ML19345G435

Staff Requirements Memo Re 801021 Continuation of Discussion on Fire Protection Program.Commission Requested Editorial Changes.Fr Notice Re NRC Fire Protection Program Encl

ML19345G435
Person / Time
Issue date:	10/24/1980
From:	Chilk S NRC OFFICE OF THE SECRETARY (SECY)
To:	Bickwit L, Dircks W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO), NRC OFFICE OF THE GENERAL COUNSEL (OGC)
Shared Package
ML19295E769	List: ML19295E768 ML19295F842 ML19345G430 ML19345G432 ML19345G434 ML19345G435
References
FOIA-81-80, FRN-45FR76603, REF-10CFR9.7, RULE-PR-50 M801021, NUDOCS 8104070245
Download: ML19345G435 (17)

Text

IN RESPONSE, PLEASE

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REFER TO: M801021 UNITED STATES b'

y y ~,. g, ' g NUCLEAR REGULATORY COMMISSION E

WASHIN GT ON. D.C. 20555 n

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Denton

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October 24, 1980 Cys:

Dircks M

Cornell i

Rehm OFFICE OF THE

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• Minogue SECRETARY P

Shapar MEMORANDUM FOR: William J. Dircks, Executived Director for Operations 13[] Sk Leonard Bickwit, General cunsel FROM:

Samuel J. Chilk, SecretaO S

SUBJECT:

STAFF REQUIREMENTS - C0 tit ITJATION OF DISCUSSION ON FIRE PROTECTION PROGRAM (SEEiSEdY-80-438A), 2:05 P.M., TUESDAY, OCTOBER 21, 1980, COMMISSIONERS' CONFERENCE ROOM, D.C.

0FFICE (OPEN TO PUBLIC ATTENDANCE)

The Commission

• continued its discussion of the Fire Protection Program.

The Commission requested:

1.

That language be developed:

a.

for the rule, on_backfitting selected portions of Appendix R for all operating plants issued Ols prior to 1/1/79; b.

for the statement of considerations, on backfitting selected portions of Appendix R for all operating plants issued OLs prior to 1/1/79; c.

for the rule, to make Appendix R applicable to all plants, including plants licensed or to be licensed after January 1,1979; d.

to give credit, in terms of time schedule to comply with AppendixR,tothosewhohavealreadyimplementedchangesin_/2 discussions with staff; e p-fc (NRR)(SECYSuspense:

10/24/80) -

2.

That alternate language be developed providing for relaxation of current requirements; (0GC) (SECY Suspense:

10/24/80) 3.

That the subject be scheduled for an additional meeting the week of October 27.

(Subsequently a meeting was scheduled for Monday, October 27, at c

2:00 p.m.)

-cc: Chairman Ahearne Commissioner Gilinsky Commissioner Hendrie Commissioner Bradford Commission Staff Offices PDR

- *Comissioner Hendrie was not in attendance.

810407 03A6

E Wednesday

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November 19,1980 e

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E Part 11 M

Nuclear Regulatory l

l Commission Fire Protection Program for Operating Nuclear Power Plants

t 711602 Federal Register / Vol. 45, No. 225 / Wednesday. November 19,1980 / Rules and Regulations NUCLEAR REGULATORY that the comment period should have are already set forth in General Design COMMISSION been extended.

Criterion 3 of Appendix A to 10 CFR The Commission does not agree. The Part 50 and in the NRC guidance 10 CFR Part 50 NRC has been developing fire protection documents. These general provisions requirements since 1975. The NRC gave rise to a number of disputes over Fire Protection Program for Operating published comprehensive fire protection whether specific methods adequately Nuclear Power Plants guidelines. Branch Technical Position accomplished the intended goal. The AGENCY: Nuclear Regulatory BTP APCSB 9.5-1, and its Appendix A in proposed rule is intended to provide Commission.

1976. Licensees have compared their fire sufficient specific guidance to ensure ACTION: Final rule.

Protection programs against these satisfactory resolution of these issues.

guidelines and have discussed their Thus, reverting to generabred guidance suaAMARY: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 during the NRC's fire protection reviews The second issue involved some protection in operating nuclear power of operating 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 upgra'le fire protection at nuclear power supplements to the Safety Evaluation unintended restrictions. For example, plarne licensed to operate prior to Report have been issued for each the proposed rule called for a " fresh January 1.1979, by requiring resolution operating reactor. These reports water" supply. For firefighting purposes, of certain contested generic issues in describe fire protection alternatives that brackish water is satisfactory and a fire protection safety evaluation reports.

have been proposed by the licensee and

fresh" water supply is unnecessary.

EsFECTIVE 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 Often portions of a fire main loop run the Comptroller General 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 guiden. The similar changes are discussed in Section effective, unless advised to the contrary, Commission believes that a 30-day 111. " Specific Requirements," of this reflects inclusion of the 45-day period comment period was adequate under preamble.

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

U.S.C. 3512(c)(21).

2. Many licensees questioned the need requirements pn plants with presently installed or with existing commitments POR FURTHER INFOnafATION CONTACT:

for backfitting all the requirements of a ir David P. Notley, Office of Standards Appendix R. They commented that they de in staff M 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 genera;jy agrees that, except for three Ferguson, Office of Nuclear Reactor completed certain modifications. They Regulation, U.S. Nuclear Regulatory contend that the staff has properly

[p endi s

Id no be tr actively Commiss on. 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 sumptEe0ENTARY WeFOnseATION:On May protection described by the guidance sat sfying the provisions of Appendix A 29,1980, 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 pagister (45 FR 30082) a notice of They also contend that these original proposal for Appendix R, that 4 proposed rulemaking inviting wr tien 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 contamed in the proposed rule. 'Ihey fire protection features. Thus, the staff notice concerned p*oposed amendments express the concern that the proposed had not intended the provisions of to 10 CFR Part 50, " Domestic 1.icensing rule was written in such specific Appendix R to require modification of of Production and Utilization Facilities,"

language that fire protection issues that previously approved features. This was which would require certain nnnimum were thought closed would be reopened not clearly described in the proposed provisions for fire protection m 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 1+1t rs were modifications could be accomplished published with the proposed arule received regarding the proposed only by the expenditure of considerable explicitly indicated that "[ajll licensees amendments. A number of comments engineering, design, and construction will be expected to meet the g

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. However, 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 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 commentern stated that the 30 issues. The first relates to the need for install fire protection features previously day comment period was too sho.t 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 Federal Register / Vol. 45, No. 225 / Wednesday, November 19. 1980 / Rules and Regulations 76603 9.5-1,it is important to recognize that arrangements were accepted in some permitted either an oil collection system Appendix R addresses only a portion of early fire protection reviews. As a result or a hre suppression system. The staff the specific items contained in the more of some separate effects tests, the staff has also accepted an automatic fire comprehensive document. Branch changed its position on this suppression system as an acceptable Technical Position UTP APCSD 9.5-1 configuration, and subsequent plans method of fire protection for this and its Appendix A. Appendix A to BTP have been required to provide application. The Commission has APCSil9 5-1 has been the basic fire additional protection in the form of fire concluded that fire suppression systems protection guidance used by the staff in 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 coatings as fire The Commission therefore believes that several years. For many plants, barriers is allowed 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 satisfactorily achieved the fire Technical Position BTP APCSD 9.5.1 and collection systems that can withstand protection criteria set forth in Appendix the proposed Appendix R recognized seismic events.

A to DTP APCSD 9.5-1 and began to that there were plant-unique The technical basis on which these promptly implement such features and configurations that required fire three sections are based are further systems.

protection features that are not identica] discussed in Section 111. " Specific Satisfactory features and systems are to those listed in Section 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 licensee and described in a fire the proposed rule is impossible to meet 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 same criteria of Appendix A to BTP as providing equivaler.t protection to the implementation schedule in the effective APCSU 9.5-1. In general, the features requirements of Section llI.G to rule is the same as that in the proposed previously approved by the NRC staff in Appendix R.

rule, the Commission must be prepared its reviews of fire protection using the Requirements that account for all of to either shutdown each operating criteria of Appendix A to UTP APCSD the parameters that are important to fire nucle r power plant, or process 9.5-1 provide an equivalent level of fire protection and consistent with safety exempti n requests.

