit> of fire hazards m a nuclear that.dl hoses would be tested at a teast one means of achies mg and generatmg station as compared to a pressure greater than the maumum mamtaining sale shutdown conditwns manufacturms plant, the Commission pressure found m the fire protection wd1 remain atadable durme and after behews that it is not necessarv to water dlstnbution systems The correct an3 postulated fire m the plant. Because mandate a f ull> staffed hre department, termmmoc) is operatmg pressare the it is not possible to predict the specihc However. manual fire response rule n is be(n so changed. In add; tion-conditions under which hres may occur cap ibihty is required at a nuclear plant the staff added a specific mmimum test and propagate. the design basis -

and a properly eqmpped and fully pressqre requirement of 100 pu to meet protectn.e features are specihed rather tramed fire brigade will satisfy this the N1 PA standard than the design basis bre.1hree need 't he Commission has determined One commenter also pomted out that different means for protectmg the safe that a brigade of five persons constitutes hoses should be mspected for mildew.

shutdown capabihty outside of the nummum size sufficient to perform rot. cuts or other damage Although this contamment are aueptable The first the actions that may be reqwred by the means is separation of redundant safe Wade during the hre and to provide is a tahd comment, it is not an unresob ed issue with any licensee so it shutdow n trains and assouated circmts unne margm for unanticipated esents '

need not be emered by this rule. In bv means of 3. hour fire rated barners.

Smularh. the tra nmg requirements addition. such mspections are already The secoed means is a combmation of hsted are considered the minimum bemg performed in accordance with the se aration of redundat.t safe shutdown needed to ensure that the fire brigade wd! he able to function effectively plant s T echmcal Specihcattons y

g V ktomatw h, re Detectwn 7h hmcal d" ? ro

."r g

Hmis. lhe requirement that automatic

" ("[

I uired emergency d

fire dett ( tion systems he installed m all breathmg apparatus without specifying dw ha & M wm' areas that contain safe shutdown or the number of such pieces of apparatus.

which may be used only when The rule has been modified to sPecif -

safety.related systems or components redundant t*ains and associated circuits 3

the personnel for whom such apparatus fgigows generay accepte,d fire ne p ted by m fM or more of dm protection practice. Installation of such is to l>e protided and to specify reserve fire detection capability is mdependent spam reqmres automatic fire suppression and detection systems in it Are Bngade-Comment of any requirements for automatic or the area. An alternatn e or Jedicated manual fire suppression capabihtv in an g gg g safe shutdown capabihty mdependent of changmg this req'uirement to a simple area.The purpose of these detectmn systems is to give early warnmg of fire the hre area is required if fire protection statement that a trained and equipped, conditions in an area so that the fire for safe shutdown capabihty cannot be nom nal sire. site fire brigade of five provided as authned above. For cables persons be provided on each shift unless brigade can initiate prompt actions to mmimize fire damage within the plant. and equipment needed for safe a lesser number is justified. This shutdown located inside of noninerted nmommended cyiange was rejected by Comment Resolutwo contamments a lesser degree of fire the Commission for the reasons stated Meny commenters suggested that the protection is permitted because in th Tehal Bs w ords " automatic hre detection transient exposure fires are less likely Some commenters objected to the capabiht)" he substituted for inside contamment during plant Msion of the shift supervisor from ' automatic fire detection systems" on operation. Section Ill.M. " Fire Barriers. the fire brigade. The commenters felt the basis that, as worded. the discusses the technical basis for the 3 that the shift supervisor should go to the requirements are too limiting. They hour burner. and Section !!LL hre and prodde the beneht of his stated that an automatic spnnkler " Alternative and Dedicated Shutdown expertise and authonty. The rule would system with appropriate alarm t heck Capabdity." discusses the technicai not present this. Ilowever, the shift vahes and central alarm features basis for safe shutdown capainhty-superusor may hu e to go elsewhere proudes.o.ceptabb detectmn/alarmmg Comment Re3olanon during the course of a fire that adversely capabihty. Ses eral c ommenters claimed affetts plant operation.The fire brigade that a separate detection sy stem is not Many commenters suggested that the leader must stay with the fire brigade l needed in areas c m ered by sprinkler hrst paragraph be changed shghtly and and be assigned no other setems equipped with fusible hnk the rest of this section deleted Th" respons;bihties durmg a hre emergencv. sprinkler heads. A fusib!c hnk has a basis for ti.eir contention is that the rufe therefore. the shif t superusor must be~ time delay before it actuates. Iloweser. should state simply the regmrement to excluded from membership on the hre more importantly a smoldering protect cables or equipment of systems brigade. locabred hre that could do damage may necessary for safe shutdown of the phmt L Are Bngade Trainmg-Comment not generate enough heat to melt the and leave specific implementation Resolatwn. Many commenters have fusible hnk While we do not disagree details in some other type of document. ~ that the alarm from an automatic fire We have modified this section by m.m dma.a twu uc mir, suppressmn sy stem serves as removmg the listing of considerations, M*n of M nem bre Dnwe %h W. M W " 1" " P" "" "d* E

• f"* D" notihcatmn that a hre exists. we deletmg Table 1. and reusing the conchided that the mimmum wording to proside clarification.

[(M ((j[y@"((g$c requirement for a separate fire detection 11 Are Bngade. m

Federal Register / Vol. 45. No,225 / Wednesday. November 19, 1980 / Rules and Regulations 76607 st.tv ' e NIE ned unnecessary detal. fire emergeria and operators.nsoneJ modiin.ations to pros de abernatis e e nehmg cut spec fic requirements for in safe plant snutdown shouW not also shutdown systems are extensive, en ciasecom mstruction. fire fightmg have to be concerned with lightmg m the dedicated sys:em that is essentially a prm % e and fue drills. Some arer The small cost differential mimmum capabibty safe shutdown train commenters fe:t that these requirements between 2 hour supply and the and is independent of those already were more detailed than an> thing the substantial additional protection existing may be provided. This mmimum Comm:ssion has published with regard afforded by the 8. hour supply does not t..pabibty is required to maintain the to operater traimng The Commission warrant reducing this requirement. The process sariabies within those values here pomts out that most of the Commission has dscided to require an 8 predicted for a loss of offsite power.The ins est:gations of the TMI accident hour battery power supply in all areas case ofloss of offsite power is assumed identified inadequately trained needed for operation of safe shutdown because fires in certain circumstances operators as an important factor and equipment and in access and egress (e.g.. electrical distnbution systems) that work is now being done in this routes. could cause or be related to such a loss. aret The fact is not that the training K. Administrative Controls Technical Fire damage to cold shutdown capability requirements spelled out here for the fire Basis. The fire protection program uses is limited to damage that cen be bngade members are excessive when administrative controls for fire repaired within 2 hours to provide a compared to training requirements for prevention and prefire planning.The margin in achieving cold shutdow n reactor opera

• ors, but that fire brigade items listed in this section are generally conditions. Consideration is given to training is further along in development, accepted within the fire protection associated circuits because most plants and traming parameters that are community as minimum requirements were not designed with this concept in essential to a comprehensive program for an effective administration of the fire mind. Should either the alternative or have been identified.

