ML20148P168

Advises of Provisions of 10CFR50,App R,That Are Applicable to Fire Protection Features of Facility.Fr Notice & Summary of Staff Requirements to Resolve Open Items Encl

ML20148P168
Person / Time
Site:	Calvert Cliffs
Issue date:	11/24/1980
From:	Eisenhut D Office of Nuclear Reactor Regulation
To:	BALTIMORE GAS & ELECTRIC CO.
References
NUDOCS 8101130136
Download: ML20148P168 (8)

Text

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4/ "%g% UNITED STATES y) 5.

'$ C NUCLEAR REGULATORY COMMISSION WASHINGTON, D, C. 20555 .

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(3ry Docket No. 50-317/318 Plant Name: Calvert Cliffs Nuclear Power Plant, Units 1 and 2 k!- yIG

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,l m Of TO ALL POWER REACTOR LICENSEES WITH PLANTS N I LICENSED PRIOR TO JANUARY 1,1979 .

The Coninission published on November 19,1980 (45 FR 76602), a revised Section 10 CFR 50.48 and a new Appendix R to 10 CFR 50 regarding fire protection features of nuclear power plants. The revised Section 50.48 and Appendix R will become effective February 17, 1981, which is 90 days after publication. A copy of the Federal Register Notice is enclosed (Enclosure 1).

The provisions of Appendix R that are applicable to the fire protection features of your f acility can be divided into two categories. The first category consists of those provisions of the Appendix that are required to be backfit in their entirety by the new rule, regardless of whether or not alternatives to the specific requirenents of these Sections have been previously approved by the NRC staff. These requirements are set forth in Sections III.G, Fire Protection of Safe Shutdown Capability; III-J, Emergency Lighting; and Ill-0, Oil Collection Systents for Reactor Coolant Pump. The fire protection features of your f acility nost satisfy the specific requirements of these three Sections by the dates established by Paragraph 50.48(c), unless an exemption f rom the Appendix R requirenents is approved by the Contnission. You should note the provisions for tolling ,

the time for conpleting the modifications required by these three Sections

' of Appendix R set forth in Paragraph 50.48(c)(6).

The second category of Apperiuix R provisions applicable to the fire protection f eatures of your f acility consists of requirenents concerning the "open" items of previous NRC staf f fire protection reviews of your f acility. An oper item is defined as a fire protection feature that has not been previously approved by the NRC staff as satisfying the provisions of Appendix A to ,

Branch Technical Position BTP PCSB 9.5-1, as reflected in a staff fire protection safety evaluation report. The f1re protection features of your f acility that are in this category nust satisfy the specific requirenents of Appendix R by the dates established by Paragraph 50.48(c), unless an exenp-tion f rom the Appendix k requirenents on those features is approved by the Conmi ss ion.

Enclosure 2 is a summary listing of the open items concerning the fire protection f eatures of your f acility based on a review of our records. Also included is our position on the specific requirements that nust be satisfico in order to resolvo these open items. If you have any questions or disagree-ments with this enclosure, please advise us within 30 days of your receipt of this letter. l l.lO$1ON l

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l 2- l With regard to the fire protection modifications that have been previously approved by the NRC staff, Paragraph 50.48(d) specifies a new schedule for their conpletion. This paragraph, when it becomes effecti'.s, will supersede the currently effective section of the regulations that temporarily suspends conpletion dates for previously approved fire protection modifications that are given in f acility license conditions (45 FR 71569, October 29,1980).

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

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

If you have previously requested extensions of dates for completion of modifications that are required by license conditions for your facility which were not approved, and you have determined that these extensions are still necessary and justifiable, it will be necessary for you to reapply for any such extensions in accordance with the provisions of Paragraph 50.48(d).

All requests for Ccamission action resulting f rom this rule are subject to the schedule of fees specified in 10 CFR 170.21. If you have any '

questions concerning the subject matters of this letter, please contact the NRC Project Manager for your facility.

Sincerely,

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[DarrellG.Eisenhu, Director Division of Licensing Office of Nuclear Reactor Regulation

Enclosures:

1. Notice - Fire Protection Rule 2, Summary of Staff Require-ments to Resolve Open Items cc w/ enclosures:

See next page

i Baltimore Gas and Electric Comp'any i

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James A. Biddison, Jr. Mr. Bernard Fowler , l General Counsel President, Board of County  :

G end E Building Commissioners '

Prince Frederick, Maryland 20768 Charles Center

' Baltimore, Maryland 21203  !

DLrector, Criteria and Standards DLvision George F. Trowbridge, Esquire Trice of Radiation Programs (ANR-460)

Shaw, Pittnan, Potts and U.S. Envirorimental Protection Agency .

Trowbridge Washington, D.C. 20460 1800 M Street, N.W. .

Washington, D. C. 20036 U. S. Enviromental Protection Agency -

Region III Office [

Mr. R. C. L. Olson ATTN: EIS COORDINATOR Baltimore Gas and Electric Company Curtis Building (Sixth Floor)

Room 922 - G and E Building Sixth and Walnut Streets -

Post Office Box 1475 Philadelphia, Pennsylvania 19106 Baltimore, Maryland 21203  :

Mr. Leon B. Russell Ralph E. Architzel f Plant Superintendent Resident Reactor Inspector Calvert Cliffs Nuclear Power Plant NRC Inspection and Enforcement l Baltimore Gas & Electric Company P. O. Box 437  ;

Lusby, Maryland 20657 Lusby, Maryland 20657 f

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Bechtel Power Corporation Mr. Charles B. Brinkman Ma ashington Nuclear l Ctief N 1e Engineer 15740 Shady Grove Road C-E Power Systems Gaithersburg, Maryland 20760 Combustion Engineering, Inc. .

4853 Cordell Ave., Suite A-1 Combustion Engineering, Inc. Bethesda, Maryland 20014  !

ATTN: Mr. P. W. Kruse, Manager Engineering Services l Post Of fice Box 500  ;

Windsor, Connecticut 06095 Calvert County Library i Prince Frederick, Maryland 20678 j Director, Department of State Planning i 301 West Preston Street ,

Baltimore, Maryland 21201 l i

Mr. R. M. Doug1 css, Manager  :

Quality Assurance Department Administrator, Power Plant Siting Program Room 923 Gas & Electric Building Energy and Coastal Zone Administration P. O. Box 1475 , Department of Natural Resources i Baltimore, Maryland 21203 Tawes State Office Building Annapolis, Maryland 21204  ;

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Enclosure i Nove e 19,1960

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1 Part ll ,

Nuclear Regulatory Commission lle".',70e'r' ?I n?.'"' '" #"'"""

7%fl2 Federal Rzglster / Vol. 45. No. 225 / Wednesday, November 19,1980 / Rules and Regulations NUCLEAR REGULATORY that the comment penod snould nave ati already set icrth in General Design COMMISSION been extended Criterion 'I of Appendo A to 10 CFR The Commission does not agree. The Part 50 and in the NRC guidance 10 CFR Part 50 NRC has been developmg fire protection dacuments These general provisions requnernents smce 1975 The NRC uave rise to a number of disputes over

• Fire Protection Program for Operating published comprehensis e fire protection khether specific methods adequately Nuclear Power Plants guidelines. Branch Technical Position accomplished the intended goal. The AcENcy: Nuclear Regulators HTP APCSU 9 5-1. and its Appendix A in pr )poseo rule is intended to provide ,

19m 1.icensees have compared their fire sufficient specific guidance to ensure Commission.

prole don programs against these satisfactory resolution of these issues.

ACTION: Final rule - guidehnes and have discussed their IFus, reverting to generalized guidance

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suMMAny: The Nuclear Regulatery ileviations from these guidelines with would not accomplish the intended Commission is .unen ling its regulations the NRC staff for the past four years purpose of the proposed rule.

to requir9 certain provisions for fine during the NRC's fire protection reviews The second issue involved some of operating . rtors. A Safety instances in which the specific wording protection in operating nuclear power plants. This action is being taken to Evaluation Rep .t and. in most cases, used resulted in unnecessary and upgrade fire protection at nuclear power supplements to the Safety Evaluation unintended restrictions. For example, plants licensed to operate priot to Report. have been issued for each the proposed rule called for a " fresh ,

January 1,1979, by requiring resolution operating reactor.These reports water" supply.1lor firefightmg purposes, of certain contested generic issues in describe fire protection alternatives that br ickish water is satisfactory and a fire protection safety evaluation reports. have been proposed by the licensee and " fresh" water supply is unnecessary.

found acceptable by the staff as well as Similarly, the proposed rule called for EFFECTIVE DATF' February 14,1981. an " underground yard fire main loop.

Noto The Nuclear Regula'ory unresolved fire protection issues remaining between the steff and the Of ten porhons of a fire main loop run Commission has submitted this rule to the Comptroller General for rev:ew as licensee. Proposed Appendix R provided above ground m, and as they enter the Commission's requirements for structures. The Commission had not may be appropriate under the Federal miended to prohibit runmng portions of Reporta Act, as amended (44 U.S C, resolving those issues. Thus, it concerns 35t2). The date on which the reporting only a limited number of issues derivro! ".qe rnain 1 op above ground. Other from the use of the c :dier guides. The s radar changes are discussed in Section requirement of this rule becomes

!!! " Specific Requirements / of 'his effective, unless advbed to the contrary, Commission believes that a 30 day reflects inclusion of the 45-day period comment period was adequate under pman&

The third issue relates to impos,. tion of that statute allows for such review (44 tnese circumstances.

requirements n plants withPresently U.S.C. 3512(c)(2)). 2. Many licensees questioned the need installed or with existing commitments FOft FURTHER INFORM ATION CONTACT: for backfitting all the requirements of David P. Notley, Office of Standards Appendix R.They commented that they 'P Development, U.S. Nuclear Regulatory had previously complied with staff fire de [ k "$taff to satisfy the guidance of Appendix A to Commission. Washington. D.C, 20555, protection recommendations in good HTP APCSD 9.5-1. The Commission phone 301-443-5921 or Robert L. faith and have committed to or generally agrees that, except for three Ferguson, Office of Nuclear Reactor completed certam modifications. 'I hey sections that will be back fitted.

Regulation, U.S. Nuclear Regulatory contend that the staff has properly Appendix R should not be retroactively Commissmn, Washington, D.C. 20555, determined that these modifications appl ed to features that have been phone 301-492-70n0. provide at least the level of fire previously approved by the NRC staff as EUPPLEMENT ARY INFOriMATION: On May protection described by the guidance satisfying the provisions of Appendix A l

29,19a0, the Nuclear Regulatory contained in Appendix A to Uranch to UTP APCSilo.5-1.

Commission published in the Federal Technical Position HTP APCSil 9.51. The NRC staff had intended,in its Register (45 FR 30082) a notice of They also contend that these original proposal for Appendix R, that proposed rulemaking inviting written modifications provide a level of the requirements be applicable only for suggestio9s or comments on the protection at least equivalent to that the resolution of unresolved disputed proposed rule by June 30,1980. The contained in ths proposed rule. They fire protection features. Thus, the staff notice concerned proposed amendments express the concern that the proposed had not intended the provisions of to 10 CFR Part 50, " Domestic Licensing rule was written in such specific Appendix R to require modification of of Production and Utilization Facilities." language that fire protection issues that p eviously approved features. This was which would rt quire certain minimum were thought closed would be reopened not clearly described in the proposed provisions for fire protection in nuclear and new, but not necessarily better. rule as published for comment. In fact, power plants operating prior to January modifications would be required. These the Supplementary information 1.1979. Fifty one comment letters were modifications could be accomplished published with the proposed arule received regarding the proposed only by the expenditure of considerable explicitly indicated that "[alll licensees amendments. A number of comments engineering, design, and construction will be expected to meet the ,

pertained to specific requirements in the effort and at great undue expense. The requirements of this rule, in its effective proposed Appendix R, and these will be commenters request that the form, including whatever changes result dealt with below, llowever, there were requi;ements in the prorcsed rule be from public comments /

three substantive contentions which rewritten to specify only the, general In determining whether the specific were raised by many of the commenters. requirements of what needs to be recuirements of Appendix R should be These three comments are summarized accomplished. ir. posed on licensees with presently as follows: These comments raise three related installed or existing commitments to

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

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Federal Register / Vol. 45. No. 225 / Wednesday. November 19, 1980 / Rules and Regulations 76603 9 5-t it is important to recognize that air 4ngements were accepted in some permitted either an oil collection system Append;x R addresses only a portmn of early fire protection reviews. As a result nr a fire .,uppression system The staff th9 specific items containeriin the more of i,ume separate effects tests the staff has a%o accepted an automatic fire comprehensive document. Branch changed its position on this suppression system as an acceptable

'l echrucal Position BTP APCSB 9 5-1 configuratmn. and subseq ent plans method of fire protection for this and its Appendix A. Appendix A to BTP have been required to provide application. The Co amission has APCSil 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 staffin b or:ers or substantial physical do not give adequate protection for fires their fire protection reviews conducted separation for safe shutdown systems, that may be induced by seismic events.

for all operating plants during the past No credit for such coatings us fire The Commission therefore believes that several years. For many plants, barriers is allowed by Sect:on lit G of previously approved suppression hcensees proposed systems and features Appendix R. Appendix A to Branch systems should be replaced with oil ,

that satisfactorily achieved the fire Techmcal Position DTP APCSB 9.5.1 and collection systems that can withstand I protection criteria set forth in Appendix the proposed Appendiv R recognized "eismic events.

