ML20032E229

Requests Comparison of Facility Fire Protection Program to App R to 10CFR50.Deviations Should Be Identified & Justified.Fr Notice of Revised 10CFR50.48 & New App R Encl

ML20032E229
Person / Time
Site:	Millstone
Issue date:	10/21/1981
From:	Eisenhut D Office of Nuclear Reactor Regulation
To:	Counsil W NORTHEAST NUCLEAR ENERGY CO.
References
NUDOCS 8111191051
Download: ML20032E229 (19)

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Mr. W. G. Counsil, Sr. Vice President TWambach TERA Nuclear Engineering & Operations VBenaroya NRC/PDR Northeast ticclear Energy Company GHarrison L/PDR Post Office Box 270 PSears NSIC Hartford, Connecticut 06101 RAnand TIC RHVollmer ACRS (16)

Dear Hr. Counsil:

RMattson PCheck

Subject:

Appendix R of 10 CFK Part 50 - Fire Protection Rule The Comission publisned a revised Section 10 CFR 50.48 and a new Appendix R to 10 CFd Part 50 on t.overaer 19,1960 (45 FR 76602). This rule became ef fective on February 17, 1981, and it specifies certain fire protection features for operating nuclear power plants licensed before January 1979. The tecnnical requirenents stated in Appendix R were adopteu af ter 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 Appena1x R to 10 CFR Part 50 are now being used as guidelines in our evaluation of the fire protection progran 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 fron Appendix R should be identified as early in the review process as possible, so that tney may be resolved and all fire protection features be implement.d by the time the plant is ready for fuel loading.

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

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._j e The reporting / record keeping requirenents associated with Appendix R of 10 CFR 50 have been approved by the Office of Management and Budget' under approved nunber 3150-0011 which expires September 30,1983. - Corrients on burden and duplication may be directed to the Office of Management and Budget, Reports Manageraent Roon 3208, b Executive Office. Building, Washinoton, D. C.

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a Darrell G. Eis hut', Directnr Division of Licens'ing Office of Nuclear Reactor Regulation -

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Mr. W. G. Counsil Vice President Nuclear. Engineering and Operations Northeast Nuclear Energy Company Post Office Box 270-Hartford,' Connecticut 06101 cc: Mr. John J. Korkosz,. Manager Mr. H.. R.. Nims, Manager City of Chicopee Electric Nuclear Products Light Department Northeast Utilities Service Company.

725 Front Street Post Office Box 270

.Chicopee, Massachusetts 01014 Hartford, Connecticut 06101 Mr.' Guy W. Nichols, President Mr. Richard T. Laudenat, Manager New Engla'nd' Electric System Generation Facilities Licensing 25 Research Drive Northeast Utilities Service Company Westborough,-Mass. _01581 Post Office Box-270 Hartford, Connecticut 06101 Mr. Bruce R. Garlick Manager, Energy Supply Resident Inspector / Millstone NPS Fitchburg Gas and Electric c/o U. S. NRC Light Company P. 0. Drawer KK 655 Main Street Niantic, Connecticut- 06357 Fitchburg, Massachusetts 01421 Mr. Wardman Yo Brcoksbank, Manager Town of South Hadley Electric Light Decartment

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Mr. Ralph H. Wood Ger,eral Counsel L

Public Service Company of New Hampshire l

1000 Elm Street Manchester, New' Hampshire 03101 William H. Cuddy, Esq.

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John D. Fassett, Vice President

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The United Illuminating Company 80 Temple Street New Haven, Connecticut 06508

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o 79802 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 COedenSSION been extended.

Criterion 3 of Appendix A to 10 CFR The Commission does not agree. The Part 50 and in the NRC guidance to CFR Port 50 NRC has been developing fire protection documents. nese general provisions requirements smce 1975. The NRC gave rise to a number of disputes over Fire Protection Program for Operating published comprehensive fire protection whether specific methods adequately Nucteer Power Plants guidelmes. Branch Technical Position accomplished the intended goat The AGENCv: Nuclear Regulatory BTP APCSB 9 5-1. and its Appendix A in proposed rule is intended to provide Commission.

1976 Licensees have compared their fire sufficient speufic guitjence to ensure ACTIoec Final rule.

prot ction programs agamst these satisfactory resolution of theseissues.

guidelines and have discussed their Thus. reverting to generalized guidance

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

to require certain provisions for fire during the NRC's fire protection reviews The second issue involved some protection in operating nuclear power of operatmg reactors. A Safety instances in which the specific wording 1'

plants. This action is being taken to Evaluation Report and. in most cases.

used resulted in unnecessary and upgrade fire protection at nuclear power supplements to the Safety Evahiation unintended restrictions. For example, plants licensed to operate pnor to Report. have been issued for each the proposed rule called for a " fresh January 1.1979, by requinng resolution operating reactor. These reports water" supp!y. For firefighting purposes, of certain contested generic issues in descnbe fire protection alternatives that brackish water is satisfactory and a fire protection safety evaluation reports.

have been proposed by the licensee and

" fresh" water supply is unnecessary, arraCTiva DATE. February 19.1981.

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

Commission has submitted this rule to remaining between the staff and the Often portions of a fire main loop run the Comptroller General for review as licensa Proposed Appendix R provided above ground in end as they enter may be appropnate under the Federal the Commission's requirements for structures. 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).ne date on which the rep irting only a hmited number of issues derived a fire main loop above ground. Other requirement of this rule becomes from the use of the earlier guides. The sir ilar changes are discussed in Section effective, unless advised to the contrary. Commission believes that a 30-day IIL " Specific Requirements." of this reflects inclusion 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 imposition of U.S C. 3512(c)(2.

2. Many licensees questioned the need requirements on plants with presently ins talled or with custing comreitments rom FURTHER INFOmasATION CCNTACT:

for backfitting all the requ:rements of I install fire pr tection features David P.Notley Office of Standards Appendix R. They commented thr.t they previ usly determined by the staff to Development. U.S. Nuclear Regulatory had previously complied with staff fire satisfy the guidance of Appendix A to Commission. Washington. D.C. 20555, protection recommendations in " good BTP 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 certain modifications. They secti ns that will be back fitted. Regulation. U.S. Nuclear Regulatory contend that the staff has properly Appendix R should not be retroactively Commission. Washington. D.C. 20555. determined that 'hese modifications applied to features that have been phone 301-492-7096. provide at least the level of fire E suertassamTARY H6FOmssATior On May protection described by the guidance [; ,Pp i pen 29,1980, the Nuclear Regulatory contamed in Appendix A to Branch to IITP APCSB 9 5-1. Commission published in the Federal Technical Position BTP APCSB 9.5-1. The NRC staff had intended. In its Itegister (45 FR 360e2) a notice of They also contend that these original proposal for Appendix R. that proposed rulemaking inviting wr tren modifications provide a sevel of the requirements be applicable only for suggestions or comments on the protection at least equivalent to that the resolution of unresolved disputed proposed rule by June 30.1980. The contsined in the proposed rule. They fire protection features. Thus, the staff notice concerned proposed amendm.mts express the concern that tne proposed had not intended the provisions of to 10 CFR Part 50. " Domestic Licensing rule was wntten 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 descnbed in the pmposed provisions for fire protection in nuclear and new, but not necessanly better-rule as published for comment. In fact. power plants operatmg prior to January modifications would be required. These the Supplementary Information 1.1973. Fifty-one comment letters were modifications could be accomplished published with the proposed arule received regarding the proposed only by the expenditure of considerable explicitly indicated that "[a}ll licensees amendments. 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 / prepcsed Appendix R. and these wdl be commenters request that the form. including whatever changes result dealt with below. However there were requirements in the proposed rule be from public comments." three substantive contentions which rewritten to specify only the general in determining whether the spec.f. were raised by many of the commenters. requirements of what needs to be requirements of Appendix R should be '[hese three comments are summarized accomplished. imposed on licensees with presently as follows: These comments raise three related installed or existing commitments to

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

s - Federal Register / Vol. 45, No. 225 / Wednesday. November 19, 1980 / Rules and Regulations 78803 9.bl,it is important to recognize that arrr.ngements were accepted in some permitted either an oil collection system Appendix R addr-sses only a portion of early fitt protection reviews. As a result or a fire suppreasion system.The staff the specific items contained in the more of some separate effects tests, the staff * - has also accepted an automatic fire comprehensive document. Branch changed its position on this suppression system as an acceptable Technical Position BTP APCSD 9.5-1 configuration, and subsequent plans method of fire protection for this and its Appendix A. Appendix A to BTP have been required to provide application. The Commission has APCSB 9.5-1 has been the basic fire additional protection in the form of fire concluded that fire suppression systems protection guidance used by the staff in barriers or substantial physical do not give adequate protection for fires their fire protection reviews conducted separation for safe shutdown systems. that may be induced by seismic events. for all operating plants during the past Na credit for such coatings as fire The Commission therefore believes that ' several years. For many plants, barriers is allowed by Section IILG of previously approved suppression licensees proposed systems and features Appendix R. Appendix A to Branch ystems should be replaced with oil ( that satisfactorily achieved the fire - Technical Position IrrP APCSB 9.5.1 and collection systems that can withstand protection criteria set forth in Appendix the proposed Appendix R recognized seismic events. A to BTP APCSB 9.F1 cnd 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 III," Specific Satisfactory features and systems are to those listed in Section III.G of Requirements," of this preamble. already in place and in operation in Appendix R. For these cases, fire

3. Afost commenters stated that the many plants. There is a reasonable protection features were developed by implementation schedule contained in 5