The commenters then concluded that 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 pri d for comphance.The proposed rule st ted that all fire protection ana approved icatures be modified to years, the Commission believes that the conform to the specific !anguage set licensees should reexamine those m difications identified by the staff as forth in Appendix R is outweighed by previously approved configurations of mssary to satisf Criterion 3 of 3

the overall benefit of the early fire protection that do not meet the Appendix A to this part, whether implementation of such previously requirements as specified in Section c ntamed m Appendix R to this part or ther staff fire protection guidance

'n approved features, which in many cases III.G to Appendix R. Based on this

[, u down ca

)sha$1 e ompleted are currently being installed.

reexamination the licensee must either I

Nevertheless, as a result of its meet the requirements of Section III.C of by November 1,1980 unless, for good continuing review of fire protection Appendix R or apply for an exemption cause shown, the Commission approves matters, the NRC staff has m, dicated to that justifies alternatives by a f,re i

an extension,"(proposed paragraph the Commission that there are hazard analysis. However, based on 50A81.(c)). The Commission went on to requirements m 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 over and above that previously exemptions for fire-retardant coatings plant would be allowed to continue to accepted, may be desirable. The used as fire barriers.

operate after November 1,1980, or Comminion has decided that these The second relates to emergency beyond an extended date approved by requirements should be retroactively N,hting. Section Ill.) 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 not meant to reflect adversely on in some cases less than 8-hour shutdown capability) have been previous licensee or staff evaluations, emergency lighting has been accepted as implemented."

rather its purpose is to take fully into satisfying Appendix A to BTP APCSD The Commission has reconsidered the account the increased knowledge and 9.5-1. While an adequate level of safety impiementation schedule and has experimce developed on fire protection may be provided by less than an 8-hour determined that it should be modified matters oser 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 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 achieve and maintain safe shutdown are licensees should upgrade the previously 6 months, the staff has informed the free from fire damage. Appendix A to approved facilities to satisfy the 8-hour Commission that the date of November DTP APCSD 9.51 permits a combination lighting requirement of Appendix R.

1,1980. is not possible because the of fire retardant coatings and fire The third relates to protection against effective date of the rule will be after detection and supression systems fires in noninerted containments that date.

without specifying a physical separation involving reactor coolant pump

+ The staff has informed the distance to protection redundant lubrication oil (Section 111.0 of Commission that it would expect systems (Appendix A, D.1(2)), and such Appendix R). The proposed rule virtually all licensees to request

r 76604 Federal Register / Vol. 45. IJo. 225 / Wednesday. November 19. 1980 / Rules and Regulations exemptions if the new implementation Section !!I. 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.The time comments and a statement of the staffs is set aside and dedicated for fire and manpower resources needed by the disposition of those comments, protection uses to be available at all times regardless of other simultaneous licensees to prepare such requests and Section I. Intmduction and Scope water uses in the plar.t. 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 revisedimplementation 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 shutJown."

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 must be located at a higher level to phased schedule that is as prompt as can be reasonably achieved.

This section has been substantially ensure that the minimum 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 is locked and those requirements already imposed were consolidated with trie appropriate valves to em.ute adequate water supply in license conditions or Technical parts of Section III " Specific for fire fightins 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 requirement

• imposed by Appendix R.

dropped.

Afany commenters stated that we including the items "backfit" tc all Section Ill. Specific Requirements were being too restrictive by stipulating plants, the schedule provides a reasonable time after,ublication of the The requirements in this rule are an underground yard fire main h.op and rule for completion of required based upon pnnciples long accepted fresh water su, j!ies. Our intent was modifications. For requirements already within that portion of American industry only that a yard fire main loop be that has been classified by their furnished. We have deleted th imposed by license conditions providing insurance carriers us ~!mproved Risk" specification for an u. der;;rond loop for implemention after November 1.

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

may be excessive."Ilius, 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 soecific 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. Water Supplies for Fire the fire protection system is designed existing licenses if such schedules Suppmssion 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 d opped. Other initially. Relief from such limitation may site in the United States is a separate operational problems unrelated to fire be granted by the Director of Nuclear water distribution system for fire protection that may reruit from the tase Reactor Regulation upon a showing that protection with dual water supplies.

of salt or brackisl. waier 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 capability 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 plants use a single large intake structure imposed a schedule with a compliance suctions 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 requirements.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 distnbution 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 dedicated tanks or i 50.48 (45 FR 71589). which will be valves for isolating portions of the use of vertical standpipe for other water 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.

public comments received and the staffs 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

t Federal Register / Vol. 45, No. 225 / Wednesday, November 19, 1980 / Rules and Reg 71ations 76605 related issues are involved here.ne hour water supply is considered by a visually indicating or key. operated first is the requirement for dedicated adequate. It should a'ao be noted that (mrb) valve," and there was an water storage tanks for fire fighting this minimum dedicated water volume is opportunity to comment on this purposes.ne suggestion that the based on maximum flow rates. Since document.

requirement for dedicated tanks be most fires are controlled and D. Afanualfire Suppression Technical deleted was rejected for the reasons extinguished with much smaller flow Basis. Considerable reliance is placed stated in the preceding Technical Basis.

rates, this requirement realistically on automatic fire suppression systems ne other point 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.

Ilowever, manual fire fighting activities B.Sectionallsolation Valves.

often can control and extinguish slowly suppression activities when storage tInks are used for combined service.

C.HydrantIsolation Valves developing fires before an automatic fire water / fire. water uses. The term TechnicalBasis. Dese 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 treaud together. Proper valving is extinguished by automatic systems for other water uses in common storage regi:ed to isolate portions of the water require a certain amount of manual t nks will be located sufficiently high to distribution system fm maintenance or response. Also, some areas of the plant Ensure the minimum water volume repair without interrupting the water do not warrant the installation of needs for fire suppression activities. lf supply to manual or automatic fire automatic fire suppression systems.

the commenters were assuming that 8"ppression 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 areas:

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 storage tank is more desirable since any maintenance or repair without areas of the plant, and that standpipe Irakage would be immediately evident.

interrupting water supply to fire and hose stations be located throughout On an internal standpipe a leak in the sqppressi,on systems inside the plant.

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

So*

mmmenters objected to the ch"$8t il olves omment C

system except for those inside containment, which may be connected requi-

' that other water systems Resolution. Many commenters stated to other reliable water supplies if a used6 ackup water supply for fire that the requirement for " approved separate penetration into containment protection should be permanently visually indicating" sectional control cannot be made for fire water service connected to the fire main system and valves was overly restrictive, needs.

suggested 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 mam system withm The Commission has accepted this Several commenters suggested adding ten minutes of the loss of normal water suggestion: the rule now requires that supply or pumps. The rule does not sectional control valves shall be a sentence reading Standpipe and'iose s_ddress 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 gustification 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 ndicator or key-operated valves are been provided to account for a given fire all of the requirements of the fire mentioned as two examples of area." This suggestion was tejected.He protection water supplies. Additional acceptable valves.

staff has taken the position that the backup supplies need not meet these C.HydrontBlock Volves-Corrment 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 investigat ons 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 systems in any area containing or further reduced.

tarlier. 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 equipment.

Basis. Fire hoses should be use of only one fire hose stream, the fire -

One commenter suggested that this hydrostatically tested periodically to was extinguished within one-half hour.

requirement be dropped in its entirety ensure that they will not rupture during The staff would find unacceptable any since it "is a new requirement which has use. The requirement for a 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 and extinguished on the basis that Appendix A to BrP Association Standard No.196--

withm two hours with any combination APCSB 951 contains the following Standard for Fire Hose), a nationally cf manual and automatic fire sentence: 'The lateral to each hydrant recognized consensus standard.This suppression activities.nerefore, a two-from the yard main should be controlled ' standard contains other guidance for the

I 76606 Federcl Register / Vol. 45. No. 225 / Wednesday. November 19. 1980 / Rules and Regulations use and care of fire hose that most system in all such areas should be

1. Fire Brigade Training Technical industries find useful.

retained. The fire hazards analysis may Basis. Most modern industrial plants e all for a separate suppression system.

with replacement cost values Comment Resolation but this would be in addition to the fire app:oaching those of a modern nuclear Many commenters pomted out the detection system.

powered electric generatmg station have erroneous usage of the term " service G. Pmtection of Su/e Shutdown a full. time fully equipped fire pressure" rather than " operating Capability TechnicalBasis. The department. including motorized fire pressure" in this requirement.The objectise for the protection of safe apparatus. Because of the reduced intended meaning for this requirement is shutdown capability is to ensure that at severity of fire hazard in a nuclear that all hoses would be tested at a least one means of achieving and generating statmn as compared to a pressure greater than the maximum maintaining safe shubwn conditions manufacturing plant, the Commission pressure found in the fire protection wdl remain available during and after believes that it is not necessary to water distnbution systems. The correct any postulated fire in the plant. Because mandate a fully staffed fire department.

terminology is " operating pressure." The it is not possible to predict the specific flowever, manual fire response rule has been so changed. In addition, conditions under which fires may occur capability is required at a nuclear plant the staff added a specific minimum test and propagate, the design basis and a properly equipped and fully pressure requirement of 300 psi to meet protective features are specified rather trained fire brigade will satisfy this the NFPA standard.

than the design basis fire. Three need. The Commission has determined One commenter also pointed out that diffe rent means for prr,tecting the safe that a brigade of five persons constitutes hoses should be inspected for mildew.

shutdown capability outside of the minimum size sufficient to perform rot. cuts, or other damage. Although th.is containment are acceptable.The first the actions thai may be required by the is a valid cor. ment. it is not an means : separation of redundant safe brigade during the fire and to provide unresobed issue with any licensee so it shutdown 11ains and associated circuits some margin for unanticipated events.'

need not be covered by this rule. In by means of 3.hou fire rated barriers.

Sirailaily, the training requirements addition, such inspections are already The second means is a combmation of listed are considered the minimum bemg performed in accordance with the separation of redundant safe shutdown needed to ensure that the fire brigah plant s lechnical Specificaitons.

