ML20032B107

Requests Util Compare Plant Fire Protection Program W/ 10CFR50 App R.Deviations Should Be Identified & Justified

ML20032B107
Person / Time
Site:	Wolf Creek
Issue date:	10/21/1981
From:	Eisenhut D Office of Nuclear Reactor Regulation
To:	Koester G KANSAS GAS & ELECTRIC CO.
References
NUDOCS 8111040456
Download: ML20032B107 (19)

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Docket + File u m FRosa OCT 21191 LB#1 Rdg MSrinivasan DEisenhut/RPurple FRosa RLTedesco OParr BJYoungblood WVJohnston Docket No.

STH 50-482 GEdison NHughes MRushbrook RFerguson bcc:

Mr. Glenn L. Koester TWambach TERA Vice President, Nuclear VBenaroya NRC/PDR Kansas Gas & Electric Company GHarrison L/PDR 4

210 North tiarket Street PSears NSIC Wicnita, Kansas 07201 RAnand TIC RHVollmer ACRS (16)

Dear 11r. Koester:

RMattsor.

4 PCheck

Subject:

Appendix R of 10 CFR Part 50 - Fire Protection Rule The Commission published a revised Section 10 CFR 50.48 and a new Appendix R to 10 CFR Part 50 on November 19,1980 (45 FR 76602). This rule became effective on February 17, 1981, and it specifies certain fire protection features for operating nuclear power plants licensed before January 1979. The technical requirements stated in Appendix R were adopted after several years experience with the fire protection guidelines of Appendix A to BTP-ASB 9.5-1 in evaluating fire protection programs. A copy of the Federal Register Notice is enclosed (Enclosure 1).

The technical requirements of Appendix R to 10 CFR Part 50 are now being used

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as guidelines in our evaluation of the fire protection program for plants under review for operating. licenses.

It has been our recent practice to perform the fire protection reviews for OL plants using the provisions of Appendix R.

Accordingly, as part of your overall fire protection program submittal, we request that you include a comparison of your fire protection program to Appendix R to 10 CFR Part 50.

Specifically identify and justify any deviation from Appendix R.

Deviations from Appendix R should be identified as early in the review process as possible, so that they may be resolved and all fire protection features be implemented by the time the plant is ready for fuel loading.

If you have any questions on this subject, please contact the IRC Project lianager for your facility.

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1 The reporting / record keeping requireraents associated with Appendix R of 210 CFR 50 inave been approved by the Office of Management and Budget under

approvea number 3150-0011 which expires Septeober--30,1983. - Coments on burden and duplication nay be directed to the Office of Managecent and 4

Budget, Reports Management Room 3208, New Executive Office Building, Washington, D. C.

-20503 Sincerely, hb0 Darrell G. Eisenhut, Director Divis'on of Licensing Office of Nuclear ~ Reactor Regulatten I

Enclosure:

4-Notice of Fire Protection

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Mr. Glenn L.- Koester Vice President Nuclear Kansas Gas and Electric Company 201 North Market Street P. 0.-Box 208 Wichita, Kansas 67201

.4 cc: Mr. Nicholas A. Petrick Hs. Wanda Christy Executive Director, SNUPPS 515 N. Ist Street.

5 Choke Cherry Road Burlington, Kansas 66839 Rockville, Maryland 20750 t

Eric A. Eisen, Esq.

Mr. Jay Silberg, Esquire Birch, Horton, Bittner & Monroe Shaw, Pittman, Potts & Trowbridge 1140 Connecticirt Avenue, N. W.

1800 M Street, N. W.

Washington,'D. C.

20036 Washington, D. C.

20036 Kansans for Sensible Energy Mr. Donald T. McPhee P. O. Box 3192 Vice President - Production Wichita, Kansas 67201 Kansas City Power and Light Company 1330 Baltimore Avenue P. O. Box 679 Kansas City, Missouri 64141 Ms. Mary Ellen Salva Route 1, Box 56 Burlington, Kansas 66839 Ms. Treva Hearne, Assistant General Counsel Public Service Commission P. O. Box 360 Jefferson City, Missouri 65102 Mr. Tom Vandel Resident Inspector / Wolf Creek NPS c/o U.S.N.R.C.

P. O. Box 1407 Emporia, Kansas 66801 Mr. Michael C. Kenner Wolf Creek Project Director State Corporation Commission State of Kansas Fourth Floor, State Office Bldg.

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70002 Fedeial 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 COGANISSION 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 developmg fire protection documents. These general provisions requirements since 1975, The NRC gave rise to a numoer of disputes over Fire Protection Program for Operatin9 published comprehensive fire protection whether specific methods adequately Nuclear Power Plents guidelmes. Branch Technical Position accomplished the intended goal. ne Asseecv: Nuclear Regulatory BTP APCSB 9.5-1, and its Appendix A in proposed rule is intended to previde Commission.

1976. Licensees have compared their fire sufficient specific guidance to ensure ACTIOor: Final rule' protection programs against these satisfactory resolution of these issues.

guidelines and have discussed their Thus, reverting to generalized guidance suasesAny: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 purpcse 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 ruclear 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 onnecessary and upgrade fire protection at nuclear power supplements to the Safety Evaluation unintended restrictions. For example, plants licensed to operate prior to Report. have been issued for each the proposed rule called for a " fresh January 1,1979, by 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 satisfactcry ano a fire protection safety evaluation reports.

have been proposed by the licensee and

" fresh" water supply is unnecessary, arreCreva oATE: 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 m " underground" yard fire main loop.

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

resolving those issues. Thus, it concerns intended to prohibit running portions of 3512).The date on which the reporting only a limited number of issues derived a fire main loop above ground. Other requirement of this rule becomes from the use of the earlier guides. The similar changes are discussed in Section effective, unless advi ed to the contrary, Ccmmission believes that a 30-day III. " Specific Requirements," of this reflects inclusicn of the 45-day period comment period was adequate under preamble.

that statute allows for such review (44 these circumstances.

The third issue relates to impos., tion of U.S.C. 3512(c)(2)).

2. Many licensees questioned the need requirements on plants with presently installed or with existing commitments FOR FURTHeR Ip6FOpedATION CONTACT:

for backfitting all the requirements of to install fire protection features David P. Notley. Office of Standards Appendix R.They commented that they db t e Development. U.S. Nuclear Regula tory had previously complied with staff fire

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Commission Washington. D.C. 20555, protect.on recommendations in ' good BTP APCSD 9.5-1.The Commission phone 301-443-5921 or Robert L faith and have committed to or generally agrees that. except for three Ferguson. Office of Nuclear Reactor completed certam modifications. They

!!egulation. U.S. Nuclear Regulatory contend that the staff has properly

[p' di ld no be tr actively Commission. Washington. D.C. 20555, determmed that these modifications applied to features that have been phone 301-4924096.

provide at least the level of fire previousiv approved by the NRC staff as suppt.anssNTARY INFOMsAATiosc On May protection described by the guidance satisfy ng the provisions of Appendix A

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29,1980, the Nuclear Regulatory contained in Appendix A to Branch to BTP APCSB 9.5-1 Commission published in the Federal Technical Position UTP APCSB 9.5.-l.

Th6 NRC staff had intended,in its Register (45 FR 3e082) a notice of They also contend that these ori;inal proposal for Apper. dix R that 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 resolutian of unresolved disputed proposed rule by June 30,1980. The contained in the proposed rule. They fire protection features. Thus, the staff notice concerned proposed amendments express the concern that the proposed had not intended the provisions of to 10 CFR Part 50, " Domestic Licensing rule was written in such specific Appendix R to require modification of of Production and Utilization Facilities,"

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

three substantive contentions which rewritten to specify only the general in cetermining whether the specifia were raised by many of the commenters. requirements of what needs to be requirements of Appendix R should be

'Ihese three comments are summarized accomplished.

imposed on licensees with presently as follows:

These comments raise three related installed or existir.g commitments to

1. Most commenters stated that the 30 issues.The first relates to the need for install fire protection features previously day c6mment period was too short to specific requirements. The general determined to satisiy Appendi< A to persait adquate detailed response and requirements relating to fire protection Branch Technical Position DTP APCSB

Federal Register / Vol. 45 No. 22A / Wednesday. November 19, 1980 / Rules and Regulations 78603 9.hl, 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 fire suppression system. The staff the specific items contained in the more of some separate effects tests, the staff has also accepted an automatic fire comprehenswe document, Branch changed its position on this suppression system as an acceptable Technical Position BTP APCSB 9.b1 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 APCSD 9.b1 has been the basic fire additional protection in the form of fire concluded that fire suppression systems protection guihnce 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.C of previously approved suppression licensees proposed systems and features Appendix R. Appendix A to B anch systems should be replaced with oil

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that satisfactorily achieved the fire Technical Position BTP APCSB 9.5.1 and collection systems that can withstand protection criteria set forth in Appendix the proposed Appendix R recognized seismic events.

A to BTP APCSD 9.b1 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 identical discussed in Section !!I. " Specific Satisfactory features and sptems are to tho6e listed in Sa. lion 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 l

trap ementation schedule contained in many plants. There is a reasonable protection features were developed by 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 D'IP as providing equivalent protection to the implementation schedule in the effective APCSB 9.b1. In general, the features requirements of Section III.G to rule is the same, as that in the proposed previously apprcved 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 operatmg criteria of Appendix A to BTP APCSB the parameters that are important to fire nuclear power plant, or process 9.5-1 provide an equivalent level of fire protection and consistent with safety exemption requests.