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 c mmenters further stated that if the same criteria of Appendix A to BTP as providing equivalent protection to the implementation schedule m the el'ertive APCSB 9.5-1. In general, the features requirements of Section III.G to rule is the same as that in the propored previously approved by the NRC staffin Appendix R. rule, the Commission must be prepared its reviews of fire protection using the Requirements that account for all of to either shutdown each operating criteria of Appendix A to BTP APCSB the parameters that are important to fire nuckar power plant, or process 9.5-1 provide an equivalent level of fire protection and consistent with safety eQp n{,q[ysr hen concluded that protection safety to that provided under requirements for all plant-unique the specific provisions of Appendix R. configurations have not been developed. the implementation schedule should be Thus, the further benefit that might be In light of the experiente gained in fire p nce I e p d provided by requiring that previously protection evaluaticns over the past four approved features be modified to years, the Commission believes that the stated that "all fire protection and I cenform to the specificlanguage set licensees should reexamine those modifications identified by the staff as forth m Appendix R is outweighed by previously approved configurations of necessary to satisfy Criterion 3 of the overall benefit of the early fire protection that do not meet the Appendix A to this part, whether implementation of such previously requirements as specified in Section contained in Appendix R to this part or approved features. which in many cases III.G to Appendix R. Based on this in other staff fire protection guidance (except for alternate or dedicated are currently being installed. reexamination the licensee must either Nevertheless, as a result ofits meet the requirements of Section III.C of shutdown capability) shall be completed continuing review of fire protection Appendix R or apply for an exemption by November 1,1980 unless, for good matters. the NRC staff has indicated to that justifies anternatives by a fire cause shown, the Commission approves the Commission that there are hazard analysis. Ilowever, based on an extension,"(pxposed paragraph = 50.481.(c)). The Commission went on to requirements in three sections in which present information, the Commission state its intention in the Statement of the protection afforded by Appendix R does not expect to be able to approve Consideration to the rule that "... no over and above that previously exemptions for f re retardant coatmgs accepted, may be desirable.The used as fire barn! plant would be allowed to continue to ers. 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 !!! } of Appendix R calls the Comission, unless all modifications applied to all facilities. This decision is for 8-hour emergency lighthg. whereas (except for alternate or dedicated not meant to reflect adversely on in some cases less than 8-hour shutdown capability) have been previous licensee or staff evaluations; emergency lighting nas been accepted as implemented " rather its purpose is to take fully into satisfying Appendix A to BTP APCSB The Commission has reconsidered the t account the increased knowledge and 9.5-1. While an adequate lesel of safety implementation schedule and has - experimee developed on fire protection may be provided by less than an 8-hour determined that it should be modified .g matters over the last several years. supply, an 8-hour system would provide for the following reasons: The first of these sections is related to added protection and would generally . After reviewing the comments and fire protection features for ensuring that involve only a small cost. The the information developed as a result of - systems and associated circuits used to Commission therefore believes that completion of fire reviews over the past achieve and maintain safe shutdown are licensees should upgrade the previously 6 months, the staff has informed the free fro n fire damage. Appendix A to approved facihties to satisfy the 8-hour Commission that the date of November DTP APCSB 9.51 permits a combination lighting requirement of Appendix R. 1.1980, is not possible because the of fire-retardant coatinas and fire The third relates to protection against effective date of the rule will be after detection and supression systems n:es in noninerted containments that date. without specifying a physical separation involving reactor coolant pump

• The steff has informed the distance to protection redundant tubricetion oil ISection III O of Commission that it would expect systems (Appendix A, D 1(2)), and such Appendix R). The proposed rule virtually alllicensees to request t

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.~ o 7gsM 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 Technical Dasis 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 manpower resources needed by the dispoaltion of those comments. protection uses to be available at all times regardless of other simultaneous licensees to prepare such requests and Section I. Introduction ondScope water uses in the plant.This water by the staff to formulate recommendations or these requests is This section has been revised as a volume is dedicated for fire service by act warranted frort the standpoint of result of comments to include a means of separate storage tanks or timely fire protection improvement, discussion of the importance of safe separate pump suctions from a large

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

suctions must be at the bottom of the tank and other water supply suctione 9 to be implemented and installed on a Section ll. GeneralRegrimments phased schedule that is as prompt as must be located at a higher level to can be reasonably achieved. This section has been substantially ensure that the minimum dedicated The revised schedules distinguish rewritten as a result of comments to water volume is set aside for fire between requirements imposed for the provide a concise summary of general protection needs. Administrative first time on the licensee by Appendix R requirements. The specific requirements controls by themselves. such as locked and those rrequirements already in posed were consolidated with the appropriate valves to ensure adequate water supply in license conditions or Technical parts of Section 111. " Specific for fire fighting needs, are deemed Specifications issued prior to the Requirements." except that the credit unacceptable at nuclear power plants. effective date of the rule. For given for 50-foot separation has been Comment Resolution requirements imposed by Appendix R. dropped. hiany commenters stated that we including the items "backfit" to all Section Ill. Specific Requirements were being too restrictive by stipulating plants. the schedule provides a reasonable time after publication of the The requirements m. this rule are an underground yard fire main loop and based upon principles long accepted fresh water supplies. Our intent was rule for cornpletion of required modifications. For requirements already within that portion of American industry only that a yard fire main loop be that has been classified by their furnished. We have deleted the imposed by license conditions providing insurance carriers as " Improved Risk" specification for an underground loop forimplemention after November 1. or "llighly Protected Risk". In each of since special conditions may dictate that 1980, the Commission has reviewed these cases, the Commission has part of the loop be above ground or these schedules and has found that in decided that the overallinterest of inside safety-related buildings. Such some instances the allotted time for completion of the seguired modifications public safety is best served by arrangements are acceptable. may be excessive. nus, for fire establishing some conservative level of With regard to the specification for a protection features other than those fire protection and ensuring that level of fresh water supply, the staff was covered by Appendix R. although the compliance exists at all plants. The attempting to avoid potential plant Commission has extended the following is a list of the specific problems that are not associated with compliance dates beyond the November technical bases and resolution of public fire protection. From a fire protection 1.1980. date in the proposed rule the comments for each of the specific standpoint, salt or brackish water is Commission has added a requirement requirements in Appendix R. acceptable for fire suppression provided that limits the compliance schedule in A. WaterSupplies for Fite the fire protection system is designed existing licenses if such schedules Suppression Systems Technico/Bosis. and maintained for salt or brackish extend beyond what we now believ, One of the basic fire protection water.The requirement for fresh water should have been a reasonable schedule requirements for a modern industrial supplies is therefore dropped. Other initially. Rehef from such limitation may site in the United States is a separate operational problems unrelated to fire be granted by the Director of Nuclear water distribution system for fire protection that may result from the use Reactor Regulation upon a showing that protection vdth 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 date and that public health and safety is ensure uninterrupted fire suppression scope of this regulation. not adversely afiected by such capabihty allowing for single failures Several commenters took issue with extension. ind periodic maintenance and repair of the requirement for two separate It should also be noted that for vital portions of the systems. Duplicate redundmt suctions stating that some licensees whose license conditions water supplies may consist of separate plants tise a single large intake structure imposed a schedule with a compliance suctions for fire pumps from a large on a lak e or a river for all water a date of November 1,1980, or other date body of water such as lake, river, or requirements.The requirement for prior to the effective date of I 50.48. the pond or from two water storage tanks. separate intake structures was not Commission has suspended such For nuclear power plants. the intended and the rule has been clarified. p compliance dates by promulaating 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 inclating portions of the use of vertical standpipe for other water superseded by this rule. system for maintenance or repair servi <:es 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 staff's the various fire suppression systems in on the basis that this is overly restrictne resolution of these comments. the the plant. Thus, with dual supplies and a and other ways are available to ensure followmg section will consider each loop concept an adequate water supply a dedicated supply sua es welrs, section of Appendix R to this part. In can be ensured to each manual or suction location, etc. Two separate but

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 is 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. Manual Fire 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 suppression activities when storage B.SectionalIsolation Valves. often can control and extinguish slowly tanks are used for combined service. C.HydmntIsolation Val es developing fires before an automatic fire TechnicalBasis. These tv o suppression system is actuated. In water / fire. water uses.The term f " vertical standpipe for other water requirements are similar and can be addition, fires that are controlled or - service" simply means that the suction treated together. Proper valving is extinguished by automatic systems for other water uses in ccmmon storege required to isolate portions of the water require a certain amount of manual tanks will be located sufficiently high to distribution system for maintenance or response. Also, some areas of the plant ensure the minimum water volume repair without interrupting the water do not warrant the installation of needs for fire suppression activities. If supply to manual or automatic fire automatia fire suppression systems. the commenters were assuming that suppression systems inside the plant. Manual response is the only fire "sertical standpipe" referred only to Valves are similarly required to permit suppression available for these areas; isolation of outside yard hydrants from thus, it is important that manual fire pipes inside the tank, this is not the the water distribution system for fighting capability be present in all case. In fact a standpipe exterior to the maintenance or repair without areas of the plant, and that standpipe storage tank is more desuable since any nterrupting water supply to fire and hose stations be located 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 indicating valves such as post stations are to be located so that at least pipe could actually allow depletion of indicator valves are preferred so that one effective hose stream can be the water otherwise to be reserved for the position of the valve can be readily brought to bear at any location in the fire uses.The rule has been clarified to determ, ed. Howeser, key-operated plant containing or presenting a hazard m allow physical alternatives for water valves (mmmonly known as curb to structures, systems, or components supply dedication but to preclude valves) are acceptable for these important to safety.They are to be exclusive use of administrative controls purposes where plant-specific supplied from the fire water supply for this purpose. Som commenters objected to the "hu $,*$*t system except for those inside ,y Ives Commet containment, which may be connected reqwement that other water systems Resolution. Many commenters stated I ther reliable water supphes if a used as a backup water supply for fire that the requirement for " approved n parate penetration into containment protection should be permanently v sually indicating" sectional contrcl carmot be made for fire water service connected to the fire main system and valves was overly restrictive, "'d8' suggested that it would be sufficient to unnecessary, and not specific with provide a water supply capable of being respect to who should give the approval. Coinment Resolution connected to the fire mam system within The Commission has accepted this Several commetyr u psted adding i ten minutes of the loss of normal water suggestion: the rule now requires that a sentence reading hW and hose supply or pumps.The rule does not sectional control valves shall be stations are not ruquireo af.tdficient address backup water supplies.The provided to isolate portions of the fire requirement means that,if another main for maintenance or repair without jushfication can be provided that adequate fire protection features have water system is used as one of the shutting off the entire system. Post redundant water supplies. it must satisfy indicator or key-operated valves are been provided to account for a given fire all of the requirements of the fire mentioned as two examples of area." This suggestion was rejected. The protection water supplies. Additional acceptable valves. staff has taken the position that the backup supphes need not meet these C.flydmnt Block Volves-Comment minimurn requirements are that at least requirements. Resolution. A numberof commenters one effective hose stream that will be One commenter asked why only a made suggestions for rewording this able to reach any location that contains two-hour water supply is required when section. This section has been clarified or could present an exposure fire hazard the Ernns Ferry Fire lasted well over to state the requirement for capability to to the safety-related equipment. The 5 two hmrt All of the investigations of isolate hydrants from the fire main Commission concluded that no analyses the Browns Ferry Fire clearly show that without disrupting the water supply to can identify hazards so carefully that if wat a bad been used immediately, the automatic or manual fire suppression this minimum requirement can be further reduced. fire would have been extinguished much systems in any area containing or I earlier. indeed once the manual fire presenting a fire hazard to safety-related E.1/ydrostatiellose Test Technical fightina 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 suggested that this hydrostatically tested periodically to was eninguished 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 requirement which has use. The requirement for a minimum test condition in which a postulated fire that not been subjected to the peer review pressure of 300 psi comes from NTPA could threaten safe shutdown capability process." This suggestion was rejected No.196 (National Fire Protection could not be controlled and extinguished on the basis that Appendix A to HTP Association Standard No.196-within two hours with any combination APCSB 9.5-1 contains the following Standard for Fire Ifose). a nationally of manual and automatic fire sentence: "The lateral to each hydrant recognized consensus standard.His supp ession activities. %erefore, a two-from the ya d main should be controlled standard contains other guidance for the