F. Automatic Fire Detection Technical trains and associated circuits by a 1-will be able to function effectively during a fire emergency.

hour bre rated barrier and automatic f..e Bosis. The requirement that automatic fire detection systems be m, stalled m all suppression and detection capability for The proposed rule required em ergency both redundant trains. The third me'ans.

breathing apparatus without specifying areas that contain safe shutdown or the number of such pieces of apparatus.

safety-related systems or components which may be used only when redundant ' rains and associated circuits The rule has been modified to specify follows generally accepted fire the personnel for whom such apparatus protection practice. Installation of such are separated by 20 feet or more of clear is to be providd and to specify reserve fire detection capability is independent 8 pace. requires automatic fire g

of any requirements for automatic or suppression and detection systems n,.

II. Fire Bngade-Comment the area. An alternative or dedicated manual fire suppression capability in an Resolution. Many commenters suggested area. The purpose of these detection safe shutdown capability mdependent of changing this requirement to a simple systems is to give early warning of fire the fire area is required if fire protection statement that a trained and equipped.

conditions in an area so that the fire f r safe shutdown capability cannot he nominal size, site fire brigade of five brigade can initiate prompt actions to provided as onth,ned above. For cables persons be provided on each shift unless minimize fire damage within the plant.

and equipment needed for safe a lesser number is iustified. This hutdown located mude of noninpted recommended chase was rejected by Comment Resolution containments, a lesser degree of fire the Commission for the reasons stated Many commenters suggested that the protectmn is permitted because in the Technical Basis.

words " automatic fire detection tranuent exposure fires are less likely Some commenters objected to the capabihty" be substituted for msufe contamment during plant exclusion of the shift supervisor from

" automatic fire detection systens" on oper stion. Section lit.M. " Fire Barriers.'

the fire brig.ide. The commenters felt the basis that, as worded, the discusses the techmcal basis for the 3-that the shilt supervisor should go to the requirements are too limiting. They hour barrier, and Section III.L fire and provide the benefit of his stated that an automatic sprinkler

" Alternative and Dedicated Shutdown expertise ard authority. The rule would system with appropriate alarm check Capability." disc;sses the technical not prevent this liowever, the shift valves and central alarm features basis for safe shutdown capability.

supervisor may have to go elsewhere provides acceptable detection /alarmmg Comment Resolution during the course of a fire that adversely capability. Several commenters claimed affects plant operation.The fire brigade that a separate detection system is not Many commenters suggested that the leader must stay with the fire brigade needed in areas covered by sprinkler first paragraph be changed slightly and and be assigned no other systems equipped with fusibla link the rest o? this section deleted. The

. iponsibilities during a fire emergency, sprmkler heads. A fusiblelink has a basis for their contention is that the rule tt.erefore, the shift supervisor must be time delay before it actuates. Ilowever, should s!ste simply the requirement to excluded from meinbership on the fire more importantly, a smoldering protect cables or equipment of systems brigade.

localized fire that could do damage may necessary for safe shutdown of the plant

1. Fire Brigade Training-Comment not generate enough heat to melt the and leave specific implementation Resolution. Many commenters have fusible link. 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 i Ttna in dricussed at tength in the NRC staffs suppression system serves as removing the listing of considerations.

" Evaluation of Minimum Fire Bngade Shift Sire".

notification that a fire exists, we delet.ng Table 1. and revising the d'ted Nne a.19~9: copies are available from Dmd concluded that the minimum word ng to provide clarification.

E ',N $ $ *"d N N,,P"" N c h g requirement for a separate fire detection

11. Fire Brigade.

m5ss.

t Federal Register / Vol. 45, No. 225 / Wednesday, Noverser 19. 1980 / Rules and Regulations 76607 stated that NRC used unnecessary detail fire emergency and operators involved modifications to provide alternative in spelling out specific requirements for in safe plant shutdown should not also shutdown systems are extensive, a classroom instruction, fire f.ghting have to be concerned with lighting in the dedicated sys9m that is essentially a practice, and fire drills. Some area.The small cost differential minimum capability safe shatdown train commenters felt 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 ninimum Contaission has published with regard afforded by the 8-hour supply does not capability is required to maintain the to sperator traming. The Commission warrant reducing this requirement. The process variables within those values tere points out that most of the Commission has decided to require an 8-predicted for a loss of offsite power. The investigations of the TMI accident hour battery power supply in all areas case of loss 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 distribution systems) that work is now being done in this routes.

could cause or be related to such a loss.

area. The fact is not that the training K. Administrative Controls Technicol Fire damage to cold shutdown capability requirements spelled out here for the fire Basis. The fire protection program uses is limited to damage that can be brigade members are excessis e when administrative controls for fire repaired within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to provide a compared to training requirements for prevention and prefire planning. The margin in achieving cold shutdown reactor operators, 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 training parameters that are community as minimum requirements were not designed with this concept in essential to a comprehensive progt am 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 combustib:e function because of a fire,it must not be Bosis. Emergency lighting is required in materials to reduce the fire loading in disabled by fire damage to associated all nuclear power plants. [3attery.

safety-related 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 criterion 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> is usually sufficient for Precedures are used to control actions because it is only one of severallevels emergency egress. !!, wever, the postfire t, be taken b" individuals who discover of defense. Seismic Category I criteria is emergency lighting requirements in a a fire an 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 uuon Comment Resoluuon op ra e by a t perso n to eff ct safeplant shutdown during plant hiany commenters stated that this hiany of the commenters stated that emergdacies. Scause such activities 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 lighting capability to allow Other commenters stated that a simple and shouhi be dropped. They also sufficient time for normallighting to be statement that administrative contend that this regulation does not restored with a margin for unanticipated procedures should be established to take into account the many plant

events, control the various fire hazards reviews b eing conducted under the throughout the plant was sufficient, and Systemati: Evaluation Program (SEP).

Comment Resolution that the details could be spelled out in a It is generally understood that cold Af any comrr enters 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 restrictive in three specifics: first, hiinor changes have been made in the different means may be used and may that emergency lighting is unnecessary wording of this. equirement for be necessary to achieve cold shutdown.

in many of the designated areas: second. clarification.

Because a fire in certain areas at some that the requirement for sealed beam or L Alternative and Dedicated plants would have the capability of fluorescent units is overly restrictive:

Shutdown Capability.

disabling systems required to achieve third, that the requirement for individual TechnicalBasis. 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 t

plant-specific power supply; and one systems against adverse effects of fire or being made under the Systematic commenter recommended that there be fire suppr. ssion activities only through Evaluation Program (SEP) may also call no permanent installation.

the use of fire protection features for alternative or dedicated shutdown These suggestions have been accepted because the redundant safe shutdown capability for reasons other than fire in part. Lighting 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:nodifications. Each egress routes thereto.The reasoning cable spreading room, s.vitchgear rooms licensee should be aware of the status of behind 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

r 76608 Federrl Rexist:r / Vol. 45. No. 225 / Wednesday. November 19. 1980 / Rules and Regulations protection to the extent possitile.

required to casure safe shutdown the national consensus standard used flowever, the Commission has decided capability. The use of a 1. hour barrier in for testing and rating these cable that the modifications required to conjunction with automatic fire penetration seals. Since the cables cemplete the fire protection program suppression and detection capability for conduct the heat thiough the barrier, should not be 15rred une A 'IEP each redundant train of safe shutdown and since the cable insulation is review is completed.

equipment is based on the fpilowing combustible, the acceptance criteria of M. Mre Barriers.

censiderations. Automatic suppression the ASTM Standard E-119 relating to Technica/ Basis. The best fire is required to ensure prompt. effective temperature on the unexposed sida must pmtection for redundant trains of safe application of suppressant to a fire that be appropriately modified.

shutdown systems is separation by could endanger safe shutdown Comment Resoludon unpierced fire barriers-walls and capability. The activation of an ceilint oor assemblies. Because these automatic fire detection or suppression Some commenters suggested that this fl barriers 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 mamtained. 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 will 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 sma'ler. more acceptable risks. Even fire These requirements have now been review and relevant test data or barriers with openings have successfully incorporated in Section !!LG. 7 ire qualification tests may be made." The interrupted the progress of many fires Protection of Safety Functions."

commenters felt that sufficient test data are avadaW to permit evaluation of provided the openings were properly Comment Resolut/on prutected by fire doors or other design requirements without full-scale Several commenters made a number mockup testing and that many of the acceptable means..

of suggestions of an editorial nature.

Items spelled out in the regulation, such Fire barriers are " rated" for fire resistance by being exposed to a One suggestion was to add "or unless as the water hose stream test, were too 4

" 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 Materials 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 barriers were rule to (a) require the use of Building Materials." Fire barriers are stipulated unless a lower rating was noncombustible materials only in the commonly rated as having a tire justified by the fire hazards analysts.

construction of fire barrier penetration resistance of from 1 to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. Most The Commission feels that this adds seals. (b) require fire barrier penetration

" improved Risk" or "Ihghly Protected nothing in the way of clarification 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) industrial 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 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

supporting any fire barrier have a fire Technical Basis. Door openings in fire While a nuclear power 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.

metallath 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 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> 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 bar-fers 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.