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

configurations have not been developed. the implementation schedule should be Thus, the further benefit that might be In light of the experience gained in fire rewritten to allow an adequate time provided by requiring that previously protection evaluations over the past four priod for compliance.The proposed rule approved features be modified to years, the Commission believes that the stated that "all fire protection and conform to the specific language set licensees should reexamine those m difications identified by the staff as forth in Appendix R is outweighed by previously approved conf:grations of newssary to sahfy Criterion 3 of the overall benefit of the early fire protection that do rw? wet the Appendix A to this part, whether implementation of such previously requirements as specified e W6n c ntained in Appendix R to this part or approved features, which in many cases I!!.G to Appendix R. Based on e it other staff fire protection guidance are currently being installed.

reexamination the licensee ra uther (ewrt f r a ternate or dedicated fy"h["j,",P hu le ompleted Nevertheless, as a result ofits meet the requirements Mection !!! C of or g continuing review of fire protection Appendix R or apply for an exemption matters. th,e NRC staff has mdicated to that justifies alternatives by a fire cause shown, the Commission approves the Commission that there are,

hazard analysis. Ilowever, based on nn ntension,"(proposed paragraph requirements m three sections m which present information the Comm:ssion sa461.(c)). The Commission went on to state its intention in the Statement of the protection afforded by Appendix R uoes not expect to be able to approve Consideration to the rule that ".. no over and above that previously exemptions for fire-retardant coatmg' plant would be allowed to continue to accepted, may be desirable.The used as fire barriers.

operate after November 1,1980, or Commission has decided that these The second relates to emergency beyond an extended date approved by requirements should be retroactively lighting.Section III.) of Appendix R calls the Comission, unless all modifications applied to all facilities. This decision is for 8-hour emergency lighting, whereas (except for altrmate 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

.e account the increased knowledge and 9.5-1. While an adequate level of safety implementation schedule and has experienen deseloped on fire protection may be provided by less than an 8-hour detern'ined that it should be modified matters over the last several years.

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

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

. After re.lewing the comments and fire protection features for ensuring that involve only a small cost. The the informelion 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 tha distance to protection redundant lubrication oil (Section III.O of Commission that it would expect systems (Appendix A, D.1(2, and nach Appendix R). The proposed rule virtually all licensees to request

79tl04 Federal Register / Vol. 45. No. 225 / Wednesday November 19. 1980 / Rules and Regulations exemptions if the new implementation Section ill, we provide a summary of the automatic water suppression system dates do not provide an appropriate Techmcal 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 staff's is set aside and dedicated for fire and rantower resources needed by the disposition of those comments. protection uses to be available at all times regardless of other simultaneous hcensees to prepare such requests and Section 1. Introduction ork/ Scope water uses in the plant. This water by the staff to formulate recoramendations 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 co.nments to include a means of separate storage tanks or timely fire protection improvement. discussion of the importance of safe separate pump suctions from a large + The revised implementation shutdown capability and the distinction body of water. When common tankage schedule provides a careful balance of between requirements for " safety-is employed for fire service needs and these considerations, calling for the related" equipment and equipment other water services, the fire pump remaining fire protection modifications needed for " safe shutdown" suctions must be at the bottom of the tank and other water supply suctions g to be implemented and installed on a Section II. Genera / Requirements must be located at a higher level to phased schedule that is as prompt as This section has been substantially ensure that the minimum dedicated can be reasonably achieved. 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 nrotection needs. Administrative first time on the licensee by Appendix R requirements.The specific requirements controls by themselves, such as locked and those requirements already imposed were consohdated with the appropriate valves to ensure adequate water supply in license conditions or Technical parts of Section !!!. " Specific for fire fighting needs, are deemed Specifications issued prior to the Requirements." except that the credit unacceptable at nuclear power plants. effective date of the rule. For given for Efoot separation has been Comment Resolution requirements imposed by Appendix R. dropped. Many commenters stated that we including the itens "backfit" to all Section III. Specific Requirements were being too restrictive by stipulating plants, the schedule provides a The requirements in this rule are an underground yard fire main loop and reasonable time after publication of the based upon principles long accepted fresh water supplies. Our inter.t was rule for completion of required within that portion of American industry only that a yard fire mah loop be modifications. For requirements already ! hat has been classified by their furnished. We have deleted the imposed by license canditions providing insurance carners as

• Improved Risk,,

specification for an underground loop for implemention after November 1, or "Ilighly rotected Risk". In each of since special conditions may dictate that p 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 decided that the overall interest of inside safety.related buildings. Such some instances the allotted time for completion of the required modifications public safety is best served by arrangements are acceptable. establishing some conservative level of With regard to the specification for a may be excessive.Thus, for fire fire protection and ensuring that level of fresh water supply, the staff was protection features other than those covered by Appendix R. although the compliance exists at all plants. The attempting to avoid potential plant Commission has extended the following is a list of the specific problems that are not associated with technical bases and resolution of public fire protection. From a fire protection - compliance dates beyond the November t 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. WaterSupp//es for Fire the fire protection system is designed existing licenses if such schedules Suppression Systems Technica/ Basis. 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 ressonable schedule requirements for a modern industrial supplies is therefore dropped. Other site in the United States is a separate operational problems unrelated to fire initially. Relief from such limitation may be granted by the Director of Nuclear water distribution system for fire protection that may result from the use Reactor Regulation upon a showing that protection with dual water supplies. of salt or brackish water for fire there is good cause for extending such Duplicate water supplies are required to suppression activities are outside the f 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 I and periodic maintenance and repair of the requirement for two separate I extension. 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 ose a single large intake structure imposed a schedule wi+h 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 l 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. g compliance dates by promulgating on distribution system is required to consist Several comments called for deleting [ October 29,1980, a temporary rule of a loop around the plant with suitable the requirements for dedicated tanks or i 50.48 (45 FR 71569). 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 staf!'s the various fire suppression systems in on the basis that this is overly restrictive resolution of these comments, the the plant. Thus, with dual supplies and a and other ways are availaole to ensure followmg section will consider each loop concept, an adequate water supply a dedicated supply sua as weirs, section of Appendix R to this part in can be ensured to each manual or suction location, etc. Iwo separate but

c Federal Register / Vol. 45. No. 225 / Wednesday. November 19, 1980 / Rules and Regulations 76605 related issues are involved here.The hour water supply is considered by a visually indicating or key-operated first !s the requirement for dedicated adequate. it should also be noted that (curb) valve." and there was an water storage tanks for fire fighting this minimum dedicated water volume is opportunity to comment on this purposes. The suggestion that the based on maximum flow rates. Since document. requirement for dedicated tanks be most fires are controlled and D. Manualfire 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 The 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. However, manual fire fighting activities D. Sectional / solation Valves. often can control and extinguish slowly suppression activities when storage tanks are used for combined service-C.HydrontIsolotion Valves developing fires before an automatic fire Technica/ Basis. These two suppression system is actuated. In water / fire. water uses.The term ( " vertical standpipe for other water requirerr-nts are similar and can be addition, fires that are controlled or i service" simply means that the suction treated together. Proper valving is extinguished by automatic systems for other water uses in common storage required to isolate portions of the water require a certain amount of manual tanks will be located sufficiently high to distnbution system for mamtenance 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 activit;es. If supply to manual or automatic fire automatic fire suppression systems. the commenters were assuming that suppression systems mside the plant. Manual response is the only fire " vertical standpipe" referred only to Valves are similarly required to permit suppression available for these areas: sotation of outside yard hydrants from pipes inside the tank, this is not the 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 maintenance or repair without areas of the plant, and that standpipe ^ storage tank is more desirable since any interrupting water supply to fire and hose stations be locatcd throughout leakage would be immediately evident. suppression systems inside the plant. the plant. The standpipe and hose On an internal standpipe a leak in the Visually mdicating valves such as post stations are to be located so that at least pipe could actually allow depletion of mdicator 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.The rule has been clarified to determmed. H wever, key-operated plant containing or presenting a hazard allow physical alternatives for water valves (commonly known as curb to structures, systems, or components i supply dedication but to preclude valves) are acceptable for these mportant to safety. They are to be exclusive use of administrative controls purposes where plant-specific supplied fium the fire water supply for this purpose. "s Some commenters objected to the jonbt system except f r those inside es-Comment c ntainment, which may be connected requirement that other water systems Resolution. Many coinmenters stated to ther reliable water supplies if a used as a backup water supply for fire that the requirement for " approved separate penetration into containment protection should be permanently visually indicating" sectional control cannot W made for fire water seMce 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 conne,cted to the fire main system within The Commission has accepted this Several commenters suggested adding ten ramutes of the loss of ncanal water suggestion; the rule now requires that a sentence reading " Standpipe and hose 8 supply or pumps.The rule does not sectional cor. trol valves shall be stations are not required if sufficient address backup water supplies. The provided to isolate portions of the fire justification can be provided that requirement ineans that. if another mam for maintenance or repair without adequate f,re protection features have water system is used as one of the shutting off the entire system. Post i redundant water supplies, it must satisfy indicator or key-operated valves are been provided to account for a given fire area." This suggestion was rejected.The all of the requirements of the fire mentioned as two examples of staff has taken the position that the protection water supplies. Additional acceptable valves. backup supplies need not meet these C. Hydrant Block Volves--Cominent minimum requirements are that at least one effective hose stream that will bc requirements. Resolution. A number of commenters One wmmenter 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 Pruns Ferry Fire lasted well over to state the requirement for capability to to the safety.related equipment. The two hon All of the investigations of isolate hydrar,ts from the fire main Commission concluded that no analyses a the Browns Ferry Fire clearly show that without disrupting the water supply to can identify hazards so carefully that if wats had been used immediately. the automatic or manual fire suppression this minimum requirement con be further reduced. fire would have been extinguished much systems in any area containing or i carher. Indeed once the manual fire presenting a fire hazard to safety-related F. flydrostatic / lose Test Technical fighting activities were started with the or safe shutdown equipment. Basis. Fire hoses should be use of anly one fire hose stream, the fire One commenter suggestad that this hydrostatically tested periodically to was estinguished within one-half hour. requirement be dropped in its entirety ensure that they will not rupture during The etaff would find unacceptable any since it "is a new requi ement 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 safa 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 BTP Association Standard No.19G-within two hours with any combination APCSB 95-1 contairis the following Stardard for Fire Hose). a nationally of manual and automatic fire sentence:"The lateral to each hydrant recognized consensus standard.His suppression activities. Therefore, a two-from the yard main should be controlled standard contains other guidance for the