A to BTP APCSB 9.5-1 and began to that there were plant-unique The techmcal basis on which these promptly implement such features and configurations that required fire three sections are based are further i protec: ton features ' hat are not identical discussed in Section 111. " Specific l sy s t en,.

to thnse leted in Section ll! G of Fequirements." of this preamble.

Satisfactory features and systems are Appendix R. For these cases. fire 3. Most commenters stated that the i already in place and in operu' tion in implement ation schedule contamed in I many plants. There is a reasonable protection features were developed by the licensec and desent ed in a fire the proposed rule is impossible to meet degree of uniformity among most of for any of the operating plants. The these approved features for all facilities hazards analysis. Some m these arrangements were accepted by the staff commenters further stated that if the since they were reviewed against the same criteria of Appendix A to BTP as providing equivalent protection to the implementation schedule in the effective rule is the same as that in the proposed APCSB 9.5-1. In general, the features requirements of Section III.G to rule, the Commission must oc prepared previously approved by the NRC staffin Appendix R. to either shutdown each operating its reviews of fire protection using the Requirements that account for all of nuclear power plant, or process criteria of Appendix A to DTP APCSB the parameters that are important to hre exemptm requess.

9.5-1 prov'de an equivalent level of fire protection and consistent with safety The commenters ' hen concluded that protection safety to that provided under reqckements for all plant unique the implementation schedule should be the specific provisions of Appendix R. configurations have not been developed. rewritten to allow an adequate time Thus, the further benefit that might be In Ught of the experience gained in fire pri d for compliance.The proposed rule provided by requiring that previously protection evaluations over the past four stated that "all fire protection and approved features be modified to years. the Commission believes that the m dificatw, ns identified by the staff as conform to the specific language set licensees should reexamine those n cessary to satisfy Criterion 3 of forth in Appendix R is outweighed by previously approved configurations of Appendix A to this part, whether the overall benefit of the early fire protection that do not meet the c ntained in Appendix R to this part or implementation of such previously requirements as specified in Section in ther staff fire protection guidance apprred features, which in raany cases Ill.G to Appendix R. Based on this (mept f r alternate or dedicated are en rently being installed. reexamination the licensee must either shutdown capability) shall be completed Nes rtheless, as a result of its meet the requirements of Section III.C of by November 1,1980 unless, for good contmuing aview of fire protection Appendix R or apply for an exemption matters, the NRC staff has indicated to that justifies alternatives by a fire cause shown.,the Commission approvcs the Commission that there are hazard analysis. However, based on 50A8 "[he Con mi sion nt on to requirements in three sections in wk,:h present information, the Commission state its intention in the Statement of the protection afforded by Apper. dix R does not expect to be able to approve Considerution to the rule that " .no over and above that previously exemptions for firn-retardant coatmgs plant would oc allowed to continue to accepted, may be desirable. The used as fire barriers. operate after November 1.1980, or Commission has decided that these The second relates to emergency im %d an extended date approved by requirements should ba retroactively lighting. Section !!!.] of Appendix R calls the Comission, unless all modifications appued to all facilities. bs decision is for 8-hour emergency lighting, whereas (except for alternate or dedicated not meant to reflect adveru 'v on in some cases less than 8. hour shutdown capability) have been previous licensee or staff eva. ations; emergency hghting has been accepted as implemented."

rather its purpose is to take fuh, into satisfying Appendix A to BTP APCSB The Commission has reconsidered the account the increased knowledge "d 9.5-1. While an adequate level of safety implementation schedule und has experience developed on fire protection may be provided by less than an 8. hour determined that it should be modified matters over the last several years. supply, an tohour system would provide for the followmg reasons:

The first of these sections is related to added protection and would generally . After resiewing 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 beheves that completion of fire reviews over the past achieve and maintain safe shutdown arr hcensees should upgrade the previously 6 months. the staff has informed the free from fire damage. Appendix A to approved facilities to satisfy the a hour Commission that the date of November DTP APCSB 9.51 permits a combination lighting requirement cf Appendix R. 1,1980, is not possible because the of fire retardant coatings and fire The third relates to protection against effective date of the rule will be after detection and supression systems fires in noninerted containments that date.

without specifying a physical separation involvmg reactor coolant pump

• The staff has informed the distance to protection redundant lubrication ml(Section Ill.O of Commission that it would expect systems ( Appendix A, D.1(2)). and such Appendix Rt The proposed rule viitually alllicensees to request l

a 76604 Federal Register / Vol. 45, No. 225 / Wednesday, November 19, 1980 / Rules and Ptgulatio'ns exemptions if the new implementation Section 111, we provide a summary of the automatic water suppression system dates do not provide an appropriate Technicalliasis 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 disposition of those comments, protection uses to be available at all ,

licensees to preparc such requests and times regardless of other simultaneous by the staff to formulate Sedion 4 NMdion m/Smp- water uses in the plant.This water recommendations on these requests is This section has been revised as a volume is dedicated for fire service by not warranted from the standpoint of result of comments to include a means of separate storage tanks or ,

timely fire protection improvement, discunion of tne importance of safe separate pump suctions from a large

• The revised implementation shutdown capability und 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 "$afe shutdown." suctions must be at the bottom of the to be implemented and installed on a tank and other water supply suctions phased schedule that is as prompt as Section /L Ceneral Hv/uirements 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 wmer volume is set aside for fire be; ween requirements imposed for the provide a concise summary of general protection needs. Administrative first time on the licensee by Appendix R requirements. The specGc requirements controls by themselves. such as locked and those requirements already imposed were consolidated with the appropriate valves to ensure adequate water supply in license conditions or Technical parts of Section III. " Specific for fire fighting needs, ara 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 dropped. Comment Resduh,on requirements imposed by Appendix R, including the items "backfit" to all Snction ///. Specific Requirements Many cmnmentes stated Wut we ,

plants, the schedule provides a w(r: beim too restrictive by stipulating reasonable time after publication of the The requirements in this rule are an underground yard fire main loop and rule for completion of required bain'd upon principles long accepted fre 6 wa ; . uppl%, Our intent was modifications. For requirements already within that portion of American industry only that a yard fire main loop be imposed by license conditions providing that has been classified by their furnished. We have deleted the for implemention after November 1, insurance carriers as " Improved Risk" specification for an underground loop

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

may be excessive. Thus, for fire establishing some conservative level of With regard to the specification for a protection features other than those fire pmtection 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 in a list of the specific problems that are not associated with compliance dates beyond the November technical bases und resolution of public fire protection, From a fire protection l

1,1tW), date in the proposed rule, the comments for each of the specific standpoint, salt or brackish water is Commission has added a requirement requirements in Appendix R. acceptable for fire suppression provided that limits the compliance schedule in A. Water Supphes for Fire the fire protection system is designed existing licenses if such schedules Suppression Systems Technica/ Basis. and maintained for salt or brackish extend beyond what we now believe One of the basic fire protection water. The requirement for fresh water should have been a reasonable schedule requirements for a modern industrial supplies is therefore dropped. Other initially. Relief from such limitation may site in the United States is a separate operational problems unrelated to fire be granted by the Director of Nuclear water distribution system for fire protection that may result from the use Reactor Regulation upon a showing that protection with dual water supplies. of :all or brackish water for fire there is good cause for extending such Duplicate water supplies are required 'o suppression activities are outside the date and that public health and safety in ensure uninterrupted fire suppression scope of this regulation.

not adversely affected by such capability allowing for single failures Several commenters took issue with extension. and periodic maintenance and repair of the requirernent for two separate it should also be noted that for vital portions of the systems. Duplicate redundant suctions. stating that nome licensees whose license condipons water supplies may consist of separate pla,Ms Lee a sirwie large intake structere .

Imposed a schedule with a compliance suctions for fire pumps from a large on a lake or a river for all water date of November 1, Ifmo, or other date body of water nu..h as lake, river, or require.n.ents. The requirement for prior to the effective dnte of i 50Att, the pond or from two water storage tanks, separate intake structures was not Commission has suspended such For nuclear power plants, the intended and the rule has been clarified.

• compliance dates by promulgating on distribution system is required to consist Several comments called for deleting October 29. ItM a temporary rule of a loop around the plant with suitable the requirements for dedicated tanks or

( $0 48 (45 FR 71509), which will be valves for isolating portions of the use of vertical standpipe for other water superseded by this rule. system for maintenance or repair services when storage tanks are used for To better understand the nature of the without interrupting the water supply to combined service water / fire water uses, public. comments received and the staff's the various fire suppression systems in on the bain that this is overly restrictive resolution of these comments, the the plant. Thus, with dual supplies and a und other ways are available to ensure following section will consider each loop concept, an adequate water supply a dedicated supply such as weirs, section of Appendix R to this part. in can be ensured to each manual or sucHon location, etc.Two separate but

Federal Register / Vol. 45 No. 225 / Wednesday, November 19, 1980 / Rules and Regulations 76805

• 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. Manuall' ire Suppression Technical deleted was telected 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 tLroughout a nuclear power plant.

in excess of two hours.

minimum water storage capacity for fire However, manual fire fighting activities i suporession activities when storage D. Sectional /so/ation vahes. often can control and extinguish slowly l tanks are used for combined service. C. Hydrant ho/ation Valves developing fires before an automatic fire water / fire water uses.The term TechnicalBasis. Thu two suppression system is actuated. In

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

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i the commenters were assuming that suppression systems inside the plant. Manual response is the only fire

" vertical standpipe" referred only to Valves are similarly required to permit suppression available for these creas; pipes inside the tank, this is not the is lation of outside yard hydrants from thus, it is important that manual fire case. In fact a standpipe exterior to the the water distribution system for fighting capability be present in all storage tank is more desirable since any maintenance or repair without areas of the plant, and that standpipe leakage would be immediately evident. interrupting water supply to fire and hose stations be located throughout On an internal stand ipe a leak in the suppression systems inside the plant. the plant. TFe standpipe and hose pipe could actually a low depletion of Visually indicating valves such as post stations are to be located so that at leest the water otherwise to be reserved for indicator valves are preferred so that one effective hose stream can be fire uses.The rule has been clarlfied to the position of the valve can be readily brought to bear at any location in the allow physical alternatives for water determined. However, key-operated plant containing or presenting a hazard sup ly dedication but to preclude valves (commonly known as curb to structures, systems, or components exc unive use of administrative controls es e acc pta

,e p a t pe n ' important to safety. They are to be for this purpose. {a g 8upplied from the fire water supply Some commenters objected to the conditions warrant their use.

system except f r those inside requirement that other water systems B. Section Control Valves-Comment Resolution. Many commenters stated ntainment, which may be connected used as a backup water supply for fire t ther reliable water supplies if a that the requirement for " approved protection should be permanently 3eparate penetration into containment visually indicating" sectional control connected to the fire main system and cannot be made for fire water service valves was over suggested that it would be sufficient t unnecessary, an[t restrictive, needs.

not specific with provide a water supply capable of being respect to who should give the approval. Comment Resolution connected to the fire main system within The Commission has accepted this ten minutes of the loss of normai water suggestion: the rule now requires that several commenters suggested addmg supply or pumps. 'Ihe rule does not a sentence reading Standpipe and hose sectional control valves shall be address backup water supplies. The provided to isolate portions of the fire stations are not required if sufficient requirement means that,if another justification can be provided that main fer maintenance or repair without water system is used as one of the shutting off the entire system. Post adequate fire protection features have redundant water supp!!es,it must satisfy indicator or key operatd velves are been provided to account for a given fire all of the requirements at :he fire aren." This suggestion was rejected.The mentioned as two examples of prutection water supplies. Additional acceptable valves. staff has taken the position that the backup supplies need rot meet these C. Hydrant Block Valves-Comment minimum requirements are that at least requirements. one effective hose stream that will be Resolution. A number of commenters