protection program. Controls are placed dedicated capability be required to J. Emergency Lighting Technical on the storage and use of combustible function because of a fire. it must not be Basis Emergency lighting is required in materials to reduce the fire loading in disabled by fire damage to associated all nuclear power plants. Battery. safety-relate;d areas and on ignition circuits. Also, this capability does not powered lights with capacities of 1% to sources to avoid careless operations. have to meet the single failure critenon 2 hours is usually sufficient for Procedures are used to control actions because it is only one of severallevels emergency egress. However the postfire to be taken by individuals who discover of defense. Seismic Category I criteria is emergency lighting requirements in a a fire and by the fire brigade for the not imposed because fires that would nuclear power plant are of a different development of preplanned fire fighting require the installation of alternative or kind. The need is for lighting that aids strategies and actual fire fighting dedicated shutdown capability are not the access to equipment and techniques. seismically induced. omment Reso vuon Comment Resoludon op ra ed b a t pers n 1 o ff ct safeplant shutdown during plant Many commenters stated that this Many of the commenters stated that emergencies Because such actisities requirement was much too detailed for a this requirement exceeded the scope of may extend over a considerable period regulation. Some stated that the Appendix R by defining alternative of time both during and after the fire,it requirements should apply only to those shutdown requirements. They stated is prudent to provide 8-hour battery areas having safe shutdown equipment. that the time requirements are excessive emergency hghting capability to allow Other commenters stated that a simple and si ould be dropped. They also sufficient time for normal lighting to be statement that administrative conter d that this regulation does not restored with a margin for unanticipated procedures should be established to take hto account the many plant events. control the various fire hazards rev.ews being conducted under the throughout the plant was sufficient. and Systematic Evaluation Program (SEP). Comment Resolution that the details could be spelled out in a It is generally understood that cold Many commenters stated that the regulatory guide or some other similar shutdown is the ultimate safe shutdown requirement for emergency lighting is document. condition and that. for each fire area. overly rastrictive in three specifics: first. Minor changes have been made in the different means may be used and may that emergency lighting is unnecessary wording of this requirement for be necessary to achieve cold shutdown. in many of the designated arecs; second, clarification. Because a fire 'n certain areas at some that the requirement for sealed beam or L Alternatire andDedicated plants would have the capability of fluorescent units is overly restrictive: Shutdown Capability. disabling systems required to achieve third, that the requirement for individual Technical Basis. In some locations both hot and cold shutdown. it is 8-hour battery power supply is (such as the cable spreading room) necessary to specify the minimum excessive. Three commenters within operating nuclear power plants. it capability and time requirement for each recommended a 2-hour battery power is not always possible or practicable to condition necessary to achieve safe supply; five commenters recommended a protect redundant safe shutdown shutdown. We agree that evaluations plant. specific power supply; and one systems against adverse effects of fire or being made under the Systematic commenter recommended that there be fire suppres. ion activities only through Evaluation Program (SEP) may also call no permanent installation. the use of fire protection features for alternative or dedicated shutdown e These suggest ons have been accepted because the redundant safe shutdown capability for reasons other than fire in part. Lightmg units with 8-hour systems in a given fire area are too close protection. For example, seismic. battery supplies are to be provided in all to each other. Alternative shutdown flooding. or emergency core cooling areas needed for operation of safe capability has usually been required to - requirements resulting from the SEP may shutdown equipment and in access and be independent of the control room. require additional modifications. Each egress routes thereto. The reasoning cable spreading room, switchgear rooms licensee should be aware of the status of behmd the requirement for an 8-hour and cable riser areas because redundant the SEp so that the requirements battery power supply is that there can systems in these areas are not resulting from SEP can be effectively be a great deal of other activity during a adequately separated. When plant integrated with those relating to fire

~6608 Federal Register i M 45 No. 225 / Wednesda h ember 19.120 / Rules and Regulations protu tom m the extent possib'e required to ensure safe shutdown the national conse. sus standard use,f Ilown er. the Commission has decided capabiW ~Ihe uw of a 1-hour barner in for testmg and rating these cable that the modificatmns required to conjunction with automatic fire penetration seals. Smce the cables complete the fire protectmn program suppression and detection capabibty for conduct the heat through the barner should not be deferred untd the SEp each redundant tram of safe shutdown and smce the cable insulation is review is completed. equipment is based on the following combustible. the acceptance cntena of h1 Fire Barners. considerations. Automatic suppression the ASTN1 Standard E-119 relating to Techmra/ Hons. The best fire is required to ensure prempt, effective temperature on the unexposed side mast protection for redundant trams of safe application of suppressant to a fire that be appropriately modified. shutdown systems is separation by could endanger safe shutdown gyggggf g,ygfyf,y unpierced fire barners-walls and capability.The activation of an ceibng-floor assemblies. Because these automatic fire detection or suppression Some commenters suggested that this barners are passive fire protection system does not occur until sufficient entire section be deleted and replaced features. they are inherently reliable smoke or heat has been developed by with the following two sentences: provided they are properly installed and the fire. Therefore, the Commission is " Penetration seals shall provide the maintained. Fire barriers have been requiring a 1-hour barrier to ensure that equivalent protection which is required used successfully for many years to fire damage wdl be limited to one train of the fire barrier. Evaluation of the subdivide large potential fire losses into until the fire is extinguished. penetration seals based upon a design smaller. more acceptable risks. Even fire These requirements have now been resiew and relevant test data or barriers with openings have successfully incorporated in Section lil G. " Fire qualification tests may be made." The interrupted the progress of many fires Protection of Safets Functions.- com'nenters felt that sufficient test data provided the openings were properly are available to permit evaluation of C,omment Resdutwn protected by fire doors or other design requirements without full. scale acceptable means. Sescral commenters made a number mockup testing and that many of the Fire barriers are " rated" for fire of suggestions of an editonal nature, items spelled out in the regulation. such resistance by being esposed to a One suggestion was to add "or unless as the water hose stream test, were too " standard test fire". This standard test other fire protection features have been detailed and did not belong in the fire is defined by the American Society provided to ensure equivalent regulation. The Commission has for Testing and hiaterials in ASTN E. protection" in the first paragraph, where reconsidered this issue and revised the 119. " Standard for Fire Resistance of three-hour rated fire barners were rule to (a) require the use of Budding hiaterials." Fire barriers are stipulated unless a lower rating was noncombustible materials only in the con monly rated as havmg a fire justified by the fire hazards analysis. construction of fire barrier penetration resistance of from 1 to a hours. Niost The Commission feels that this adds seals. (b) require fire barrier penetration " Improved Risk" or "llighly Protected nothing in the way of clanfication and seals to be qualified by test; and (c) Risk"(as classified by insurance the suggestion was not adopted. The require such tests to satisfy certain carriers) industnal properties in the second paragraph requires that acceptance criteria. United States require fire barriers to structural steel forming a part of or O. Fire Doors. have a resistance rating of 2 to 4 hours. supporting any fire barner have a fire Technica/ Basis. Door openings in fire While a nuclear puwer plant has a resistance equivalent to that required of walls constitute another breach that low fire load. the potential the barrier. An example was given of must be protected. Fire doors that have consequences of fire are serious. metal lath and plaster covering as being been tested and rated for certain fire Therefore, the Commission has selected one means of providing equivalent exposures are installed to protect these 3 hours has been as an acceptable protection. Several commenters stated openings. Fire doors frequently fail to minimum fire resistance rating for fire that they thought this was too narrow protect the openings in which they are barriers separating redundant trains for and would be interpreted by some installed because they are not fully safe shutdown systems. This will give people as the only acceptable method closed. Various methods are available to ample time for automatic and manual permitted. Since the example seemed to licensees to ensure that fire doors are in fire suppression activities to control any be confusing, a decision has been made proper operating condition and that they potential fire and for safe shutdown to eliminate it. Other comments to the will be closed during a fire. These activities to properly control the reactor, effect that the requirement was options are listed in Appendix R. hiany operating plants. or plants that excessively restnctive with regard to C####"# N#8#I"N " are a'iready budt but that are not yet fire barrier penetrations. including fire operatmg, hase both trains of safe doors and their associated frames and hiany commenters stated that this shutdown equipment located in close hard.vare, and ventdation systems have requirement is too detailed and should proximity and a single fire could been acted upon by the staff and the be deleted. hiinor editorial changes have damage or destroy the functional requirement, as it had affected these been made in order to more clearly state capability of both redundant trair.s. If items was deleted. the requirements. specific plant conditions preclude the N. Fire Barrier Cable Penetration Seal P. Reactor Coolant Pump I.ubrication installation of a 3-hour fire barrier to Qualification.

System, separate the redundant trains, a 1. hour TechnicalBasis. Unpierced fire TechnicalBasis. Each reactor coolant fire barrier and automatic fire barriers offer the best protection for pump motor assembly typically contains suppression system for each redundant

• eparating redundant trains of safety-140 to 220 gallons of lube oil. Oil leaking train wdl be considered the equivalent related or sde shutdown equipment.

from some portions of the lube oil of 3-hour barrier. Ilowever these barriers must be pierced system may come in contact with If the 1. hour fire barrier and automatic for both control and power cables. surfaces that are hot enough to ignite the fire suppression for each redundant These penetrations must be sealed to oil. The resulting fire could be large. and train cannot be provided because of achieve a degree of fire resistance access to the fire would be delayed plant specific conditions, alternative or equivalent to that required of the barrier because of the time required to enter the dedicated shutdowns capability will be that is pierced. ASTM Standard E-119 is containment. Containent air temperature