78808 Federal 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 L Fire Brigade Training Technica/ - industries find useful. retained.The fire hazards analysis may Basis. Most modern industrial plants call for a separate suppression system, with replacement cost values Comment Resolution but this would be in additicn to the fire approaching those of a modern nuclear - Many commenters pointed out the detection system.. powered electric generating station have erroneous usage of the term " service G. Protection of Sofe Shutdown a full-time fully equipped fire pressure" rather than " operating Capability TechnicalBasis. The department,includmg motorized fire objective for the protection of safe apparatus. Because of the reduced pressure"in this requirement.The intended meaning for this requirement is shutdown capability is to ensure that at severity of fire hazards in a nuclear that all hoses would be tested at a least one means of achieving and generating station as compared to a pressure greater than the maximum maintainmg safe shutdown conditions manufacturing plarit, the Commission pressure found in the fire protection will remain available during and after believes that it is not necessary to water distribution 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 inn so changed,In addition. conditions under which fires may occur capabihty is required at a nuclear plant ) the staff aAled a mecific rninimum 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 need. The Commission has determined - the NFPA standard. than the design basis fire.Three One commenter also pointed out that diff< rent means for protecting the safe that a brigade of five persons constitutes the minimum size sufficient to perform hoses should be inspected for mildew, shutdown capabihty outside of rot cuts. or other damage. Although this containment are acceptable.%e first the actions that may be required by the is a valid comment,it is not an means is separation of redundant safe brigade during the fire and to provide unresolved issue with any licensee so it shut:fown trains and associated circuits some margin for unanticipated events.8 need not be covered by this rule. In by means of 3-hour fire rated barriers. Similarly, the trair ing requirements fisted are considered the minimum addition, such inspections are almady The second means is a combination of needed to ensure that the fire brigade being performed m accordance with the separation of redundant safe shutdown will be able to function effectively plant's Technical Specificaitons. trains and associated circuits by a 1 hour fire rated barrier and automatic fire during a fire emergency. F. Automatic Fire Detection Techm. col The proposed rule required emergency Basis. The requirement that automatic suppression and detection capability for breathing apparatus without specifying fire detection systems be installed in all both redundant trains. The third means. the number of such pieces of apparatus. areas that contam safe shutdown or which may be used only when The rule has been modified to specify safety.related systems or components redundant trains and associated circuits the personnel for whom such apparatus follows generally ar.cepted fire am separayd by 20 Ieet or mom of clear is to be provided and to specify reserve protection practice. Installation of such space. requires automatic fire fire detection capability is independent 'uppression and detection systems in lifire Brigade-Comment g i of any requirements for automatic or the area. An alternative or dedicated Reso/uticn. Many commenters suggested manual fire suppression capability in an safe shutdown capability independent of chaaging this requirement to a simple trea. ne purpose of these detection the fire area is required if fire protection statement that a trained and equipped, systems is to give early warning of fire f r safe shutdown capability cannot be nominal size. site fire brigade of five conditions in an area so that the fire provided as outlined above. For cables persons be provi led on each shift unless brigade can initiate prompt actions to minimize fire damage within the plant. and equipment needed for safe a lesser number is justified.This - shutdown located.nside of noninerted recommended change was rejected by mme ion contamments, a lesser degree oi fire the Commission for the reasons stated Many commenters suggested that the protection is permitted because in the Technical Basis. words " automatic fire detection tranuent exposure fires are less likely Some commenters objected to the capability" be substituted for mside containment during plant exclusion of the shift supervisor from " automatic fire detection systems" on operation. Section Ill M. " Fire Barriers.'. the fire brigade.The commenters felt the basis that, as worded, the discusses the techmcal basis for the 3-that the shif t supervisor should go to the requirements are too limiting. They hour barrier, and Section IllL fire and pro <ide the benefit of his stated that an automatic sprinkler " Alternative and Dedicated Shutdown expertise ar d authority. The rule would system with appropriate alarm check CapAility." discusses the techn cal not prevent this. However, the shift i valves and central ala m features basis for safe shutdown capability. . supervisor may have to go elsewhere p ovides acceptable detection /alarmmg comment geso/urfon during the course of a fire that advert capability. Several commenters claimed affects plant operation.The fire brigat 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 fusible link the rest of thi> section deleted.The responsibilities during a fire emergency, sprinkler heads. A fusible link has a basis for thet. contention is that the rule therefore. the sh2ft supervisor must be time delay before it actuates. Ilowever, should staN simply the requirement to excluded from rr.embership on the fire I more importantly, a smoldering protect cables or equipment of s) stems brigade. localized fire that could do damage may necessary for safe shutdown of the plant

1. Fire Brigade Training-Comment not generate enough ' eat to melt the nd 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 Wo have modified this section by a nis is discussed at length m the NRC stafre suppression system serves as removing the listing of considerations, " Evaluation of Mininum Fire Brisade Shift Size *. dated June a. to s; o, pies.r available from David notification that a fire exists we delet:ng Table I. and revising the concladed that the minimum wordmg to provide clarification. fis($*,M*,"d'j'['[,C'"N requirement for a separate fi e detection lifire Brigode. zess.

~ Federal Register / Vol. 45. No. 225 / Wednesday. November 19, 1980 / Rules and Regulations 78807 3 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 syst2ms are extensive, a classroom instruction, fire fighting have to be concerned with lighting in the dedicated system that is essentially a practice, and fire drills. Some area. The small cost differential minimum capability safe shutdown train commenters felt that these requirements between 2. hour supply and the and is independent of those already were more detailed than anything the substantial additional protection existing may be provided. This minimum Commission has published with regard afforded by the 8-hour supply does not capability is required to maintain the to operator training. The Commission warrant reducing this requirement.The process variables within those values here points out that most of the Commission has decided to require an s-predicted for a loss of offsite power. The investigations of the TMI accident hour battery power supply in all areas case ofloss of offsite power is assumed identified inadequately trained needed for operation of safe shutdown because fires in certain circumstances operators as an important factor and equipment and in access and egress (e.g, electrical distribution systems) that work is now being done in this routes. could cause or be related to such a loss. i area.%e fact is not that the training K. Administratire Contmis Technical Fire damage to cold shutdown capability requirements spelled out here for the fire Basis. The fire protection program uses is limited to damage that can be brigade members are excessive when administrative controls for fire repaired within 72 hours 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 tratnmg is further along in development, accepted within the fire protection associated diccits because most plants and training parameters that are community as minimum requirements were not designed with this concept in essential to a comprehensive program for an effective administration of the fire mind. Should either the alternative or have been identified. protection program. Controls are placed dedicated capability be required to ]

l. Emergency Lighting Technical on the storage and use of combustible function because of a fire,it must not be Basis. Emergency lighting is required in materials to reduce the fire loading in disabled by fire damage to associated 1

all nuclear power plants. Battery- . safety-related areas and on ignition circuits. Also, this capability does not pov.ered lights with capacities of 1% to sources to avoid careless operations. have to meet the single failure criterion 2 hours is usually sufficient for Procedures are used to control actions because it is only one of severallevels emergency egress. However, the postfire to be taken by individuals who discover of defense. Seismic Category I criteria is emergency lightmg requirements in a a fire and by the fire brigade for the not imposed because fires that would nuclear power plant are of a different development of preplanned fire fighting require the installation of alternative or kind.The need is for lighting that aids strategies and actual fire fighting dedicated shutdown capability are not the access to equipment and techniques. seismically induced. C ment Resoludon Comment Resoludon p ra e by a t pe onn 1 a ff ct safeplant shutdown during plant Many commenters stated that this Many of the commenters stated that emergencies. Because 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 should 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 ring conducted under the throughout the plant was sufficient, and Systemati: Evaluation Program (SEP). Comment Resolut.on that the details could be spelled out in a It is generally understood that cold Many commenters stated that the regulatory guide or some other similar shutdown is the ultimate safe shutdown requirement for emergency lighting is document. condition and that, for each fire area. ~ overly restrictive in three specifics: first. Minor changes have been made in the different means may be used and may that emergency lighting is unnecessary wording of this requirement for be necessary to achieve cold shutdown. In many of the designated areas: second. clarification. Because a fire in certain areas at some that the requirement for sealed beam or L Alternative andDedicated plants would have the capability of fluorescent units is overly restrictive: Shutdown Capability. disabling systems required to achieve third, that the requirement for individual TechnicalBasis. In some locations both hot and cold shutdown,it is i 8-hour bn ry 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, fiu: ummenters recommended a protect redundant safe shutdown rhutdown. We agree that evaluations l plant-specific power supply; and one systems against adverse effects of fire or being made under the Systematic '4 commenter recommended that there be fire suppression activities only through Evaluation Program (SEP) may also call no permanent installation, the use of fire protectian features for alternative or dedicated shutdown These suegestions have been accepted because the redundant safe shutdown capability for reasons other than fire in part. Ughung 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 i shutdown equipment and in access and be independent of the control roo'n. require additional modifications. Each egress routes thereto. The reasoning cable spreading room. switchgear rooms licensee ahuuld be aware of the status of i behind the requirement for an 8. hour and cable riser areas because redundant the SEP so that the requiremets battery power supply is that there can systems in thes.s areas are not resulting from SEP can he effectively be a great Jeal of other activ.ty during a adequately separated. When plant integrated with those relating to fire 4