Many operating plants, or plants that excessively restrictive with regard to Comment Resolution are already built but that are not yet fire barrier penetrations, including fire operating. have both trains of safe doors and their associated frames and Many commenters stated that this shutdown equipment located in close hardware, and ventilation systems have requirement is too detailed and should proximity and a single fire could -

been acted upon by the staff and the be deleted. Minor editorial changes have damage or destroy the functional requirement, as it had affected these been made in order to more clearly state capabil?y of botti redundant trains. If items, was deleted.

the requirements.

epecific plant conditions preclude the N.Fim Barrier Cable Penetmtion Seal P. Reactor Coolant Pump Lubrication 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 separating redundant trains of safety-140 t: 220 gallons of tube oil. Oilleaking

- train will be considered the equivalent.

related or safe shutdown eqiJpment.

from some portions of the tube oil of 3-hour barrier.-

Ilowever, these barriers must be pierced system may come in cor. tact with if the 1-hour fire barrier and automatic for both conhol 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 equiva*ent 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 --..s--a----.-u.-

n Federal Register / Vol. 45. No. 225 / Wednesday. November 19, 1980 / Rules and Regulations 76609 would increase, severe lacalized pump oil collection system is covered by Capability.") In the fire hazards analysis environments would develop in the area paragraph C2 because its function is for a plant, the equipment relied upon to of the fir /. and a large amount of smoke required to protect safety-related perform both functions must be would be generated. These cor ditions sy ' ems rather than to perform a safety identified for each fire area. It follows could affect operability of safety related function. Because the fail ire of the oil that any associated non-safety circuits equipment inside containment, collection system for a scismically in the fire area that could adversely

%es efore, 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 feeding 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 from becoming a fire hazard by draining paragraph C2), the oil collection system or control circuits of that equipment 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 induced because the existing tube oil to a fire affecting safety-related disabling conditions must be prevented to provide assurance that the identified system piping and oil collection systems equipment as a result of an earthquake.

may not be designed to withstand a The proposed rule permitted two safe shutdown equipment will function design basis seimic event' alternatives-an oil collection system or as designed. These requirements have Appendix A to BTP APCS *3 9.5-1 an automatic fire suppression system.

now been incorporated in Section !!!.L.

We have deleted the alternative of the

" Alternative and Dedicated Shutdown stktes 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 safety-related systems from the burning concurrent with other plant accidents. or of oil before the suppression system is htany commenters stated that th,s i

the most severe natural phenomena 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 w thstand seismic events. In addition, consider associated circuits and this is, structures, and essential serv ces are these pumps are located within the therefore, a new design requirement.

designed to withstand earthquakes and biological shield inside containment.

The commenters felt that the analysis other natural phenomena. Second the history of many fires associated with therefore, timely fire brigade action that will be required to satisfy this recent earthquakes have been would be difficult if the suppression requirement will be both long and system malfunctions.Further,if the complicated and the requirement should evaluated.These evaluations showed suppression system becomes inoperable therefore be deleted.

mabieg s during operation, a fire watch or patrol The Commission rejected these f pi no anks o a s

cann t enter the area during operation.

suggestions for the following reasons.

or liquids such as municipal natural gas distribution systems or gasoline stor ge Comment Resolution

1. Virtually all of the fire protection and/or dispensing stations. Where such A number of commenters suggested mooifications made to date have been potential fire hazards exist in nuclear that this section is too deteiled and required to correct deficiencies that power plants (e.g., hydrogen for should be substantially modified. This resulted from lack of consideration of generator cooling, or oil fuel for the requirement was changed to delete the certain specific iterrs during laitial Emergency diesel generator or station option of protecting the reactor coolant design and construction.

space heating boilers) they are designed pump lubrication system with an

2. ne 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 te crevent the disabling of safety are prnvided as necessary. llowever.

system be designed to provide systems by a single fire. This has been General Design Criterion 2 Design Bases reasonable assurance that it will discussed with licensees during for Pmtection Against Natural withstand the Safe Shutdown evaluations of alternative and dedicated Phenomeno requires that structures.

Earthquake can be met by satisfying shutdown capability and !s necessary to systems, and components important to paragraph C2. of Reg.datory 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 affects of earthquakes without loss of described above.

of fire capability to perform their safety Q. Associated Cirruits.

3.Thie staff considers incomplete any function. Regulatory Guide 1.29.

7'echmcalBasis. When considering fire hazard analysis that does not Seismic Design Classification, the consequences of a fire in a given f. ire describes an acceptable method for area during the evaluation of safe e nsider the effects of fire damage to identifying and classifying those shutdown capabilities of a plant. the circuits that are associated with safe f2atures of light. 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 indicated above, as a result of the withstand the effects of th Safa 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 paragraph C1 applies to systems that by that fire. ne staff must also be able fact been adequately considered by Cre req' aired to remain functional to to conclude that damage to one train of licensees in their reviews using the ensure heat removal capability; equipment used for achieviv cold guidance of Appendix A to BTP APCSB paragraph C2 applies to systems that do shutdown will be limited so that the 9.5-1. To ensure tinat 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 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. (See nuclear power plants will be required to the functioning of those systems covered Technical Basis for Section III.G, meet the requirements of Section III.G of by paragraph C1. The reactor coolant

" Protection of Safe Shutdown Appendix R.

~

70610 Feder:t Register / Vol. 45. No. 225 / Wednesday. November 19. 1980 / Rules and Regulations CeneralComments Resolutwn shutdown capability. The Commission comments received on the proposed does not agree. We believe inat the regulations. other commenters Several commenters contended that Commission's overali fire protection demonstrated a thorough understanding Commission regulations mandate that program involvmg extensive plant.

of the proposed requirements.

en adjudicatory hearing be conducted specific fire protection modifications pursuant to the Atomic Energy Act of prior to a final decision. One commenter that are based on guidance set forth in 1954, as amended, the Energy labeled the regulation an " order ' within Branch Technical Position UTP ApCSD Reorganizstion Act of1974.as amended.

the meaning of the Administrative 9.5-1 and its Appwdix A and the and Sections 552 and 553 of Title 5 of the Procedure Act (5 U S.C. 551(a)) ( APA) and asserted that 10 CFR 2.204 of the specific requirements of Appendix R to United States Code, notice is hereby resolve disputed issues provide given that the following amendments to l

Commission's regulations. " Order for adequate fire protection.

Title 10. Chapter 1. Code of Federal J

Modification of License." apphes to this One commenter stated that the Regulations. Part 50, are published as a rulemaking proceeding.

ambiguity of the proposed regulation document subject to codification.

The Commission disagrees with these comments. A " rule"is defined in the - with regard to critical items requires

1. A new i 50.48 is added to read as that it be renoticed. The commenter follows:

APA to mean the whole or a part of an referenced three portions of the agency statement of general or proPo5ed Appendix R as exr.mples of particular applicabihty an.d future effect such ambiguity. They were Section til C.

(a) Each operating nuclear power Section III.N. and Section Ill.Q. We have plant shall have a fire protectica plan 8 d implem

. or d"Si "'g, taw or po,ent.

pre sc.ri icy,,

l5..C.

that satisfies Criterion 3 of Appendix A 4

les.

reviewed these exambrat example. theto this part. This fire protection plan 551(4)). The agency action questioned in reference to the here is clearly one that treats similarly commenter stated that the first shall describe the overall fire protection situated licensees equally and that paragraph of Section !!!.G identifies program foi the facil2y. identify the prescribes future conduct or alternative shutdown capability as an various positions within the licensee's require nents. For those licensees wh optional protective fea;.re and that organization that are responsibile for the have not already provided an equivalent paragraph !!!.G.2.c then identifies program. state the authorities that are level of fire protection, certain specific alternative shutdown capability as a delegated to each of these positions to fire protection features are required.

minimum fire protection feature. We do implement those responsibilities, and Various of these requirements would not agree ith this statement.The first,

outline the plans for fire protection. fire apply to approximately 40 facilities.The paragraph of Section Ill.G identifies detection and suppression capability, commenter's charac.*erization of the rule alternative shudown capability as one and limitation of fire damage.The plan as an order, along with the ansertion option in a combination of fire shall also describe specific features that to CFR 2.2t>4 mandates a hearing protection features for a specific fire necessary to implement the preg am area. Paragrapn Ill.G.3 indicates when described above, such as administrative nco c On t a e that gulation this option should be used.

comrols and personnel requirements for I

(which does grant a hearing nght) in reference to the second example, fire prevention and manual fire, aEplies only to Commissien orders that the commente? stated that Section Ill.N suppression activities, automatic and modi'y a license.81t does not apply t requires a pressure differential across rr.'nually operated fire detection and requirements promulgated through a the test specimen during the testing of suppression systems, and the means to rulemaking action conducted in fire barrier penetration seals but fails to limit fire damage to structures, systems, accordance with the requirements of define the pressure differentialThis or components important to safety so c mm nt is incorrect.The pressure that the capobility to safely shut down veral m nenters contended that differential called for by the proposed the plant is ensured.'

the environmentalimpact had not been provision was the maximum pressure (b) Appendix R to this part establishes adequately addressed. One commenter, differential that the barrier would fire protection features required to citing the requirements in Section Ill.A experience in the specific plant satisfy Criterion 3 of Appendix A to this of Appendix R for two water supplies installation. In any event, the part with respect to certain generic and two separate redundant sections as requirement for pressuro differential issues for nuclear power plants licensed examples of requirements involving during such testing has been deleted to operate prior to January 1.1979.

environmentalissues. contended that since only noncombustible materialis Except for the requirements of Sections the Commission relied upon its staff's now being used for such seals.