= ~ ,=. a. x_ n i i i Federal Register / Vol. 45. No. 225 / Wednesday, Nosember 19. 1980 / Rules and Regulations 76609 i would increase, severe localized pump oil collection system is covered by Capabihty J1 In the fare hazards analysis 4 environments would develop in the area paragraph C.2 because its function is for a plant. the equipment rehed upon to of the fire, and a large amount of smoke required to protect safety-related perform both functions must be would be generated. These coaltions systems rather than to perform a safety identified for each fire area. It follows could affect operabihty of safety related function. Because the failure of the oil that any associated non-safety circuits equipment inside containment. collection system for a seismically in the fire area that could adversely i Therefore, an oil collection system is induced oil fire should not prevent a affect the identified shutdown necessary to confine any oil discharged safety-related system from performing equipment by feedmg back potentially due to leadkage or failure of the its safety function (Regulatory Guide disabling conditions (e.g. hot shorts or lubrication system and to prevent it 1.29. " Seismic Design Classification.' shorts to ground] to the power supplies i from becoming a fire hazard by draining paragraph C.2), the oil collection system or control circuits of that equipment i it to a safe location. These occurrences should be designed, engineered and must also be evaluated. Of course such could be random or could be seismically installed so that its failure will not lead disabling conditions must be prevented j induced because the existing lube oil to a fire affecting safety-related system piping and oil collection systems equipment as a result of an earthquake. to provide assurance that the identified may not be designed to withstand a The proposed rule permitted tw safe shutdown equipment will function design basis seimic event. alternatives-an oil collection system or as designed. These requirements have now been incorporated in Section Ill.L Appendix A to BTP APCSB 9.5-1 the he' e of t e " Alternative and Dedicated Shutdown s" "P hd states that for operating plants, postulated fires or fire protection suppression system because Capability? system failures need not be considered unacceptable damage may result to the Comment Resolution concurrent with other plant accidents or safety-related systems from the burning the most severe natural phenomena. of oil before the suppression system is Many commenters stated that this t actuated and because the fire water requirement should be deleted because The basis for that statement is two fold. First. nuclear power plants are massive supply system is not designed to many older plant designs did not withstand seismic events. In addition, consider asaoc. lated circuits and this is, structures, and essential services are designed to withstand earthquakes and these pumps are located within the therefore, a new design requirement. biological shield inside containment. be commenters felt that the analysis other natural phenomena. Second. the history of many fires associated with ther. fore, timely fire brigade action that will be required to satisfy this would be difficult if the suppression requirement will be both long and recent earthquakes have been evaluated.These evaluations showed system malfunctions. Further, if the complicated and the requirement should suppression system becomes Inoperable therefore be deleted. that such fires usually are due to failure during operation, a fire watch or patrol The Commission rejected these of { pjgor ta mjb e gasses cannot enter the area during operation. suggestions for the following reasons. of distribution systems or gasoline storage Comment Resolution

1. Virtually all of the fire protection-and/or dispensing stations. Where such A number of commenters suggested modifications made to date have been potential fire hazards exist in nuclear that this section is too detailed and required to correct deficiencies that -

power plants (e.g., hydrogen for should be substantially modified.This resulted from lack of consideration of j generator cooling. or oil fuel for the requirement was changed to delete the certain specific items during initial emergency diesel generator or station option of protecting the reactor coolant design and construction. cpace heating boilers) they are designed pump lubrication system with an 2.The Browns Ferry fire showed the and installed to withstand the damaging automatic fire suppression system. We necessity of divisional separation of the effects of various natural phenomena. have modified the rule to indicate that associated circuit of the control cables and other special fire protection features the requirement that the oil collection to prevent the disabling of safety - are provided as necessary. However. system be designed to provide systems by a single fire. Tnis has been General De, sign Criterion 2 Design Bases reasonable assurance that it will discussed with licensees during for Protection Against Natural withstand the Safe Shutdown evaluations of alternative and dedicated Phenomena requires that structures. Earthquake can be met by satisfying shutdown capability and is necessary to gystems, and components important to paragraph C.2. of Regulatory Guide 1.29. ensure that safe shutdown systems will safety be designed to withstand the " Seismic Design Classification." as be able to_ function properly in the event effects of earthquakes without loss of described above. of fire ~ i capability to perform their safety Q. AssociatedCircuits. function. Regulatory Guide 1.29. Technical Bosis. When co isidering 3.The staff considers incomplete any " Seismic Design Classification." the consequences of a fire in a given fire fire hazard analysis that does not describes an acceptable method for area during the evaluation of safe c nsider the effects of fire damage to circuits that are associated with safe 4 identifying and classifying those shutdown capabilities of a plant, the i features oflight. water-cooled nuclear staff must be able to conclude that one shutdown systems. power plants that should be designed to train of equipment that can be used As irdicated above, as a result of tne withstand the effects of the Safe immediately to bring the reactor to a hot comments received on this issue. it is Shutdown Earthquake. In this guide, shutdown condition remains unaffected unclear that associated circuits have in paragraph C.1 applies to systems that by that fire.The staff must also be able fact been adequately considered by - are required to remain functional to to conclude that damage to one train of licensees in their reviews using the j ensure heat removal capability; equipment used for achieving cold guidance of Appendix A to BTP APCSB paragraph C.2 applies to systems that do - shutdown will be limited so that the 9.5-1.To ensure that the associated not have to remain frunctional for that equipment can be returned to an circuits are considered, all operating purpose, but whose failure could reduce operable condition within 72 hours. (See nuclear power plants will be required to the functioning of those systems covered Technical Basis for Section Ill.G. meet the requirements of Section !!I.G of by paragraph C.1. The reactor coolant " Protection of Safe Shutdown Appendix R. 4 t- . ~. -,.---._.-.-.---._,...-.--e.,, ---,-.-.,-.--~--,----,,.,.m ,--mm..--_-,~y

76fi10 Federal Register / Pot 45. No. 225 / Wednesday November 19 1%0 / Rules and Regulations G ,-lC n Rew ' h shutdown < apabihn The Commis non comments recen ed on the proposed Nend mmenters contended that d n n t am We t;ehese that the regulations. other commenters f am= m reditums mandate that Commismon s os enos fue protectmn demonmated a thorough understandmg an mheda aN s hearma be condut ted program insolving extensne plant-of the proposed requiremer;ts. pnor to a fmal Jeasma. One commenter specific fire protection modifw ations Pursuant to the Atomjc Energy Act of that are based on guidance set forth m 1954. as amended. the Energy I Acad the nplation an " order ' withm Branch Technical Position BTP APCSD Reorgamzation Act of 1974 as amended. 9 5-1 and as Appenda A and the and Set tmns 552 and 553 of Title 5 of the \\t t {\\ pal and awrted ihmt 10 (TR 2 2f 4 of the sprofic reqmments of Appenh R to UndM States C, ode. notice is hereby Comnussmn s regulatmns " Order for resch e disputed sues provide given that the following amendments to mbf u anon of I.icense. apphes to this adequate fire protedmn lule 10 Chapter I. Code of Federal g One commenter stated that the Regulations. Part 50, are published as a ru!em.done proceedmg amb.guity of the proposed resulation document subtect to codification. The Comrmssien disagrees with these .umn + ns A ruh ~ is dehned in the with recard to criticai items requires 1 A new 150 48 is added to read as that it be renotn ed The commenter follows lhe w hole or a part of an Tp \\ m : ,4 W e .s att ment of gens nd or f 50.48 Fire Protection. g preposed Appendix R as examples of

p. r t u m.ar app!n abiiq am!yture eggect They were Sntion 111 C.