i 7tl608 Federal Register / Vol 45. No. 225 / Wednesday,'Nosernber 19, 1980 / Rules and Regulations protecticn to the extent possitsle. required to ensure 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 complete the fire protection program suppression and detection capability for conduct the heat through the barrier, should not be deferred until the SEP 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. Fire Barriers. considerations. Automatic suppression the ASTM Standard E-119 relating to TechnicalBasis. The best fire is required to ensure prompt. effective temperature on the unexposed side must 4 protection for redundant trains of safe application of suppressant to a, fire that be appropriately modified. shutdown systems is separation by could endanger safe shutdown go,,,,, g,,,jyfjy, unpierced fire barriers-walls and capability. The activation of an ceiling. floor assemblies. Because these automatic fire detection or suppression Some commenters suggested that this barriers are passive fire protection system does not occur until sufficient entire section be deleted and replaced features. they are inherently reliable smoke or heet has been developed by with the following two sentences: provided they are properly installed and the fire. Therefore. the Commission is " Penetration seals shall provide the maintained. Fire barriers have been requiring a 1. hour barrier to ensure that equivalent protection which is required used successfe!!y for many yi ars 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 smaller. more acceptable risks. Even fire These requirements have now been resiew and relevant test data or barriers with openings have successfully incorporated in Section III.G. " Fire quaht'icanon tests may be made." The interrupted the progress of many fires Protection of Safety Functions." commenters felt that sufficient test data are,avadaMe to permit, evaluation of prouded the openings were properly gg,,g,, gy,gjy,jy, protected by fire doors or other design requirements without full. scale acceptable means. Several commenters made a number mockup testing and that many of the Fire barriers are " rated ' for fire of,aggestions of an editorial nature. items spelled out in the regulation. such resistance by being exposed to a Ont suggestion was to add "or unless as the water hose stream test, were too " standard test fire".This standard test other fire protection features have been detailed and did not belong in the fire is defined by the American Society provided to ensure equivalent regulation.The Commission has for Testing and 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 fire justified by the fire hazards analysis. construction of fire barrier penetration resistance of from 1 to 8 hours. Most The Commission feels that this adds seals. (b) require fire barrier penetration " Improved Risk" or "flighly 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. Fim Doors. have a resistance rating of 2 to 4 hours. supporting any fire barrier have a fire 7'echnical 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. metal lath and plaster covering as being been tested and rated for certain fire Therefore, the Commission has selected one means of providing equivalent exposures are installed to protect these 3 hours has been as an acceptable protection. Several commenters stated openings. Fire doors frequently fail to minimum fire resistance rating for fire that they thought this was too narrow protect the openings in which they are barriers separating redundant trains for and would be interpreted by some installed because they are not fully safe shutdown systems. This will give people as the only acceptable method closed. Various methods are available to ample time for automatic and manual permitted. Since the exam; le 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 i requirement was options are listed in Appendix R. Many operating plants, or plants that excessively ustrictive with regard to Comment Resolution l 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 rr. ore clearly state capability of both redundant trains.If items, was deleted. the raquirements. epecific plant conditions preclude the N. Fim Barrier Cable Penetration Seal P. Reactor Coolant Pump Lubricatiot' installation of a 3-hour fire barrier to Qualification. System. separate the redundant trains, a 1. hour ' TechnicalBasis. Unpierced fire TechnicalBasis. Each reactor roolant I 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 to 220 gallons of tube oil. Oil leakmg train will be considered the equivalent related or.afe shutdown equipment. from some portions of the lube oil of 3. hour barrier. Ilowever, these barriers must be pierced - system may come in contact witk If the 1. hour fire barrier and automatic for both control and power cables. surfaces that are hot enough to ignite the fire suppression for each redundant These penetrations must be sealed to oil. Tbi 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 p!snt-specific conditions, alternative or equivalent to that required of the barrier because of the time ru, med to enter the dedicated shutdowns capability will be that is pierced. ASTM Standard 3-119 is containment.Containeni it temperature

Federal Register / Vol. 45, No. 225 / Wednesday, November 19, 1980 / Rules and Regulations 76609 would increase, severe localized pump oil collection system is covered by Capability.")In the fire hazards analysis environmenta wo ild develop in the area paragraph C.2 because its function is for a plant, the equipment relied upon to of the fire and a large amount of smoke required to protect safety-related perform both functions must be . would be generated. These conditions systems rather than to perform a safety identified for each fire area. It follows could affect operability of safety-related function. Because the failure of the oil that any associated non-safety circuits equipment inside containment. collection system for a se.ismically in the fire area that could adversely Herefore, 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 lubrica3on 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 lacation.These occurrences should be designed, engineered, and must also be evaluated. Of course such q could be random or could be seismically matalled so that its failure will not lead disabling conditions must be prevented induced because the existing tube oil to a fire affecting safety-related to provide assurance that the identified system piping and oil collection systems equipment as a result of an earthquake, safe shutdown equipment will function may not be designed to withstand a The proposed rule permitted two as designed.These requirements have design basis seimic event. alternatives-an oil collection system or an automatic fire suppression system. now been incorporated in Section !!!.L. Appendix A toIrlP ApCSB 9.5-1 We liave deleted the alternative of the " Alternative and Dedicated Sh itdown states that for operating plants, suppression systern because Capability." , postulated fires or fire protection unacceptable dannage may result to the Comment Resolution system failures need not be considered safety-related systems from the burning concurrent with other plant accidents. or f il before the suppression system is Many commenters stated that this the most severe natural phenomena.. actuated and because the fire water requirement should be deleted because ne basis for that statement is two fold. supply system is not designed to many older plant designs did r.ot First nuclear power plants are massive withstand seismic events. In addition. consider associated circuits and this is, structures, and essential services 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 ana1ysis other natural phenomena. Second. the therefore, timely fire brigade action that will be required to satisfy th,s i history of many fires associated with w uld be difficult if the suppression requirement will be both long and recent earthquakes have been system malfunctions. Further,if the complicated and the requirement should evaluated. *lliese evaluations showed 8uppression system becomes inoperable therefore be deleted. that such fires usually are due to failure during operation, a fire watch or patrol The Commission rejected these of piping or tanks of flammable gasses cann t enter the area during operation. suggestions for the following reasons. or liquids such as municipal natural gas distribution systems or gasoline storage Comment Resolution

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

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 items during initial 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. The Browns Ferry fire showed the and installed to withstand the damagin8 automatic fire suppression system. We necessity of divisional separation of the effects of various natural phenomena.

have modified the rule to indicate that associated circuit of the control cables and other special fire protection features the requirement that the oil collection to prevent the disabling of safety are provided as necessary,llowever. system be designed to provide systens by a single fire. 'Iliis has been General Design Criterion 2 Design Bases reasonable assurance that it will dbcussed with licensees during for Protection Against Naturul withstand the Safe Shutdown evaluation = of alternative and dedicate:1 Phenomeno requires that structures. Earthquake can be met by satisfying shutdown capability and is necessary to systems, and components important to paragraph C2. of P.2gulatory Guide 1.29, ensure that safe shutdown systems will safety be designed to withstand the " Seismic Design Classification." as be able to function properly in the event effects of earthquakes without loss of described above. offre capability to perform their safety Q. AssociatedCir uits. 3.'lke staff considers incomplete any function. Regulatory Guide 1.29 TechmcalBasss. When considering fire hazard analysis that does not " Seismic Design Classification," the consequences of a fire in a given fire c nsider the effects of fire damage to describas an acceptable method for area during the evaluation of safe circuits that are associated with safe identifying and classifying those shutdown capabilities of a plant, the features of light-water-cooled nuclear staff must be able to conclude that one shutdown systems. O 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 the Safe immediately to bring the reactor to a hot comments received on this issue, it is Shutdown Earthquake. In this guide, shutdown condition remains unaffected unclear that associated circuits have in paragraph C1 applies to systems that by that fire.The staff must also be able fact been adequately considered by are required to remain functional to to conclude that damage to one train of licensees in their reviews using the ensure heat removal capability; equipment used for achieving cold guidance of Appendix A to IfTP APCSB paragraph C2 applies to systems that do shutdown will be limited so that the 93-1.To ensure that the associated not have to remain frunctional for that equipment can be returned to an circuits are considered, all operating pwpose, but whose failure could reduce operable condition within 72 hours. (See nuclear power plants will be required to the functioning of those systems covered Technical Basis for Section Ill.G, meet the requirements of Section III.G of by paragraph C1. The reactor cooiant " Protection of S ife Shutdown Appendix R. +

78610 Federal Register / Vol. 45, No. 225 / Wednesday. November 19, 1980 / Rules and Regul:tions GeneralComments Resolution; shutdown capability.The Commission comments received on the proposed does not agree. We believe that the regulations. other commenters Several commenters contended that Commission's overall fire protection demonstrsted a thorough understanding Commission regulations mandate that program involving extensive plant-of the proposed requirements. an adjudicatory hearing he conducted specific fire protection modifications, Pursuant to the Atomic Energy Act of rior to a final decision. One commenter fabe:ed the regulation an " order" w.ihin that are based on guidance set forth m 1954, as amended, the Energy Isranch Technical Position DTP APCSB Reorgamzation Act of 1974, as amended. the meaning of the Administrative 9.5-1 and its Appendix A and the and Sections 552 and 553 of Title 5 of the Procedure Act (5 U.S C. 55t(6}} ( APA) specifimquirements of Appendix R to United States Code, notice is hereby and asserted that 10 CFR 2.204 of the res Ive disputed issues provide given that the following amendments to Commission's regulations. " Order for Title 10. Chapter I, Code of Federal Modification of License," applies to this adequate firgrotection.WMad h b Regulahs, Part 50, are published as a e com rulemaking proceeding. ambiguity of%e proposed regulation document subject to codification. The Commission disagrees with these with regard to critical items requires