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

earlier. Indeed once the manual fire presenting a fire hazard to safety-ri ted E. Hydrostatic Hose Test Technical fighting activities were started with the or safe shutdown equipment. Basis. Fire hoses should be use of only one fire hose stream, the fire One commenter suggested that this hydrostatically tested periodically to was extinguished withia one-half hour. requirement be dropped in its entirety ensure that they will not rupture during The staff would find unacceptable any since it "is a new requirement which has use. The requirement for a minimum test condition in which a postulated fire that not been subjected to the peer review pressure of 300 psi comes from NFPA i

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 BTp Association Standard No.196-within two hours with any combination APCSB 9M ccntains the following Standard for Fire llose), a nationally of manual and automatic fire sentence: "The lateral to each hydrant recognized consensus standard. This suppression activities. Therefore, a two. from the yr.rd main should be controlled standard contains other guidance for the

e 70fts Federal Registoi / Vol. 45 No. 225 / Wednesday, November 10. 1980 / Nies and Regulations use and care of fire hose that most system in all such areas should be 1. Fire Brigade Training Technical industries fmd useful. retained. The fire hazards analysis may Basis. Most modern industrial plants caU for a separate suppmssion system, with replacement cost values ,

Comment Resolution but th,si would be in addition to the fire approachmg,those of a modern nuclear Many commenters pointed out the detection system. powered electric generating station have erroneous usage of the term " service G. Protection o/ Safe Shutdown a full time fully equipped fire pressure" rather than "operatinH Capability Techmca/ Basis. The departme,t. including motorized fire ,

pressure" in this requirement. The objective for the protection of safe apparatus Because of the reduced intended meaning for this requirement is shutdown capability is to ensure that ai severity of rire hazards in a nuclear that all huses would be tested at a least one means of achieving and generatinc. mtion as compared to a pressure greater than the maximum maintaining safe shutdown conditions manufacturing plant, the Commission pressure found in the fire protection will remain available during and after believes that it is not necessary to water distribution systems.The correct any postulated fire in the plant. ilecause mandate a fully staffed fire department.

terminology is " operating pressure." The it is not possible to predict the specific f lowever, manual fire response rule has been so changed. In addition- conditions under which fires may occur capability is required at a nuclear plant the staff added a specific minimum test and propagate, the design basis and a properly equipped and fully pressure requirement oI 300 psi to meet protective features are specified rather trained fire brigade will satisfy this the NFpA standard. than the design basis fire.Three need. The Commission has determined One commenter also pointed out that different means for protecting the safe that a brigade of five persons constitutes hoses should be inspected for mildew'. shutdown capability outside of the minimum size sufficient to perform rot, cuts, or other damage. Although this containment are acceptable The first the actions that may be required by the is a valid comment it is not an means is separation of redundant safe brigade during the fire and to provide unresolved issue with any licensee so it sbutdown trains and associated circuits semo margin for unanticipated events.8 need not be covered by this rule. In by means of 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire rated barriers. Similarly, the training requirements addition, such inspections are ainyady The second means is a combination of listed am considered the minimum j being performed m acc,ordance with the needed to ensure that the fire brigade separation of redundant safe shutdown plant,a l echnical, Specificaitons. trains and associated circuits by a 1- will be able m, function effectively I Agitomatic hre Detection Technical hour fire rated barrier and automatic fire during a fire emergency.

Basis. The requirement that automatic The proposed rule required emergency supprusion and detection capability for fire detection systems bem, stalled m all both redundant trains.The third means, breathing apnaratus without specifying areas that contain safe shutdown or which may be used only when the number of such pieces of apparatus.

safety related systems or components The rule has been modified to specify fo lows generally accepted fire edundant trnins and associated circuits the personnel for whom such apparatus pr itection practice, installation of such an: separated Ijy 20 feet or more of clear is to be provided and to specify reserve fir i detection cv

• ability is independent space, requm automahc fin' air requirements.

suppression and detection systems in R Fire Brigah--Comment of my requirements for automatic or ma Tual fire suppression capability in an the area. An alternative or dedicated Reco/ution. Many commenters suggested are o The purpose of these detection safe shutdown capability indeper. dent of changing this requirement to a simple sys. ems is to give early warning of fire the fire area is required if fire protection statement that a trained and equipped, conditions in an area no that the fire f r safe shutdown capability cannot be nominal size, site fire brigade of five brigade can initiate prompt actions to provided as outh,ned above.1 or cables persons be provided on each shift unless minimize fire damage within the plant ami equipment needed for safe a lesser number is justified. This shutdown located Inside of noninerted recommended change was rejected by immen eso ion containments, a lesser degree of fire

, the Commission for the reasons stated Many commenters suggested that the protection is permitted because n the Technical Ilasis.

words " automatic fire detection transient exposure fires are less likely Some commenters objected to the capability" he substituted for inside containment during plant exclusion of the shift supervisor from

" automatic fire detection systems" on operation. Section !!!.M. "Igre Ilarriers' the fire brigade. The commenters felt the basis that, as worded, the discusses the technical basis for the 3- that the shift supervisor should go to the requirements are too limiting. They hour barrier, and Section III.L fire and provide the benefit of his stated that an automatic sprinkler "Alternah,ve and Dedicated Shutdown expertise and authority. The rule would system with appropriate alarm check Capability " discusses the technical not prevent this. Ilowever, the shift valves end central alarm features basis for safe shutdown capability. supervisor may have to go elsewhere provides acceptable detection /alarnung Con, ment Resolution during the course of a fire that adversely -

capabdity. Several commenters claimed affects plant operation. The fire brigade that a separate detection system is not Many commenters suggested that the leader must stay with the fire brigade needed in areas covered by sprinkler first paragraph be changed slightly and and be assigned no other syslems equipped with fusible link the rest of this section deleted.The responsibilities during a fire emergency, sprinkler heads. A fusible link has a basis for their contention is that the rule therefore, the shift supervisor must be time delay before it actuales. llowever, should state simply the requirement to excluded from membership on the fire more importantly, a smoldering protect cables or equipment of systems brigade.

locabzed fire that could do damage may necessary for safe shutdown of the plant 1. Fire Brigade Daining-Comme 9t not generate enough heat to melt the and leave specific implementation Reso/ution. Many commenters have fusible bnk. While we do not disagree details in some other type of document.

that the alarm from an automatic fire We have modified this section by 'Ttus is discused ul length m ihe NRC siaffs surpression system serves as removing the listing of considerations.  %.wauon of Minimum rue origade shifi sae".

notification that a fire exists, we deleting Table I, and revising the da'"d I""" " '** '"P'"" "" "' a'lal'l' 'r"m Da vid "d

concluded that the minimum wording to provide clarification. [i 7p,$[c"'"d;",d$"('j"";"';$

requirement for a separate fire detection 11. Fire Brigade, msss

Federal Register / Vol. 45. No. 225 / Wednesday, November 19, 1980 / Rules and Regulations 76607 stated that NRC used unnecessary detail fire emergenc J operators involved modifications to provide alternative in spelling out specific requirements for in safe plant o..adown should not also shutdown systems are extensive, a classroom Instruction, fire fighting have to be concerned with 1.ghtmg in the dediceted 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 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> supply and the and is independent of those already were more detailed than anything the substantial additional protection existing may be provided. This minimum Commission has published with regard afforded by the 8. hour supply does not capability it, required to maintain the to operator training. The Commission warrant reducing this requirement. The process variables within those va!ur i here points out that most of the Commission has decided to require an 8- predictod for a loss of offsite power. The investigations of the TMI accident hour battery power suppiy in all areas case ofloss of offsite power is assumed identified inadequately tralr.ed ner.Jed for operation of safe shutdown because fires in certain circumstances operawrs as an important factor and equipment and in access and egress (e.g., electrical distribution systema) that work is now being done in this routes. could cause or be related to such a loss.

area, The fact is not that the training K. Administrative Controls Technical Fire damage to cold shutdown capability requirements spelled out here for the fire Basis. The fire protection program uses is limited to damage that can be bngade niembers are excessive when administrative controls for fire repaired within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to provide a compared to training requirements for prevention and prefire planning. The margin in achieving cold shutdown ,

reactor operstors, bat that fire brigade items listed in this section are generally conditions. Consideration is given to l training is further along in developtrent, 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 alternative or have been identified. protection program. Controls are placed dedicated capability be required to l J. Emergency Lighting Technical on the storage and use of combustible function because of a fire,it must not be Basis. Emergency lighting is required in materials to reduce the fire loading in disabled by fire damage to associated l all nuclear power plants. Battery. safety-related areas and on !gnition circuits. Also, this capability does not i powered lights with capacities of1% to sources to avoid careless operations. have to meet the single failure criterion i 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> is ur ally sufficient for Procedures are used to control actions because it is only one of severallevels emergency i ess. However, the postfire to be taken by individuals who discover of defense. Seismic Category I criteria is emergenc' . ting requirements in a a fire and by the fire brigade for the not imposed because fires that would nuclear ps plant are of a different development of preplanned fire fighting require the installation of alternative or kind. The r, .d is for lighting that aids strategies and actual fire fighting dedicated shutdown capability are not the accet. equipment and techniques. seismically induced.

op ra e i b a it perso n 1 o ffect Comment Resoludon Comment Resoludon safeplant shutdown during plant Many commenters stated that this Many of the commenters stated that emergecies. Because such activities requirement was much too detailed for a this requirerrant exceeded the scope of may extend over a censiderable period regulation. Some stated that the Append;x R by defining alternative of time both during and after the fire,it requirements should apply only to those shutdown requirements. They stated is prudent to provide 8-hour battery areas having safe shutdown equipment. that the time requirements are excessive emergency lighting capability to allow Othe commenters stated that a simple and should be dropped. They also sufficient time for normallighting to be statement that administrative contend that this regulation does not restored with a margin for unanticipated procedures should be established to take into account the many plant events. control the various fire hazards reviews bein8 conducted under the throughout the plant was sufficient, and Systematic Evaluation Program (SEP).

Comment Resolution that the details could be spelled out in a It is generally understood that cold Many commenters stated that the regulatory guide or some other similar shutdown is the ulte ate safe shutdown requirement for emergency lighting is document. condition and that, for each fire area, overly restrictive in three specifier 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. Drcause a fire in certain areas at some that the requirement for sealed beam or L Alternatite ondDedicated plants would have the capability of fluorescent units is overly restrictive: Shutdown Capability. dii.ebling systems required to achieve

. third, that the requirement for individual Technica/ Basis. In some locations both hot and cold shutdown,it is 8-hour battery power supply is (such as the cable spreading room) necessary to specify the minimum excessive. Three commenters within operating nuclear power plants, it capability and time requirement for each recommended a 2-hour battery power is not always possible or practicable to condition necessary to achieve safe supply; five commenters recommended a protect redundant safe shutdown shutdown. We agree that evaluations plant. specific power supply; and one systems against adverse effects of fire or being made under the Systematic commenter recommended that there be fire suppression activities only through Evaluation Program (SEP) may also call no permanent installation. the use of fire protection features for alternative or dedicated shutdown These suggestions have been accepted because the redundant safe shutdown capability for reasons other than fire in part. Lighting units with 8.hout systems in a given fire area are too close protection. For example, seismic, battery supplies are to be provided in all to each other. Alternative shutdown flooding, or emergency core cooling areas needed for operation of safe capability has usually been required to requirements resulting from the SEP may shutdown equipment and in access and be independent of the control room, require additional modifications. .e.h egress routes thereto. The reasoning cable spreading room, switchgest rooms licensee should be aware of the status of behind the requirement for an 8-hour and cable rii,er 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 relat!ng to fire