(al Each operatmg nuclear power designed to impkment or Sectmn Ill.N. and Section Ill.Q. We base plant shall have a fire protection plan 551f4Uprescrd t he agency action questioned ' to he first example. the to this part. This fire protection plan law or pohcy,, 15USC wed these examples that satisfies Cnterion 3 of Appendix A I here m sara one that treats simihrly commenter stated that tne first shall describe the oserall fire protection situated la enwes equally and that M m G a nh program for the faciht), identify the prev r: es f uture conduct or a ternative shutdown capabihts as an s armus positions withm the licensee's reymre:.cnts 1 or those hcensees who o tional protectn e feature and that orgamzatmn that are responsibile for the haw wt already pronded an equivalent En h wd program. state the authorities that are leve!,f hre protet tmn. certam specifa: alternatne shutdown ta;mtuhty as a delegated to each of these positions to f re proiettinn features are reymred mmimum fire protection feature. We do imp!ement those responsibihties, and \\ ar.ous of these reqmrrments would a ree with this statement. The first outhne the plans for fire protection, fire apply to approumatch 40 f acihties The aguph of Section !!!.G identifies detection and suppression capability, commenter s characterization of the rule ahernatne shutdown capability as one and hmitation of fire darnage. The plan as an order ahmg with the assertmn on in a combmation of fire' shall also describe specific features that to CFR 2 m4 mandates a hearme protection features for a spccifa fac necessary to implement the program before the rule becomes fmal is area paragraph Ill.G.3 mdicates w hen described above, such as administrative mcorrec t On as face. that regulation this option should he urd. controls and personnel requirements for (wha h does grant a hearing rightl In reference to the second example. fire prevention and manual fire apphes enly to Commission orders that the commenter stated that Secuon Ill.N suppression activities, automatic and mod:fv a hrense.211 does not apply to Ws a pessure differential across manually operated fire detection and requiremi nts promulgated through a the test specimen dunng the testing of suppression systems, and the means to rulemakmg action conducted in fire barrier penetration seals but fails to hmit fire damage to structures, systems, accordaipe with the requirements of define the pressure differential. This or components important to safety so appbcabm law-comment is mcorrect. The pressure that the capability to safely shut down Smeral commenters contended that differential called for by the proposed the plant is ensur'ed.5 the enurimmental impact hed not been provision was the rnaximum pressure (b) Appendix R to this part estabhshes adequaten addressed One commenter, differential that the barrier would fire protec tion features required to atmg the requirements in Section III.A experience m the specific phnt satisfy Criterion 3 of Appendix A to this of Appenda R for two water supphes installatwn. In any esent. the part with respect to certain generic and two separate redundant sections as requirement for pr' essure differential issues for nuclear power plants hcensed examples of reqmrements ins olvmg durmg such testmg has been deleted to operate prior to January L 1979 environment.d issues. contended that smce only noncombustible material is Except for the requirements of Sections the Comrmssmn rehed upon its staff's now being used for such scalt ill.G. ill J. and 111 O. the provismns of " unsupported deternunation that. In reference to the third example. the Appenda R to this part shall not be pursa.mt to in CFR } 515!dh an commenter stated that Set tion Ill.Q is appbcable to nuclear power plants ens ironn.en+.d m: pact statement. totally lackmg in defmition. We do not hcensed to operate pnor to January 1 appraw or nentue declaration is not agree. Footnote 6 references Regulator) 1979. to the extent that fire protection reqmred ~ The Commissa a has Guide 13 and IEEE Std 34-19~4 The features proposed or implemented by < onsidered Section 111 A and has further latter document is a commonly used conudend the remaming requirements mdustry standard that defines ~. nm r,, gn,,,.nmn guain, c for nua,2r p,mer t.f Appendn R and remams conunced assocwted circuits and proudes sus is ut+nea n i% vc amu nena that the revulanons are not substantive guidance for ensuring that such circuits Hret *u at Powma ^ Mar > h" and are msmmhc ant from the standpomt do not compromise the independen:.e of '"""""

• m l"
• h l' IP ^ 'CSD * '1 -

of couronm.mnd unpact. the shutdown ciremts they are '""*""""""'""""'""'P^*Wo. P6re. W new r6nts am keted af ter Niy 1. ( Me con.raenter sugested that all associated with. as a % wo piants be reqmred to mstall dedmated Based on the abose examples and our . Aruna A m irrP AltSB m "Gmdchne, tesiew of the other provisions of the W bre Winnon for % dear Po n PWnis ', u. u.n , s a.. g : a.4 s ui! ca m proposed rule, we do not behese that D"' 6 *'"o P"' '" l* 1 #" " for PL a " ' h * "' ma pw 9. < u i s e o ; N et e a w,o n e rWe as pmPm d was ambiguous so < neunmn bew",'M i era e,ted Awi.t 23 e ,, n - o a %a u - w a u ise c r' m3vrrymm.cmsM %+vna as to R4ude NR inE N M.d. W6 la more iw ( IF 2 Zsq u n Japhes ogpMd ) should be noted that. based on other A% - % 4

- - _ - = - _ - = - - - _ - __-.__ t i Federal Register / Vol. 45. No. 225 / Wednesday. November 19. 1980 / Rules and Regulations 76611 l the bcensee hn e been accepted by the after the effective date of this rection determines. upon a showmc by the NRC staff as satisfymg the provisions of and Appendix R to this part: licensee, that there is good cause for Appendix A to 11 ranch Technical (i) the first refueling outage; extending such date and that the public Positmn DTP APCSB 9.5-1* reflected in (ii) another planned outage that lasts health and safety is not adversely staff fire protection safety evaluation for at least 60 days: or affected by such coension Extensions reports issued prior to the effective date (iii) an unplanned outage that lasts for of such date shall not exceed the dates of this rule, or to the extent that fire at least 120 days. determined by paragraphs (c)(1) through protection features were accepted by (4) Those fire protection features that (c)(4) of this section. the staff in comprehensive fire require prior NRC approval by Of Those fire prctection features that protection safety evaluation reports paragraph (c)(5) of this section, shall be involve revisions of administrative issued before Appendix A to Branch implemented within the following controls, manpower changes, and Technical Position BTP APCSD 9.5-1 schedule: Dedicated shutdown traimng shall be implemented wtthin 4 was published in August 1976. With systems-30 months after NRC months after the date of the NRC staff respect to all other fire protection approval: modifications requiring plant Fire Protection Evaluation Report features covered by Appendix R. all shutdown-before startup after the accepting or requiring such features. nuclear power plants licensed to operate earliest of the events given in paragraph (2) Those fire protection features pnor to January 1,1979 shall satisfy the (c)(3) commencing 180 days after NRC involving installation of modifications applicable requirements of Appendix R approval; modifications not requiring not requiring prior approval or plant to this part, including specifically the plant shutdown-6 months after NRC shutdown shall be implemented within requirements of Sections !!!.G Ill.J, and approval. 12 months after the date of the NRC 111 0. (5) Licensees shall make any staff Fire Protection Safety Evaluation m difications necessary to comply with Report accepting or requiring such I. (c) All fire protection modifications these requirements in accordance with features. require to satisfy the provisions of the above schedule without prior review (3) Those fire protection features, Appendix R to this part or directly and approval by NRC except for including alternative shutdown affected by such requirements shall be m difications required by Section Ill.G.3 capability, involving installation of completed on the following schedule: of Appendix R to this part. Licensees modifications requiring plant shutdown , (1) Those fire protection features that shall submit plans and schedules for shall be implemented before the startup mvolve revisions of administrative meeting the provisions of paragraphs after the earliest of the following events controls. m'anpower changes, and (c)(2), (c)(3), and (c)(4) within 30 days commencing 9 months or more after the training. shall be implemented within 30 after the effective date of this section date of the NRC staff Fire Protection days after the effective date of this and Appendix R to this part. Licerisees Safety Evaluation Report accepting or section and Appendix R to this part. shall submit design descriptions of requiring such features: (2) Those fire protection features that modifications needed to satisfy Section (i) The first refueling outage; a involve installation of modifications that III.G.3 of Appendix R to this part within (ii) Another planned outage that lasts do not require prior NRC approval or 30 days after the the effective date of for at least so days; or plant shutdown shall be implemented this section and Appendix R to this part. (iii) An unplanned outage that lasts within 9 months after the effective date (8)In the event that a request for for at least 120 days. i of this section and Appendix R to this exemption from a requirement to comply (4) Those fire protection features pa rt. with one or more of the provisions of involving dedicated shutdown capability (3) Those fire protection features. Appendix R filed within 30 days of the requiring new buildings and systems l except for those requiring prior NRC effective date of this rule is based on an shall be implemented within 30 months i approval by paragraph (c)(5) of this assertion by the licensee that such of NRC approval. Other modifications section, that involve installation of required modifications would not requiring NRC approval prior to modifications that do require plant enhance fire protection safety in the installation shall be implemented within j shutdown, the need for which is justified facility or that such modifications may 6 months after NRC approval. i in the plans and schedules required by be detrimental to overall facility safety. (e) Nuclear power plants licensed to the provisions of paragraph (c)(5) of this the schedule requirements of paragraph operate after January 1.1979. shall i section. shall be implemented before (c) shall be tolled until final Commission complete all fire protection startup after the earliest of the following action on the exemption request upon a modifications needed to satisfy i events commencing 180 days or more determination by the Director of Nuclear-Criterion 3 of Appendix A to this part in. Reactor Regulation that the licensee has accordance with the provisions of their .ciannunon and guidance with respect to provided a sound technical basis for

licenses, permissible attematnes to satisfy Appenda A to such assertion that warrants further

2. A new Appendix R is added to trre Arcss 9 51 has been provided in four other staff review of the request.

10 CFR part 50 to read as follows: Appendix R-Fire Protection Program for 5p er ntary Guidance on Inforrnation bY 'R f in F ectio Nuclear Powe-Facilities Operating Prior to Needed for Fire Protechon Evaluanon." dated - Ociober :t.1,rg Safety Evaluation Reports referred to in January 1.1979

• "sampw Technical Specificat on." dated May paragraph (b) of this section and 12 197.

supplements to such reports. other than I. Introduction ondscope . wear plant Fire Protecuan Furctional features covered by paragraph (c). shall This Appendix applies to bcensed nuclear - Ropeibd.t es. Admmistratne Control and be completed as soon as practicable but power electnc generating stations that were

• * * ^ " " * " ' '

d* d I""'

• no later than the completion date operstmg prio-iunuary 1.1979. except to j, j

= %npowee Requirernents for Operstma the extent set fortn in paragraph SoA8(bl of HeactersJ deted May 11.19*8 Currently speCified in license Conditions this part. With respect to certain generic i j A Fire Prmettson Safety Es aluation Report that or technical specifications for such issues for such facilities it sets forth fire has been issued for each operating plant states ho* facility. or the date determined by protection features required to satisfy. i de$.$es o nfeYroNctonneue "b b, paragraphs (d)(1) through (d)(4) of this criterion 3 of Appendix A to this part.' t section, whichever is sooner. unless the i resol.ed when the facsty sonstws the appropnate reqmrements of Appenda R to this part Director of Nuclear Reactor Regulation 'see footnote 4.