1. A new i 50.48 is added to read as comments. A " rule"is defined in the that it be renoticed. The commenter follows:

APA to mean "the whole or a part of an e e enc tr d o" agency statement of general or paea ples of 9 50.48 Fire Protection, particular applicability and future effect such ambiguity. They were Section !!LG, (a) Each operating nuclear power designed toimplement,, Section Ill.N. and Section Ill.Q. We have plant shall have a fire protection plan or prescribe law or poucy (5 U.S C. that satisfies Criterion 3 of Appendix A reviewed these examples. 551(4)). The agent y action questioned In reference to the first example, the to this part.This fire protection plan here is clearly one inat treats similarly commenter stated that the first shall describe the overall fire protection situated licensees equally and that paragraph of Section Ill.G identifies program for the facility, identify the prescribes future conduct or alternative shutdown capability as an various positions within the licensee's requirements. For tho +e licensees wh optional protective feature and that organization that are responsibile for the have not already provMed an equivalent paragraph Ill.G.2.c then identifies program, state the authorf ties that are level of fire protection, certain specific alternative shutdown capability as a delegated to each of these positions to fire protection features are iequired. minimum fire protection feature. We do implement those responsibilities, and Various of these requirements woule not agree with this statement. The first outline the,lans for fire protection fire apply to approximately 40 facilities.The paragraph of Section Ill.G identifies detection and suppression capability, commenter e characterization of the rule alternative shutdown capability as one and limitation of fire damage. The plan as an order, along with the assertion option m a combination of fire shall also describe specific features that to CFR 2.204 mandates a hearing protection features for a specific fire necessary to implement the program before the rule becomes finalis area. Paragraph Ill.G.3 indicates when described above, such as administratvo incorrect. On its face, that regulation this o tion should be used. controls and personnel requirements for (which does grant a hearing right) In reference to the second example, fire prevention and manual fire applies only to Commission orders that the commenter stated that Section III.N suppression activities, automatic and modify a license.81t does not apply t requires a pressure differential across manually 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 f re barrier penetration seals but fails to limit fire damage to structures, systems, accordance with the requirements of define the pressure differential.This or components important to safety so applicable law. comment is incorrect. The pressure that the capability to safely shut down Several commenters contendeJ that differential called for by the proposed the plant is ensured.8 the environmental impact had not been provision was the maximum pressure (b) Appendix R to this part establishes adequetely addressed. One commenter, differential that the barrier would fire protection features rec aired to citing the requirements in Section Ill.A experience in the specific plant satisfy Criterion 3 of Appe idix A to this of Appendix R for two water supplies instalb tion. In any event, the part with respect to certain generic i and two separate redundant sections as ,,q,g ,nent for pressure differential issues for nuclear power plants licensed examples of requirements involving dur,t.g such testing has been deleted to operate prior to January 1.1979. envirunmental issues, 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. Ill.J. and 111.0, the provisions of " unsupported determination that. In reference to the third example, the Appendix R to this part shall not be pursuant to 10 CFR l 51.5(d), an commenter stated that Section Ill.Q is applica.ble to nuclear power plants environmentalimpact statement, totally lacking in definition. We do not licensed to operate prior to January 1. appraisal, or negative declaration is not agree. Footnote 6 references Regulatory 1979, to the extent that fire protection required." The Commission has Gaide t.75 and IEFE Std 384-1974.The features proposed or implemented by considered Section Ill.A and has further letier document is a commonly used 4 considered the remaining requirements ir dustry standard that defines . Basic are proiection,maance fo, n ciear power of Appendix R and remains convinced a +sociated circuits and provides plants is contamed in two NRC documents: that the regulations are not substantive g tidance for ensuring that such circuits

• Branch Technical Position Aouillary Power I

Convermon System Branch BTP APCSB 9 5-1. and are insignificant from the standpoici d ) not compromise the independence of of environmentalImpact. the shutdown circuits they are

• • 'd',I""'""'*"'"N"*"'""*".
• "I"'#

One commenter suggested that all associated with. Sal",'[d Y'"" # ' plants be required to install dedicated Based on the above examples and our . Appendix A toirrP APCSBeF1."CcWhnes review of the other provisions of the for F!rt Protection for Nuclear Power Plante Docketed Prior ta fely 1J9?s." for plants that wew alt should also be noted that i 2.204 is codMed in proposed rule, we do not believe that UPerstmg or under vanous stages d demgn or Sobpart 5 of to Cm Part 1 The scope of Subpert B ige tuje as proposeg was amgiguouF %o construction W W MW6. dM August n la specifically lindled to " cases inittsted by the staff as to require renoticmg. Moreover,it ira.

• no n, e rewrem.nu by or*r on a heensar no tra taunten. (sephams suppheAl shocid be noted that, based on other Also see Note 4

Federal Register / Vol. 45. No. 225 / Wednesday. November 19, 1930 / Rules and Regulations 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 provisions of and Appendix R to this part: licensee, that there is good cause for Appendix A to Branch Technical (i) the first refueling outage:. extending such date and that the public Position DTP APCSB 9.5-1* reflected in (ii) another planned outage that lasts health and safety is not adversely staff fire protection safety evaluation for at least 60 days: or affected by such extension. Extensions - reports issued prior to the e ffective date (iii) an unplanned outage that lasts for of suchilate shall not exceed the dates of this rule, or to the extent that fire at least 120 days. determined by paragraphs (c)(1) through protection features were at cepted by (4) Those fire protection features that (c)(4) of this section. - the staff in comprehensive fire require prior NRC approval by (1) Those fire protection features that protection safety evaluation reports paragraph (c)(5) of this section, shall be involve revisions of administrative issued before Appendix A to Branch implemented within the following controls, manpower changes, and schedule: Dedicated shutdown training shall be implemented within 4 Technical Position IrTP APCSD 9.5-1 was published in August 1976. With systems-30 months after NRC months after the date of the NRC staff 4 respect to all other fire protection approval; modifications requiring plar.1 Fire Protection Evaluation Report features covered by Appendix R all shutdown-before startup after the accepting or requiring such features. earliest of the events given in paragraph (2) Those fire protection features nuclear power plants licensed to operate prior to january 1,1979 shall satisfy the (c)(3) commencing 180 days after NRC involving installation of modifications applicable requirements of Appendix R approval; modifications not requiring not requiring prior approval or plant. to this part,indading specifically the plant shutdown-6 months after NRC shutdown shall be implemented within requirements of Sections Ill.C,111], and approval. 12 months after the date of the NRC (5) Licensees shall make any staff Fire Protection Safety Evaluation !!! D. m difications necessary to comply with Report accepting or requiring such (c) All fire protection. modifications these requirements in accordance with features. require to satisfy the provisions of the above schedule without prior review (3) T!.ose fire protection features, Appendix R to this part or directly and approval by NRC except for including alternative shutdown affected by such requirements shall be m difications required by Section III.G.3 capability,involvmg matallation of completed on the fo!!owing schedule: of Appendix R to this part. ; 5censees modifications requirmg plant shutdown , (1)Those fire protection features that shall submit plans and schedules for shall be implemented before the startup mvolve revisions of admmistrative meeting the provisions of paragraphs after the earliest of the following events controls, manpower changes, and (c)(2). (c)(3), and (c;(4) within 30 days commencing 9 months or more after the training, shall be implemented within 30 after the effective date of this section date of the NRC staff Fire Protection days after the effective date of this and Appendix R to this part. Licensees Safety Evaluation Report accepting or section and Appendix R to this part. shall submit design descriptions of requiring such features: (2)Those fire protection features that modifications needed to satisfy Section (i) The first refueling outage; myolve installation of modifications that Ill.G.3 of Appendix R to this part within (ii) Another planned outage that lasts - do not require prior NRC approval or 30 days after the the effective date of for at least 60 days; or plant r.hutdown shall be implemented this section and Appendix R to this part. (iii) An unplanned outage that lasts within 9 months after the effective date (6) In the event that a request for for at least 120 der - of this section and Appendix R to this exemption from a requirement to comply (4) Those fire protection features - part. with one or more of the provisions of involving dedicated shutdown capability (3) Those fire protection features. Appendix R filed within 30 days of the requiring new buildings and systems except for those requiring prior NRC effective date of this rule is based c. an shall be implemented within 30 months approval by paragraph (c)(5) of this assertion by the licensee that such of NRC approval. Other modifications section, that involve installation of required modificaticas would not requiring NRC approval prior to modifications that do require plant enhance fire protec' ion safety in the installation shall be implemented within shutdown, the need for which is justified facility or that such nadifications may 6 months after NRC approval, in the plans and schedules required by be detrimental to overall facihty 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 exemption request upon a modifications needed to satisfy events commencing 180 da)s or more determination by the Director of Nuclear Criterion 3 of Appendix A to this part in Reactor Regulation that the licensee has accordance with the provisions of their provided a sound technical basis for licenses. a ctanfication and suidance with respect to permmible ehernatms to salidy Appendis A to such assertion that warrants further

2. A new Appendix R is added to arv Apan s s-s has been provided in four other staff review of the request.

10 CFR Part 50 to read as follows: E "U" "'" ** * 'E Appendix R-Fire P stection Program for

• w pie ntary Guidance on Information by the NRC staff in Fire Protection,

g,ci,,, p,,, y,c;;;,;,, op,,,,;,, p,;,,,, Needed for "tre Protection Evaluatinn? dated Safety Evaluation Reports referred to in lanuary 1.197s October 21. We 9

• '%r-pte Techmcal Specificatio i" dated May paragraph (b) of thi4 section and I /naducoon ondscope 12.1M supplements to such reports other than
• " Nuclear Mant Fire Peutectmn f unctional features covered by paragraph (c). shall This Appendix apphes to licensrl nuclear Respons.oihtees. Admimstratm Control and be completed as soon as practicable but power electric generating stations that were operating prior to lanuary L 1979. except to Quahty Assurance. dated lune te.1977.

no later than the compledon date the extent set forth in paragraph 50.48(bl of currently specified in license conditions A Fire Protection Safety Evaluetmn Report that or technical specifications for such I,pa h fac 1 tle it s Rea t ated y1 I s gf r forth has been mued for each operatins plant states how facility, or the date determined by protection features required to satisfy Paragraphs (d)(1) through (d)(4) of this Criterion 3 of Appendis A to this part.' $so fi e pr e is s a t de section, whichever is sooner, unless the resolved when the facdtty satisfws the approprtate reqmrements of Apcenden R to this part Director of Nuclear Reactor Regulation

• see footneve 4.