- - - - .~. _

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4 76608 Federal Register / Vnl, 45 No. 225 / Wednesday, November 19. 1980 / Rules nnd Regulations protection to the extent possible, required to ensure safe shutdown the national consensus standard used I I!owever, the Cornmissinn has decided capabdity. The use of a 1-hour barrier in for testing and rating these cable that the modifications required to conjunction with autor; ntic fire penetration seals. Since the cables cornplete the fire protection program supprension and detection capability for conduct the heat through the barrier, ,

should not be deferred unta the Ep each redundant train of anfe shutdown and since the cable insulation is review is completed. equipment is based on the following combustible, the acceptance crittrin of M. Fire #arr/crs. considerations. Automatic suppression the ASTM Standard Fr119 relating to Technica/ Basis. The best fire is required to ensure prompt. effective temperature on the unexposed side must 4 protection for redundant trains of anIe upphcation of supprennnnt to a fire that be uppropriately modified.

shutdown systems is neparation by could endunger safe ahutdown Comment Resolution

- unplerced fire barriern-wnlls and capability. The activat,m n oInn celling floor nseemblies. llecause these nutomatic fire detection or suppression Some commenters suggested that tun barriers are pnanive fire protection systern does not occur until sufficient enhre section be deleted and replaced features, they are inherently reliable smoke or heat has been developed by with the following two sentences:

provided they are properly installed and the fire. Therefore, the Commission is " penetration seuls shall provide the maintained,l' ire barriers have been requiring a 1. hour barrier to ensure that equivalent protection which is required used succennfully for many years to fire damage will be limited to one train of the fire barrier Evaluation of the

, subdivide large potential fire losses into until the fire is extinguis!.ed. penetrution seals based upon a design smaller, more acceptable risks. Even fire These requirements have now been review and relevant test data or barriers with open!ngs have successfully incorporated in Section lit.G,"l' ire qualification tents may be made." The interrupted the progress of many firen Protection of Snfety I' unctions / commentern felt that sufficient test data provided the openings were properly are available to permit evaluation of omnnvd Reso uh.on design requirements without full.ncale protected by fire doors or other acceptable menna, Several commenters made a number mockup testing and that many of the l' ire barriern nre "rnled" for fire of suggestions of an editor lal nature. Items apelled out in the regulation, such resistance by being exposed to a One seggestion was to add "or unlens as the water hose stream test, were too "nlandard test fire". This standard test other fire protection featuren have been delnited and did not belong in the hre h defined by the American Society provided to ensure equivalent regulation.The Commission has for leting and Materinis in ASTN E- protection"in the first paregraph, where reconsidered this innue and revised the 119. " Standard for l' ire Resistance of three-hour rated fire barriers were rule ta (a) require the une of fluilding Materinin." I' ire barriers are stipulated unless a lower rnting was noncombustible materials only in the commonly rnted as having a fire justihed bv thc fire hazards analysis. construction of fire barrier penetration resistance of from 1 to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. Mont The Com, onion feeln that this ndda senis. (b) require fire barrier penetration

" improved Rink" or "llighly protectml nothing in the way of clarification and senin to be qualified by test: and (c)

Risk" (no classified by insurance the suggestion was not adopted. The require such testa to natisfy certain carriers) industrial propa tien la the necond paragraph requires that acceptance criterin.

United States require fire barriern to structurn! nicel forming a part of or O. Fire Doors.

have a resistance ruting of 2 to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. nupporting any fire barrier have a fire Technico/ Basis. Door openings in f!m While a nuclent power plant has a resistance equivalent to that r uired of walls constitute nnother breach that low fire lond. the potential the barrier. An example was g m of must be prefected. Fire doorn that have consequences of fire are serious. metal lath and plaster cos cring as being been tuted and rated for crvtnin fire Therefore, the Commission has selected one means of providing egalvntent exposurce are installed to protect these 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> has been as nn accepinble protection. Several commen'ern stated openings. Fire doors frequently fall to minimum fire resistance rating for fire that they thought this was toa narrow protect ihn openings in which they are barriers separating redundant trainn for and would be interpreted by mme installed becounc they are not fully safe shutdown systems. Thin will give people as the only acceptable nethod closed. Various methods are available to ample time for automatic and manunt permitted. Since the example seemed to licennees to ensure that fire doors are in fire supprension nctivitlen to control any be confusing, a declaion hun been made proper operating condition and that they potential fire and for safe shutdown to eliminate it. Other commentr. to the will be closed during a fire. These activities to properly control the reactor, effec' that the requirement was options are linled in Appendix R.

Many operating plants, or plants that excennively restrictive with regard to nre already built but that are not yet fire barrier penetrations, including fire C "U""#' N"8"I"'*."

I operating, have both tralna of safe doorn and their nasociated frames und Many commentern stated that this .

l nhutdown equipment located in close hardwnie, nud ventilation systems have requirement is too detailed and should proximity and a single fire could been noted upon by the 5tnif und the be deleted. Minor editorial changes have e damnge or destroy the functional requirement, as it ha l affected these been made in order to more clearly state capability of both redundant trainn. If items, was deleted. the requirements.

npecific pinnt conditionn preclude the N. Fire Harrier Cable Penetration Seal p. Hvactor Coolant Pump Lubrication ,

installation of n 3. hour fire barrier to Quohfication. System.

separnte the redundant trains. n I hour Technical Basis. Unplerced fire Technical # asis. Each reactor coolant fire barrier und nu.amatic fire barriers offer the best protes.tlon for pump motor assembly typically contains suppression system for each redundant neparating redundant trains of snfety- 140 to 220 gallone of f abe oil. Oil leeking )

trnin will be considered the equivalent related or nnfe shutdown equipment. from nome portions of the lube oil of 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> barrier. Ilowever, these barriers must be pierced system may come in contact with if the 1. hour fire barrier and automatic for bath control and power cuales. surf,ces that are hot enough to ignite the Ilre suppression for each redundant These penetrations must be sealed to oil. The resulting fire could be large, and train cannot be provided because of achieve n degree of fire resistance access to the fire would be delayed plant. specific conditions, niternnhve or equisalent to that required of the barrirr bec=une of the time required to entar the ,

dedicated shutdowns capahdity will be that is pierced. ASTM Standard FAlu la com dnment. Containent nir temporature j l

1 l

l l

l l

Federal Register / Vol. 45, No. 225 / Wednesday, November 19, 1980 / Rules and Regulations 76609 would increase, severe localized pump oil collection system is covered by Capability.") In the fire hazards analysis

. 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 laq r 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 asrociated non. safety circuits eqolpment inside containment. collection system for a seismically in the fire ares that could adversely Tnerefore, 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 performina equipment by feeding 1.ack potentially due to leadkage or fallure of the its safety function (Regulatory Guide dieabling 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 oil collection system or control circuits of that equipment it to a safe location. These occurrences should be designed, engineered, and must also be evrluated. Of course such could be random or could be seismically installed so that its failure will not lead disabling conditions must be prevented induced because the existing tube oil to a fire affecting safety related to provide assurance that the identified cystem piping and oil collection systems equipment as a result of an earthquake. safe shutdown equipment will function may not be designed to withstand a The proposed rule permitted tw alternatives-an oil collection system or as designed. These requirements have design basis seimic event, now been incorporated in Section Ill.L.

a a 'P syste Appendix A to BTP APCSB 9.5-1 states that for operating plants, hd kthegl {ye9{t e " Alternative and Dedicated Shutdown suppression system because Capability."

, postulated fires or fire protection system failures need not be considered unacceotable damage may result to the Comment Reso/ution a rela ed Ystems fr m the ing concurrent with other plant accidents or gfet ( ,f the s the most severe natural phenomena, requirement should be deleted because The basis for that statement is two fold. actuate:1 and because the fire water supply system is not designed to many older plant designs did not P  !

ct r s nd e s n a e ic j' withstand seismic events. In addition, these pumps are located within the consider associated circuits and this is, therefore, a new design requirement.

designed to withstand earthquakes and

" pbnom " biological shield inside containment, The commenters felt that the analysis

$1 t ry of ny { , assoc ed th therefore, timely fire brigade action that will be required to satisfy this w uld be difficult if the suppression requirement will be both long and b

system malfimettons.Further,if the complicated and the requirement should va afed.T es eva$uations showed that such fires usually are due to failure 8uppression systen becomes inoperable therefore be deleted.

during operation, a fire watch or patrol The Commission rejected these of iping or tanks of flammable gasses or fiquids such as municipal natural gascann t enter the area durms operation. suggestions for the following reasons, distribution systems or gasoline storage Comment Resolution 1. Virtually all of the fire protection and/or dispensing stations. Where such A number of commenters suggested modifications made to date have been potential fire hazards exist in nuclear that this section is too detalled and required to correct deficiencies that powei 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 bollers) they are designed pump lubrication system with an 2. The Browns Ferry fire showed the and installed to withstand the damaging automatic fire suppression system. We necessity of divisional separation of the effects of various natural phenomena. have modified the rule to indicate that associated circuit of the control cables and other special fire protection features the requirement that the oil co'lection to prevent the disabhg of safety are provided as necessary, flowever. system be designed to provide systems by a single fre. This has been General Design Criterion 2 Design Bases reasonable assurance that it will discussed with licensees during for Protection Against Natural withstand the Safe Shutdown evaluations of alternative and dedicated Phenomena requires that structures, Earthquake can be met by satisfying shutdown capability and is necessary to systems, and components important to paragraph C.2. of Regulatory Guide 1.29, ensure that safe shutdown gystems veill safety be designed to withstand the " Seismic Design Classification," as effects of earthquakes without loss of be able to function properly in the event described above. of fire' capability to perform their safety Q. Associated Circuits.

function. Regulatory Guide 1.29 TechnicalBasis. When considering 1 The staff considers incomplete any

" Seismic Design Classification," the consequences of a fire in a given fire fire hazard analysis that does not describes an acceptable method int area during the evaluation of safe consider the effects of fire damage to identifylne ind classifying those shutdown capabilities of a plant, the circuits that are associated with safe features at Lghbwater-cooled nuclear staff must be able to conclude that one shutdown systems.

power plants dmt 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 act comments received on this issue,it is Shutdown Earthquake. In this guida, shutdown condition remains unaffected unclear that associated circuits have in paragraph C.1 applies to systems that by that fire.The staff must also be able fact been adequately considered by are required to remain functional to to conclude that damage to one train of licensees in their reviews using the ensure heat removal capability: equipment used for achieving cold guidance of Appendix A to BTP APCSB <

parr. graph C.2 applies to systems that do shutdown will be limited so that the 9.5-1. 'io ensure that the ass 6ciated {

not have to remain frunctional for that equipment can be returned to an circuits are considered, all operating i purpose, but whose failure could reduce operable condition within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. (See nuclear power plants will be required to i the functioning of those systems covered Technica' Basis for Section III.G, meet the requirements of Section Ill.C of '

by paragraph C.1. The reactor coolant " Protection of Safe Shutdown Appendix R. )

i l

76610 Federal Register / Vol. 45, No. 225 / Wednesday, November 19, 1980 / Rules and Regulations General Comments Resolution shutdown capability. The Commission comments received on the proposed does not agree. We believe that the regulations, other commenters Several commenters contended that Commis ion s ovell fire protection demonstrated a thorough undenAanding ,

Commission regulations mandate tnat of the pmposed requirements.

an adjudicatory hearing be conducted program involving extensive plant.

specific fire protection modifications Pursuant to the Atomic Energy Act of prior to a final decision. One commenter that are based on guidance set forth in 1954. as amended, the Energy labeled the regulation an " order" within Reorganization Act of 1974, as amended. .

the meaning of the Administrative Branch Technical Position BTP APCSB 9.5-1 and its Appendix A and the and Sections 552 and 553 of Title 5 of the Procedure Act (5 U.S.C. 551(6))(APA) specific requirements of Appendix R to United States Code, notice is hereby and asserted that to CFR 2.204 of the given that the following amendments to resolve disputed issues providc Ccmmission's regulations," Order for Title to, Chapter 1, Code of Federal M#ication of License," applies to this adequate fire protection.

One commenter stated that the Regulations, part 50, are pub!ished as a rulemaki g proceeding. ambiguity of the proposed regulation document subject to codification.