76612 Federal Register / Vol. 45. No. 225 / Wednesday. November 19. 1980 / Rules and Regulations Cnteen 3 of Appendis A to this part program shall establish the fire protection D. Alternatae orDedratedShutdown specifies that Strudures, systems and pohcy for the protection of structures. Capabihty components important to safety shall be systems. and components important to safet) In areas where the fire protection features designed and located to mmimize. consistent at each plant and the procedures, equipmen' cannot ensure safe shutdown capability in with other safety requirements, the and personnel required to implement the the egent of a fire m that area. alternatise or probabihty and effect of fires and program at the plant site. dedicated safe shutdown capabihty snall be es plosions " The fire protection program shall be under prouded. When considenng the effects of fire those the direction of an mdividual who has been

1. 1. 8P"C'I'C N#9"'"**###

systems assoaated with achiermg and delegated authority commensurate with the 4 maintaimng safe shutdown conditions responsibihties of the position and who has A. Water Supphes for Fire S ppressmn 4 assume mator importance to safety because available staff personnel knowledgeable in Systems damase eu Geds un twJ io core damage both fire pmtection and naclear safety Two separate water supplies shall be resulting from loss of coolant :hrough boiloff. The fire protection program.h4 atend pad 4d t f.u:ts meseary water volume k i The phrases "important to safety." or the concept of defense-in.debth to fire and pressure to the fire main loop. " safety related!' will be used throughout this protection in fire areas important to safety. Each supply shall consist of a storage tank. 4 Appendix R as applymg to all safety with the followmg objectives: pump, pipmg. and appropriate isolation and functions The phrase " safe shutdown" will . to prevent fires from startmg: control salves. Two separate redundant be used throughout this Appendix R as

• to detect rapidly, control and extinguish suctions in one or more intake structures applying to both hot and cold shutdown promptly those fires that do occur; from a large body of water (nver. lake. etc.1 functions.
• to provide protection for structures.

will satisfy the requirement for two separated Because fire may affect safe shutdown systems, and components important to safety water storage tanks.These supplies shall be systems and because the loss of function of so that a fire that is not promptly separated so that a failure of one supply will systems used to mitigate the consequences of extinguished by the fire suppression activities not result in a failure of the other supply. design basis accidents under postfire will not prevent the safe shutdown of the Each supply of the fire water distnbution conditions does not per se impact pubhc plant. system shall be capable of providing for a J safety, the need to hmit fire damage to B. Fire Harords Analysis period of 2 hours the maximum expected systems required to achieve and maintain A fire hazards analysis shall be performed water demands as determined by the fire safe shutdown conditions is greater than the by quahfied fire protection and reactor hazards analysis for safety-related areas or need to hmit fire damage to those systems systems engineers to (1) consider potential in other areas that present a fire exposure required to mitigate the consequences of situ and transient fire hazards, f2) determine hazard to safety-related areas. . design basis accidents.Three levels of fire the consequences of fire in any location in When storage tanks are used for combined damage limits are established accordmg to the plant on the ability to safely shut down service-water / fire-water uses the minimum the safety functions of the structure. system. the reactor or on the ability to minim.ze and volume for fire uses shall be ensured by or component; control the release of radioactivity to the means of dedicated tanks or by some environment: and (3) specify measures for physical means such as a vertical standpipe fire prevention. fire detection, fire for other water service. Administrative saw won-- r= esmage imi. - suppression, and fire containment and controls, including locks for tank outlet He smm.o one een of eaueme w necena,v w alternative shutdown capabihty as required valves, are unacceptable as the only means - achew hm snutom irom ev for each fire area containing structures. to ensure minimum water volume. ,", Q"[,, systems, and components important to safety Other water systems used as one of the ese of he osmage tw a onge he in accordance with NRC guidelines and two fire water supphes shall be permanently usueno an emmure we ' regulations. connected to the fire main system and shall cmo snum-a ~ seni em m wnern ne'"'"

• C. Fim Prevention Feotums be capable of automatic alignment to the fire aY..,.a f.

M Fire protection features shall meet the main system. Pumps, controls, and power an egoeure we. eus osmage mme following general requirements for all fire supplies in these systems shall satisfy the be wind so niet at inst one een areas that contain or present e. fire hazard to requirements for the main fire pumps. The [*j'* ones[caoneskstructures. systems. or components important use of other water systems for fire protection 1 to safety. shall not be incompatible with their functions e DemonBam een eens ce _ _ ; necessary

1. In situ fire hazards shall be identified required for safe plant shutdown. Fadure of 8"**"

"'****'*"8'*""'***"'""' and suitable protection provided. the other system shall not degrade the fire 17[**,"ng*,, *"J'*

2. Transient fire hazards associated with main system.

ke normal operation, mamtenance, repair. or D.Sectionolfsolotion Vo/ves modification activities shall be identified and Sectional isolation valves such as post e, a9= eliminated where possible. Those transient . indicator valves or key operated valves shall e e fire hazards that can not be eliminated shall be installed in the fire main loop to permit or compo.nenis iocama be controlled and sui;able protection isolation of portions of the fire main loop for acom. m an, seunu,,..,y.iem. rw suca *e a c' *g4=gw,sgap_e .euciu,n m.m o, compone, pons, m wei, provided. maintenance or repair without interrupting r%. e in.a.*no one = w we snu=*=a eaueawn:

3. Fire detection systems, portable the entire water supply..

I O o Yoe,e'sa. al"*"a'*.Uw7M co

• extinguishers, and standpipe and hose C. flydmnt Isolotion volves om inere roounone een mav cor==uw an emona stations shall be installed.

Valves shall be installed to permit isolation '*d"""*"'* " '"'*** * " "** "

4. Fire barriers or automatic suppression of outside hydrants from the fire main for The most strmgent fire damage limit shall systems or both shall be installed as -

maintenance or repair without interrupting apply for those systems that fallinto more necessary to protect redundant systems or the water supply to atitomatic or manual fire than one category. Redundant systems used. components necessary for safe shutdown. suppression systems in any area containing to mitigate the consequences of other design

5. A site fire brigade shall be estabbshed.

or presenting a fire hazard to safety-related basis accidents but not necessary for safe trained. and equipped and shall be on site at or safe shutdown equipment. shutdown may be lost to a single exposure all times. D. Monuof fire Suppression j fire. However. protection shall be provided so

6. Fire detection and suppression systems.

' Standpipe and hose systems shall be that a fire within only one such system will shall be designed. installed, maintained, and installed so that at least one effective hose not damage the redundant system tested by personnel properly quahfied by stream will be able to reach any location that experience and traming in fire protection contains or presents an exposure fire hazard - II. Cenem/ Reqwrements systems. to structures, systems, or components A. Fire Pmtectwn Prtymn-L Surveillance procedures shall be - important to safety. A ' ire protection program shall be established to ensure that fire barriers are in - Access to permit effective functioning of estabbshed at each nuclear power plant The place and that fire suppression systems and - the fire brigade shall be provided to all areas components are operable. that contain or present an exposure fire ,_-__,m.-_.__.. -. - -.. - -. ~,. -,m m.