\\ i

w. 76612 Federal Register / Vol. 45. No. 225 / Wednesday. Nosember 19,198u, nu.es and Regulations Cnterion 3 of Appendis A to this part program shall estab;ish the fire protection D. 41ternative orDedicatedSbardown specifies that " Structures. systems and twhey for the ; rotection of sirsctures. Capability components important to safety sh.dl be n stems. and ccmponcNs important to safety in areas where the fire protet. tion features dessned and located to mmimize. onsistent at each plant and the procedures. equipment. cannot ensure safe shutdown capabdity in with other safety requirements. the and personnel acquired tm nplement the the esent of a fire in that area. alte natne or probabihty and effect of hres end prognm at the plant site dedicated safe shutdown capatahty shah be The f re protection program shat! be ender prended csplosions/' the duemon of an mdmdual wh'o has t'een /// Sperdic Requirements When considerms the effetts of ire. those systerns associated with achieving md delegated authonty commensurate with the maintaming safe shutdown conditrt n, responsibihties of the position and who has A. Water Supphes for Are Suppression assume major importance to safety bemuse asailable staff personnel knowledgeable m Systers damage to them can lead to core d. mae both fire protection and nuclear safety. Two separate water supphes shall be resultma frem loss of coolant throu gh bodoff. The hre protection program sha3 estend provided to furnish necessary water vclume s The phrases "important to safe *y ~ or the concept of defense 4n.debth to fire and pressure to the fire main loop. " safety-rated? wdl be used 6u thout this protection in hre areas important to safety. Each supply shall consist of a storage tank. Appen6 R as app!ymg to aU uret - with the followmg obtectives: pump. piping. and appropriate isolation and functions. The phrase " safe shutdoun" wdl

• to prevent fires from startmg:

control S alves. Two separate redundant be used throughout tNo Appendis F as

• to detect rapidly, control and extinguish suctions in one or more intake structures applyina to both hot and cold shutd awn promptly tha.e fires that do occur:

from a large body of water (river. lake etc.)

• to provide protection for structures, wdl satisfy the requirement for two separated functions.

Becausa fire erey af'ect safe shutdown rystems. and components important to safety water storage tanks. These supphes shall be systems and because the loss of function of so that a hre that le not promptly separated so thct a failure of one supply will systems used to mitigate the consequences of estingunhed by the fire suppression activities not result in a failure of the other supply. design basis accidents under postfire wdl not prevent the safe shutdown of the Each supply of the fire water distnbution system shall be capable of providing for a conditions does not per se impart pubhc plant. B. AreHarords Analysu period of 2 hours the maximum otpected safety, the need to hmit Gre damage to A fire hazards analysis shall be performe<l water demands as determined by the fire systema required to schieve and maintain safe shutdown conditions is greater than the by quahf.ed fire protection and reactor hazards analysis for safety.related areas or need to hmit fire damage to those systems systems engmeers to (1) consider potential in other areas that present a fire exposure required to mitigste the consequences of situ and transient fire hazards. (21 determine hazard to safety related areas. des:en basis accidents. Three fevels of hre the consequences of fire in any location in When storage tanks are used for combined damage hmits are estabhshed accordmg to the plant on the abihty to safely shut down service. water / fire-water uses the mimmum the reactor nr on the abihty to mimmize and volume for fire uses shall be ensured by the eCety functiors of the structnr. system. control the release of radicactaity to the means of dedicated tanks or by some or component; environment and (3) specify measures for physical means such as a vertical standpipe hre prevention. fire detet. tion, fire for other water service. Admimstrative suppression and fire contamment and controls. includmg locks for tank oudet sees, owinen ne ee e. e, abernative shutdown capabihty as required s alves, are unacceptable as the only means a si w on. v.a or.w,e a.c , e .cm. w swoma **' ***' for each fire area contaming structures. in ensure minimum water volume. f Other water systems used as one of the ,',,Z",' g",.ZZ systems, and components important to sa ety in accordance with NRC guidelmes and two fire water supphes shall be permanendy e or w o. ti,a woww. connected to the fire main system and shall .'cusag. m co w. W ' regulations. ces er man.u_ seei v on.wnm nee ",'

• C. Fire Preunt on Features be capable of automatic shgnment to the fire

.acw. cosa. woo.a Fire protechon features shall meet the mam system. Pumps, controls, and power m. b. following general requirements for all fire supphen in these systems shall satisfy the ,,.a e,,.,q. w ,,me,,, sa _. - w ena a. mag. a%se

• • *'=.a no w a mesi w. e.*'

areas that contain or present a fire hazard to requirements for the mam fire pumps. The use of other water systems for fire protection

• • • **lC" *,**,*,,L'**

structures, systems, or components important sha'l rat be incompatible nth their functions ,,,,7 to safety.

1. In situ fire hazards shall be identified required for safe plant shutdown. Failure of av D= c a som

. ee.wom.e n.c ,y and suitable protection provided. the other system Uall not degrade the fire "9"

• • • • 3"*"

2. Transient fire hazards associated with mam system.

normal operahon. mamtenance, repair. or B.Sectionallsolation Vo/res

b. e.m.e.o by a wg=.ww.

w modification activities shall be identified and Sectionalisolatmn valves such as rost ag.y ebminated where possible. Those transient indicator valves ce key operated vahes sh a ew.w. aa. fire hazards that can not be eliminated shall be installed in the fire main loop to permit be controlled and suitable protection isolation of portions of the fire main loop for .,cm,on w a (* g4N,pgre. mamtenance or repair without interruptmg

== .uc provided. se cw.a wn a, ey, s. noon.,e e

3. Fire detection systems. pertable the entire water supply.

g yggoy extinguishers. and standpipe and hose C. Hydmnt Isolation volves

• • • e=a *** *wa.a' wme, ce<*w *mse=*

stations shall bc installed. Valves shall be installed to permit isolatmn .na, w ,ca e., 4 Fire barners or automatic suppression cf outside hydrants from the fire main for The most stringent fire damage hmit shall systenis or both shall be mstalled as mamtenance or repair without interrupting apply for those syst.ms that fallinto more necessary (2 protect rede dant systems or the water supply to automatic or manual fire than one category. Redundant systems used components necessary for safe shutdown. soppression systems in any area containing i A site hre bngade shall be estabhshed. or presenting a fire hazard to safety.related to mitigate the consequences of of er design trained. and equipped and shall be on site si or safe shutdown equipment. g basis accidems but not necessary :or safe D. Atonua/ Fire Supprenion all hmes. shutdown may be lost to a single esposure

6. Fire detection and suppression systems Standpipe and hose systems shall be fire. Howes er. protection shall be i rovided so shall be designed installed. mamtained and installed so that at least o,e effective how that a fire within only one such syrem wdl tested by personnel properly quahfied by stream will be able to reach any lo% tion that not damage the redundant system.

experience a ad traimns in fire protectir<n contains or presents an exposure fire bzard to structures, systems. or comp'nents l 11 Cenerallleguhements systems. A. Fire Pmtection Program

7. ssrveillance procedures shall be important to safety.

A fire protection program shall b. established to ensure that fire barriers are in Access to peimit effective functionmg of estabhahed at each nuclear power lant. The place and that fire suppression systems and the fire brigade shall be pmy'ded to all areas components are operable. that contain or p esent an exposure tre

Federal Register / Vol. 45, No. 225 / Wednesday, November 19, 1980 / Rules and Regulations 79613 hazard to structures, systems, or components hour rating. In additioe. fire detectors and an Institute for Occupational Safety and important to safety. automatic fire suppression system shall be llealth-approval formerly given by the U A Standpipe and hose stations shall be inside installed in the fire area: Bureau of Mines) shall tm provided for fire PWR containments and BWR containments inside noninerted containments one of the brigade. damage control, end control roar, that are not inerted. Standpipe and hose fire protection means specified above or one personnel. At least 10 maska shall be stations inside containment may Ne of the following fire protection means shall available for fire brigade personnel Ccntrol connected to a high quality waU 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 associsited non-safety circuits of redundant storage reservoir if practical Service or rated trains ' y a horizontal distance of more than operating life shall be a minimum of one. half prevent extending the fire main supply inside u

O containment. For BWR drywells. standpipe 20 feet with no intervening combustibles or hour for the self<ontained units. and hose stations shall be placed outside the fire hazards: At least 'wo extra air bottles shall be dry well with adequate lergths of hose to

e. Installation of fire detectors and an located on site fer each self<ontained reach any location inside the dry well with automatic fire suppression system in the fire breathing unit. In addition. an onsite e hour an effective hose stream.

area; or supply of reserve air shall be provided and E. flydmstoric flose Tests I. Separation of cables and equipment and arranged to permit quick and complete Fire hose shall be hydrostatically tested at associated non-safety circuita 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 compressors are used maximum fire main operating pressure, shield. as a source of breathing air, only units whichever is gnak Home

• red in onteid, 1 Alternative or dedicated shutdown approved for breathing air sha!! be used; hose houses shall be tested annually. Interior capability and its associated circuits.'

compressors shall be opera %Ie assuming a standpipe hose shall be tested every three independent of cables, systems or loss of offsite power. Special care must be years. components in the area, room or zone under taken to locate the compressor in areas free F. AutomaticFireDetection consideratioA shall be provided: of dust and contaminants. Autoraatic fire detection systems shall be

a. Where the protection of systems whose I.FimBrigade Tmining installed in all areas of the plant that contain function is required for hot shutdown does ne fire brigade ' raining program shall or present an exposure fire hazard to safe not satisfy the requir.rment of paragraph G.2 ensure that the capability la fight potential shutdown er safety-related systemi or of this section; or fires is established and maintained. ne components. These fire detectian systems

b. Where redundant trains of systems program shall consist of an initial classroom shall be capable of operstmg with or without mquired for hot shutdown loca'ed in the instruction progran. followed by periodic offsite po ver.