The Co,nmission disagrees with these with regard to critical items requires 1. A new I 50.48 is added to read as comments. A " rule"is defined in the follows:

APA to mean "the whole or a part of en that it be renoticed. The commenter referenced three portions of the agency statement of general or f 50.48 Fire Protection.

particular applicability and , future effect {cfa bi ui$y ey ere$ec io fil.G, (a) Each operating nuclear power designed to implement or Sectian Ill.N. and Section ll!.Q. We have plant shall have a fire protection plan prescribe law or policy , , (5U.S.C. les, that satisfies Criterion 3 of Appendix A 551(4)). The agency action questioned reviewed these exambrat example, the to this part. Thio fire protection plan in reference to the here is clearly one that treats similarly shall describe the overall fire protection situated licensees equally and that commenter stated that the first paragraph of Section Ill.G identifies program for the facility, identify the alternativa shutdown capability as an various ppsitions within the licensee's re r ents Ior tho elic nsees who ptional protective feature and that organization that are responsibile for the have not already provided an equivuent paragraph III.G.2.c thea identifies program, state the authorities that are level of fire protection, certain specif'. alternative shu.down c.pability as a delegated to each of these positions to fire protection features are required. minimum fire protection feature. We do implement those responsibilities, and Various of these requirements would not agree with this statement. The first outline the plans for fire protection, fire paragraph of Section Ill.G identifies detection and suppression capability, c n nt sh acterizatio It I and limitation of fire damage.The plan as an order, along with the assertion alternative shutd,own capability as one ption in a combmation of fire shall also describe specific features that 10 CFR 2.204 mandates a hearing ,

necessary to implement the program protection features for a specific fire area. Paragraph Ill.G.3 indicates when described above, such as administrative n arrect. O ts$a at regulation this option should be used. controls and personnel requirements for (which does grant a hearing right)

. . In reference to the second example, fire prevention and manual fire applies only to Commission orders that the commenter stated that Section Ill.N suppression activities, automatic and modify a license.81t does not apply to requires a pressure differential across manually operated fire detection and requirements promulgated through a the test specimen during the testing of suppression systems. and the means to relemaking action conducted in f re barrie penetration seals but fails to limit fire aamage to structures, systems, accordance with the requirements of define the pressure different!al.This or components important to safety so c mment is incorrect.The pressure that the capability to safely shut down ver il commenters contended that differential called for by the proposed the plant is ensured.'

the environmental impact had not been provision was the maximum pressure (b) Appendix R to this part establishes adequately addressed. One commenter, differential that the barrier would fire protection features required to citing the requirements in Section Ill.A experience in the specific plant satisfy Criterion 3 of Appendix A to this of Apoendix R for two water supplies installation. In any event, the part with respect to certain generic end two separate redundant sections as requirement for pressure differential issues for nuclear powei plants licensed ecamples of requirements involving durmg such testing has been deleted to operate prior to January 1,1979, environmental issues, contended that since only noncombustible material is Ihcept for the requirements of Sections the Commission relied upon its staff's now being used for such aeals. Ill.G.1111, and til O, the provisions of .

unsupported determination that, in reference to the iniM example, the Appendix R to this part shall not be pursuant to 10 CFR l 51.5(d), an commenter stated that bection Ill.Q is applic.able to nuclear power plants environmental impact statement, totally lacking in definition. We do not licensed to operate prior to January 1,

~

appraisal, or rqa4ve declaration ,s i not ag ee. Footnote o references Regulatory 1979, to the extent that fire protection required. Tht Commission has Guide 175 and IEEE Std 33&-1974. The features proposed or implemented by considered ScWon llLA and has further latter document is a commonly used considered the remaining requirements industry standad that defines

• nasic fire protection suidance for nuclear power of Appendix R and remains convinced associated circuit 9 and provides plants is contained in two NRC documents:

tl At the regulations are not substantiv0 guidance for ensuring that such circuits

• Branch Technical Position Aux 61iary Power and are insignificant frorr, the standpoint do not compromise the independence of Cd'nnrsion System Branch irrP APCSB 9F1.

of environmentalimpact. the shutdown circuits they are "G"id".',

'" inn

'" fw Mm " " Pnnad

' " " n for"""Nucler Powtr' One commenter suggested that ali associated with. da y tr-plants be required to install dedicated Based on the above examples and our

• Appendin A to DTP APCSB 95-1. "Guidehnes

- review of the other provisions of the far hre Protection for Nuclear Power Plants

'It should alas tie noted that i 2.204 is codified in pMposed rule, we do not believe that D*ked Prior to July 1,1976." for piant that were Subpart H of m CFR Pair 2. The scope of Subpart D Ih Ie proposed was anbiguous so P""""8 " ""d" * "" "' "'""" I d"'8" "

con.irucnon before luiy 2.1978. dated Aususi 23.

l.a s.pecifically hmited to "tases init!sted by the statt

. to impo.e requirements by order on a as to require renoticing. Moreover, it me hcens*'e'* (10 Cl3 2.2nu(s)). (Emphasis supphed > should be noted that, based on nher Also see Note 4.

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 !!TP APCSB 951* 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 effected by such extension. Extensions reports issued prior to the effective date (iii) an unplanned outage that lasts for of such date shall not exceed the dates of this rule, or to the extent that fire at least 120 days. determined by paragraphs (c)(1) through

)rotection features were accepted by (4) Those fire protection features that (c)(4) of this section.

the 6taff in comprehensive fire require prior NRC approval by (1) Those fire protection features that protection oafety evaluation reports paragraph (c)(S) of this section, shall be involve revisions of administrative issued before Appendix A to Branch implemenied within the following controls, manpower changes, and Technical Position UTP APCSil 9.5-1 schedule: Dedicated shutdown training shall be implemented within 4 was published in August 1970. With systems-30 months after.NRC months after the date of the NRC staff respect to all other fire protection approval; modifications requiring plant Fire Protection Evaluation Report features covered by Appendix R, all shutdown-before startup after the accepting or requiring such features.

nuclear power plants licensed to operate earbest of the events given in paragraph (2) Those fire protection features prior to january 1,1979 shall satisfy the (c)(3) commencing 180 days after NRC involving installation of modifications applicable requirements of Appendix R approval; modifications not requiring not requiring prior approval or plant to this part, including specifically the plant shutdown-a months after NRC shutdown shall be implemented within requirements of Sections !!!.G, III.j, and a pproval. 12 months after the date of the NRC 111. 0 .

(5) Licensees shall make any staff Fire Protection Safety Evaluation m difications necessary to comply with Report accepting or requiring such (c) All fire protection modifications require to satisfy the provisions of Wese requirements m,accordance with features.

the above schedule without prior review (3) Those fire protection features, Appendix R to mis part or directly and approval by NRC except for including alternative shutdown effected by such requirements shall be m difications required by Section III.G.3 capability, involving installation of completed on the following schedule:

of Appendix R to this part. Licensees modifications requiring plant shutdown (1)Those fire protection featuces that shall submit plans and schedules for shall be implemented before the startup involve revisions of administrath;o meeting the provisions of paragraphs after the earliest of the follewing events controls, manpower changes, an(* (c)(2). (c)(3), and (c)(4) within 30 days commencing 9 months or more after the training, shall be implemented witnin 30 after the effective date of this section date of the NRC staff Fire Protection days after the effective date of this and Appendix R to this part. Licensees Safety Evaluation Report accepting or section and Appendix R to this part. shall submit design descriptions of '

requiring such features:

(2) Those fire protection features that modifications needed to satisfy Section (i) The first refueling outage; invMve installation of modifications that III.G.3 of Appendix R to this part within (ii) Another planned outage that lasts do not require prior NRC approval r r 30 days after the the effective date of for at least 00 days: or plant shutdown shall be imolemented this ution and Appendix R to this part. (iii) An unplanned outage that lasts within 9 months after the effective date (0) 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 part. with one or more of the provisions of involving dedicated shutdown capability (3) Those fire protection features, Appendix R filed within 30 days of the requiring new buildings and systems except for those requiring prior NRC effective date of this rule is based on an shall be implemented within 30 months approval by paragraph (c)(5) of this assertion by the licensee that such of NRC approval. Other modifications ecction, 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 shall1;e implemented within shutdown, the need for which is justified facility or th n such mod'fications may 6 months after NRC approval.

In the plans and schedules required by be detrimental to overall facility safety, (e) Nuclear power plants licensed to the provisions of paragraph (c)(5) of this the sched:. le requirements of paragraph operate after January 1,1979, shall section, shall be implemented before (c) shall be tolled until final Commission complete all fire protection startup after the earliest of the following action on the exemption request upon a modifications needed to satisfy events commencing 180 days or more determination by the Director of Nuclear Criterion 3 of Appendix A to this part in Reactor Regulation that :he licensee has accordance with the provisions c' their

• ciarincanon and suidance with respect to provided a sound technical basis for licenses.

parniisalble alternatives to satisfy Appendix A to such assertion that warrants further 2. A new Appendix R is edded to irrP ApCSU 9 S-1 haa been provided in four other staff review of the request. 10 CFR Part 30 to read as follows:

8 accepted S pie e tary Guidance on Information gY Appendix R-bre Proution Program for Needed for Fire Protection Evaluauun." deled Nuclear Power Facilities operating Prior to October 21.1rs. Safety Evaluation Reports referred to in january 1,1979 a " Sam;>1e Technical Specifical on." dated May para 3raph (b) of this section and

( 12. tr7. supplements to such reports, other than I Introduction and scope l * "Nudear Plant Fire Protection Functional features covered by paragraph (c), shall This Appendix applies to licensed nuclear Responsibihhes. Administrative Cortrol and power electric generatmg stations that were Qua'ity Assurance. dated lune 14,1977.

be completed as soon as practicable but no later than the completion date operatmg pior to lanuary 1.1979. except to the extent set forth in paragraph So.48(b) of React s " dat i 1 1 8 currently specified in license conditions '

l A Fire Protection Safety Evaluation Report that or technical specifications for such Io,P,"$r "P has been issued for each operaung plant states how f cl$iddsNUoSNI facility, or the date determined by protection features required to satisfy dni e '"'*'"l"

0 p ion l j'y resolved when the facihty satisfies the appropnate paragraphs (d)(1) through (d)(4) of this section, whichever is sooner, unless the Cnterion 3 of Appendix A to this part.'

requirements of Appendin R to this part Director of Nuclear Reactor Regulation a sce fdotnote 4

.;- w l

l l

l l

l 76612 Federal Register / Vol. 45, No. 225 / Wednesday, November 19, 1980 / Rules and Regulations Cnterion 3 of Appendix A to this part program shall establish the fire protection D. A/ternotive or Dedicated Shutdown specifies that " Structures, systems. and pokey for the protection of structures, Capobihty components important to safety shall be systems. and components important to safety in areas where the fire protection features l designed and located to mimmize. consisten< at each plant and the procWures, equipment, cannor ensure safe shutdown capability in '

with o'her safety requirements, the and personnel required to implement the the event of a fire in that area, alternative or  ;

probatnhty and effect of fires and program at the plant site, dedicated safe shedown capability shall be explosions " The fire protection program shall be under provided.

When considenng the effects of fire, those the direction of an individual who has been ///. Specific Requirements systems associated with achieving and delegaied authonty commensurate with the maintaining safe shutdown conditions responsibilities of the positmn and who has A. Water Supplies fo.- Fire Suppression assume major importance to safety because available staff personnel knowledgeable in Systems damage to them can lead to core damage both fire protection and nuclear safety. Two separate water supplies shall be resulting from loss of coolant through boiloff. The fire protection program shall extend provided to furnish necessary water volume The phrases "important to safety," or the concept of defense in debth to fire arJ pressure to the fire main loop.

" safety related," will be used throughout this protection in fire areas important to safety. Each supply :,, hail consist of a storage tank.

Arapendix R as applying to all safety with the following objectives: pump, piping, and appropriate isolation and innations. The phrase " safe shutdown" will

• to prevent fires from starting: control valves. Two separate redondant be used throughout this Appendix R as a to detect rapidly, control, and extinguish suctions in one or more intake structures applying to both hot and cold shutdown promptly those fires that do occur; from a large body of water (river, lake, etc.)

iunctions. e to provide protection for structures, will satisfy the requirement for two separated Hecause fire may affect safe shutdown systems, and components important to safety water storage tanks. These supplies shall b'e systems and because the loss of function of so that a fire that is not promptly separated so that a failure of one supply will systems used to mitigate the consequences of extinguished by the fire suppression activities not result in a failure of the other supply.

design basis accidents under postfire will not prevent the safe shutdown of the Each supply of the fire water distribution conditions does not per se impact public plant, system shall be capable of providing for a,.

safety, the need to hmit fire damage to il Fire Horon/s Anal; sis period of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> the maximum expected systems required to achieve and maintain A fire hazards analysis shall be performed water demands as determined by the fire a safe shutdown conditions is greater than the by quahfied fire protection and reactor hazards analysis for safety related areas or need to limit. fire damage to those systems systems engineers to O) consider potential in other areas that present a fire exposure j' required to mitigate the consequences of situ and transient fire hazards;(2) determine hazard to safety-related areas.

design basis accidents. Three levels of fire the consequences of fire in any location in When storage tanks are used for combined damage limits are estabhahed according to the plant on the ability to safely shut down service water / fire water uses the minimum the safety functions of the structure, system, the reactor or on the ability to minimize and volume for fire uses shall be ensured by or component: cnntrol the release of radioactivity to the means of dedicated tanks or by some

_ environment; and (3) specify measures for physical means such as a vertical standpipe Safety furrium Fee derhage beta fire prevention. fire deteClion, fire for other water service. Administrative

=

suppression, and fire containment and controls, including locks for tank outlet Hni rieuu=n . or= van or assinnent <=ceus y io alternative shutdown capability as required valves, are unacceptable as the only means actwo tot sewu=n km" *** for each fire area containing structures, to ensure minimum water volume.