76606 Federal Register / Vol 45. No. 225 / Wednesday. November 19. 1980 / Rdes and Regulations use and care of fire hose that rnost e stem in a!! such areas should be I. Are Bngede Training Technical industnes find usefu!. retamed. The fire hazards anal) sin may Basis. Most modern industrial plants caU a separate s4Pression systent we mplacement cost values Comment Resolutmn but this wculd be in addit 2on to the fire approaching those of a modern nuclear Many commenters pented out the detection system. powered elettnc generatmg station have erroneous usage of the term "semce G. Protectica MSve Shutda n a full. time fully equipped fire pressere" rather than "operatma Ccpchhn Techmcc/ Basis. The department. including motonzed fire pressure" m this requirement Pe c.b;ectne for the protection of saft apparatus. Because of the reduced ~ miended meaning for this rm nment is shotdown capabiht) is to ensure that at ses enty of fire hazards in a nuclear that all hoses would be tested a a ! cast one means of achiesma and generatmg station as compared to a prenure greater than the rnaumum miMainmg safe shutdown condmons manufacturmg plant, the Commission e pressure found in the fire protection will remam avadable dunng and after behes es that it is not necessary to w ater distnbution sy stems. The correct any postulated fire m the plant. Because mandate a fully staffed fire department. termmofogy is "operatmg prer sure " The it is not pcssible to predict the specific Nowes er, manual [ ire response rule has been so changed In addition. conditices under which fires may occur capabihty is required at a nuclear plant i the staff added a specific mmimam test and propagate. the design basis ~ and a properly equipped and fully pressure requirement of 330 psi to rneet protectn e features are specihed rather f ramed fire bngade will satisfy this need. The Commission has determined the NFPA standard. than the design bnis Ere. Three One commenter also pointed out that d6ff, rent means for prctectmg the safe that a bngade of five persons constitutes the mmimum size suf ficient it, perform hoses should be mspected for mddew. shutdown capabihty outside of rot. cuts. or other damage. Ahhough this contamment are acceptab!c The first the actions that may be required by the is a vahd comment,it is not an meau is separat:en of redundant safe bngade dunng the fire and te proude s me margm for unanticipated eventn> unresclved issue with any l'censee so it shdiwn trams and associated circuts need not be covered by this ru.e. In bv n: cans of 3 hour fire rated barners hilarly, the traming requirements hsted are considered the mmimum addition. such inspect ons are already T' e second means is a combmation of h needed to ensure that the fire bngade bems, performed m accordance with the separanon of redundant safe shutdown d b aW to Ndon ehdy piant s Techmcal Specificattens trams and associated circuits by a b hour fire rated barner and automatic fire dunng a fire emergency. F. 4utomatic Ere Detectwo Technca', ressmn and detection capabihty for & pmp sed rule required emergency vous The requirement that au'omatic,l su ~ breathmg apparatus without spec fying f3e detection systems be installed m ai both reduMant trams The third meant the number of such pieces of apparatus. areas that contam safe shutdown or which may be used on!v when The rule has been modified to specify saf ety-related systems or components redundant' trams and associated circurts the personnd for whom such e pparatus fahcws generally accepted fire are separated by 20 feet or more of clear is to be pros. :ed and to specify resuve protection practice. Insta:latwn of such sp ce requires automatic fire f;te detection capabihty is independent p sqpres=i n and detection systems m R M B eade--Cemment of any requirements for automatic or the arra. An ahernative or dedmateu Resc/ution. Many commenters suggested mariual fire suppression capabihty m an safe shutdown capabihty mdependent of changms this requirement to a simple area. The purpcse of these detection the fire area is raquired if fire prowction nr2 arnent ' hat a tramed and equipped. systems is to give early warnmg of fire for safe shu'down canabihty cannot be nommal sae. site fire brigade of five conditions in an area so that the fire prmided as outhned abme. For cables ersuns be prouded on each shift unless bngade can initiate prompt actwns to mimmize fire damage withm the plant. nd equ.pment needM fot safe a lesser number is justified This shutdown located ms 4 amnerted recommended change was rejected by " en e50 W" containments a lesser cegree of fire the Commission for the reasons stated Many commenters suggested that the protectmn is pe mitted because in the Techmcal Basis words ~ automatic fire detectmn tranuent exposure fires are less hkel) Some commenters objected to the capabihty" be substituted for msice con'amment dunng plant exclusion of the shift superusor from " automatic fire detection sy stems" en cper atmn Section III M ' Tire Nrners,. the fire bng ide. The commenters felt the basis that. as worded. the msct.sses the techmcal basis for the 3' that the shi!: superusor should go to the requirements are too hmitmg. They hour ba ntr. and Sectwn Ill L fire and proade the benefit of his stated that an automatic sprmkler "Alternatae and Ded:cated Shutdown npertise ard authonty. The rule would i sy stem with appropnate alarm check Capabihty." d:scusses the technical not pres ent this. However. the shift valves and central alarm features basis for safe shutdawn capabaht)- superusor may hu e to go elsewhere during the cou'rse cf a fire that adversely p-ovides acceptable detection /alarmmg Commet Rem /utwn l capabihty. Several commenters claimed affects plant cperation. The fire bngade that a separate detection system is not Many commenters suggested that the leader must stay with the fire bngade needed in areas covered by sprinkler first paragraph be changed shghtly and and be ass!gned no other sy stems equipped with fusible hnk the rest of this section deleted De responsibthties dunng a fire emergency. spnnkler heads. A fusib!e Enk has a bas:s for their contention is that the rule therefore. the sh:ft superusor must be 5 time delay before it actuates However. should state simply the requirement to e,cluded from mernbership on the fire more importantly. a smoldenng pretect cables or equipment c. systems bngade locahzed fire that could do damage may necessary for safe shutdown of the plant llEre Bngade Trommg-Comment not generate enough heat to melt the and leas e specific irr:plementatwn Resoh.twn. Many commenters base fusible Unk. While we do not d:sagree deta:!s in some other type of document. I that the alarm frem an automatic fire We hase modified this section by

m.., s.u.m o v n in 19 sec #,

suppression system serves as remming it:e hstma of consideratmns. wea o' em e M &nen s r. d*'*d M * "* w" m **b *

• M notificatmn that a f.re exists. we delet ng Tab!e I. and reusmg the concladed that the nimmum werd na to proside clanficatmn CNNQZ'77Q requirement for a separate fire detection II. Ere Br:gede ms a