i Federal Register / Vol 45. No. 225 / Wednesday. November 19, 1980 / Rules and Regulations 76613 l herard to structures. :) stems. or components hour rating. In addition. fire detectors and an Institute for Occupational Safetv and important to safety. automatic fire suppression system shall be Health-approval formerly gnen by the (LS Standpipe and hose stations shall be inside installed in the fire area. Bureau of Mmes) shall be provided for fire 1 PWR containments and BWR contamments inside noninerted contamments one of the brigade. damage control, and control room i that are not tnerted. Standpipe and hose fire protection means specified abose or one personnel. At least 10 masks shall be i stations inside containment may be of the following fire protection means shall available for fire bngade personnel. Control connected to a high quahty water supply of be provided. room personnel may be furmshed breathms i sufficient quantity and pressure other than

d. Separation of cables and equipment and air by a manifold system piped from a the fire main loop tf plant-specific features associated non-safety circuits of redundant storage reservoir if practical Service or rated 1

j present extending the fire main supply maide trains by a honzontal distance of more than operatmg hfe shall be a minimum of one. half contamment. For BWR drywells, standpipe 20 feet with no intervening combustibles or hour for the self. contained units. and hose stations shall be placed outside the fire hazards: At least two extra air bott'es shall be dry well with adequate lengths of hose to e Installation of fire detectors and an located on site for each self-contained i reach any location inside the dry well with automatic fire suppression system m the fire breathmg unit. In addition. an onsite Shour an effective hose stream. area; or supply of reserve air shall be provided and E. HydrostaticHose Tests

f. Separation of cables and equipment and arranged to permit quick and complete Fire hose shall be hydrostatically tested at associated non-safety circuits of redundant replenishment of exhausted supply air bottles i

a pressure of 300 psi or 50 psi above trains by a noncombustible radiant energy as they are returned. If compressors are used maximum fire mam operstmg pressure. shield. as a source of breathing air, only units whichever is greater. Hose stored in outside

3. Alternative or dedicated shutdown approved for breathmg air shall be used; 4

hose houses shall be tested annually. Intenor capability and its associated circuits? compressors shall be operable assumma a standpipe hose shall be tested every three independent of cables, systems or loss of offsite power. Special care must be years. components in the area. room or zone under taken to locate the compressor in areas free F. Automatic Are Detection consideration. shall be provided: of dust and contaminants. 1 Automatic fire detection systems sha!! be

a. Where the protection of systems whose

1. Are Bngade Training installed in all areas of the plant that contain function is required for hot shutdown does The fire brigade training program shall or present an exposure fire hazard to safe not satisfy the requirement of paragraph G.2 ensure that the capability to fight potential shutdown or safety-related systems or

< f this section; or fires is established and maintained. The components. These fire detection systems

b. Where redundant trains of systems program shall consist of an initial classroom shall be capable of operstmg with or wr hout required for hot shutdown located in the instruction program followed by penodic offitte power.

same fire area may be subject to damage classroom instruction, fire fightmg practice. G. Are Protection of Safe Shutdown -ire suppression activities or from t ie and fire drills: I Capabihty rupture or inadvertent operation of fire

1. Instruction

1. Fire protection features shall be provided suppression systems.

a. The initial classroom instruction shall i

for structures. systems, and components in addition. fire detection and a fixed fire include: important to safe shutdown. These features suppression system shall be installed in the (1) Indoctrination of the plant fire fightmg i shall be capable of limiting fire damage so area. room. or zone under consideration. plan with specific identification of each that: R fiiv Bngade ' individual's responsibilities.

a. One tram of systems necessary to A site fire bngsde trained and equipped for (2) Identification of the type and location of achieve and maintain hot shutdown fire fighting shall be established to ensure fire hazards and associated types of fires that conditions from either the control room or adequate manual fire fighting capability for could occurin the plant.

emergency control station (s)is free of fire all areas of the plant containing structures. (3) The toxic and corrosive characteristics damage; and systems. or components important to safety. of expected products of combustion.

b. Systems necessary to achieve and The fire brigade shall be at least five (4) Identification of the location of fire maintain cold shutdown from either the members on each shift. The brigade leader fightmg equipment for each fire area and control room or emergency control station (s) and at least two brigsde members shall have familiarization with the layout of the plant.

can be repaired within 72 hours. sufficient training in or knowledge of plant including access and egress routes to each

2. Except as provioed for paragraph G.3 of safety related systems to understand the area.

( l this section, where cables or equipment, effects of fire and fire suppressants on safe (5) The proper use of available fire fighting includmg associated non-ssfety circuits that shutdown capabihty.The qualification of fire equipment and the correct method of fightmg brigade members shallinclude an annual each type of fire. The types of fires covered could prevent operation or cause maloperation due to hot shorts, open circuits, physical examination to determine their should include fires in energized electrical or shorts to ground, or redundant trains of ability to perform stenuous fire fighting equipment fires in cables and cable trays. activities. The shift supervisor shall not be a hydrogen fires. fires involving flammable and systems necessary to achieve and maintain member of the fire brigade.The brigade combustible liquids or hazardous process hot shutdown conditions are located withii leader shall be competent to assess the chemicals, fires resultmg from construction or the same fire area outside of primary p tential safety consequences of a fire and modifications (welding). and record file fires. I containment. one of the following means of advise control room personnel. Such (6) The proper use of communication. ensuring that one of the redundant trains is c mpetence by the brigade leader may be lighting. ventilation, and emergency breathing free of fire damage shall be provided; evidenced by possession of an operator s equipment.

a. Separation of cables and equipment and license r equivalent knowledge of plant (7) The proper meihod for fighting fires associated non-safety circuits of redundant safety-related systems.

inside buildings and confined spaces. trains by a fire barner having a 3 hour rating. Structural steel forming a part of or @e hec @n ad coodnahn d h m r 8.ede shall consist of personal protective fire fighting activities (fire bngade leaders supporting such fire barriers shall be equipment such as turnout coats, boots. only)' Detailed review of fire fightmg protected to provide hre resistance g! oves, hard hats, emergency communications (gj equivalent to that required of the barrier-equipment. portable lights. portable strategies and procedures

b. Separation of cables and equipment and ventdation equipment, and portable (10) Review of the latest plant associated non-safety circuits of redundant extinguishers. Self-contained breathin8 modifications and corresponding changes in trame ya onzontal distance o more than apparatus using full-face positive-pressure fire fighting plans' 20 feet with no mtervening combustible or masks approved by NIOSH (National 4

a fire hazards. In addition. fire detectors and an Note.-Items (9) and (10) may be deleted j automatic fire suppression system shall be from the training of no more than two of the b opm by non-operations personnel who may be ] installed in the fire area: or at ns e be rer r g, J

c. Enclosure of cable and equipment and sptems. dedicated shutdown capabitity is provided assign m & Gre Mgade.

associated non-safety circuits of one by installing new structures and systems for the

b. The instruction shall be provided by redundant train in a fire barner having a 1 function of post-fire shutdown.

qualified individuals who are knowledgeable.

76614 Uderal Register ' M 45. No C, Wedp.esday. Nm ember a N R-.n and RecuLnoEs -!g-nr2 b~g, je,, r i s e r pe !are s + & !. e p~ tee 's e g. ..r r 9e p # pr:c-t c j f r f c.rg su 29g es Mr s m, ~ e, L? 'e . M s. c,~ a e m a r gce -w s , t n, --, s of g-

- sa.. ~ t \\ un e._.w,d e c f h. s -

e-- .c,'y'-

• 4 f e. * * : t ' 3:. s.c t ; r -- : wed m

s f g.' rg vr o g re c.,ss..m. ex^ -z g ir s ; r. r-s so i tfe. arh4 cs N f.re /o eu e o of t e : so rm - A wwe pere e s -- r , eo d h+a ?ed 4et.rgs3 a'!+ ei' % +b. r s c onfer* 3nt e w tt e s'd!.i,s"* T Pas h a*s a w hrre wOrg !*fe * -.' d *-' c i t i c, 'esen3m m f t 4 brw te pi,.nt fmc f:gntirg pra ed2es ed uw > f:r+ w -i ( en: nues m er r-ore % n ore smf t. He v rees m the f. ' e n2 eqmp nen!. usng se;i.c oneofef , ~ c sr 2 be s aLd for n at r-.cr ths-24 ,. rv - s . s -w r m is o errgerc. brect s appar.ca F w r + n : e ; L nt a c ;s. rm s : f r tre mer v. m. sg v, ss in J < a'en eu _ p~nt ands.n-2.or e N c n cf a part .a>1 d m.y i s' b . r, f, s . a vsu m su, e 2. re e nt n e.w ' p e c., w e ,w n e N n 1iin;ec ' l ass-om mstru ? un 3: Ibe omia'ed use of f;e f g nnt ' C; r - 'N m.n d fr m tr.c o o of J o de re m!+rs m er o :.a errm nt rem.ared 'n cne w '" 5 s n en a e', de H se n 0:. sh + cr, 'e- , r cc G 2 o n esu :.ng imm te w cri acta,!3 se ,4 -. T rre wssn s mu be an! Spc offrese M 'ed* W dn The (e e m e -

• w en ' e reo.:a r p an ed a re 4 oni n pe cf f.re, - wn W *een" m d.crb fe cw q toWrt..,ef're sw.d d.f4 fmm twe w d m tv prn v.