[* , , [Q$ systems, and components important to safety Other water systema used as one of the tree of we damson by a engte fwe in accordance with NRC guidelines and two fire water supphes shall be permanently ackmano an enxaure we ' regulations. connected to the fire main system and shall W stwumn . som vans a, w C. Fire Prevention Features be capable of automatic alignment to the fire am,mmnt _

dernaged by e anule ke, artshno Fire protection features shall meet the main systern. Pumps, controls, and power an emoeus rue, but ammage mu.i following general requirements for all fire supplies in these systems shall satisfy the

• i at e en areas that contain or present a fire hasard to requirements for the .nain fire pumps. The

["""o structures. systems, or components important use of other water systems los fire patection

,,eva n hours unne on.iw capena.

ny to safety, shall not be incompatible with their functions Demun Ham. Both tem. oi equemeni n een'y 1. In situ fire hazac 4 shall be identified required for safe plant shutdown. Failure of

^**'" '9"

((*'",*'""[*" and suitable protect.on provided. the other system shall not degrade the fire t= damavad by a anum *=m,* 2. 'Iransient fire hazards associated with main system.

we normal operation, maintenance, repair, or II. Sectional /solaimn Vo/ves modification activities shall be identified and Sectionalisolation valves such as post

• • • a

",wla ehminated where possible Those tranaient indicator valves or key operated valves shau ediD.i w any strucium.u l *ni c m$.*nC. k,: ims

..wm $* $ *.i'". *er *=e.*r*.

m me. m comp, ment fire hazards that can not be climinated shall be installed in the fire malr loop to permit contmHed and suitable protection isolation of portions of the fire main loop for Ioe9*wnY.rY.i..E enam ev mm or conamni "w7n5*c* n1.no m*."N anwn uie,, .Q,Q provided. maintenance or repair without interrupting 4 y detection systems. portaMe the entire water supMy, Ic2

[nY. e*<E*m*nT.,eme *amn.N"wN' O.7,Imgj nu.,m, m ine . and . we mwuno come=.

on men ent= <=ium t e n nay con mute r emo.u's extmguishers. and standpipe and bone siations shall be installed.

C. /tydmnt /solatwn volves Valveo shall be inntalled to permit isolation t Fire barriers or au oma ic suppression of outside hydrants from the fire main for The most stringent fue damage limit shall systems or both shall be installed as maintenance or repair without interrupting apply for those systems that fallinto more necessary to protect redundant systems or the water supply to automatic or manual fire than one category. Redundant systems used components necessay for safe shutdown suppression systems in any area continning to mitigate the consequences of other design 5. A site fire bngao > shall be establisWl. or presenting a fire hazard to safety-related i basis accidents but not necessary for safe trained, and equipped and shall be on site at or safe shutdown equipment. j shutdown may be lost to a single exposure a". times. D. Monna! Fire Suppression '

fire. liowever, protection shall be provided so n. Fire detection and snppressen systems Standpipe and hose systems shall te that a fire within only one such system will shall be designed instand, ma;rhimi. and installed so that at least one effective hose l not damage the redundant system. tested by pernat3cl properly quabfel W stream will be able to reach eny location that experience and training in fire protection contains or presents an exposure fire haze'd l // Generalflequirements systems. to structures, systems, or components A. Fire Protection Prrrrum 7. Surveillance procedures shall be important to safety.

A fire protection program shall be establi.hed to ensure that fire barriers a e ir. Access to permit effective functioning of estabhshed at each euckar power plant. The place and that fire suppression systems and the fire brigade shall be provided to all areas components are operable. that contain or present an exposure fire

Federal Register / Vol. 45. No. 225 / Wednesday, November 19, 1980 / Rules and Regulations 76613 herard to structures. systems, or components hour rating. In addition. fire detectors and en Institute for Occuptional Safety and

, important to safety, automatic fire suppression system shall be Ilealth-approval f onnerly given by the U.S. i Standpipe and hose stations shall be inside installed in the fire area Bureau of %nes) shail be provided for fire l PWR containments and BWR containments Inside noninerted containments one of the brigade, damage control, and contcol room that are not inerted. Standpipe and hose fire protection means specified above or one personnel. At least to masks shall be stations inside containment may be of the following fire protection means shall available for fire brigade personnel. Control connected to a high quality water supply of be provided: room personnel may be furnis!.ed 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 loopif plant specif!c features associated non-safety circuits of redundant storage reservoir if practical. Service or rated prevent extending the fire ma!n supply inside trains by a horizontal distance of more than operating life shall be a minimum of one-half containment. For UWR drywells, standpipe 20 feet with no intervening combustibles or hour for the self contained units.

and hose stations shall be placed outside the fire hazards; At least two extra air 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 tha fire breathing unit. In ad4fidon, an onsite e-hour en e.ffective hose stream. area: or supply of reserve air shall bei provided and E. Hydmstatic Hose Tests I. Separation of cables and equipment and arranged to permit quick and complete Fire hose shall be hydrostatically tested at associated non-safety circuits of redundant replenishment of exhausted supply air bottles a pressure of 300 pel or 50 pel above trains by a noncombustible radiant energy as they are returned. If compressors are used maximum fire main operating pressure, shield. as a source of breathing air.only units whichever la greater. Ilose stared in outside 3. Alternative or dedicated shutdown approved for breathing air shall be ut.ed:

hose houses shall be tested annually. Interior capability and its associated circuits /' compressors shall be operable assunting a vtandpipe hose shall be tested every three independent of cables, systems or lou of off.ite power Special care must be years. componenta in the area, room or zone under taken to la ate the compressor in areas free F. Automatic Fire Detection consideration, shall be provided: of dust and contaminants.

Automatic fire detection systems shall be a. Where the protection of erstems whose 1. rire Brigade Tro/nirig inctalled in all areas of the plant that contain function is required for hot shutdown does The fire brigade train mg progam shall or present an exposure fire hazard to safe not entisfy 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 b'e capable of operating with or without required for hot shutdown located in the instmction program followed by periodic offsite power, same fire area may be subject to damage clauroom instruction, fire fighting practics, G. Fire Protection of Safe Shutdown orn tire suppression activities or from the and fire drills:

(;opobility rupture or inadvertent operation of fire 1. Instmetion

1. Fire protection features shall be provided suppression systems, s. The initial clauroom instruction shall for structures. systems, and components in addition, fire detection and a fixed fire include:

Important to safe shutdown. These features suppress!on system shall be installed in the (1) Indoctrination of the plant fire fighting shall he capable oflimiting fire damage so area, room cr zone under consideration. plan with specific identification of each that: 11. fin Brigade individual's responsibilities.

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

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

b. Systems necenary to achieve and The fire brigade shall be at least rive (4)1dentification of the louition of fire maintain cold shutdown from either the members on each shift. The brigade leader fighting equipment for each fire area and control room or emergency control station (s) and at least two brigade members shall have familiarization with the layout of the plant, can be repaired within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. sufficient tralr!!ng in or knowledge of plant including access and egren routes to each

2. Except as provided for paragraph G.3 of safety related systems to understand the area, this section, where cables or equipment, effects of'lre and fire suppressants on safe (5) The proper use of available fire fighting including associated non. safety circuits that shutdown capability. The qualification of fire equipment and the correct method of fighting could prevent operation or cause brigade members shallinclude an annual each type of fire.The types of fires covered maloperation due to hot shorts, open circuits, physical examination to determine their should include fires in energi2ad electrical or shorts to ground, or redundant trains of ability to perform stenuous fire fighting equipment, fires in cables and cable trays, sysmms necessary to achieve and maintain activities. The shift supervisor shall not be a hydrogen fires, fires involving flammable and member of the fire brigade.The brigade combustible liquids or hazardous process hot shutdown conditions are located within leader shall be competent to assess the the same fire area outside of primary chemicals, fires resulting imm construction or pctential safety consequences of a fire and modifications (welding), and record file fires, containmar.t. one of the following means of advise control room personnel. Such (e) ne proper use of communication,

, ensuring that one of the redundant trains is competence by the brigade leader may be lighting, ventilation, and emergency breathing free of fire damage shall be provided:

evidenced by possession of an operator's equipment.

a. Separation of cables and equipment and license r equivalerit knowledge of plant (7) ne proper method for fighting fires

. associated non-safety circuits of redundant safety-related systems. Inside buildings and confined spams.

. trains by a fire barrier having a 3. hour ratlog. The minimum equipment provided for the Structural steel forming a part of or (8)The direction and coordination of the brigade shall consist of personal protective fire fighting activities (fire brigade leaders supporting such fire barriero shall be '

protected to provide fire resistance 89u!pment such as turnout coats, boots, only).

gl 5es, hard hats, emergency communications (9) Detailed review of fiw fighting equivalent to that required of the barrier:

'9" ment, portable lights, portable straiegies and procedures.

b. Separation of cables and equipment and ye ti gation equipment, and portable associated non-safety circuits of r,edundant (10) Review of the latest plant trains by a horizontal distance of mcce than [pp,"fe"tu u m d fi tions and corresponding changes in f1 a epo e i 20 feet with no intervening combustible or masks approved by NIOSU (National "8 "8 E ""

fire hazards. In addition, fire detectors and an Note-Items (0) and (10) may be deleted automatic fire suppression system shall be * " "8 " *" ' " '

• I installed in the fire area; or

• Alternative shutdown capability is provided by rerouting. relocating or modificating of existing non- pwations personnel who may be

c. Enclosure of cable and equipment and systemm dedicated shutdown capability is provided assigned to the fire brigade.

associated non. safety circuits of one by installing new structures and systerns for the b. The instruction shall be provided by redendant tram in a fire barrier having a 1- function of post. fire shutdown. qualified individuals who are knowledgeable.

9 76614 Federal Register / Vol 45. No. 225 / Wednesday, November 19, 1980 / Rules ed Regulations experienced, and suitably trained in fightmg brigade. and selection. placement ard use of required additional fire protection in the the types of fires that could occur in the plant equipment, and fire fightmg strategies, work activity procedure.

and in using the types of equipment available (2) Assessmen' of each brigada member's 5. Go<ern the use of ignition sources by use in the nuc! car power plant. knowledge of his ur her role in the fire of a flame permit system to control welding. '

c. Instruction shall be provided to all fire fighting strategy for the area assumed to flame cutting, brazing. or soldering bngade members and fire b-igade leaders. contam the fire. Assessment of the brigade operations. A separate permit shall be issued d_ Reguber planned meetings shall be held member's conformance with established for each area where work is to be done. lf at least every 3 months for all brigade plant fire fighting procedures and use of fire work continues over more than one shift, the e members to review changes in the fire fighting equipment, including self. contained permit shall be valid for not more than 24 protection program and other subjects as emergency breathing apparatus, hours when the plant is operating or for the necessary. communication equipment, and ventilation duration of a particular job during plant

c. Perio.hc refresher training sessions shall equipment, to the extent practicable. shutdown.

be held to repeat the classroom instruction p)The simulated use of fire fighting 6. Control the removal from the area of all progtum for all brigade members over a Iwo- equipment requircd to cope with the situation waste, debris, scrap, oil spills, or other year penod. These sessions may be and type of fire selected for the drill. The combastibles resulting from the work activity conrurrent with the regelar planned area and type of fire chosen for the drill immadiately following completion of the meetmgs should differ from those uned in the previous activity, or at the end of each work shift.