s Federal Regisler / Vol. 45. No. 225 / Wednesday, November 19, 1980 / Rules and Regulations 78607 stated that NRC used unnecessary detail fire emergency and operators involved modifications to provide alternative in spelling out specific requirements for in safe plant shutdown should not also shutdown systems are extensive, a classroom instruction, fire fightmg 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.His minimum Comraission 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.%e process variables within those values here points out that most of the Commission has decided to require an a-predicted for a loss of offsite power. The investigations of the TMI accident hour battery power supply in all areas case of loss of offsite power is assumed o 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. f area.%e fact is not that the training K. Administrative Controls Technical Fire damage to cold shutdown capability requirements spelled out here for the fire Basis. The fire prote ' ion program uses is limited to damage that can be brigade members are escessise when administrative controls for fire repaired within 72 hours to provide a compared to training requirements for prevention and prefire planning.%e margin in achieving cold shutdown reactor operators, but that fire brigade . items listed in this section are generally conditions. Consideration is given to training is further along in development. accepted within the fire protection associated circuits because most plants and training parameters that are community as minimum requirements were not designed with this concept in essential to a comprehensive program for an effective administration of the fire mind. Should either the alternetive or have been identified. protection program. Controls are placed dedicated capability be required to l.EmergencyLlghting Technical on the storage and use of combustible function because of a fire,it must not be Basis. E nergency lighting is required in materials to reduce the fire loading in disabled by fNe damage to associated all nuclear power plants. Battery-safety-related areas and on ignition circuits. Also, this capability does not powered lights with capacities of 1% to sources to avoid careless operations. have to meet the single failure criterion 2 hours is usually sufficient for Procedures are used to control actions because it is only one of several levels emergency egress. However, the postfire to be taken by individuals who discover of defense. Seismic Category I criteria is emergency lighting requiremo 4 in a a fire and by the fire brigade for the not imposed because fires that would nuclear power plant are of a cifferent development of preplanned fire fighting require the installation of alternative or kind.The need is for lighting that aids strategies ac'i actual fire fighting dedicated shutdown capability are not - the access to equipment and techniques. seismically induced. C mmentResoludon Comment Resoludon op ra e by a t perso I o effect safeplant shutdown during plant Ef any commenters stated that this Many of the commenters stated that emerydacies. Because such activities requirement was much too detailed for a this requirement exceeded the scope of may extend os er a considerable period regulation. Some stated that the Appendix R by defining alternative of Ume both during and after the fire,it requirements should apply only to those shutdown requirements. %ey stated is prudent to provide 8-hour battery areas having safe shutdown equipment. that the time requirements are excessive i emergency lighting capability to allow Other commenters stated that a simple and shoulin 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 occount 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 Resolution that the details could be spelled out in a It is generally understood that cold Many commenters stated that the regulatory guide or some other similar shutdown is the ultimate safe shutdown requirement for emergency lighting is document. condition and that, for each fire area. overly 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 Alternafire andDedicated plants would have the capability of fluorescent units is overly restrictive; Shutdown Capability. disabling systems required to achieve third, that the requirement for indiv! dual Technical Basis. In some locations both hot and cold shutdown,it is 8-hour bcny power supply is (such as the cable spreading room) necessary to specify the minimum excessive. Three commenters within operatmg nuclear power plants, it capability and time requirement for each y recommended a 2-hour battery power is not always possible or practicable to condition necessary to achieve safe supply, fis 2 ammenters recommended a protect redundant safe shutdown shutdown. We agree that evaluations plant-specific power supply; and one systems against adverse effects of fire or being made under the Systematic ( commenter recommended that there be fire suppression actisities only through Evaluation Program (SEP) may also call no permanent installation. the use of fire protection features for alternative or dedicated shutdown These smestions have been accepted because the redundant safe shutdown capability for reasons other than fire in part. Ughting 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 @eration of safe capability has usually been required to requirements resulting from the SEP may shatdown equipment and in access and be indenendent of the control room, require additional modifications. Each egress rouies thereto. The reasoning cable sprearling room, switchgear rooms licensee should be aware of the status of behind ttw quirement for an 8-hour and cable riser areas because redundant the SEP so that the requirements battery power supply is that there can systems in these areas are not resulting from SEP can be effectively be a great deal of other activity during a adequately separated. When plant integrated with those relating to fire

76608 Federal Register / Vol. 45. No. 225 / Wednesday. November 19, 1980 / Rules and Regulations protection to the extent possinfe. required to ensure safe shutdown the national consensus standard used However, the Commission has decided capabihty. The uw of a 1-hour barrier in for testing and raiing these cable that the modifications required to conjunction with automatic fire penetration seals. Smce the cables complete the fire protection p ogram suppression and detection capability for conduct the heat through the barrier, shodd not be deferred until the SEP i.ach redundant train of safe shutdown and since the cable insulation is review is completed. equipment is based on the following combustible. the acceptance criteria of M. Fire Barrwes. considerations Automatic suppression the ASTM Standard E-It9 relating to Tec hnico/ Basis. The best fire is required to ensure prempt. effective temperature on the unexposed side must protection for redundant trains of safe upphcation of suppressant to a tire that be appropriately modified. shutdown systems is separation by could endanger safe shutdown Comment Resolution unpierced fire barners-walls and capability.'Ihe actisation of an ceding-floor assemblics. Because these automatic fire detection or suppression Some commenters suggested that this barriers are passive fire protection sy stem does not occur untd sufficient entire section be deleted and replaced features, they are inherently reliable smoke or heat has been developed by with the followmg two sentences: provided they are properly installed and the fire. Therefore, the Commission is " Penetration seals shall provide the i mamtamed. Fire barners have been requinng a 1-hour barrier to ensure that equivalent protection which is required used successfully for m any y ears to hre damage wdl be hmited to one train of the fire barrier. Evaluation of the subdivide large potential fire losses into untd the fire is e tinguished, penetration seals based upon a design smaller, more acceptable risks. Even fire These requirements have now been review and relevant test data or barners with opemngs have successfully incorporated in Section !!!.G. " Fire quahfication testa may be made." The interrupted the progress of many f;res Protection of Safety Functions! commenters felt that sufficient test data prouded the openings were properly are available to permit enaluation of protccted by fire doors or other ~ 6, * * ""' N * " * " design requirements without full-scale acceptable means. Seseral commenters made a number mockup testing and that many of the Fire barriers are " rated" for fire of suggestions of an editorial nature. items spelled out in the regulation. such resistance by being exposed to a One suggestion was to add "or unless as the water hose stream test, were too " standard test fires This standard test other fire protection features have been detailed and did not belong in the fira is defined by the American Society "rovided to ensure equivalent regulation. The Commission has c otection" in the first paragraph, where reconsidered this issue and revised the for Testmg and Matenals in ASTN E-119. " Standard for Fire Resistance of three-hour rated fire barners were rule to (a) require the use of Buddmg Materials." Fire barriers are stipulated unless a lower rating was noncombustible materials only in the commonly rated as having a fire just:fied 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 "Rghly Protected nothmg in the way of clanfication and seals to be qualified by test; and (c) Risk" (as classified by insurance Se suggestion was not adopted. The require such tests to satisfy certain carriers)industrict properties in the second paragraph ter;uires that acceptance criteria. Umted States require fire barriers to structural steel forming a part of or O. Fire Doors. have a resistance ratmg of 2 to 4 hours. supportmg any fire barrier hase a fire Technica/ Basis. Door openings in fire While a nuclear power plant has a resistance equivalent to that required cf walls constitute another breach that hw fire load. the potential the barrier. An example was given of must be protected. Fire doors that have consequences of fire are serious. metallath and plaster cosering as bems been tested and rated for certain fire Therefore. the Commission has selected one means of providing equivalent exposures are installed to protect these 3 hc urs has been as an acceptable protection. Seseral commenters stated openings. Fire doors frequently fail to minimum fire resistance rahng for fire that they thought this was too narrow protect the openings in which they are barriers separating redundant trains for and would be mterpreted by some installed because they are not fully safe shutdown systems. This will give people as the only acceptable method closed. Various methods are available to ample time for automatic and manual permitted Since the example seemed to licensees to ensure that fire doors are in fire suppression activities to control any be confusing. a decision has been made proper operating condition and that they potential fire and for safe shutdown to elimmate it Othtr comments to the will be closed during a fire.These activities to properly control the reactor. effect that the requirement was options are listed in Appendix R. Many operating plants, or plants that excessively restnctive with regard to C **""#N*S"I"'I"" tre already budt but that are not yet fire barner 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 sentdation s> stems have requirement is too detailed and should proximity and a single fire could been acted upon by the staff and the be deleted. Minor editorial changes have damage or destroy the functional requirement. as it had affected these been made in order to more clearly state capability of both redundant trains. If items. was deleted. the requirements. specific plant conditions preclude the N. nre Barrier Cable Penetratwn Scal P. Reactcr Coolant Pump lubrication installation of a 3-hour fire barrier to Quchfication. System. separate the redundant trains. a 1-hour Technica/ Basis. Unpierced fire TechnicalBasis. Each reactor coolant fire barner 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 Od Icakirg tram wdl be considered the equivalent related e safe shutdown equipment. from some portions of the lube oil of 3-hour ba.rier. Ilowever, these barners must be pierced system may come in contact with !! 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 rtdundant These penetrations must be sealed to oil. The resulting fire could be brge. and train cannot be provided because of achieve a degree of fire resistance access to the fire woutd be delayed plant-specific conditions, alterna tive or equivalent to that required of the barner because of the time rc, aed to enter the dedicated shutdowns capabihty will be that is pierced. ASB1 Standard E-119 is contaminent. Containen dr temperature

I s' Federal Register / Vol. 45, No. 225 / Wednesday, November 19, 1980 / Rules and Regulations 76809 would increase, severe localized pump oil collection system is covered by Capability,") In the fire hazards analysis environments would 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 'Ilierefore, an oil collection system is induced oil fire should not prevent a affect the identified shutdown necessary to confine any oil discharged safety.related system from performing equipment by feeding back potentially due to leadkage or failure of the its safety function (Regulatory Guide disabling conditions (e.g., hot shorts or lubrication system and to prevent it 1.29, " Seismic Design Classification," shorts to ground) to the power supplies from becoming a fire hazard by draining Paragraph C.2), the od collection system or control circuits of that equipment it to a safe location. These occurrences should be designed, engineered, and must also be evaluated. Of course such g could be random or could be seismically installed so that its failure will not lead disabling conditions must be prevented induced because the existing lobe 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. may not be designed to withstand a The proposed rule permitted tw safe shutdown equipment will function desiga basis seimic event. alternatives-en oil collection system or as designed. These requirements have Appendix A to ITIP APCSB 9.5-1 an automatic fire suppression system. rP g We have deleted the alternative of the " Alternative and Dedicated Shutdown states that for operating plants' n suppression system because Capability." postulated fires or fire protectio system failures need not be considered unacceptable damage may result to the Comment Resolution safety.related systems from the burning concurrent with other plant accidents. or of oil before the suppression system is Many commenters stated that this actuated and because the fire water requirement should be deleted because e as a t at st tementis o old. supply system is n t designed to many older plant designs did not 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 analysis other natural phenomena. Second, the therefore. Umely fire Wgraic action that will be required to satisfy this history of many fires associated with would be difficult if the suppression requirement will be both long and ]nt ea system malfunctions. Further,if the complicated and the requirement should ua es e en g suppression system becomes inoperable therefore be deleted. that such fires usually are due to failure during operation, a fire watch or patrol The Commission rejected these of piping or tanks of flammable gasses cann t enter the area during operation. suggestions for the following reasons. or liauids 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 such A number of commenters suggested potential fire hazards exist in nuclear that this section is too detailed and required to correct deficiencies that power plants (e.g., hydrogen for should be substantially modified.This resulted from lack of consideration of 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.ne Browns Ferry fire showed the and installed to withstand the damaging automatic fire suppression system. We necessity of divisional separation of the effects of various natural phenomena. have modified the rule to indicate that associated circuit of the control cables and other special fire protection features the hquirement that the oil collection to prevent the disabling of safety are provided as necessary. llowever. system be designed to provide systems by a single fire. This has been General Design Criterion 2 Design Bases reasonable assurance that it will discussed with licensees during for Pmtection Against Natural withstand the Safe Shutdown evaluations of alternative and dedicated Phenomena requires that structures. Earthquake can be met by satisfy.ng shutdown capability and is necessary to systems, and components important to paragraph C.2. of Regulatory Guide 1.29, ensure that safe shutdown systems will safety be designed to withstand the " Seismic Design Classification." as be able to function properly in the event effects of eartLquakes without loss of described above. of fire. capability to perform their safety Q. Associateo Cimuits.