Ill.G, III.J. and !!I.O. the provisions of

' unsupported determination that, In reference to the third example, the Appendix R to this part shall not be 2

pursuant to 10 CFR l 51.5(d) an commenter stated that Section Ill.Q is applicable to nuclear power plants environmental impact statement.

totally lacking in definition. We do not licensed to operate prior to January 1, appraisal, or negative declaration is not agree, eootnote 6 references Regulatory 1979, to the extent that fire protection required.' The Coramission has G aide 1.75 and IEEE Std 384-1974.The features proposed or implemented by considered Section III.A and has further la tier document is a commonly used considered the remaining requirements it dustry standard that defines

> Basic tire prot,cuan smaance for nuclear power of Appendix R and remains convinced a isociated circuits and provides plants le contamed in two NRC documents-that the regulations are not substantive g.tidance for ensuring that such circuits

• Branch Techrucal Position Auuhary Power I

Conversio9 System Branch BTP arc 6B e s-1.

and are insignificam from the standpoint d a not compromise the independence of T"'d'.h""'""""""'""""*"

of environmento apact.

the shutdown circuits they are One com'nenter suggested that all associated with.

dee N 1E '""

plants be required to install dedicated Based on the chove examples and our

. Appendix A to BTP APCSB 9.5-1."Guadelsnes review of the other provisions of the for bre Protection for Nutlear Powar Plante weied %r to luly 1ss.- for plants thai were 811 should also be noted that i 2.204 is codified in proposed rule %e do not believe that opstma w undn unmutagu of dnisn m Subpart 8 of to CHL Part s. The scope of Subpart B 1ge fu}e as proposeg we8 amgiguous so construction before luly 1.197s. dated Ausust 21

's spotefically knuted ta cases innheted by the staff as to require renoticing. Moreover, at 19's.

• *

• to tenpose sequtweents by order on a heense6 tia CFR 2JM(eH. (F.mpheese suppued.)

should be noted that, based on other Also we Note t i

.-.n,.

n

.-w

FVderal Register / Vol. 45. No. 225 / Wednesdiy. Nosernher la 1980 / Rules and Regu!ations 76611 the licensee have been accepted by the after the effective date of this section determines. upon a showing by the NRC staff as satisfying the prosiuuns of and Appendis R to this part:

hcensee, that there is good cause for Appendis A to Isranch Technical li) the first refuelmg outage:

extendmg such date and that the public Position Ill P APCSil 9 bl

• reflected in lu) another planned outage that lasts health and safety is not adscrsely staff fire protection safety evaluatmn for at least 60 days. or affecmd b) such extension. Estensions reports issued pnor to the e ffectne date (tu) an unplanned out, age that lasts for of sui h date shall not eueed the dates of this rule or to ihe estent that fire at least 120 day s.

deterrnmed by paragraphs (cll1) through protection features were ai cepted by (4) Those fire protection features that (cl{4) of this section.

the st off in c.nprehensne fire require prior NRC approval by (1) Those fire protection features that protection safety evaluation reports paragraph (c)(5) of this section. shall be involse revisions of admimstratne issued before Appendix A to f1 ranch implemer'ed within the following controls, manpower changes. and To hnical Position IrfP APCS 119 51 schedule: Dedicated shutdown training shall be imp lemented within 4 was pubhshed in August two With

5) stems-30 months af ter NRC months after the date of the NRC staff respect to all other fire protection approval: modifications requinng plant Fire Protection Evaluatmn Report features covered by Appenda R. all shutdown-before startup after the accepting or requirma such features.

nuclear power plants licensed to operate earhest of the esents given in paragraph (2) Those fire protection features prior to lanuary 1,1T9 shall satisfy the (c)(3) commencmg 1H0 da)s af ter NRC involving installation of modifications

.epplicable requirements of Appenda R approval: modifications not requirma not requiring prior apprm al or plant to this part. including specifically the plant shutdown-+ months af ter NRC shutdown snall be implemented within requirements of Sections Ill.C, IH J, and approval.

12 months after the date of the NRC iggy (5)1.icensees shall make any staff Fire Protection Safety Es aluation (c) All fire protection modifications m Micanons necenary to comply with Report accepting or requiring such these requirements in accordance with fea tures.

require to satisfy the provisions of Appendix R to this part or directly e above schedule without prior review (3) Those fire protection features, and approval by NRC cuept fc' including alternatis e shutdown affecttd by such requirements shall be nmdifications required by Section 111 G 3 capability, ins olving installation of completed on the following schedule:

of Appendis R to this part. Licensees modifications requiring plant shutdown (1) Those fire protection features that shall submit plans and schedules for shall be implemented l'efore the startup involve revisions of administratise meeting the provisions of paragraphs after the earliest of the followmg events controls, manpower changes, and (c)(2). (c)(3). and (c)(4) within 30 da) s commencing 9 mooths 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 effectise date of this and Appendis R to this part. Licensees Safety Evaluation Report acceptmg or section and Appenda 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 refuelmg outage:

insolve installation of modifications that Il!.G.3 of Appendis R to this part within

[ii) Another planned outage that lasts do not require prior NRC approval or 30 days e frer the the effective date of for at least 60 days: or plant ? hutdown shall be implemented this section and Appenda R to this part.

(iii) An unplanned outage that lasts within 9 months after the effective Jate (6)In the event that a request for for at least 120 days.

of this section and Appendis R to this esemption from a requirement to comply (4) Those fire protection features part.

with one or more of the provisions of invo'ving dedicated shutdown capabihty (3) Those fire protection features.

Appenda R filed wnhin 30 days of the requiring new buildings and sptems except for those requiring prior NRC effective date of this rule is based on an shall be implemented withm 30 months approval by paragraph (c)(5) of this assertion by the licensee that such of NRC approval. Other modifications section, that involve inste tion of required modifications would not requiring NRC approval prior to modifications that do require plant enhance Lre protection safety in the installation shall be implemented within shutdown, the need for which is justified facility or that such modifications may 6 months after NRC approval.

in the plans and schedules required by be detrimental to oserall 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 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 esemption request upon a modifications needed to satisfy events commencing 180 day s or more determination by the t?irector of Nuclear Criterion 3 of Appendix A to this part in Reactor Regulation that the hcensee has accordance with the provisions of their

.ctanrwanon and swdance with respeti to prosided a sound technical basis for licenses.

pennissa atiernatars to s.tury Append, A to such assertion that warrants further

2. A new Appendix R is added to BTP APCSH 9 s-1 has been prmded in four other Staff review of the request.

to CFR Part 50 to read as follows:

W n atums amW Appendis R-Fire Protection Program for neary cuidance on tr!mmation by the NRC staffin Fire Pratcction.

Nuclear Power racilities Operatmg Pnor to

%cded r.r nee Protection Evalustrn." dated October 21.19's.

Safety Evaluation Reports referred to in January 1,1979

• %rr plc Tethmcal Spen 6catm c dated hto paragraph (b) of thi4 section and c 197 supplements to such reports, other than

/ Intmc'uction and scme

• Nudc4r Plant Mrc Protection bmotmnal features covered by paragraph (c). shall This Appenda apphes to hcensed nuclear Responmuties, Admmistratne control and be completed as soon as practicable but power electnc generat ng stations that were Quahiv As.urance. dated lune 14 19. '

operatmg pnor to January 1.1979 except to

• Mwpo.cr Regmrements for operanne no later than the completion date.

Reectors? dated May 11. tra.

eurrently specified in license conditions the estent set forth in paragraph 50.48(bl of this part With respect to certain genenc A Mee Protection Safeiy Evaluatm Report that of technical Specifications for such issue < for such 1.suhties it sets forth fire has been issued for cath operating plant states ho*

faciliiy or the date determined by proi,ction reaiores required to satisfy en r"e "" [i ot paragraphs (d)(1) through (d)(4) of this Cnterion 3 of Appenda A to this part.'

n fi n is sh b

resobed when the fanhty satishes the apprepnat, section whichever is sooner. unless the requirements of Appendra It to this part UlreCle7 of Nuclear Reactor Regulation see roetnoi,5

78612 Federd Rexistzt / Vol. 45. No. 225 / Wednesdn. November W.1980 / Rules and Regulatienn_,.

Critersrm 3 of Appendis A toihin part program shall4 stabhsh the fire protection D. Alternative otDed.coredShutdown specifies that %rrut.tures. systems and pohcy for the protectwn of strut.tures.

Capohdsry components important to safety sh41 be sy stems. and components important to safety in areas where the fire protection features desianed and lacated to mmimne, onsistent at each plant and the procedures. equipment.

cannut ensure safe shutdown capabihty in with other safety requirements. the and personnel required to amplement the the esent of a fire m that area, alternative or probability and effect of fires and program at the plant site.

dedicated safe shutdown capabehty shall be The fire protectien program shallbe onder presided.

empinsions?

the direction of an mdividual wh*3 h4s been When considenog the effects of are those Ill SF"C'II# N"9"##"*""'"

systems aw.r tWd with achiesing.and delegated authonty commensura'e with the maintaining safe shutdown constia ns responsituhties r f the position and who has A. Water Supphes for Are Suppression assume maior importance ta safety because asadable staff personnel knowirdyemble in Systems damage to them can feed to core d.. maw both fire protection and nuclear safety.