same fire area may be subject to damage classroom instruction. fire fighting practice. G. Fim Protecten of Sofe Shutdown from fire suppression activities or from the and fire drills: Copobility rupture or inadvertent operation of fire

1. Instruction

1. Fire protection features shall be provided suppression systems.

a. ne initial classroom instruction shall for structures, systems, and components in addition, fire detection and a fixed fire include:

important to safe shutdown. These,*eatures 8uppression system shall be installed in the (1) Indoctrination of the plant fire fighting shall be capable of limiting fire damage so area, room. or zone under consideration. plan with specific identification of each I1. Fire Brigade individual's responsibilities. that[. a One train of systems necessary to A site fire brigade trained and equipped for (2) Identification of the tge and location of achieve and mainiain hot shutdown fire fighting shall be established to ensure fire hazards and associated types of fires that conditions from either the control room or adequate manual fire fighting capabi:ity for could occur m the plant. emergency control station (s)is free of fire all areas of the plant contammg structures. (3) ne toxic and corrosive characteristica damage; and 8Ystenu. of components unpodant to sa4 of expected products of combustion.

b. Systems necessary 4 cchieve and he fire brigade shall be at least five (g) Identification of the location of fire maintain cold shutdown from either the members on each shift. ne 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, can be repaired within P hours.

su icient training m or knowledge of plant including access and egress routes to each

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

this section, where cables or equipment, effects of fire and fire suppressants on safe (5)ne proper use of available fire fighting including associated non-safety circuits that shutdown capability.ne qualification of fire equipme at and the correct method of fighting bngsde merr.bere shallinclude an annual each t pe of fire, ne types of fires covered physical examination to determine their sh6d include fires in energized electrical alop r ion du to o orts open circuits, ability to perform stenuous fire fighting er.iipment. fires m cables and cable trays. or shorts to ground, or redundant trains of. activities. ne shift supervisor shall not be a tiydrogen fires, fires involving flammable and systems necessary to achieve and maintain hot shutdown conditions are located within member of the fire brigade, ne brigade combustible liquids or hazardous process leader shall be competent to assess the chen icals, firew resulting from construction or the same fire area outside of primary potential safety consequences of a fire and modifications (welding), and record file fires. contairment. one of the following means of advise control room personnel. Such (6) ne proper use of communication, suri that one of h dundant trams is g pro competence by the brigade leahaay be lighting, ventilation. and emergency breathing

s. Separation of cables and equipment and evidenced by possession of an operator's equipment.

associated non. safety circuits of reoundant license or equivalent knowledge of plant (7) He proper method for fighting fires safety-related systems. inside buildings and confined spaces. trains by a fire barrier having a 3 hour rating. ne minimum equipment provided for the (a) ne direction and coordination of the Structural steel forming a part of or 1,rigade shall consist of personal protective fire fighting activities (fire brigade leaders ( supporting such fire barriers shall be equipment such as turnout coats, boots, onlyy protected to provide fire resistance gloves. hard hats, emergency communications (9) Detailed review of fire fighting equivalent to that required of the barn.er; equipment, portable lights, portable strategies and proced xres.

b. Separation of cables and equipment and ventilation equipment and portable (10) Review of the latest plant associated non-safety circuits of redundant extinguishers. Self-contained breathing modifications and corresponding changes in trains by a horizontal distance of more than apparatus using full-face positive-pressure fire fightmg plans.

20 feet woh no intervemrg combustible or masks approved by NIOSil(National fire hazards. In addition. fire detectors and an Note.-Items J. ) and (10) may be deleted automatic fire suppression system shall be from the training of no more than two of the installed in the fire area; or a Altemative shr%vn capatnhty is provided by non-operations personnel who may be reroutmg. relocatua r. mod 6cating of existing

c. Enclosure of cable and equipment and systems. dedicated shuthwn capatnhty is provided asMgned to the fire bdgade.

associated non-safety (ficuits of one by installms new structures and systems for the

b. The instruction shall be provided by redundant train in a fire barrier having a 1 function of posofire shumwn.

qualified individuals who are knowledgeable.

766M Federal Register / Vol. 45. No. 225 / Wednesday. November 19, 1980 / Rules and Raulations expenenced. and suitably tramed m fighting bngade, and setertion. placement and use of required additional fire protection in the the types of fries that could occur in the plani equipmeni, and fuc fightmg strategies. work actiuty procedure. and m usmg the types of equipment aulable (2l Assessmeat of each bngade member's

5. Govern the use of ignition sources by use in the nuclear power plai.t knowledge of his or her roie m the fire of a flame permit system to control welding.

c. Instruction shall be provided to all fire fightmg strategy for the area assumed to flame cutting. brazmg. or soldenng hngade members and fire bngade leaders contam the fire. Assessment of the bngade operations. A separate permit shall be issued

d. Regular planned meetmas shall be held member's conformance witif estabbshed for each area where work is to be done. If at least escry 3 nonths for all bnede plant fire fightmg procedures and use of fire work contmues oser more than one shift. the members to review charges m the fire fehting equipment, mcludmg self-contamed permit shall be vahd for not more than 24 protection program and 01her subjects as emergency breathmg apparatus.

hours when the plant is operating or for the commumcation equipment. and sentilation d ratior of a particular job during plant necessary

e. %nodic refresher traimng sessiens aball equipment, to the estent practicable.

shutdown be held 'o repea the elassroom mstruction IJ)The simulated use of fire fighting ti. Control the removal from the area of all 4 program for all bngade members oser a two-equipment requued to cope with the si:uation waste debris. scrap, oil spills, or other year period. These sessions may be and type of fire sclerled fur the drill. The combustibles resultmg from the work activity concurrent with the regular planned area and type of bre thosen fer the drill immediately followmg completion of the should d.ffer frcin those used in the previous actaity. or at the end of each work shift. g meetmgs

2. /hrwe dnll so that bngade members are trammlin whichever t.omes first.

Practir.e sessions sha'l be held for each . ghtmg fires m vanous plant areas. The

7. Maintam the periodic hounckeepmg shif t f re br:gade on the proper method of situatwn selected should smutate the size inspections to ensure contmued comphance fightmg the sanous types of fires that could and arrangemerit of a fire th at could with these admimstrative controls.

necur m a nuclear power plant These reasonably occur in the arra selec'-d.

6. Contrei the use of specific combust.bles sessions at!all prmide bngade members with a!!owmg for fire deselopment due to the time m safely-related areas. All woud used in espenence in actual Dre extmguishment and required to respond. to obtam equiprnant, and safety-related areas dunng maintenaime, the use of emergency breathmg apparatus orgamre Inr le fire. assummg loss of modification, or refuchng operations (such as

_nder strenuous conditions encountered n automatic suppression capabihty. lay-down blocks or scaffoldmgl shall be hre f;ghtma These practire sassions shall be

14) Assessment of bngade leader's treated with a flame retardant. Equipment or provided at least once per year for each fire directmn of the fire fightmg effort as to supphes (such as new fuell shipped m bngade member.

thoroughness, accuracy. and effectiveness. untreated combustible packing containers 1 Dn#s

4. Rn ords may be unpacked in safety-related areas if

a. Fire bngade dnlls shall be performed m Individual records of tramma provided to required for vahd operating reasons.

the plant sc that the fire bngade can practice each fire bngade member mcludmg drill llowever all combustible materials shall be cntiques. shall be mamtained for at least 3 removed from the area immediately fo!!owing as a team. b Dnlis shall be performed at regular 3 ears to ensure that each member receives the unparkmg. Such transient combustible meervals not to exceed 3 months for each frammg in all parts of the trainmg program. material. unless stored in approved shift fire bngade. Each fire bngsde member these records of trainmg shall be asailable containers, shall not be left unattended should participate in each dnll, but must for NRC review Retrainmg or broadened dunng lunch breaks. shift changes, or other participate m at least two drills per year. trammg for fire hghting withm buildmgs shall similar penods. Loose combustible packing A sufficient number of these dnlls, but not be scheduled for all those brigade members material such as wood or paper excelsior, or less than one for each shift fire bngade per whose performance records show polyethylene sheeting shall be placed in year. shall be unannounced to determine the deficiencies. metal containers with tightJ tting self-closma i fire fightmg readmess of the plant fire i Emeryency Lightm3 metal covers. bngde, bngade t ader, and f re protection Emergeracy hgating umts with at least an B-

9. Control actions to be taken by an r

systems and equipment. persorts pl enmng hnur battery power supply shall be provided individual discovering a fire, for estample. and authorizing an unannounced dnil shall m all areas needed for operat:on of safe notification of control room. attempt to ensure that the responding shift fire brigade shutdown equrpment and in access and extmguish fire. and actuat.on cf local fire members are not aware that a dnllis bemg egress coutes thereto suppression systems. planned until it is begun. Unannounced drills K Admmistmhe Controls

10. Control actions to be taken by the shall not be scheduled closer than four Admimstratise controls shall be control room operator to determine the need weeks.

rstablished to minimize fire hazards in areas for bngade assistance upon report of a fire or At least one dnll per S ear sh all be containing structures. systems. and receipt nf alarm on control room annunciator performed on a "back shifr for each shift fire components important to safety. These panel fi r eitample, announcing location of brigade. controls shall estabbsh procedures to: fire oser pA system. scunding fire alarms.

c. The dnlls shall be preplanned to

1. Gosern the handling and hmitation of the and noteying the shift supervisor and the fire estAlish the traimng obiectives of the dnll use of ordmary combustible materials.

bngade ieader of the type. size, and location and shall be critiqued to determme how well combustible and flammable gases and of the fire. the traming objectives have been met. liquids. high efficiency particulate air and