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

TechnicclBasis. When considen.ng fire hazard analysis that does not 4 " Seismic Design Classification, the consequences of a fire in a given fire describes an acceptable method for area during the evaluation of safe consider the effects of fire damage to 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. 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 C.1 applies to systems that by that fire.The staff must also be able fact been adequately considered by are required to remaia functional to to conclude that damage to one train of licensees in their reviews using the ensuse heat removal capability; equipment used for achieving cold guidante of Appendin A to BTP APCSB paragraph C.2 applies to systems that do shutdown will be limited so that the 9.5-1. To ensure that the associated not have to remain frunctional for that equipment can be returned to an circuits are considered, all operating purpose, but whose failure could reduce operable condition within 72 hours. (See nuclear power plants will be requ; red to the functioning of those systems covered Technical flasis for Section III.G. meet the requirements of Section 111 C of by paragraph C.1. %e reactor coolant " Protection of Safe Shutdown Appendix R.

l 70610 Federal Register / Vol. 45, No. 225 / Wednesday November 19, 1980 / Rules and Reguliti:ns r GeneralComments Resolution shutdown capabihty. The Commission comments received on the proposed d es not agree. We beliese that the regulations. other commenters Several commenters contended that Commission s overall fire protection demonstrated a thorough understanding Commission regulations mandate that program involving extensive plant-of the proposed requirements. an adjudicatory hearing be conducted specific fire protection modifications Pursuant to the Atomic Energy Act of rior to a final decision. One commenter fabeled the regulation an " order" within that are based on guidance set forth in 1954, as amended, the Energy Branch Technical Position BTP APCSD Reorganization Act of1974, as amended, 9.5-1 and its Appendix A and the and Sections 552 and 553 of Title 5 of the ce u ct (. C. 551(6 APA) specific requirements of Appendix R to United States Code, notice is hereby and asserted that to CFR 2204 of the res Ive disputed issues provide given that the following amendments to Commissicn's regulations. " Order for adequate fire protection. Title 10. Chapter 1. Code of Federal Modificanon of License," applies to this One commenter stated that the Regulations. Part 50 are published as a rulemaking proceeding. ambiguity o' the propcsed regulation document subject to codification. . The Commission disagrees with these with regard to criticalitems requires

1. A new i 50.48 is added to read as comments. A " rule"is defined in the U " h "## D """

APA to mean "the whole or a part of an thr ort ons o t e agency statement of general or er{cfgp I 50.48 Fire Protection. p p p es of particular applicability and future effeu, such ambiguity. They were Section Ill.G, (a) Each operating nuclear power designed to implement o Section 111R and Section !!I.Q. We have plant shall have a fire protection plan that satisfies Criterion 3 of Appendix A prescribe law or pohcy,,, (5 U.S.C. reviewed those examples. 551(4)). ne esency action questioned in reference to the first example, the to this part. This fire protection plan here is clearly one that treats similarly commenter stated that the first shall describe the overall fire protection situated licensees equally and that paragraph of Section !!'I.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 those licensees wh optional protective feature and that organization that are responsibile for the have not alresc'y provided an equivalent paragraph Ill.G2 c then identifies program, state the authorities that are level of fire protection. certain specific alternative shutdown capability as a delegated to each of these positions to fire protection features are required. m nimum fire protection feature. We do implement those responsibilities, and Various of these requirements would not agree with this statement.The first outline the,lans for fire protection, fire apply to approximately 40 facilities.The paragraph of Section III.G identifies detection and suppression capability, ccmmenter s caaracterization of the rule alternative shutdown capability as one and limitation of fire damage.ne plan es an order, along with the assertion option m a combination of fire shall also describe specific features that 'O CFR 2.204 msadates a hearing protection features for a specific fire necessary to implement the program befste the rule becomes final is area. Paragraph !!!.G.3 indicates when described above, such as administrative incorrect. On its face, that regulation this option should be used. controls and personnel requirements for (which does grant a hearing righ*) in reference to the second example. fire prevention and manual fire applies only to Commission orders that the commenter stated that Section Ill.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 testi.1g of suppression systems, and the means to rulemaking action cona.:cted in fire 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 contended that dif ferential called for by the proposed the plant is ensured.8 the environmental impact had not been provnion was the maximum pressure (b) Appendix R to this part establishes adequately addressed. One commenter* differential that the barr er would fire protection features required to citing the requirements m section Ill.A experience in the specific plant satisfy Criterion 3 of Appendix A to this of Appendix R for two water supphes nstallation. In any event, the pa*t with respect to certain generic and two separate redundant sections as requirement for pressure differential issues for nuclear power plants licensed examples of requirements mvolving during such testing has been deleted to operate prior to lanuary 1.1979. environmentalissues, contended that since only noncombustible materin' is Except for the requirements of Sections the Commission relied upon its staff a now being used for such seals. 'IhG,!!!J. and 1110, the provisions of " unsupported determiration that. In reference to the third examph h Appendix R to this part shall not be apphcable to nuclear power plants pursuant to 10 CFR l 51.5(dl. an commenter stated that Section Ill.Q es environmentalimpact statement, totally lacking in defmition. We do nct licensed to operate prior to january 1. appraisel, or negative declaration is not arree. Footnote 6 references Regulatory 1979, to the extent that fire protection reouired. The Commission has Guide 1.75 and IEEE Std 3M-1974. The teatures proposed or implemented by considered Section Ill.A and has further latter document is a commonly used considered the remaining requirements ir dustry standard that defines in.eic fire protecten suid.nce for nucie., power of Appendix R and remams convinced c,sociated circuits and provides pl.nie :. coni.ined in two Nec documente: that the regulations are not substantive g aidance for ensuring that such circuits Branch Technical Po ihon Auniliary Poaer aan sy. rem or.nch eTP APcss a s-t. C""yn tw hm Marmn fw Nuctur Paw and are insignificant from the standpoint d not compromise the independence of Tw of environmentalimpact. the shutdown circuits they are l One commenter suggei.ted that all associated with. $i/d plants be required to install dedicated Based on the above examples arid our . Appendia A to BTP Am.se e oi. " cum unn i review of the other prosluions of the for bre Protect a for %cleu Pown Plants Dukewd Pnw to l@ t mer fw I ute Mat wn. J 'It should eleo be noted tht i 2.204 se codf.ed in proposed rule, we do not believe that e nhns m u d n m m s w W u p a Subvert 8 of to Cf14 Part 2. The scope of Subput B Ige rug

• as proposeg was amgiguous so g, g, p t g & d.

2 %st n l.a specallcotty limited to " cases intuated by 11.s staff as to require renoticing. Moreover. It uct .. i.,,,,,,,,,,,,,. by oder on e lesenseP(to CPR HooleR LEmpbeats suppbed.) should be noted that, based on other h see Nota $ s ._--,o-_-- ____,~--_m ~_ _ _ _ - - - _. -. - -,. - -. _ _ - _ _ - -

s. Federal Register / Vol. 45. No. 225 / Wednesday, November 19, 1980 / 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 da*e and that the public Position BTP APCSD 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 < ffective date (iii) an unplanned outage that lasts for of such date shall not exceed the dates of this rule, or to the extent that fire at least 120 days. determined by paragraphs (c)(1) through (4) Those fire protection features that (c)(4) of this section. protection features were at cepted by require prior NRC approval by (1) Those fire protection features that the staff in comprehen.ive fire paragraph (c)(5) of this section. shall be involve revisions of administrative protection safety evaluation reports implemented within the following controls, manpower changes. and issued before Appendix A to Branch schedule: Dedicated shutdown training shall be implemented within 4 Technical Position BTP APCSD 9.5-1 was published in August 1976. With systems-30 months after NRC months after the date of the NRC staff approval; modifications requiring plant Fire Protection Evaluation Report I respect to all other fire protection shutdown--before startup after the accepting or requiring such features. features covered by Appendix R. all earliest of the events given in paragraph (2) Those fire protection features nuclear power plants licensed to operate (c)(3) commencing 180 days after NRC involving installation of modifications prior to (anuary 1.1979 shall satisfy the approval; modifications not requiring not requiring prior approval or plant applicable requirements of Appendix R plant shutdown ~6 months after NRC shutdown shall be implemented within to this part. including specifically the 12 months after the date of the NRC requirements of Sections Ill.G.111.(, and approval. (5) Licensees shall make any staff Fire Protection Safety Evaluation 111 O. 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) Those fire protection features, mcludmg alternatise shutdown Appendix R to this part or direct!y and approval by NRC except for affected by such requirements shall be m difications required by Section Ill.G.3 capability, involving installation of completed on the following schedule: of Appendix R to this part. Licensees modifications requirire picnt shutdown , [1] Those fire protection, features inat shall submit plans and schedules for shall be implemented before the startup mvolve revisions of admirustrative 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 traming, 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 par +. shall submit design descriptions of requiring such features: (2) Those fire protection features that modifications needed to satisfy Section (i) The first refueling outage; involve installation of modifications that Ill.G.3 of Appendix R to this part within (ii) Another planned cutage that lasts do not require prior NRC approval or 30 days after the the effective date of for at least 60 dayc or plant shutdown shall be implemented this section and Appendix R to this part. (iii) An unplanned outage that lasts within 9 months after the effective date (6)in the event that a request for for at least 120 days. of this section and Appendix R to this exemption from a requirement to comply (4) Those fire protection features with one or more of the provisions of involving dedicated shutdown capability part. (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 on an shall be implemented within 3nmonths approval by paragraph (cpl of this assertion by the licensee that such of NRC approval. Other modifications section, that involve installation of required modifications would not requiring NRC approval prior to modifications that do require plant enhance fire protection safety in the installation shall be implemented within shutdown. the need for which is justified facihty or that such modifications may 6 months after NRC approval. be detnmental to overall f acility safety. (e) Nuclear power plants licensed to in the plans and schedules required by the schedule requirements of paragraph operate after January 1.1979 shall the provisions of paragraph (cl(5) of this section, shall be impir:W before (c) shall be rolled until final Commission complete all fire protection modifications needed to satisfy action on the exemption request upon a startup after the eathest of.he foliowmg determination by the Director of Nuclear Criterion 3 of Appendix A to this part in events commencing 180 das s er m.we Reactor Regulation that the licensee has accordance with the provisions of their prosided a sound technical ba.,is for licenses. a c!w6 cation and gustante m'ti respect to permissible alternatives to satists Appendin A to such assertion that warrants further