Two separate water supphes shall be resulting from loss of r.oolant throu ah bodoff ne fire protection program shall estend prouded to furnish necessary water volume The phrases "important to safety " or the concept of defense-m-debth to fire and pressure to the hre main loop.

" safety.related." wdl be used throu ghout this protection in f.re areas important to safety.

Each supply shall consist ni a storage tank.

Appendin R as applymg to a!! safet r with the fouowmg objectnes:

pump. pipmg. and appropriate isolation and functions. The phrase "safn shutdoun" wdl

• to prevent fires from starttng:

control salves. Two separate redundant be used throughout this Appendas } as e to detect rapidly, control and extmguish suctions in one or more intake structures applying to both hot and cold shutd iwn promptly those fires that do occur; from a large body of water (river. lake, etc.)

functions.

• to provide protection for structures, will satisfy the requirement for two separated Detause fire may affect safe shutlown sy stems, and components important to safety water storage tanks. These supphes shall be systems and because the loss of function of so that a fire that is not promp fy separated so that a failure of one supply will sy stems used to mitigate the consequences of extinguished by the fire suppression actiuties not result in a failure of the other supply.

design basis accidents under postfire will not prevent the safe shutdown of the Esch supply of the hre water datnbution conditiota does not per se impact puhhc plant.

system shall be capable of providmg for a safety, the need to hmit fire damage to ft Are Hazorals Analysis.

period of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> the maximum expected systetas required to achieve and snaintain 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 hmet fire damage to those systems systems engmeers to (t) consider potential in other areas that present a fire exposure required to mitigate the consequences of situ and transient fire hazards. (2) 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 estabhshed accordmg to the plant on the abihty to safely shut down service. water / fire. water uses the minimum the safety functinas of the structure. system.

the reactor or on the abihty to minimize and volume for fire uses shall be ensured by control the release of radioactivity to the means of dedicated tanks or by some or component:

environment; and (3) specify measures for physical means such as a vertical standpipe fire prevention, hie detection. bre for other water service. Administrative

--secy un m F o p wi.is

- suppression, and fire containment and.

controls,includmg locks for tank outlet alternatwe shutdown capabthty as required salses, are unacceptable as the only means nw seemem

. o. e w, m.no a.c.wn, is

"'=* 's" *d8c=

• • a " for each fire area containing structures, to ensure minimum water volume.

Other water systems used as one of the 7d".7,",7CZ systems, and componenta important to safety in accordance with NRC guidehnes and two fire water supphes shall be permanently s., w w a.

t, a w.

anuaas emoama *. '

regulations.

conr.ected to the fire main system and shall cme sesadama _ see.= ee.een.no a.

C. Are Preventhn Features tne capable of automatic alignment to the fire Fire protection features shall meet the mam system. Pumps. controls, and power

,4 n,.

,ng,.

followmg general requirements for all fire-supphes in these systems shall satisfy the wi w w. sw. mm osmap must

• • **d *a w. emes on. *aa areas that contain or present a fire hazard to requirements for the main fire pumps.The use of other water systems for fire protection

• • ",,,'*g** ",,",*,*,*.[M' *** structures, systems, or components important - shall not be incompatible with their functions

- to safety.

. Denga a -

acei v w

m n n.c.w v

1. In stu fire hazards shall be identified required for safe plant shutdown. Fadure of Q * **"*g**g and suitable protection provided, the other system shall not degrade the fire

2. Transient fire hazards associated with main system.

n. 4.m.,a e,.,,s'a.wou's normal operation. maintenance, repair. or B.Sectionallsolotson Valves w.

modification activities shall be identified anit Sectionalisolation valves such as post e.y a ehminated where possible. Those transient indicator valves or key operated valves shall e.cews F e

fire hazards that can not be ehminated shall be installed in the fire main loop to permit

.n, ve

., ma, ca,ons is w a

(*, g,*,,N, g a,J L. Q.nr,to newvdjg be controlled and suitable protection isolation of portions of the fire main loop for provided.

mamtenance or repair without interrupting

...ucem. e,s.ma a com.ca npon

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

gQy estmsmshers, and standpipe and hose C.1/ydront ho/otion vo/res a

e,c se.,

.no.

.,,,,n, c., ua eyoy stations shall be installed.

Valves shall be installed to permit isolation g%=* ' enes.y

4. Fire barners or automatic suppression cf outside hydrants from the fire main for The most stringent fire damage hmit shall systerns or both shall be installed as maintenance or repair without interrupting apply for those systems that fallinto more necessary to protert redundant systems or the water supply to automatic 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 ot er design

5. A site fire brigade shall be estabhshed, or presentmg a tire hazard to safety-related basis accidents but not necessary :or safe tra'ned, and eqmpped and shall be on site at or safe shutdown equipment.

8 all times.

DJfanuolrireSuppression -

shutdown may be lost to a single esposure fire. However protection shall be 3 rovided so

6. Fire detection and suppression systems Standpipe and home systems shall be that a fire within only on.r such sys tem will shall be designed. Install d. maintained. and installed so that at least one effectwe hose not damage the redundant system.

-- tested by personnel properly quahfied by stream will be able to reach any location that esperiente and training in fire protection contains or presents an exposure fire hazard.

{ II GeneralReguirements systems.

to e.fructures systems. or components A. Fire Avrection Angram

7. Surveillance procedures shall be important to safety.

A fire protection program shall b +

estabhshed to ensure thst fire barners are in Access to permit effective functioning of estabhshed at each nuclear power ilant.We 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 1

i j

\\

Federal Register / Vol. 45. No. 225 / Wednesday. November 19. 1980 / Rules and Regulations 76613 hazard to structures, systems, or components hour ratmg. In addition, fire detectors and an Institute for Occupational Safety and important to safety.

automatic fire suppression system shall be fiealth--approval formerly given by the U.S.

Standpipe and hose stations shall be inside installed in the fire area:

Dureau of Mines) shall be provided for fire pWR cor tainments and DWR containments Inside noninerted containments one of the brigade, damage control, and control room that are not inerted. Standpipe and hose fire protection means specified abovo or one personnel. At least 10 masks shall be stations inside containment may be of the following fire protection means shall available for fire brigade personnel. Control connected to e high quahty water supply of be provided:

room personnel may be furnished breathing 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 if plant-specific features associated non-safety circuits of redundant starage reservoir if practir.al. Service or rated prevent extenama the fire ma n supply inside tralas by a horizontal distance of more than operating hfe shall be a minimum of one-half containment. For BWR drywells, standpipe 20 feet with no intervening combustibles or hour for the self-contained units.

r:nd hose stations shall be placed outside the fire hazards; At kast two extra air bottles shall be dry well with adequate lengths of hose to

e. Installation of fire detectors and an located on site for each self-contained reach any location inside the dry well with automatic fire suppression system in the fire breathing unit. In addition, an onsite ethour en effective hose stream.

area; or supply of reserve air shall be provided and E.HydmstoricHose Tests I Separahon 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 a pressure of 300 psi or 50 psi above trains by a noncombustible radiant energy as they are returned. If cornpressors are used maximum fire main operatmg pressure, shield.

as a source of breathing air, only units whichever is greater. l'ase stored in outside

3. Alternative or dedicated shutdown approved for breathing air shall be used; hose houses shall be tested annually. Interior capability and its associated circuits.'

compressors shall be operable assuming a ttandpipe 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 Fire Detection consideration, shall be provided; of dust and contaminants.

Automatic fire detection systems shall be

a. Where the protection of systems whose

1. Fire Brigode Tmining 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 er of 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 operatmg with or without required for hot shutdown located in the instruction program followed by periodic cffsite power.

same fire area may be subject to damage classmom instruction, fire fighting practice.

G. Fire Protection ofSafe Shutdown from fire suppression activities or from the an.f r c drills:

Copability mpture or inadvertent operatiort of fire i astmetion

1. Fire protection features shall be provided suppression systems,

s. The initial classroom instruction shall 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 (t) Indoctrination of the plant fire fightmg shall be capable of limiting fire damage so ama. rpom. or zone under consideration.

plan with specific identification of each that.