11. Control actions to be taken by the fire Unannounced dnlls shall be planned ar.d charcoal filters, dry ion eschange resins, or bngat, after notification by the c ontrol room a

cntiqued by members of the management other combustible supphes m safety-related operat~r of a fire, for es ample. asse abling in a desig iated location. rece:vmg directions staff responsible for plant safety and fire areas protection. Performance deficie acies of a fire 1 Prohibit the storage of combustibles in from d fire bngade leader. sind dischargma briaade or of individual fire br gade members safety-related areas or estabbsh designated specifit fire fighting responsibihties includmg shall be remedied by chedulmg additional storage areas with appropriate fire selectim and transportation of fire fightmg equipm nt to fire location. selection of trainmg for the brigade or members. protection. Unsatisfactory dnll performance shall be

3. Govern the handbng of and hmit protecto e equipment, operatmg instructions followed by a repeat dnll within 30 days.

transient I:re loads suh as combustible and for use if fire suppression systems, and use I

d. At 3-year intervals. a randomly selected flammable hquids, wood and plastic of prepLmned strategies for fightm; fires in unannounced dnll shall be cnfiqued by products, or other combustible matenals in specifu areas.

quehfied individuals independent nf the buildmus contaming safety-related systems

12. Defu.e the strategies for fighting fu es in hcensee's staff. A ropy of the wntten report or equipment during all phases of operatmg.

all safety-related areas and areas prrsenting from such individuals shall be available for and especially duririg maintenance. a hazard to safety-related equipment. These NRC review. modification. or refuelmg operations. strategies shall designate: e Dntls shall as a mmimum mclude the 4 Designate the onsite staff member

a. Fire hazards in each area covtred by the followmg-responsible for the inplant fire protection specific prefire plans.

(1) Assessment of fire alarm effectiveness, review of proposed work actatties to identify

b. Fire estinguisharts best suited for time required to notify and assemble fire potential transient fire hazards and specify controlhng the fires av ociated w ah the fir e

4 e Federal Register / Vol 45, No. 225 / Wednesday. November 1C,1980 / Rules and Regulations - 70815 - 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 containha associated circuits of one . c. Most favorable direction from which to the pressurizer for pWRs. .afe shutdown division and trays and attack a fire in eme.h area in view of the

c. ne reactor heat removal function shall conduits containing associated circuits oc ventilat on direchon, access hallways. steirs.

be s.apable of achieving and maintaining safe shutdown cables from the redundant and dot rs that are most likely 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 morntorind function shall be circuits from the safe shutdown equipment, fightmg the fire. All access and egress routes capable of providing direct readings of the shallhe such that a postulated fire involving that inv Ise locked doors should be proceas variables necessary to perform and associated circuits will not prevent safe specifically identified in the procedure with control the above functions.

shutdown i i the appropriate precautions and methods for

e. He supporting functions shall be M. Tim Barrier Coble Penetmtion Seol access specified.

capable of providing the process cooling. Qualification d plant systems that should I.e managed to lubrication, etc necessary to permit the penetratior seal designs shall utilize only 'n redt.ce the damage potential during a local operation of the equipment used for safe noncombustibic materials and shall be fire and the location of local and remote shutdc en functions. quahfied by tests that are comparable to tests controls for such management (e.g., any

3. ne shotdown capabiliry for specific Gre used to rate fire barriers.He acceptance hydraulic or electrical systems in the zone areas may be unique for eu.h such area. or it criteria for the test shallinclude:

covered by the specifh fire fighting procedure may be one unique combination of systems 1.%r cable fire barrier penetration seal that could increase the hazards in the area for all such areas. In either case, the has withstood the fire endurance test without because of oserpressurization or electrical alternative shutdown capability shall be passage of flame or ignitica of cables on the hazardsl. idependent of the specific fire area (s) and unexposed side for a period of time

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

local fire. particu'arly hazardous power is not avadabic for 72 hours.

2. %e temperature levels recorded for the combustibles that need coohng 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 capabihty to achieve and maintain is sufficiently below the cable insulation the assignment of special duties accordmg to cold shutdown will not be available because ignition temperature; and

}ob title so that all fire fighting functions are of fire damage. the equipment and splems

3. De fire barrier penetration seal reinains covered Ly any complete shift personnel comprising the means to achieve and latact and does not allow projection of water templement. Dese duties include command maintain the hot standby or hot shutdown beyond the unexposed surface during the

[ control of the brigad:. transportmg fire condition shall be capable of maintaining hose streem test. suppression and support equipment to the fire such conditions until cold shutdown can be N.Em Doors scenes. applying the extinguishant to IM fire, achieved. If such equipment and systems will Fire doors shall be self< losing or 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 electric power systems inspected semiannually to verify that g potential radiological and toxic hazards because of fire damage, an independent automatic holdepen. release and closing 3 in fire tones. onsite power system shall be provided.ne machar. isms and latches are operable. /

h. Ventitation system operation that number of operating shift personnel One of the following measures shall be ensures desired plant air distnbution when exclusive of fare brigade members, required provided to ensure they wdl protect the the ventdation flow is modified for fire to operate such equipment and systems shall opening as required in case of fire:

2 containment or araoke clearing operations. be on site at all times,

1. Fire doors shall be kept closed and

i. Operations requiring control room and

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

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

2. Fire doors shall be locked closed and general plant personnel durmg fire, by fire; or the fire damage to such equipment inspecte I weekly to verify that the doors a:e I. Ahernative and Dedicated Shutdown and systems shall be limited so that the in the closed position:

Copobihty systems can be made operable and cold

3. Fire doors shall be provided with

t. A!!e native or dedicated shutdown shutdown achieved within 72 hours.

automanc hold-open and release mechanisms capabil.ty provided for a specific fire area Materials for such repairs shall be readily and inspected daily to ver.fy that doorways 4 a e free of obstructions; or shall be able to achieve and maintain available on site and procedures shall be in subcr tical reactivity conditioct in the effect to implement such repairs. lf such

4. Fire doors shall be kept closed and reactor, maintain reactor coolant inventory equipment and systems used prior to 72 hours inspected daily to verify shat they are in the achieve and maintain hot standb> '

after the fire will not be capable of being closed position. conditions for a pWR (hot shutdown 'for a powered by both onsite and offsite electric ne fee brigade leader shsil hsve ready BWR) and achieve cold shutdown ' power systems because of fire r smsge. an access ta keys for any locked fire doors. 8 condittors within 72 hours and maintain cold independnet onsite power system shall be Ama protected by automatic total flooding shutdowa conditions thereafter. During the provided. Equipment and systems used after gas suppressi n systems shall have postfire shutdown the reactor coolant system 72 hours may be powered by offsite power eInctrically suPersised self<!asing fire doors or shall satisfy option 1 atnve process vanables shall be maintained within only. '- i those prdcted for a loss r.f nornal a.c. A Shutdown systems installed to ensure E #80*C##" N'##" I## ##"C'"# power, and the fission product boundary postfire shutdown capabdity need not be coolant pump shall be mategnty shsil not be affected;i.e there shall designed to meet seismic Category I criteria. equippe 1 with an oil collection system if the 4 be no fuel clad damage, rupture or any single fadure criteria or other design basis contaim ient is not inerted during normal primary coulart boundary, er rupture of the accident criteria. except where required for operstit r. The oil collection mystem shall be containment bound ry. other reasons, e.g.. because of interface with so designed, engineered, and installed that .The rerformance evals for t.'ie shutdown or impact on existing safety systems, or failure w dl not lead to fire during normal or functiom shall be: because of adverse valve acticns due to fire design I.. sis accident conditions and that a.The reactivity control function shall be damage. capable of achievmg and maintaining cold

7. The safe shutdown equipment and shutdown reactivPy conditions systems for each fire area shall be known to

• ^""' 'ptahle method of complying with this "I"*'" "*"Id D' ""' "'8"I'7G*id' I #5

b. Ite resctor coolant makeup function be isolated from associated norusafety shall be capable of maintaining the reactor circuits in the fire area so that hot shorts.

$db a$ h f ~ tra open circuits, or shorts to ground in t..e redundant safety divis.ons are so protected that ' As defined in tS Siandard Techrucal associated circuits will not prevent operation postulated fkea affect trays from only one safety Specificahans. of the safe shutdown equipment. The dwision _r y .,m y ~-7.,. - 3,- ~, - - ,y

5 9 y 4= 9 78816 Federal Register' / Vol. 45 No.1225 / Wednesday, November 19, 1980,/ Rulis and RegJiations 4 there is reasonable assurance that the system wn! withstan t e a ed h S f Shutdown

Earthquake

• Such collecuon systems shall be capable of col!.ains lube oil from all potential,

. pressurized and unpressurized leakage sitcs in the reactor coolant pump lube oil systems. Leakaye shall be collected and drained to a , vented closed cootainer that can hold the > entire lobe oil system inventory. A flame . arrester is required in the vent if the flash pomt characterisucs of the oil present the -g hazard of fire Dashi,ack. Leakage points to be - I . protected shall include lift pump and piping. ov,4 flow Imes, lobe oil cooler, oil fdl and drain knes and plugs, flanged connections on

oil knes, and lube oil reservoirs where such p

- features exist on the reactor coolant pumps. ,The drain hne shallbe large enough to .acc.ommodate the largest potential oilleak 1

ISec.161b, Pub. L 43-703. 68 Stat. 948; sec.

201. Pub. L 93-438,88 Sta t.1242 (42 II S C 220ttb).5841)) 1 Dated at Washington. D.C this Uth day of November 1980. For the Nuclear Regulatory Commission. Saenuel b Chilk. Secretary of the Commission. tilt Das an.asin Ned 11-iset e es anil .esLLose cosa 7sso-as.es 3. i +- {. - 1 I t l s i j p i ? See Regulatory Guide IN" Seismic Desen > Classificanon" Paragraph C2. l 3 h --}}