2. A new Appendix R is added to BTP AMLR 9 5-1 has been provpt i in four othu staff review of the request.

10 CFR Part 50 to read as follows: (d) Fire protection features accepted g _ g,, ntary Guidance on P formation by the NRC staff in Fire Protection Nuclear Power Facilities Operating Prior to e Naeded r >rrire Protew>n b alualmnf' dated Safety Evaluation Reports referred to m january 1.19'9 October ?!.19'8 a

• " Sample echmral Specifwatio t" dated Ma>

paragraph (b) of thi4 section and / In'roductmn and scope t supp!r nents to such reports, other than 12.19R

• Wear Plant Fire Protection hnchonal features covered by paragraph (c). shall This Appendix apphes to hcensed nuclear Responsomt.es. Administratne Control and be completed as soon as practicable but power elecint gener ating stations that were ty Assurance. dated lune 14. re'7' "P"r*ng pn r t lanuary 1.19 9. escept to Quij%npower Requirements for Operatmg no leer than the completion date the extent set forth in paragraph 50 48(b) of currently specified in license conditions this part. With respect to certain generic Arectors. dated May ti. tes A Fire Protection Safety Evaluatum Repe that or technical specifications for such imes for such facihnes it sets forth fire has been in aed for each operaima plant states h"*

facihty, or the date determined by protecnon features reqmred to sansfy paragraphs (dH1) through (d)(4) of this tnierion 3 of Appendia A to this part.' Is o af ep t n s ha be sectton, whiches er is sooner. unless the de resolved when the ecaty sat sfies the appropriate r i Director of Nuclear Reactor Regulation %e fwnoic 4 reqmrements of Appendia R lo this part

e s 76612 Federal Register / Vol 45, No. 225 / Wednesday. November 19, 1980 / Rttles and Regulations Critenon 3 of Appendis A to this part program shall estalbsh the fire protection D. Afternatin'e or DedicoredShutdown specifies that " Structures. systems. end pacy for the protectitn of strucures. Capability components important to safety sh-H tie y stems. and components important to safety in areas where the fire protection features de signed and located to mmimize. ensistent at each plant and the procedures. equipment cannot ensure safe shutdown capabihty in with other safety reqwrements the and personnel required to implement the the event of a hre m that area. alternative or probabihty and effect of fires and program at the plant s.te dedicated safe shutdown capabdity shall be The I re protection program shall be ender prouded explosionsJ. When considerms the effects of re. those the direcdon of an indiudual wh'o has been W Spen #c-Requwments systems associated vnth achievmg ind delegated authunts comrnensura'e with the maintainmg safe shutdown conditu ns responsdnhties of the positrea and who has A. Water Supphes for fire Suppression assutne msior importance to safety because' available staff personnel knowledgeable m Systems damase to them can kad to core d.. mage both fire protertwo and nudcar safety. Two separate water sapplies shall be resulting fromloss of coolant throu gh bodoff. The fire protectson program shah *stend provided to furnish necessary water sclume = The phrases "important to safety ^ or the cc, cept of defense-m-deb +h to bre and pressure to the bre main loop. " safety.related." wdk be used throa griout this protectinn m fire areas importsint to safety. Each supply shan consist of a storage tank. Appendix R as apply mg to a'.! safet - with the following abtectnes pump, piping. and appropriate isolation and functions.The phrase " safe shutdoun' wdl

• to prevent fires from star mg control v alves. Two separate redundant t

a be used throughout this Appenda F as

• to detect rapidly, control md extmgmsh suctions in one or more intake strtutures a pplying to both hot and cold shutd 2wn promptly those fires that do occur:

from a large body of water (river, lake. etc1 .

• to provide protect on fer structures.

wdl satisfy the requirement for two separated functions. Because fire rney affect safe shutdown sy stems. and components important to safety water storage tanks. These suppbes shall be systems and because the loss of function of so that a hre that is not promptly separated so that a failure of one supply will systems used to mitigate the consequences of estingurehed by the hre suppression activities not result in a failure of the other supply. design basis accidents under potfire wdl not prevent the safe shutdown of the Eacn supply of the fire water distribation cwiditions does not per se impact pubhc plant. system shall be capable of providing for a B. Are Hazards rinoh sis period of 2 hours the maximum expected safety. the need to hmit fire damase to A fire hazards analysis shall be performed water demands as determined by the fire sys' ems required to achieve and maintam safe shutdown conditions is greater than the by quahfied f re protection and reactor hazards analysis for safety related areas or need to Hmit fire damage to those systems s> stems eng:neers to (1) consider potential in other areas that present a fire exposure required to mitigate the consequences of situ and transient fzrc hazards f2) determine harard to safety-related areas. design basis occidents. Three levels of fire the consequences of fire in any location 6n when storage tanks are used for combined damage limits are established accordmg to the plant on the abrhty to safely shut down service. water / fire-water uses the minimum trie reactor or on the abihty to mimmize and volume for fire uses shall be ensured by the safety functions of the structure. system. control the re! ease of radioactivity to the raeans of dedicated tanks or by some or component; _ environment; and (3) specify measures for physical means such as a vertical standpipe fire prevention. fire detection, fire for other water service. Administrative F a.ne. w - suppression. and fire contammert and controls. includmg locks for tank outlet emen, enese alternauve shutdown tapabihty as required v alves, are unacceptatic as the only means i.e mm a _ cw v.a e.w m a.c , e to ensure minimum water volume.

• * * * ~ ~ * * * *
• for each fire area contaming structures, Other water systems used as one of the

["j"","",,C.C systems, and components important to safety two fire water supphes shall be permanently n accordance with NRC guidehnen and connected to the fire main system and shalt

• v w a.w try a egi u.

nwaae.a.ew. *. ' regulatrons C'" 8*** 'Q" d,'**"** *""' y C. Fire Preventwn Fec. ares be capable of automain alignment to the fire Fire protection features shall meet the mam system Pumps. controls, and power foHowmg general requirements for all fire suppbes in these systems shall satisfy the a.=g.a w. wa we nwans .n owe we nota.a.g. mon u ma so oc e " ** *" areas that contain or present a fire hazard to requiremen's fer the mam fire pumps. The

• j**,[

Q"j* structures. systems, or components impo: tant use of other water systems for fire prc tection shall not be incompatible with their functions to safety. 1 in situ fire harards shah be idennhed required for safe plant shutdown. Failure of my D. ass s som em o.wa-s== r, the other systerr shall not degrade the fire

• " "'**g 8,

$ and suitable protection provided 1 Transient fire hatards associated with mam system. normal c3 eration. mamtenance. repair. or B SectionalIsolation Volves w ,,.aw.,,,,.,ou. v. modibcation actmties shall be idenufied an i Sectional isolation valves such as nst re we 7 aa y a *a eliminated where possible. Those transient indycator valves or key operated vahes shWA fire hazards that can not be ehmmated shall be mstalled m the hre main loop to permit ..n, . ce,%,a.m.,oc a be controlled and suitable protection isolanon of portions of the fire main loop for (*, gg "g"* aggy,8,yg provided. mamtenance or repair without Intemiptmg w.a ., m e ce oa.m , win.m a s y 3 Fire detectmn systems portable the entire water supply. g yggd,a* extmguishers. and standpipe and hose C /fydron Isolation vo/res e statmns shall be instaUed Vahes shall be installed to permit isolation i , s. .,e

m. % eo,,%

Q'*,a "** g y,ce' g g g of outside hydrants from the fire mem for 4 Fire barriers or automatic suppressmn The most stringent fire damage hmit shall systems or both shall be nstalled as maintenance or repair without mterruptmg necessary to protect redundant systems or the water supply to automatic or manual fire apply for those systems tbat fallinto more components necewary for safe shutdown. suppression systems tn any area containmg than or e category. Redundant systems used

5. A site fire bngade shall be estabhshed.

or presentmg a hre harard to safetprelated to mitigate the consequences of of er des gn trained and equipped and shall be on site a: or safe shutdown equipment. s basis accidents but not necessary :or safe D ManualFire Supperwon all times shutdown may be lost to a smgfe e<posure & Fire detection and suppressien systems Standpipe and hose systems shall be fire. However. protection shal' be g rovided so that a fire within only one such syrem wdl shah be des $ned. Installed. mainta' red. and installed so that at lean one effecta e hnu i tested by personnel properly quahhed by stream will be able to reach any im -itm, that not damage the redundant system. esper:ence and tramma m fire protection contams or presents an espos tre f're F srard to structures. systems. or components ll. General Requirements systems A. Fire Protection Program ?. Survedlance procedures shall be important to safety. A fire protect 4an program shall b - estabhshed to ensure that hre bamers are in Access to per mit effective functionmg of esta%shed at each nuclear power lant. The place and that hre suppression systems and the fue bngade sham be p svided to ett areas components are operable that c.ontam er present an espesure tre ___j

Federal Register / Vol. 45, No. 225 / Wednesday. November 19, 1980 / Rules and Regulations 78613 hazard to structures systems, or components hour rating. In addition, fire detectors and an Institute for Occupational Safety and important to sefety, automatic fire suppression system shall be llealth-approval formerly given by the I.I.S. Standp:pe and hose stations shall be inside installed in the fire area: Bureau of Mines) shall be provided for fire PWR containments and BWR ccntainments inside noninerted containments one of the brigade, damage control, and contml room that are not inerted. Standpipe and hose fire protection means specified above or one personnel At least to masks shall he stations inside containment n ey be of the following fire protection means shall available for fire brigade personnel. Cor. trol connected to a high quality water supply of be provided: room personnel may be furdshed breathing sufficient quantity and pressure other than

d. Separation of cables and equipment and air by a manifold system piped from a the fire main loop if plant-specific features associated non-safety c'rcuits of redundant storage reservoir if practical. Service or rated prevent extending the fire main supply inside trains by a horizontal distance of more than operating life shall be a minimum of one-half-contamment. For BWR dryws!!s. standpipe 20 feet with no intervening combustibles or hour for the self-contained units.

and hose etations shall be placed outside the fire hazards: At least two extra air bottles shall be dry well with adequate lengths of hose to

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

area: or supply of reserve air shall be provided and F. HydmstolicHose Test,

f. Separation of cables and equipment and arranged to permit quick and complete Fire hose shall be hvdrostatically tested at associated non-safety circuits of redundant replenishment of exhausted supply air bottles a pressure of 300 psi o'r 50 psi above trains by a noncombustible radiant encrgy as they are returned. lf compressors are used maximum fire main operating pressure, shield.