11. hie Brigade individual's responsibilities.

a. One train of systems necessary to A site fire brigade 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 associatod types of fires that conditions from either the control room or adequate manual fire fighting capability for could occur in the plant.

emergency control station (s)is free of fire aU amas on 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 fighting equipment for each fire area and control room or emergency control station (s) and at least two brigade members shall have familiarization with the layout of the plant.

ccn be repaired within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, sufficient training in or snowledge of plant including access and egress routes to each

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

effects f fire and fire suppressants on safe (5) ne proper use of available Ere fighting this section, where cables or equipment, including associated non safety circuits that shutdown capability. The qualification of fire equipment and the corre method of fighting a mem sa e an annual each type of Gue We oUims coed could prevent operation or cause maloperation due to hot shorts, open circuits, phys.nl examination to determine their should include fires in energized electrical or shorts to ground. or redundant trains of abMy L perform stenuous fim fighting equipment, fires m cJles and cable trays, activities. The shift supervisor shall not be a hydrogen f:res, fires involving flammable and

d member of the fire brigade. The brigade combustible liquids or hazardous press h

wd n

the same fire area outside of primary leader shall be competent to assess the chemicals, fires resulting from construction or containment, one of the fo!!owing means of potential safety consequences of a fire and modifications (welding), and record file fires.

ensunng that one of the redundant trains is advise control room personnel. Such (6) ne proper use of communication, free of fire damage shall be provided:

competence by the brigade leader may be lighting, ventdation, and emergency breathing

a. Separation of cables and equipment and ev denced by possession of an operator's equipment.

tswciated non-safety circuits of redundant license or equivalent knowledge of plant (7) The proper method for fighting fires trrins by a fire barrier having a 3-hour rating.

safety-related systems.

inside buildings and confined spaces.

Structural steel forming a part of or The minimum equipment provided for the (8) The direction and coordination of the supporting such fire barners shall b?

brigade shall consist of personal protective fire fighting activities (fire brigade leaders equipment such as turnout coats, boots.

only).

protected to provide fire resistance gloves, hard hats, emergency communications (9) Detailed review of fire fighting equivalent to that required of the bart er-.

equipment. nortable lights. portable strategies and procedures.

b. Separation of cables and equirment anr1 ventdation equipment, and portable (10) Revieve of the latest plant (ssociated non safety circuits of redundant tr: ins by a horizontal distance of more than extinguishers. Self-contained breathing modifications and corresponding changes in 20 feet with no intervening combustible or apparatus using full. face posFve-pressum fire fighting plans, fire hazards. In addition, fire detectors and an masks approved by NIOSII(National Note.-Items (9) and (10) may be deleted tutomatic fire supgesion system shall be from de training of no more than two of the inst in t e 7 ire area; or e Alternative shutdown capabihty is provided by reroutmg. relocating or modacatma of existing non-ope ations personnel who may be r

c. Enclosure of cable and equipment and systems; dedicated shutdown capabihty is prowtied

• • • i "ed ' G' fim bd8'd' 8

(ssociated non-safety circults of cne by instalhns new structures and systems for the

b. The instruction shall be provided by redundant train in a fire barrier having a 1 funcnon of post fire shutdown.

qualified individuals who are knowledgeable.

y 76614 Federal Register / Vol. 45. No. 225 / Wednesday. November 19, 1980 / Rules and Regulations esperienced. and suitably trained m i;ghting bnsade. and selection. placement and use of required additional fire protection m the the types of fires that could occur in the plant eqeipment. and f re f:ghtmg strategies work actiuty procedure.

and m uomg the types of equiprient avadable (21 Assessment of each bngade member's

5. Govern the use of ignition sources by use m the nuclear power plant.

knowledge of his or her role m the hre of a flame permit system to control welding.

c. Instructmn shall be prosided to all fire I,ghtmg strategy for the area assumed to flame cuttmg. brarmg. or se!derine brigade members and fire bngade leaders.

contam the hre. Assessment of the brigade operations. A separate penmt shall be issued C Regular planned meetmas shall be held member a conformance witlr estabbshed for each area where work is to be done. If at least escry 3 Months for all bngade plant hre fightmg procedures and use of fire work contmues oser more than one shift. the members to review changes m the fire f;ghtmg equipment. mcludmg self-contained permit shall be vahd for not more than 24 protection program and other subjects es emergency breathing apparatus, hours when the plant is operating or for the communication equipment, and sentilation duration of a particular job dunna plant nece ssary.

e. penodic refresher trammg sessions shall equipment to the extent practicable.

shutdown.

be beld to rapeat the classroom mstruction (31 The simulated use of hre f ghtmg

6. Control the removal from the area of all program for all brigsde members over a two-equipment required to cope mth the situation waste, debns. scrap od spills. or other par penod Thse sessions may be and type of hre selected for the dnll.The combustibles resultmg from the work actmty concurrent with the regular planned area and type of fire chosen for the dnll immediately following completion of the should differ from those used m the previous actmty, or at the end of each work shift meetmgs.

2. Pructice drill so that bngade members are trained m w hiches er comes first.

practice sessions shall be held for each figh'mg hres in vanous plant areas. The

7. Maintain the periodic housekeeping shift fire brigade on the proper method of situation selected should s:mulate the size inspections to ensure contmued comphance fightmg the vanous types of fires that could and arrangement of a fire that could with these admmistratne controls.

occur in a nuclear power plant These reasonably occur in 'he area selected.

8 Control the use of specific combust bles i

sessions shall provide bngade members with allowmg for hre development due to the time m safety-related areas. All woud used in espenenre in actual hre estmguishment and required to respond to obram equipment and safety-related areas dunng mamtenance.

the use of emergency breathing apparaius organize for the fire. assummg loss of modification, or refuehng operations (such as

.nder strenuous conditions encountered in automatic suppression capabihty.

lay-down blocks or scaffoldmg) shall be hre fighting. These practice sessions shall be (4) Assessment of bngade leader's treated with a flame retardant. Equipment or pnnided at least once pcr year for each fire direction of the fire fightmg effort as to supplies (such as new fuel) shipped m bnpJe member, thoroughness. accur acy. and effectiveness.

untreated combustible packmg containers

3. Dnlls t Records may be unpacked m safety.related areas if

a. nre bngade dnlls shall be performed in Indmdual records of traming provided to required for sahd operatmg reasons.

the plant so that the fire bngade can practice each fire brigade member. includmg dnli However, all combustible matenals shall be as a team.

cntiques. shall be maintained for at least 3 removed from the area immediately followmg

b. Dnlis shall be performed at regular years to ensure that each member receives the unpackmg. Such transient combustible intervals not to exceed 3 months for each training in all parts of the training program.

matenal, unless stored m approved shift hre brigade. Each fire brigade member These records of traming shall be as adable contamers. shall not be left unattended should participate m each dnll, but must for NRC review. Retramma or broadened dunna lunch breaks. shift changes. or other participate in at least two drills per year.

training for hre fightmg withm buddmgs shall similar penods. Loose combustible packmg A sufficient number of these dnlis, but not be scheduled for all those brigade members matenal such as wood or paper excelsior,or less than one for each shift hre brigade per whose performance records show polyethylene sheetmg shall be placed m year. shall be unannounced to determine the deficiencies.

metal containers with tight httmg self-closmg fire fightmg readiness of the plant hre

1. Emergency Lightmg metal covers.

bngade, bngade leader, and fire protection Emergency lightmg units with at least an 8-9 Control actions to be taken by an systems and equipment. Persons planning hour battery power supply shall be provided individual discovenng a fire, for esample, and authonzing an unannounced dnll shall in all areas needed for operation of safe riotification of control room. attempt to ensure that the responding shift f:re brigade shutdown equipment and in access and estmguish fire. and actuation oflocal fire members are not aware that a dnllis bema egress routes thereto.

suppression sy stems.

planned until it is begun. Unannounced dnlis K. Admmistrative Coorrois to. Control actions to be taken by the shall not be scheduled closer than four Administrative controls shall be control room operator to determine the need week s.

established to minimize f re hazards in areas for brigade assistance upon report of a fire or At least one dnli per year shall be contaming structures. s> stems. and receipt of alarm on control room annunciator performed on a "back shift" for each shift fire components important to safety. These panel f r example, announcmr ' cation of bngade.

controls shall estabbsh procedures to-hre ove: PA system, soundmg f2e alarms.

e. The drills shall be preplanned to 1, Gosern the handling and hmitation of the and notoymg the shift supervisor and the hre estabbsh the traimng objectives of the drill use of ordmary combustible matenals.

brigade leader of the type, size, and locatwn and shall be cntiqued to determme how well combustible and flammable gases and of the bre.

the training objectnes have been met.

hquids, high efficienc) particulate air and

11. Control actions to be taken by the fire Unannounced drills shall be planned and charcoalidters dry ion exchange resins, or bngade after notification by the control room cntiqued by members of the management other combustible suppbes in safety-related operator of a fire. for example, assembhng in a desig iated location, receiving directions staff responsibie for plant safety and fire areas.

protecticn. Performance dehciencies of a fire

2. Prohibit the storage of combustibles in from tt fire bngade leader. and dischargmg brigade or of individual fire bngade members safet).related areas or establish designated specifis fire fightmg responsibihties includmg shall be remedied by scheduhng additional storage areas with appropnate hre selectim and transportation of fire fighting trainmg for the bngade or members.

protection.

equipm nt to fire location. selectmn of Unsatisfactory dnll performance shall be

3. Govern the handhng of and hm;t protectn e equipment. operating instructions followed by a repeat dnll within 30 days.

tranrent fire loads such as combustible and for use af fire suppression systems, and use d At 3-year intervals. a randomly selected flammat '.e I qt. ids. wood and plastic of preplanned strategies for fightmg fires in unannounced dnll shall be entiqued by products, or other combustible matenals in specifx ereas.

quahfied indmduals independent of the buildmp containmg safet).related systems

12. Defme the strategies for fightmg hres in hcensee's staff. A copy of the wntten report or equipment dunng a!! phases of operating.

all safety.related areas and areas presenting from such individuals shall be asadable for and especially dunng mamtenance.

a hazard to safety.related equipment. These NRC review.

modifution. or refuchng operations.

strategies shall designate:

e. Unlls shall as a minimum include tb L Designate the onsite staff member

a. Fire hazards m each area covered by the following-responsible for the mplant hre protection specific prefire plans.