% or of the ed c f e.n h wea sn.'t I-dr, u inc r-r gade ~emhers rete '.m d i e ' *n e a sfrst r c', a s. % n A.lteheddfrt#h f g :rs ! es m s ano s p:an' orns i re W nta n tre per.cic h%seieyng s y se:ec'ed s~dd sm M m.e

• re sr.s tmrs to enue scrnnard te pnante e

t.i a s.n'rpmperme %dof s behnnw tre s a m tye of f:res %' < x:d ad a~ancent of a f.re tta tea w e5 th se a dm;nis' ras e ton't us ~ < a m o rm Wr pe r riant T hese e nenan) occur m tne area se:eaea 6 Contro! t*e we of speufa con.se es seswes e. : prm de bniadr membe s w;tt cw.ng for f e dese.e; mert e e 're tre n safe'e s t. i cras AM w" <d t. sed r ., tre j ', re sp :Ed m c5 tam e n rment and M ?)a !ard orce det ng mwrrance e m r m e m at J f te est::.smsbr ent and

• '"8-!P". s kirea thi rp a ppa rd' a s

( r2dn.Ze br the f.re dishJrg Mas rd - pj. fKaJ n. Or f ef;e*mg PN' - e.s ( s M h e L%

1. .t tlc sf pressmn (d Onb I:')

jn d m n p h,d3 g 9t[f jyg } gg, l @. t CNs' ' or.s erh_duntered tr a L. Is*P.6-l4; Asseu ent of tr.gade.eader <- tr+wted w e a f a ne reardant Fw p,wnt or i e ff tmg Tresc ;rei(e sesses W e prm s ed 4 a e r per par f r eo nfa direct x of *Ne f.re fem effort as to

• 4th as new fueD sh pred.n nsa te mMer

'F ore.cr eu et urm ard effer*. < nm -tre ad cd;stde pdr s < c r e cnm 4 Rer em m te unpded m safets-rehted areas if 4" s F:re t:r ede dnEs shad be periermed m Inda&d records cf tramma prwced to reured fm s ad operate re avns a p'c r 50 at t* e fire br,gade can practice each f ae bmace meter inc: dms dn Howeser. oil comhus'Xe m 3*rria;s she be + e a t e. cromes shad be mactamed for at leas' 3 rer n ed from the are4.mmedeek fewmg b D%s snas be pe rformed at regalar seats o ersare that each member receaes the unpac k ms 5xh !rans:en' cebanb:e Wenis not m eu red 3 mm ths far each t a:nma m al! pas cf the tra:mng program tw nal. ruess stmed n aperm ed sh.f* f.re t po Ech f.re br gade member TFese reccrds of t a:n.ng sha" be as ci st* wn!.mers. shall not t e lef t uuttended s%td port,pue 'n en h dn!L tmt must fer NFC rm tea Retra.nmg or broadened dunns iunch breais sed! c'anges eother pa ta cate e at !ca t two drdis per 3 ear tram.ng for Fre hgh'mg withm bsim2s s au sm-liar rer:eds 1 cose ccm.Nsti e pack;ng A s;ff.crent nember of 'hese drd:s. but nat be sched.ded for aM these br:sade members matena! such as wood or paper eweher. or m than one for each shift f.re br:gade per w hose perkmante rec ords shrw p$ethuene stretms shal be p:ated m aannounced to dete m:re the defaienc es metai contamers w.th t:ght fittmg self-c!csmg srar sham e be f g 'nre rea& ness of the plant fee ! Ewrcy Lg:re metal cos ers br:m r ude leader. and f:re protec on Emersency bstnra unns wm at least an S-9 Cont ci actens ta be !. den bs an sy s9 ms and emmerit Persons plannmg h%r bat'en power supp:v sha!! be prouded mda: dual datosenna a f;re. for cump c. and autnor.r.ng an unannounced dnu shan in a'.! areas needed fm operata rf safe nonhcation of contrei t.sar. a!!empt to estmcush fire. and aa.':anen of bcal fire enure that the respondma shift fire bngade shutdown equ:pment and m access and members are not a w are that a dnllis bems egress routes thereto suppress.on sy stems pianned nn is begun L'nannount ed dnUs K Adm.ms:craeCrris to Contro! act.ons to be taken by the shdN ntt be scheduled closer than four Admm streae con'rols sham be certe d n. om operator to determme the reed w ee k s esta hed to mmim:ze f;re haza-cs m areas fer br:gade ass;starwe upon report of a fire or M ! cast ore dnH per s ear shali be conta.n rc sin;ctures. sy syms and

• ce p' of.darm en contre! room ar.nunciator mi irrr_ d rn a b.n i shtt' tm each sh:f t '.re compuner's emportant to safe's The panel fer cump:e. anno. mans lxanon of

gade centra!s sh4H estat,!.sh procedures to hre m et PA sys?cm. souning fi e a.%rms.

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Federal Register / Vol 45. No. 225 / Wednesday November 19, 1980 / Rules and Regulations 76615 m n w m av the nearest iocatior coelant ies al abm e the enn ut the core f r separation and barners between travs and H vm eenemsnants BWR$ and he wohm the lesel nd. cation m conduits containmg associated circuits of one Wst tasorable direction from which to the pressunzer for PWRs. safe shutdown d.mion and trays and a w $ a fire m eacri area in view of tne c Tne reactor heat remosal function shall conduits contamma associated circuits or u,..em d.rection. access ha!!wan stars. be capab;e of ach:evmg and mamtammg safe shutdown cables from the redundant n ace triat an most hkel to be tree of decay heat remos al. division. or the isolation of these associated N.; anJ the best station or elevatun for

d. The process momtonng function shall be circuits from tha safe shutdown equipment.

fers tbc fire Ali accen and eress routes capable of prosidmg direct readmgs of the shall be such that a postulated fire mvolving %i im A e lacked doers should tr process sanables necessary to perform and associated ctreuits will not prevent safe srecificalh idenfied in the procedure with control the above functions shutdown * % appropriate precautmns and methods for e The supportmg functions shall be M. Fire Barrier Cable Penetration Seal acces specified capable of providing the process cooling. Quahfication

d. Mant sysiets that should be managed to lubncation. etc necessary to permit the Penetration seal designs shall utilize only l

reduce the damage pctent;41 during a local operation of the equipment used for safe norcombustible matenals and shall be fire and the location of local and remote shutdown fun / ions. qualified by tests that are comparable to tests controis for sudi management (e g. any

3. The shutdown capability for specific fire used to rate fire barners. The acceptance hydraul:e or electrical systems m the zone areas may be unique for each such area. or it critena for the test shallinclude:

cescred by the specific fire fighting procedure may be one unique combination of systems

1. The cable fire barrier penetration seal that could increase the hazards in the area for all such areas. In either case, the.

has withstood the fire endurance test without because of oserpressunzation or electrical alternat,ve shutdown capabihty shall be passage of flame or igrution of cables on the hazards). independent of the specific fire area (s) and unexposed side for a period of time

e. Vital heat-sensitive system components shall accommodate postfire conditions where equivalent to the fire resistance rating that need to be kept cool while fighting a offsite power is available and where offsite required of the barrier:

local fire. Particularly hazardous power is not avadable for 72 hours.

2. The temperature levels recorded for the combustibles that need coohna should be Procedures shall be in effect to implement unexposed side are analyzed and design ated this capabihty.

demonstrate that the maximum temperature

f. Organizaban of fire fighting bngades and 4 If the capability to achieve and n:aintain is sufficiently below the cable insulation the assignment of special duties according to cola shutdown will not be available because ig1 tion temperature: and job titie so that all fire fighting functions are of fire damage. the equipment and systems 3 The fire barrier penetration seal remains.

covered by any complete shift personnel comprising the means to achieve and intact and does not allow projection of water complement. These duties include command maintain the hot standby or hot shutdown beyond the unexposed surface during the control of the Lngade, transporting fire condition shall be capable of maintaining hose stream tea. suppression and support equipment to the fire such conditions until cold shutdown can be K Fire Doors scenes. applying the estmguishant to the fire, achieved. If such equipment and systems will Fire doors shall be self-closing or provided commumcation with the control room. and not be capable of being powered by both with closing mechanisms and shall be coordination w:th outside fire departments onsite and offsite electne power systems inspected semiannually to venfy that

g. potential radiological and toxic hazards because of fire damage. an independent automatic hold.open, release, and closing in fire zones.

onsite power system shall be provided. The mechanisms and latches are operable,

h. Ventilation system operation that number of operating shift personnel.

One of the followmg measures shall be ensures desired plant air distnbution when exclusive of fire bngade members. required provided to ensure they will protect the the ventilation flow is modified for fire to operate such equipment and systems shall epenmg as required in case of fire: contamment or smoke clearing operations. be on site at all times.