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

3. Alternative or dedicated shutdown approved for breathing air shall be used:

hose houses shall be tested annual!y. Interior capabihty and its associat-d circuits.' compressors shall be operable assuming a standpipe hose shall be tested every three independent of cables, sysiems or loss of offsite power. Special care must be years. components in the area, room or zona under taken to locate the compresnor in arms free F. Automotic Fiiw Detection consideration, shall be provided: of dust and contaminants. Automatic fire detection systems shall be

a. Where the protection of systems whose I. Fire Brigade Trainis:g installed in all areas of the plant that contain function is required for hot shutdawn does ne fire brigade training program shall or present an exposure fire hazard to safe not satisfy the requirement of paragraph G.2 ensure that the capability to fight potential shutdown or safety-related systems or of this section; or fires is established and maintained.ne components. These fire detection systems

b. Where redundant trains of systems program shall consist of an initial classroom shall be capable of operating with or without required for hot shutdown located in the instruction program followed by periodic offsite power.

same fire area may be subject to damage classroom instruction, fire fighting practice. G. Fire Protection of Sofe Shutdowr, from fire suppression activities or from the and fire dnlic Copability rupture or inadvertent operation of fire

1. Instruction

1. Fire protet. tion 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 features suppression system shall be installed in the (1) Indoctrination of the plant fire fighting shall be capable of hmiting fire damage so area, room, or zone under consideration. plan with specific identification of each that:

11. Fue Bngade individual's responsibilities.

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

emervicy control station (sj is free of fire all areas of the plant cont.imng structures.

13) ne toxic and corrosive characteristics dama e:and systems, or components important to safety.

of expected products of combustion.

b. Systems necessary to achieve and he fire brigade shall be at least five (4) Identification of the location of fire maintain cold shutdown from either the members on each shift. ne brigade leader fighting equipment for each fire aree and control room or emergency control station (s) and at least two brigade mem5ers shall have familiarization with the layout of the plant.

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

2. Except as provided for paragraph G.3 of salety-related systems to understand the ar< a.

this section, where cables or equipment, effects of fire and fire suppressants on safe p) The proper use of available fire fighting including associated non. safety circuits that shutdown capability. De qualification of fire equipment and the correct method of fighting brigade members shall include an annual each type of fire. ne types of fires covered physical examination to determine their should inch.de fires in energized electrical alop tion due to hot o s oi en circuits, abdity to perform stenuous fire fighting equipment. fires in cables and cable trays. or shorts to 8round. or redundant trains of. activities. ne shift supervisor shall not be a hydrogen fires. fires mvolving flammable and systems necessary to achieve and maintam hot shutdown conditions are located within member of the fire brigade. ne brigade combustible liquids or hazardous process the same fire area outside of primary leader shall be competent to assess the chemicals, fires resulting from construction or containment, one of the following means of potential safety consequences of a fire and modifications (welding), and record file f res. advise control room personnel. Such (6) The proper use of communication. ha one h u ins'8 {srn p competence by the brigade leader may be hghting, ventilation, and emergency breathing y

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

associated non-safety circuits of redundant license or equivalent knowledge of plant (7) ne preper method for fighting fires safety-related systems. inside building, and confined spaces. trains by a fire barner having a 3-hour ratmg-Structural steel forming a part of or ne minimum equipment provided for the (8) The direction and coordination of the q supporting such fire barners shall be brigade shall consist of personal protective fire fighting activities (fire brigade leaders equipment such as turnout coats, boots. only). protected to provide fire resistance gloves. hard hats. emergency communications (9) Detailed review of fire fighting equivalent to that required of the barn.er;

b. Separation of cables and equipment and equipment, portable lights, portable strategies and procedures.

ventilation equipment. and portable (10) Review of the latest plant associated non-safety circuits of redundant extinguishers. Self-contained breathing modifications and correspunding changes in trains by a horizontcl distance of more than e,nparatus using full-face positive-pressure fire fightmg plans. 20 feet with no intervening combustible or rnasks approved by NIOSit (National fire hazards. In addition, fire detectors and an NotaMtems (9) and (10) may be deleted automatic fire suppression system shall be from the training of no more than two of the a,ltematm shutdown capabihty.is peded by installed in the fire area; or

c. Enclosure of cable and equipment and reroutmg. relocatmg or modificating of existing non-operations personnel who may be systems dedkated shutdown capabihty is provided ass gned to the fire br'gade.

sesociated non-safety circuits of one by metalling new structures and systems for the b ne instruction shall be provided by redundant train in a fire barrier havmg a 1-function of poet fire shutdown. quahfied individuals who are knowledgeable,

~ s 7ss14 ' Federal Register / Vol. 45. No. 225 / Wednesday.- November 19. 1960 / Rules and Regulations esperienced. and suitably trained in hghting - brigade, and selection, placement and use of. required additional fire protection in the the types of fires that could occur in the plant equipment, and fue fighting strategies. work activity procedure. and in usmg the types of equipment avadable (21 Assessment of each bngade member's

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

knowledge of his or her role in the fire of a flame permit system to control welding.

c. Instruction shall be provided to a l fire fighting strategy for the area assumed to flame cutting, brazma, or solJering l

brigade members and fire bngade leaders. contain the hre. Assessment of the bngade operations. A separate permit shall be isseed it Regular plarmed mee'ings shall be held member's conformance witir estabbshed for each area where work is to be done. If

a. least every 3 months for all bngade plant fire fightmg procedures and use of fire

_ work continues over more than wie shift. the rnembers to review changes m the hre - fightmg eqmpment,includmg utf-contained permit sha!! he valid for not more than 24 -protection program and other subjects an emergency breathing apparatus. hours when the plant is operating or for the necessary.. commumcation equipment, and ventilation duration of a particular job during plant

e. Penodic refresher traming sesuons shall equipment. to the extent practicable.

shutdown. ~

6. Control the removal from the area of all be held to repeat the classroom instrection

13) The simulated use of fire fighting

. waste. debris, scrap oil spills. or other program for all brigade members over a two-equipment required to cope with the situation year period.nese sessions may be and t> pe of hre selected for the drill. The combustibles resultmg from the work activity concurrent with the regular planned area and type of Dre chosen for the dnll immediately following completion of the should differ from those used in the previous activity, or at the end of each work shift. meetmas. - 2. Practice-dnll so that bngade members are tramed in whichever comes first. Practice sessions shall be held for each - hghting fires in various plant areas.The

7. Maintain the periodic housekeeping shift f re bngade on the proper method of situation selected should simulate the size inspections to ensure continued romphance f:ghting the v srious types cf fires that could and strangement of a fire that could with these administrative controls.

occur m a nuclear power plant. nese reasonably occur in the area selected. & Control the use of specific combustibles sessions shall provide bngade members with allowinit for fire development due to the time in safety-related arese All wood used in experience in actual fire extinguishment and required to respond. to obtain equipment, and safety.related areas during maintenance. the use of emergency breathmg apparatus organize for the fire, assumms loss of modification, or refuehng opersisons (such as under strenuous conditions encountered in automatic suppression capabihty. lay-down blocks or scaffoldmg! shall be hre fightmg These practice sessions shall be (4) Assessment of bngadeleader's treated with a flame retardant. Equipment or provided at least once per year for each fire direction of the hre hghting effort as to supplies (such as new fuel] shipped m brigade inember, thoroughness. accuracy, and effectiveness. untreated combustible packing containers

3. Dri#s -

4 #ccords may be unpacked in safety-related areas if.

a. Dre brigade drills shall be performed in Individual records of trainmg provided to required for valid operating reasons..

the plant so that the fire bngade can practice each fire bngade member. includmg drill flowever, all combustible materials shall be cntiques. shall be maintamed f or at least 3 removed from the area immediately following se a team..

b. Dnils shall be performed at regular years to ensure that each member receives the unpacking. Such transient combustible intervals not to exceed 3 months for each training in all parts of the trainmg program, material. unless stored in approved shift fire brigade. Each Dre bngade member These rar.ords of traming shall be available r.ontainers, shalf not be left unattended should participate m each drill. t-ut must for NRC review. Retraining or broadened during lunch breaks. shift changes or other participate m at least two dnlls per year, traming for fire fighting within buildings shall similar periods. Loose combustible parking A sufficient number of these dntis, but not be sc.heduled 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 pufyethylene sheetmg shall be placed in year, shall be unannounced to determine the deficiencies.

metal containers with tight-Dttmg self-closing fire fightmg readmess of the plant fire l Emergency Lighting metal covers. bngade bngade leader. and fire protection I:mergency lightmg units with at least an 8-.