(1) Assessment of hre alarm effectiveness.

review of proposed work activities to identify

b. Fire extinguishants best suited for time required to nottfy and assemble fire potential transient fire hazards and cpecify controlling the fires associated wi h the hre t

l i

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=

I Federal Rexister / Vol. 45. No. 225 / Wednesday. November 19, 1980 / Rules and Regulations 76615 hazards in that area and the nearest location coolant level above the top of the core for separation and barriers between trays and of these extinguishants.

BWRs and be within the levelindication in conduits containin.t associated circuits of one

c. Most favorable direction from which to the pressurizer for pYJRs.

safe shutdown division and trays and attack a fire en each area in view of the

c. The reactor heat removal function shall conduits containing associated circuits or ventilation direction. access hallways, stairs, be capable of achieving and maintaining safe shutdown cables from the redundant and dotrs that are most hkely to be free of decay heat removal.

division, or the isolation of these associated fire, and the best station or elevation for

d. The process momtoring function shall be circuits from the safe shutdown equipment.

fighting the fire. All access and egress routes capable of providing direct readings of the shall he such that a postulated fire involving that invi Ive locked doors should be process variables necessary to perform and associated circuits will not prevent safe specifically identified in the procedure with control the above functions.

shutdown. "

the appropriate precautions and methods for

e. The supporting functions shall be M. Fire Barrier Cob /c Ihnetration Seal access specified.

capable of providmg the process conhng.

Qualification

d. plant systems that should lie managed to lubrication. etc.. necessary to permit the penetration seal designs anall utdize only reduce the damage potential during a local operation of the equipment used for safe noncombustible materials and shall be fire and the location of local and remote shutdown functions.

qualified by tests that are comparable to tests controls for such management (e g, any

3. The shutdown capability for specific fire used tu rate fire barriers. He acceptance hydraulic or electrical systems in the zone areas may be unique for each such arca, or it criteria for the test shall mclude:

covered by the specific f re fighting procedure may be one unique combination of systems

1. The cable fire barner 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 overpressuritation or electrical alternative shutdown capability shall be passage of flame or ignition of cables on the hazardst 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 nee l to be kept cool while fightmg a offsite power is available and where offsite required of the barrier; local fire. particularly hazardous power is not avadable for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

2. The temperature levels recorded for the combustibles that need cooling should be procedures shall be in effect to implement unexposed side are analyzed and designated.

this capability.

demonstrate that the maximum temperature

f. Organization of fire fighting bngades and

4. If the capabilitv to achieve and maintain is sufficiently below the cable insulation the asugnment of special duties according to cold shutdown will not be available because ignition temperature; and job title so that all fire fightmg 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 complemer.t. These duties include command maintain the hot standby or hot shutdown beyond the unesposed surface during the contrcl of the brigade, transporting fire condition shall be capable of maintaining hose stream test.

suppression and support equipment to the fire such conditions until cold shutdown can be N. Fin laws scenes, apolying the estinguishant to the fire, achieved. If such equipment and systems will I' ire doors shall be self-closing nr provided communication with the control room. and not be capable of being powered by both with closing mechanisms and shall be coordination with outside fire departments.

onsite and offsite electnc power systems inspected semiannually to verify that g potential radiological and tmic 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 follow;ng 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 opening as required in case of fire:

containment or smoke clearing operations.

be on site at all times.

1. Fire doors shall.be kept closed and

1. Operations requiring control room and

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

means te achieve and maintain cold manned location;

[ Instructions for plant operators and shutdown cor.ditions shall not be damaged

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

by fire: or the fire d. mage to such equipment inspecte I weekly to verify that the doors are 1 Alternative and DedicatedShutdown and systems shall be limited so that the m the closed position; Copabihty systems can be made operable and cold

3. Fire doors shall be provided with

1. Alternative or dedicated shutdown shutdown achieve 1 within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

automatic hold-open and release mechanisms capability provided for a specific fire area Materials for such repairs shall be readily and instected daily to verify that doorways shall be able to achiese and maintain available on site and procedures shall be in are free of obstructions; or subcritkal reactivity condnions in the effect to implement such repairs. If such

4. bre doors shall be kept closed and reactor, maintain reactor coolant inventory equipment and systems used prior to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> inspected daily to verify that they are m the tchieve and maintain hot standb> '

after the fire will not be capable of being closed position.

conditions for a pWR lhot shutdown ifor a powere.1 by both onsite and offsite electric D'I' e bngade leader shall have ready DWR) and achieve cold shutdown '

power estems because of fire damage, an access a keys for any locked Gre coom conditions within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and maintain colo independnet onsite powe-system shall be Areas protected by automatic total flooding shutdown conditions thereafter. Durir.g the provided. Equiprrent and systems used after gas suppression systems shall have postfire shutdown. the reactor coolant system 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> may be powered by offsite power electricdHy supervised self-closing fire doors process variables shall be maintained within e ily.

r shall satisfy option 1 above.

those predteted for a loss of normal a.c.

6. Shutdown systems installed to ensure O. W Mectwn System for Reactor power, and the fission product boundary postfire shutdown capability need not be

,"r t]ccolant pum shall be integrity shall not be affected; i.e., there shall designed to meet seismic Category I criten,a, be no fuel clad damage, rupture or any single failure cr:teria, or other design basis equ pped with a, oil collection system if the containment is not inerted during normal primary coolant boundary, or rupture of the accident criteria. except where required for containment boundary.

other reasons, e g because ofinterface with operatic a. The oil collection system shall be so designed. engineered and installed that

2. The performance goals for the shutdown or impact on existing safety systems. or failure voll not le id to fire during normal or functions shall be:

because of adverse valve actions due to fire design lusis accident conditions and that

a. The reactivity control function shall be damage.

ccpable of achieving and maintaining cold 7.The safe ahutdown equipment and shutdown reactivity conditions.

systems for each fire area shall be known to

' ^""' 'Ptable method of co plying mth this Jnnatn d be to mM RegulaMuide 1 M b.The reactor coolant makeup function be tsalated from associated non-safety shill be capable of maintaining the reactor circuits in the fire area so that hot sh 3rts.

$ $ h"

,$o,

N,"[*g'o", "

open cirCJits. or shorts to ground in the redundant safety divtsions are so protected that 8 As defined m the Standard Technical associated circuits will not prevent operation postulated fires affect trays from only one safety Specificatmne.

of the safe shutdown equipment.ne dmswn

9 e

76616 F; der:I Regi:t;r / Vol. 45. No. 225 / Wednesday. November 19, 1980 / Rules and Regulations there is reasonable assurance that the system wdl withstand the Safe Shutdown Earthquake '

Such collecnon systems shall be capable of collecting lube mi from all potential pressurized and unpressurized leakage sites m the reactor coolant pump lube oil systems.

Leakage shall be collected and drained to a vented closed container that r.an hold the entire lube oil system inventory. A flame a

arrester is required in the vent if the flash pomt characteristics of the oil present the hatard of fire flashback. Leakage points to be protected shall mclude hit pump and piping.

os erflow Imes. lube oil cooler. oil fdl and dram hnes and plugs. flanged connections on oil Imes, and lube od reservoirs where such festures exist on the reactor coolant pumps.

The dram hne sball be large enough to acwmmodate the largest potential oil leak.

(Sec.161b. Pub. L 83-703. 68 Stat. 948 sec. 201.1%b. L 91-438,88 Stat.1242 (42 U.S.C.

2201(b). 5841))

Dated at Washington, D.C this 17th day of November 1980.

For the Nudear Regulatory Commission.

Sarnuel I. Chilk.

Secretary of the Commission.

[FR Doc. m 361?s Filed ll-16-at e 45 amj sicusso cooE Tsso41-M f

4

• See Regulatory Guide FSeismH: Design Classification' Paragraph C1

f I

NOV 131980

-. T"Pf."?U;l FOR. :

Steve Scott, Chief, Occument Management Branch, TIDC FRQ1:

David P. tiotley, EMSD SUGJECT:

JUSTIFICATION ANALYSIS FOR REPORTING REQUIRD4EhTS IN ADPEliDIX R TO 10 CFR PART 50 Attached is a copy of the Report Justification Analysis for Appendix R -

Fire Prctection Program for Guclear Power Facilities Operating Prior to January 1, 1979.

Please arrange for appropriate GAG clearance.

Original Sisnea by D.P.Netley.

David P. Ictley Fire Protection Engineer Engineering Methodology Standards Branch Office of Standards Development

Enclosure:

T.cpcrt Justification Analysis bec:

R. Smith G. Arlotto W. Morrison J. Norberg D. Notley DISTRIBUTION CEt4 TRAL FILE SD RD SD RF EMSB SUBJ EMSB READ EMSB C 7O l'

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