2. Practice dnll no that brigade members are trained in whichever comes first.

Practice sessinns shall be held for each fighting fires in variaus plant areas. The 7. Maintain the periodit houcekeeping shif t fire brigade on the proper method of situation selected should simulate the size inspections to ensure continued compliance fighting the various types of fires that could and arrangement of a fire that could with these administrative controls.

occur in a nuclear power plant.These reasonably occur in the erea selected. & Control the use of specific co.nbustibles sessions shall provide brQade members with allowing for fire development due to the time in safety related areas. All wood used in experience in actual fire ext;nguishment and required to respond, to obtain equipment, and safety related areas during maintenance, the use of en.ergency breathing apparatus organize for the fire, assuming loss of modification, or refuehng operations (such as snder strenuous conditions encountered in automatic suppression capability, lay down blocks or scaffolding) shall be fire fightmg.These practice sessions shall be (4) Assessment of brigade leader's treated with a flame retardant. Equipment or provided at least once per year for each fire direction of the fire fighting effort as to supplies (such as new fuel) shipped in bripide member. thoroughness, accuracy, and effectiveness. untreated combustible packing containers t

3. Dril/s 4. Becon/s may be unpacked in safety-related areas if

a. Fire brigade dnlls shall be performed in Individual records of training provided to required for valid operating reasons.

the plant so that the fire brigade can practice each fire brigade member, including drill However, all combustible materials aball be as a team. critiques, shall be maintained for at least 3 removed from the area immediately following

, b. Drills 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 training progiam. material, unless stored in approved shift fire brigade. Each fire brigade member These records of training shall be available containers, shall not be left unattended should participate in each drill, but must for NRC revie*v. Retraining or broadened during lunch breaks. shift changes, or other participate in at least two drills per year. training for fire fighting within buildmgs shall similar periods. Loose combustible packing A sufficient number of these drills but not be scheduled far all thosi brigade members material such as wood or paper excelsior, or less than one for each shift fire bngade per whose performance records show polyethylene sheeting shall be placed in year, shall be unannounced to determine the deficiencies. metal containers with tight-fitting self closing fire inhtmg readiness of the plant f a J. Emergency Lightirg metal covers.

brigade, bngade leader, and fire pr section Emergency bghting units with at least an 8- 9. Control actions to be taken by an systems and equipment, persons planning hour battery power supply shall be provided individual discovering a fire, for example, and authorizing an n. announced drill shall in all areas needed for operation of safe notification of control room, attempt to ensure that the responding shift I!re brigade shutdown equipment and in access and extinguish fire, and actuation oilocal fire members are not aware that a drillis be:ng egress routes thereto. suppression systems.

planned until it is begun. Unannounced dnlis K. Ad.ninistrutive Controls 10. Control actions to be taken by the shall not be scheduled closer than four Administrative controls shall be control room operator to determine the need weeks established to minimize fire hazards in areas for brigade assistance upon report of a fire or A brast one dnd per year shall be containing structures. systems and receipt of alarm on control room annunciator performed on a "back shift" for each shift fire components important to safety. These panel, for example, announcing location of brigade. controls shall estabbsh procedures to: fire over pA system, sounding fire alarms,

c. The drills shall be preplanned to 1. Govern the handling and limitation of the and notifying the shift supervisor and the fire ,

cutablish the trainine objectives of the drill use of ordinary combustible materials. brigade leader of the type, size, and location l and shall be critiqued to determine how well combustible and flammable gases and of the fire. [

the traming objectives have been met. liquids, high efficiency particulate air and 11. Control actions to be taken by the fire  ;

Unannounced drills shall be planned and charcoal filters. dry ion exchange resins. or brigade after notification by the control room  !

cniitp.ed by members of the management other combustible supplies in safety-related ope ator of a fire. for example. assembling in

• j i

staff responsible for plant safety and fire a rea s. a designated location, receiving directions k l protection, perfoimance deficiencies of a fire 2. Prohibit the storage of combustibles in from the fire brigade leader. and discharging brigade or of individual fire brigade members safety related areis or estabhsh designated specific fire fighting responsibilities including

• shall be remedied by acteduling additional storage areas with appropriate fire selection and transportation of fire fighting '

h I traimng for the brigade or members. protection. equipment to fire location. selectina of l protective equipment. operatirs instructions Unsatisfactory drill performance shal; be 3. Govern the handling of and limit l Iollowed by a repeat drill within 30 days. transient fire loads such as combustible and for use of fire suppression sptems, and use q d At 3 yearintervals, a randomly selected flammable bquids, wood and plastic cf preplanned strategies 4r fighting fires in ,

unannounced drill shall be entiqued by products, or other combustible materials in specific areas. E quahficu individuals independent of the buildings containmg safety-related systems 12. Define the strategies for fighting fires in f bcensee's staff. A copy of tha written report or equipment during all phases of operating, all safety-related areas and areas presenting i from such individuals shall be available %r and especially during inaintenance, a hazard to safety related equipment. These {

NRC review.

rnodification, or r efueling operations. strategies shall designate:  :

e. Ordle shall as a minimum include the -1 Designate the onsite staff member a Fire hazards in each area covered by the j followmg: responsible for the inplant fire protection specific prefire plans. j f1) Annessment of fire alarm effectiveness. review of proposed work activities to identify b. Fire extinguishants best suited for >

time requred to notify and assemble fire potential transient t ire harards and specify controlhng the fires associated with the fire  !

1

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

, of these extinguishants. BWRs and be within the levelindication in conduits containing associated circuits of one

c. Most-favorable direction from which to the pressurizer for PWRs. safe shutdown division and crays and attack a fire in each area in view of the c. The reactor heat removal function shall conduits containing associated circuits or ventilation direction. access hallwr.p, stairs. be capable of achieving and maintaining safe shutdown cables from the redundant and doors that are most likely to be free of decay heat removal. division, or the isolation of these associated fire. and the best station or elevation for d. The process monitoring function shall be circuits from the safe shutdown eqtpment, l i

fighting the fire. All access and egress routes capable of providing direct readings of the shallbe such that a postulated fire involving I that involve locked doors should be process variables necessary to perform and associated circuits will not prevent safe specifically identified in the procedure with con 9ol the above functions. shutd own. "

the appropriate precautions and methods for e.The supportinefunctions shall be M. Fim Barrier Cable Penetrot/on Seal access specified. capable of providing the i cocess cooling, Quahfication

d. Plant systems that should be managed to lubrica tion, etc., necessary to permit the Penetration seal designs aball utilize only

. reduce the damage potential during a local operation of the equipment used for safe noncombuctible n sterials and shall be fire and the location oflocal and remote shutdown functions, qualified by tests that are comparable to tests controls for such management (e g4 any 3. The shutdown capability for specific fire used to rate fire barriers. ne acceptance hydraulic or electrical systems in the zone areas may be unique for each such area, or it criteria for the test shallinclude:

covered by the spec!fic fire fighting procedure may be one unique combination of systems L The cable fire barrier penetration seal that could increase the hazards in the area for all such areas. In either case, the has withstood the fire endurance test without because of everpressurization or electrical alternative shutdown capability shall be 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. sensitive system components shall accommodate postfire conditions where equivalent to the fire resistance rating that need to be kapt cool while fighting a offsite power is available and where offsite required of the barrier, local fire. Particularly hazardous power is not available for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. 2. The temperature levels recorded for the combustibles that need cooling should be Procedures shall be in effect to implement unexposed side are analyzed and -

designated this capability. demonstrate that the n axirnum temperature

f. Organization of fire fighting brigades and 4. If the capability to achieve and maintain is sufficiently below the cable insulation the assignment of spcial duties according to cold shutdown will not be available because ignition temperature; and job title so that all fire fighting functions are of fire damage, the equipment and systems 3. The fire barrier penetration seal remains covered by any complete shift sersonnel comprising ths means to achieve and intact and does not allow projection of water complement. These duties include command maintain the hot standby or hot shutdown beyond the unexposed surface daring the control of the brigade, transporting fire condition shall be capa'ule of maintaining hose stream test.

suppression and support equipment to the fire such conditions until cold shutdown can be N. Fire Doors scenes, applying the extinguishant to the fire, achieved. lf such equipment and systems will Fire doors shall be self-closing or provided communication with the control room, and not be capable of being powered by both with closing mechanisms and shall be coordination with outside fire departments. onsite and offslte electric power syums inspected semiannuaUy in 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. The mechanisms and latches are operable.

h. Ventilation system operation that number of operating shift personnel. One of the foUowing measures shall be ensures desired plant air distribution when exclusive of fire brigah members, required provided to ensure they will protect the the ventilation flow is modified for fire to operate such equipment and systems shall opening as required in case of fire:

containment or smoke clearing operations. be on site at all times. 1. Fire doors aball be kept closed and I. Operations requiring control rocm and 5. Equipment and systems com,,asing the electrically supervised at a continuously shift engineer coordination or authorization. means to achieve and maintain cold manned location

j. Instructions for plant operators and shutdown conditions shall not be damaged 2. Fire doors shall be locked closed and general plant personr:el during fire. by fire; or the fire damage to such equipment inspi.cted weekly to verify that the doors are L. Alternative and DedicatedShutdown and systems shall be limited so that the in the c!osed position:

Capability systems can be made operable and cold 3. Fire doors shall be provided with

1. Alternative or dedicated shutdown shutdown achieved within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. automatic hold.open and release mechanisms capability provided for a specific fire a:ee. Materials for such repairs shall be readily and inspected daily to verify that doorways shall be able to achieve and maintain available on site and procedures shall be in am fme of ohtructions; or subcritical reactivity conditions in the effect to implement such repe'rs. If such 4. Fire doors shall be kept closed and reactor, maintain reactor coolant inventory equipment and systems used prior tc 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> ir:spected daily to verify that they are in the achieve and maintain hot standb> ' after the fire will not be capable of being ci sed position.

conditions for a PWR (hot shutdown 7 for a powered by both onsite and offsite electric The fire brigade leader shall have ready UWR) and achieve cold shutdown ' power systems because of fire damage, an access to keys for any locked fire doors.

conditions within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and mainta.n cold independnet onsite power system shall be Areas pr tected by automatic total flooding

. shutdown conditions thereafter. During the provided. Equipment and systems used after gas suppression systems shall have postfire shutdown, the reactor coolant system 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> may be powered by offsite power electrically supervised self.clasing fce doors r shall satisfy option 1 above. l process variables shall be maintained within only. ,

, e those prediced for a loss of normal a.c. 6. Shutdown systems in talled to ensure O. O# Conecuon System for Reactor '

. power, and the fission product boundary postfire shutdown capability need not be Celant Pump integrity shall not be affected;i.e., there shall designed to meet seismic Category I criteria, ne mact r coolant pump shall be be no fuel clad damage, rupture or any primary coolant boundary, or rupture of the single failure criteria, or other dasign basis accident criteria, except where required for {9", *[,([,*" j ,

C

'[** I,gthe containment boundary, other reasons, e.g., because of interface with operation. The oil collection system shall be 2 The performance goals for the shutdown so designed, engineered, and installed that or impact on existing safety systems, or functions shall be: failure will not lead to fire during normal or because of adverse valve actions due to fire

a. 'Ihe reactisity control function shall be damage. design basis accident conditians and that

. cipable of achieving and maintaining cold 7. The safe shutdown equi; ment and shutdown reactivity conditions. systems for cact. ' ire area shall be known to a An acceptable method of complying with this b The reactor coolant trakeup function ' 8" sh311 be capable of maintaining the reactor be isolated from associated non. safety circuits in t!e fire area so that hot shorts, * '{'

, ,,"jd ssa d E" Sid 384-1974 (Section 4.51 where trays from open circuits. or shorts to tround in the redundant safety divisions are so protected thai 1 As defined in the Standard Technical associated circuits will not prevent operation postutated fires affect trays from only one sa rery Specifications. of the safe shutdown equipment.The division.

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L 76616 Federal Register / Vol. 45, No. 225 / Wednesday, November 19, 1930 / Rules and Regulations f l - .

l there is reasonable assurance that the system I

will withstand the Safe Shutdown , h l Earthquake

• 3 l Such collecuan systems shall be capable of j P q

~ '

collecting tube oil from all potential  % h pressurized and unpressurized leakage site 4 F in the reactor coolant pump lube oil systems. [

Leakage shall be collected and drained to a

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l vented closed container that can hold the entlre lube oil systr.m inventory. A flame arrester is required in the vent if the flash point characteristics of the oil present the L hazard of fire flashback. Leakage points to be protected shall include li'3 pump and piping. y!

overflow lines, lube oil cooler, oil fill and , 4 drain lines and plugs flanged connections on h oil linee, and lube oil reservoirs where such features exist on the reactnr coolant pumps.