1. Fire doors shall be kept closed and L Operations requiring control room and

5. Equipment and systems comprising the electrically supervised at a continuously shift engineer coordmation or authorization.

means to achieve and maintain cold manned location: f Instructions for plant operators and shutdown conditions shall not be damaged

2. Fire doors shall be locked closed and general plant personnel during fire.

by fire; or the fire damage to such equipment pipected weekly to verify that the doors are L A/ternotwe andDedicatedShutdown and systems shall be limited so that the 'n the closed position: Ccpabdsty systems can be made operable and cold

3. Fire doors shall be provided with

1. Alternative or dedicated shutdown shutdown achieved within 72 hours.

automatic hold.open and release mechanisms capabihty provided for a specific fire area Materials for such repairs shall be readily and inspected daily to venfy that doorways shall be able to achieve and maintain available on site and procedures shall be m are free of obstructions; or subcntical reactivity conditions in the effect to implement such repairs. If such . 4. Fire doors shall be kept closed and reactor, maintam reactor coolant inventory equipment and systems used prior to 72 ho irs mspected daily to verify that they are in the - achieve and mamtain hot standb= ' after the fire will not be capable of being ci sed position. conditions for a pWR (hot shutdo'wn ifor a powered by both onsite and offsite electric The fire brigade leader shall have ready DWR) and achieve cold shutdown : power systems because of fire damage, an access to keys for any locked fire doors. conditions within 72 hours and maintain cold mdependnet onsite power system shall be Areas protected by automatic total flooding shutdown conditions thereafter. During the provided. Equipment and systems used after gas suppression systems shall have postfire shutdown. the reactor coolant system 72 hours may be powered by offsite power electrically supervised self-closing fire doors process vanables shall be mamtained within only. or shall satisfy opt.on 1 above. those predicted for a loss of normal a c.

6. Shutdown systems installed to ensure OEo#emon & stem fodeactor power. and the fission product boundary postfire shutdown capability need not be integrey shall not be affected; i.e., there shall designed to meet seismic Category I criteria, e re8Ct r CNIant pump shall be be no fuel clad damage, rupture or any single failure critena. or other design basis equipped with an oil collection system if the pnmary coolant boundary. or rupture of the accident criteria, except where required for c ntainment is n t inerted dunng normal containment boundary, other reasons, e.g.. because of interface with peration. The oil collection system shall be s designed, engineered and mstalled that

2. The performance goals for the shutdown or impact on existing safety systems, or functions shall be:

because of adverse valve actions due to fire failure will n t lead to fire dunna normal or a The reactmty control function shall be da mage. design basis accident conditions and that g capable of achievine and maintaining cold

7. The safe shutdown equipment and shutdown reactivity conditions.

systems for each fire area shall be known to

• An acceptable method of complying with this b The reactor coolant makeup function be isolated from associated non. safety ahemann would be to mut Regulato@ unde m sha.1 be capable of maintaining the reactor circuits m the fire area so that hot shorts.

f,,,*'(( ,, [,y("g ",, open circuits. or shorts to ground in the redundant safety dmsions are so protected that ' & defeed m tt;c S'a'ndard Techmcat associated circuits will not prevent operation postulated fires affect trays from only one safety Specifer.a uona of the safe shutdown equipment.ne dmsson.

76616 Federal Register / Vol. 45. No. 225 / Wednesd.n. November 19. 1980, Ruh s and Regulatorns tu *e s re.ri. nab;e.nsuranc e that the system n di w thsi,md the Nfe Shuidawn F.orthquakr Suc h t o;teuion sprems shalt he capable of collec hng lube od from all potential pressurized and unpressurized leakage sites m the reactor coolant pump lube oil systems Leakaga shall be collected and drained ta a vented closed container that can hold the entue tube oil system msentory A flame arrester is required m the sent if the Dash point (haracteristics of the oil present the hazard of fire Dashbac k I.cakage points to be g protected shall mdude hft pump and pipmg. os ernow Imes. lube oil cooler, oil fdl and drain lmes and plugs. flanged connections on oil hnes, and lobe oil reservoirs where such features exist on the reactor esolant pumps. The dram hne shall be large enough to accommodate the largest potential oil leak {Sec.161b. Pub. L 83-703,68 Stat. 948 sec. 201. Put L 93-438. 88 Stat.1242 (42 U.S.C. 2201(b).5841]) Dated at Washmgton. D.C.. this 17th day of November 1980. For the Nuclear Regulatory Commission. Samuel ]. Chilk. Secretary of the Commission. [HI lhr h36m Filed 11-im a 45 em! eiwsso CODE 7seo-41-M 4 4

• See Regulatory Guwle 13 " Seismic Des gn Clasufication" Paragraph C 2.

SUMMARY

OF STAFF REQUIREMENTS ~ TO RESOLVE OPEN ITEMS FCRT CALHOUN 00CKET NO. 50-285 3.1.15 and 3.2.4 C able Seoaration In the Fire Protection SER the concern was.that the separatien of redun-dant trains of safety-related cables in several areas of the plant was not sufficient to assure that one train of safe-shutdown system cables would remain functional after a fire. By letters dated September 29, 1978, July 9, 1979, and May 20, 1980, the licensee provided the results of his analysis. The licensee identified eight areas which contained redundant safe shutdown systems necessary for acnieving safe shutdewn. These areas include the following: Cable Tray and Perscnnel Corridor Area Intake Structure Compresscr Area Electrical Penetration Area, Basement Ficcr Electrical Penetration Area, Ground Floor Switchgear Area Cable Spreading Room Control Room Complex The licensee committed to provide alternate shutdown capability for the control room and cable spreading room areas. The licensee also proposed to erect a three-hour fire rated wall to separate the redundant switcagear trains in the switchgear area, and to either protect er reroute inter-posing cables. For the cable tray and personnel ccrridor area and the intake structure, the licensee proposed to provide a 3-hour rated enclosure er ncncombustible barrier to separate ene division of safe shutdown cables from redundant divisions. For the compresser and electrical penetration l areas, the licensee proposed to provide barriers which would meet the recuire-ments of IEEE 384. We inferred the licensee that the proposed protection for redundant safe shutdown cables, which pass through the areas of the switchgear room and l the remainder of the areas identified above,.are not adequate to ensure that at least ene means of achieving safe shutdown ccnditions will survive a postulated fire in these areas. The proposed 3-hour barriers are of construction which has not been tested to show that, when applied as a wrap arcund of electri:al cables, circuit integrity can be maintained in the protected cables for a 3-hour ASTM E-119 fire. The IEEE 384 "Sarriers" are in reality only heat shield and do not provide adequate protection from exposure fires. To meet cur fire protection guidelines, alternate shutdown capability should be provided when safe shutdown cannot be ensured by barriers and detection and l

' suppression systems because of the exposure of redundant safe shutdcwn equipment, cabling, or components in a single fire area, to an exposure fire, or fire suppression activities, or rupture or inadequate cperation of fire suppression systems. To meet Section III, Paragraph G.of Appendix R to 10 CFR Part 50, the licensee should provide alternate shutdown capacility for each of the following areas: Cable Tray and Persennel Corrider Area Intake Structure Compressor Area Electrical Penetration Area Switchgear Area The alternate shutdown system should meet the requirements of Section III, Paragraph L of Appendix R to 10 CFR Part 50. 3.1.16, Fire Water Sucoly In.the Fire Protection SER the concern was.that sand and silt from the riverced could clog sprinkler lines er prevent the fire pumps from cper-ating. By letters dated July 13, 1978 and May 20, 1980, the licensee provided a description cf the current pump suction line design, the results of ncrmal surveillance testing since modifications were completed, and the results of testing a mock-up of a sprinkler system. The test rtsuits indicate that the cuantity of sand which ficwed through the piping is unlikely to impair the performance of fire pumps or sprinklers. In additicn the licensee indicated that the fire pump discharge strainer had a 250 micren screen and that all crifices in the sprinkler system are 1/4 inch or larger. The licansee conclude.J that sand-clogging of sprinkler system pipes or orifices through which water is ficwing is unlikely. We infermed the licensee that sufficient sand may be introduced into.the ncn-flowing portion of the system and may build up to a point where individual sprinklers or small pipe sections would become clogged and not available for future operation. l To assure that sprinkler orifices and pipes will not be clogged by a buildup of sand or silt, the licensee should establish procedures to examine, test, or flush sprinkler system portions in which no ficw cccurred if one er more i sprinklers in that system have cperated. The-proceduresshould follow the recc=mendations of NFPA 13A-1978, "Recc. mended Practice for the Care and Maintenance of Sprinkler Systems." l l}}