9. Control actions to be taken by an systems and equipment. Parsons plannmg hour battery power supply shall be provided ' ~ individual discovenng a fire, for example, and authorizing an unannoimced dnll shall in all areas needed for operation of safe notification of control room. attempt to ensure that the respondmg shift fire brigade shutdown equipment and in access and extinguish fire and actuation oflocal fire members are not aware that a drillis being egress routes thereto.

suppression systems. planned untd it is begun. Unannounced drills K. Admmistrutive Controis

10. Control actions to be taken by the shall not be scheduled closer thar. four Administrative controls shall be centrol room operator to determine the need week s.

established to minimize fire hazards in areas for brigade assistance upon report of a fire or At least one dnli per year shall be containing structures. systems, and receipt of alarm on control room annunciator performed on a "back shift" for each shift fire componeats important to safety. These panel. f r example, announcing location of brigede. controls shall establish precedures to-fire ove PA system sounding fire alar,is. c.The drills shall be preplanned to

1. Govern the handimg and limitation of the and notifying the shift supervisor and the hre estabbsh the training objectives of the drill use of ordmary combustible materials, brigade leader of the type, size, and location and shall bs critiqued to determine how well combustible and flammable gases and of the bre.

the training objectives have been met. liquids. high efficiency particulate air and

11. Control actions to be tehn by the fire Unannounc-4 drills shall be planned and charcoal filters, dry ton exchange resins or brigade after notifica:1on by the control room critiqued by members of the management other combustible supplies m safety-related operator of a firw for example, essembling in a desig isted locatiea. receiving directions staff responsible for plant safety and fire areas.

protection. Performance deficiencies of a fire

2. Prohibit the storage of combustibles in from tt

• hre bngade leader, and discharging brigade or of Individual f re brigade members safety-related areas or establish designated specifi. fire fightmg responsibilities bcludmg shall be remedied by scheduhng additional storage areas with mpropriate fire selectivt and transportation of fire fighting traming for the bngsde or members.

protection. equipm nt to fire location. selection of tJnsatisfactory dnti performance shall be

3. Govern the handimg of and limit protecta e equipment. operating instructions followed by a repeat dnll within 30 days.

transient fire loads such as combustible and for use if fire suppression systems. and use

d. At 3-year intervals. a randomly selected flammable liquids. wood and plastic of prepknned strategies for hghting hres in unannounced drill shall be critiqued by products. or other combustible materials in specifa areas.

quahfied individuals independent of the bmidings containing safety.related systems

12. Defme the strategies for hghting hres ;n bcensee's staff. A copy of the written report or equipment during all phases of operating, all safety related areas and areas presenting from such individuals shall be available for and especially durtrig :naintenance.

a hazard to safety.related equipment. These NRC review. modshcation, or refuelmg operations. strategies shall designate:

e. Dnlls shall as a minimum include the 4 Designate the onsite staff member

a. lire hazards in each area covered by the following-responsible for the inplant fire protection specific prefire plans.

f!) Assessment of fire clarm effectneness. review of proposed work activities to identify

b. Fire extinguishants best puited for time requ red to notify and assemble fire potential transient fire hazards and specify controllms the fires anudated with the hre

w z. s Federal Register / Vol. 45, No. 225 / Wednesday, November 19, 1980 / Rules a.nd Regulations 79815 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 lavelindication in conduits containing associated circuits of one

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

safe shutdown division and trays aad attack a fire in each area in view of the c.The reactor heat removal function shall conduits contaming associated circuits or sentdat on diection. access hallways. stairs, be capable of achievmg 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 elevatbn ror

d. The process monitoring function shall be circuits from the safe shutdown equipment, fighting the fire. All access and egress routes capable of presiding direct readmgs of the shallle such that a postulated fire invo!ving that invi Ive locked doors should be process variables necessary to perform and associated circuits will not prevent safe d

snecifically ider tified in the procedure with control the above functions. shutdown." the appropnate precautions and methods for

e. De supporting functions shall be M. Fia Barrier Coble Tenetration Sm/

access specified. capable of providing the process cooling. Quohfication

d. Plant systems that should be managed to lubrir.ation. etc., necessary to permit the Penetration seal designs shad utilize only reduce the damage potential during a local operatien of the equipment used for safe noncombust;ble materials and shall be fire and the location of local and remote shutdown fur.ctions.

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

3. ne shutdown capability for specific fire used to rate fire barners.ne acceptance hydraulic or electncal systems in the zone areas may be u.wique for each such area, or it criteria for the test shallinclude:

covered by the specific fire fighting procedure may be one unique combination of systems L De cable fire barner penetration seal that could mcrease the hazards in the area for all such areas. In either case, the has withstood the fire endurance test wi'hout because of overpressunzation or electncal alternative shutdown capability shall t s passage of flame or ignition of cables on the hazards). Independent of the specific fire area (s) and unexposed side for a period of time

e. Vital heat-senseive system components shall accommodate postfire conditions where equivalent to the fire resistance rating that need to be kept cool while fightmg a offsite power is available and where offsite required of the barrier; local fire. Particularly hazardous power is not avadable for 72 hours

2. ne temperature levels recorded for the combustibles that need caolmg 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 achiea and maintain is sufficiently below the cable insulation the assignment of special duties according to cold shutdown will not be availab!e because ignition temperature: and job title so that all fire fighting functions are of fire damage the equipmeni and systems

3. ne fire barrier penetration seal remains covered by any cumplete shift personnel comprising the means to achieve and intact and does not allow projection of water complement. Dese duties include command maintain the hot standby or hot shutdown beyond the unexposed surface during the control of the brigade, transporting fire condition shall be capable of maintaining hose stream test.

suppression and support equipment to the fire such conditions until cold shutdown can be N. Fin Doors scenes, applying trie extinguishant to the fire, achieved. If such equipment and systems will Fire doors shall be self-clos;ag or provided communication woh ine control room. and not be capaole of being powered by botl. with closma mechanisms and shall be coordination wuh 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 hold-open, release, and closing in fire zones.

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

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

One of the following measures shall be ensures desired plant air distnbution when exclusive of fire brigade members.iequired Provided to ensure they will protect the the ventilation flow is modified for fire to opera'e such equipment and systems shall DPening as required in case of fire: containment or smcke cleanng operations. be on site at all times. t 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 coordination or authorization.

means to achieve and maintain cold manned location;

j. Instn:ctions for plant opcrators and shutdown conditions shall not be damaged

2. Fire doors shall be looked closed and general plant personnel dunng fire by fire; or the fire damage to such equipment inspecte I weekly to verify that the doors are I. Ahernative and Dedicated Shutdown and syeems shall be limited so that the in the closed position:

Copobihiy systems can be made operable and cold

3. Fire doors shall be provided with L APernative or dedicated shutdown shutdown achieved within 72 hours.

automatic holdepen and release mechanisms capability provided for a specific fire area Materials for such repairs shall be readdy and inspected daily to venfy.that doorways are free of obstructions; or shall be able to achieve and maintain available on site and procedures shall be in subcntical reactivity conditions in the effect to implement such repairs. If such

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

after the fire will not be capable of being 7{", dade !cader shall have ready condit'ons for a PWR (hot shutdown 'for a powered by both onsite and offsite electric BWR) and achieve cold shutdown ' pour systems because of fire damage, an access tJ keys for any locked fire doors. conditions within 72 hours and maintam cold mdependnet onsite power system shall be Area' protected by automatic total flooding o ae ha shutdown conditions thereafter. Dunng the prosided. Equipment and systems used after gs sup a e, d f g postfire shutdown, the reactor coolant system 72 hours may be powered by offsite power j& g,, 3 proce s senables shall be maintamed withm only. O. Od Collection System for Reactor those predv:ted for a loss of normal a c.

6. Shutdown systems install.d to ensure power, and the fission product boundary postfire shutdown carabihty need not be C "#","

l g t coolant pamp shall be integnty shall not be affected;i.e., there shall designed to meet seismic Category I cnteria, eqsppel with an oil collection system if the be no fuel clad damage. rupture or any single failure entena. or other design basis conta nnent is not inerted during normal pnmary coolant boundary, or rupture of the accident criteria except where required for operstit n. He oil collection system shall be I containment boundary. other reasons, e g because of interface with so deegned, engineered. and installed that

2. The f erformance goals for the shutdown or impact on existing safety systems, or failure mil not lead to fire during normal or functie shall be:

because of adverse valve actions due to fin' design lesis accident conditions and that

a. The reactivity control function shall be damage.

capable of achieving and maintaining cold 7.ne safe shutdown equipment and eh comply n this shutdown reactivity conditions. systems for each fire area shall be known to ^"*{'ptaj p,

b. He reactor coolant makeup function be isolated from associated non-safety posw rdathwated ws ann shall be capable of maintaining the reactor circuits m the file area so that hot shorts.

sed sa4-ts7e Isection 4 si where trays from open circuits, or shorts to ground in the ,edundant safety dmsions are so protected that ' As defined in the Standard Technical associated circuits will not preveat operation postulated fires effect trays frt,m only one safety Specifications of the safe shutdown equipment. He dmaion

r-73616 Federal Regisler / Vol. 45. No. 225 / Wednesday. November 19. 1980 / Rules and Regulations there is reasonable assurance that the system will withstand the Safe Shutdown Earthquake

• Such collecuon systems shall be capable of collectmg tube oil from all potenttal pressunted and unpressurized leakage sites in the reactor coolant pump lube oil systems.

- Isakage shall be collected and drained to a vented closed container that can hold the entue tube od system mventory. A flame enestee is tequired in the vert if the flash potnt cturactensucs of the oil present the 3, hazard of fire !!r ihback. Leakage points to be I pr7tected shall include hit pump and piping. overflow hnes. lube od cooler, oil fdl and

• '[

dram knes and plugs, flanged connections on p od hnes, and lune oil resersoirs where such features emis* on the reactor coolant pumps. De drain hne shall be large enough to - =~-w te the largest potential oilleak. a (Sec.161b Pub. L 83-703. 68 Stat. 948: sec. 201. Pub. L 93-438. 83 Stat.1242 (42 U.S.C. 2204b).5e41}} Dated at Washington. D C this 17th day of November 1980. For the Nuclear Regulatory Cr.mmission. Samuel J. Chilk. Secretary of the Commissiott gf1t Dec. Ort's FNd st ise e es ami esLLass cost 7soo-et-as t .o s 'See Regulatory Gmde tre-%mme Desen Classincatkan" Paregraph C1 -}}