The drair: line shall be large enough to accommodate the largest potential oil leak. t (Sec. tot b. Pub. L81-703,68 Stat. 948; sec.  !

201, Pub. L.93-438,88 Stat.1242 (42 U.S.C.

2201(b) $841})

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

November 1980.

For the Nucleat Regulatory Comntission. d SImuel J. Chilk, f

Secretary of the Commisswn.

lFR Doc. mat 7s Filed II-tut a 4s amj C1Luso Coct rsso41-as l

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L Eb I

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• See Regulatory Guide 1.2S " Seismic Design Classification" bragraph C2

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ENCLOSURE.2  !

STAFF REQUIREMENTS TO RESOLVE OPEN ITEMS 7,

I 3.1.19 FIRE DETECTION IN SAFETY-RELATED AREAS l i

.In the Calvert Cliffs Fire Protection Safety Evaluation Report dated l ls ' September 14, 1979 (SER), the licensee proposed to install appropriate t fire detection devices in some additional rafety-related areas. We j requested the licensee to provide design details of this modification j for our evaluation. l I

By letter dated December 21, 1979, the licensee described their fire / l smoke detection system. The licensee has taken credit for' sprinklers, i in combination with appropriate water flow alarms, as providing the  !

required fire detection when installed at the ceilings of rooms to i protect both equipment and cables, j A sprinkler system does not provide a level of fire detection which is l adequate to meet our guidelines for fire detection in safety-related areas.  ;

A sprinkler system, depending on the severity of the fire, may not be i actuated and, therefore, not detect small or slow growing fires in a i timely manner, and, therefore, does not provide the required defense-  !

in-depth.  !

i To meet Sectinn III, Paragraph F of Appendix R to 10 CFR Part 50, the licensee must install automatic fire detection systems in all l areas of the plant that contain safe shutdown'or safety-related systems I or components.

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3.1.20 UNPROTECTED DOORWAYS i In the SER, we requested the licensee to provide UL or FM listed fire doors of appropriate ratings, or an acceptable alternate, to protect the l unprotected doorways in fire barriers separating various safety-related i plant areas, including'the five doorways in the computer rooms which l currently are provided with nonfire rated bullet-proof doors.

By letter dated December 21, 1979, the licensee proposed to use auto- l matic sprinklers on one side of a fire barrier in lieu of rated fire t doors. Where credit is taken for automatic sprinklers in lieu of fire  !

doors, at least one sprinkler head will be located adjacent to and  !

immediately above the doorway to provide a water curtain to prevent ex- '

tension of the fire. No data was provided to justify the non-fire rated bullet-proof doors.

The use of automatic sprinklers on one side of a fire barrier in lieu i j

of rat d fire doors is unacceptable. The reliability and effectiveness '

of this form of protection has not been demonstrated. The licensee has l assumed that automatic fire suppression systems will always be actuated; I this is not supported by fire data.

To meet Section III, Paragraph N of Appendix R to 10 CFR Part 50, the licensee must install doors, trames, and i.ardware, that have been tested and approved by a nationally recognized testing laboratory, j in all door openir,gs of fire barriers separating the various safety .  !

related plant areas. In addition, the licensee must demonstrate that the

_ _- - __ _ ._ _ _ _ . . _ - _ _ . _ _ _ _ _ . . _ _ . ~ _ . _ _ . _ . _ _ , . ,

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2 non-fire rated bullet-proof doors, located in the fire doorways of the  ;

computer rooms, provide an adequate level cf fire protection in lieu of rated fire doors.

3.1.21 NANUAL HOSE COVERAGE i In the SER, we requested the licensee to provide the results of the hose reach tests for our evaluation.

By letter dated November 13, 1979, the licensee provided the results of the hose reach tests and the location of the~ additional hose stations.

There remain seven plant areas which will be beyond the effective rangt of the proposed or installed host stations. In all these areas, the licensee has estimated the combustible loading to be 2500 BTU per square foot or less. The licensee states these low fire loads do not justify

! extension of the standpipe and hose station system to these areas.

Transient combustibles may be introduced or moved through these seven areas and thereby increase the fire load in these areas.

I To meet Section III, Par'agraph D of Appendix R to.10 CFR Part .. .. I 50, the licensee must install standpipe and hose stationa so that at least one effective hose stream will be able to reach any location of the plant that contains or could present an exposure fire hazard to safety-related equipment.

3.2.1 FIRE HAZARD ANALYSIS in the SER, we requested the licensee to expand the Fire Hazh.d Analysis to include the effects of fire on safe shutdown capability. In those plant areas where the analysis could not demonstrate that safe shutdown capability could be preserved, appropriate modifications would be necessary, An alternate shutdown system should be provided if the provision of other fire protection does not give asrurance that safe shutdown capability.will survive a fire.

By letters dated December 21, 1979 and December 27, 1979, the licensee provided a description of proposed plant modifications based on a fire -

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hazards analysis; however, the analysis for the containment has not been provided.

We evaluated the information the licensee provided and we informed the licensee that we disagreed with the following assumptions in his analysis:

(1) The licensee as:.umes that an automatic fire suppression system will always prevent the concurrent loss of redundant divisions of cables or equipment as the results of a single fire, regardless of their separation, arrangement, proximity and nature or geometry of the room.

Fire data have shown that automatic fire suppression systems may not be actuated in the event of a fire and, therefore, do not provide, by themselves the required defense-in-depth. All areas which contain redundant systems required for safe shutdown should be provided with automatic sprinkler systems and early warning detection systems.

Further, in those areas in which the separation of the redundant e

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systems is less than 20 feet of clear air space, a 1-hour fire rated barrier should enclose one entire division. Some rystems or areas will require additional fire prctection, e.g., auxiliary feedwater system.

(2) The licensee assumes that automatic fire suppression systems have 100% reliability. As stated in Item 3.1.19, a sprinkler system does not provide a level of fire detection which is adequate to meet our guidelines for fire detection in safety related areas. A sprinkler system, depending on the seyerity of the fire, may not be actuated and, therefore, not detect small or slow growing fires in a timely manner to provide the required defense-in-depth. ,

(3) The licensee assumes that automatic sprinklers on one side of a fire barrier at doorways are equivalent to a fire door in the doorway. As stated in Item 3.1.20, the use of automatic sprinklers on one side of a fire barrier in lieu of fire rated doors is unacceptable. The reliability and effectiveness of this form of protection has not been i demonstrated. The licensee has assumed that automatic fire suppression systems will always be actuated; this is not supported by fire data.

1 The licensee has nct demonstrated that cables and equipment of redundant systems important to achieving safe shutdown conditions to ensure that at least one means of achieving such conditions' survives postulated fires.

l To meet our fire protecticn guidelines, alternate shutdown capability should be provided when safe shutdown cannot be ensured by barriers and detection and suppression systems because of the exposure of redundant -

safe shutdown equipment, cabling, or components in a single fire area to an exposure fire, fire suppression activities or rupture or inadvertent ,

operation of fire suppression systems. We informed the licensee that such alternate shutdown capability wh:ch is independent of several fire areas should be provided. By letter dated June 20, 1980, the licensee informed us that our requirements were being evaluated.

To meet Section 111, Paragraph G of. Appendix R to 10 CFR Part '

E0, the licensee should provide alternate shutdown capability for the '

following areas of the plant:

(1) Tne control room '

(2) Two cable spreading rooms with adjoining cable chases (IC L2C). '

(3) Six cable chases (IA, 1E, EA, 28, Horizontal U1, U2). i (4) Other plant areas where redundant cabline equipment required for safe shutdown cannot be separated by fire barriers of appropriate i rating, including but not limited to tre following: '

(a) Auxiliary building corridor and adjoinirg areas, elevation

(-) 10'-0". 1 i

(b) Auxiliary building ccreider and adjoining ar 'as, elevation i 5'-0".

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(c) Component cooling water pump rooms.

l (d) Each service water pump room.

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The alternate shutdown system should meet the requirements of Section  !

111, Paragraph L o'f Appendix R to 10 CFR Part 50. '

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'3.2.2(3) ADEQUACY OF DETECTOR INSTALLATION I k

In the SER, it was our concern that the fire protection provided for  !

the redundant divisions located in cable chases'1C and 2C may not be l adequate. By letter dated June 20, 1980, the licensee proposed to install  :

an automatic total flooding Halon 1301 system to prote.:t cable chases 1C  !

and 2C. The autcmatic detection for the system will consist of fixed j temperature detectors and multiple " product of combustion" type detectors  !

installed at two elevations. The licensee clains that if the early i warning " products of combustion" type detectors do not response to'a i slow developing fire, the fixed temperature detector will actuate the  !

Halon 1301 fire suppression system.  !

The licensee's proposal to provide a suppression system in cable chases f 1C and 2C does not meet the recuirements of Section III G of Appendix R {

to 10 CFR Part 50 and, therefore, is not acceptable. The licensee sho'uld i provide modifications for c'able chases 1C and 2C as outlined in .Section i III G of Appendix R to 10'CFR Part 50. '

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3.2.4 VENTILATION DUCT PENETRATIONS ,

4

. 5 By letter dated May 19, 1980, we reque:ted the licensee to verify that  ;

the proposed method of fire damper installation conforms to the conditions  !

of listing of the fire damper by the testing laboratory. ._;

By letter dated June 20,19SO, the licensee responded that they will verify that the method of fire damper installation conforms to the conditions of listing of the fire damper by the testing laboratory and the installation 3 provides the required fire r5sistance to meet the Fire Hazard Analysis. '

A report of the licensee's findings will be provided to us at a later date.  !

To meet Section D.l(j) of Appendix A to BTP APCSB 9.5-1 and Section III  !

the licensee must protect all fire barrier openings for ventilation systems  !

with an approved fire damper having a tire rating equivalent to that  !

required of the barrier. Further, the method of installation of the fire i damper should conform to the condition of the listing of the fire damper  !

by the testing laboratory.  !

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..- ,. 3.2.5 DRAIN SYSTEM BACKFLOW PROTECTION In the SER, it was our concern that the backflow of combustible liquid could occur between the Diesel Generator Rooms.

t By letter dated June 20, 1980, the licensee responded that the Diesel Generatar Room floor drains are located more than four feet.below the ,

finished floors so that before backflow can occur liquid levels in adjacent rooms must reach significant depths. Further, the Diesei Generator Rooms are at the same elevation ar.d the licensee concludes that before backflow would occur the liquid would flow through door 6penings to the yard. '

Each Diesel Generator Roem contains over 1000 gallons of combustible ,

liquids. If tne drainage sys~ ?m shared by these rooms was clogged immediately downstream of the comaon junction the backflow of combus-tible liquid between the rooms may occur.

To meet Section D.lli).of Appendix A to BTP APCSB 9.5-1, the licensee must install check valv'es to prevent the backflow of combustible liquics between these rooms.

3.3.7 OUALITY ASSURANCE PROGRAM in the SER, we requested that the licensee prohide a comparison of their Quality Assurance Pr.ogr:m for fire protection' with our guidelines.

By letter dated December 31, 1979, the licensee proviced a list of the exceptions where their fire protection QAP is not identi. cal to our guidelines. The licensee's response does not describe in sufficient detail how the ten specific quality assurance criteria in Section C of Appendix A to BTP APCSB 9.5-1 will be satisfied.

~ o meet Section C of Appendix A to BTP APCSS 9.5-1, the licensee must hcVe their QA program for fire protection under the management control of the QA organization. .This control consists of (1) formulating and/or verifying that the fire protection OA program incorporates suitable requirements and is acceptable to the management responsible for fire protection and (2) verify the effectiveness of the QA program for fire

• l protection through review, surveillance, and audits. Performance of other '

QA program functions for neeting the fire protection requirements may be performed by personnel outside of the QA organization. The QA program for fire protection should be part of the overall plar.t QA program.

These QA criteria apply to those ite'ms within the scope of the fire pro-tection program, such as fire protection systems, emergency lighting, communication and emergency bredthing apparatus as well as the fire pro-tection requirements of applicable s'afety-related equipment.

In addition, the licensee must ap?ly the same controls to each criterion of Section C which are commensurate 'with the controls oescribed in their cperational QA program. ,

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