ML20211J281
| ML20211J281 | |
| Person / Time | |
|---|---|
| Issue date: | 04/18/1985 |
| From: | Benaroya V NRC |
| To: | Vollmer R NRC |
| Shared Package | |
| ML20209D558 | List:
|
| References | |
| FOIA-86-274 NUDOCS 8606260307 | |
| Download: ML20211J281 (18) | |
Text
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[LO UNITED STATES l's
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NUCLEAR REGULATORY COMMISSION
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',. E WASHINGTON, D. C. 20555
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f APR 181985 NOTE T0:
Richard'H. Vollmer FROM:
Victor Benaroya
SUBJECT:
COMMENTS ON " FIRE PROTECTION POLICY STEERING COMMITTEE REPORT, INCORPORATION OF PUBLIC, REGION AND OFFICES COMMENTSt PROPOSED FIRE PROTECTION TECHNICAL SPECIFICATIONS" DATED APRIL 12, 1985 Bob Ferguson, Dennis Kubicki and I have reviewed the subject package.
Attached are our comments.
'\\\\ d
.vt Victor Benaroya
Attachment:
As stated cc:
t!. Johnston w/o attachment F. Rosa R. Ferguson D. Kubicki T. Wambach
~
i 8606260307 060619 G$DE8 74 PDR
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SURVEILLANCE REQUIREMENTS l
4.3.3.8.1 Eacht of the above required fire detection instruments which are accessible during plant operation shall be demonstrated OPERABLE at least once per 6 months by perfor. ance of a TRIP ACTUATING DEVICE OPERATIONAL TEST.
Fire detectors which are not accessible during plant operation shall be demonstrated OPERABLE by the performance of a TRIP ACTUATING DEVICE OPERATIONAL TEST during each COLD SHUTDOWN exceeding 2'. h;- ; unicss performed in the previous 6 months.
72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> 2C
- .... "~^^ :L
.., =;= _.YhtK 4.3.3.8.2
'hi "~ ' St;.d;rd 7::gsupervised circuits :c;;r-i:i;r, associated with the detector alarms of each of the' above required fire det e
shall be demonstrated OPERAB.LE at least once per 6 mont,hr,
}
4.3.3.S.3 The nonsupervised circLits, associated with detector alarms, between the instrument and the control room shall be demonstrated OPERAELE at least ence per 31 days.
f'-STS 3/4 3-6S f
l I
PL0ii SYSTEMS F7RE HOSE STATIONS LIMITINC CONDITION FOR OPERATION 3.7.11.5 The fire hose stations shown in Table 3.7-5 shall be OPERABLE.
APPLICABILITY:. Whenever equipment in thi areas protec.ted by the fire he'se stations is required to be OPERABLE.
ACTION:
With one or more of the fire hose stations shown in Table 3.7-5 a.
incperable, pr;;id; ;;t;d wy;(;} en thi ne ci. CTERAELE iw==
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t; pr;vid: ::v;r;;: f:r th; ;r;; 1;ft anpr;t;;t;d i3 th; inep;r;bli s%s h;;; :t:ti r.
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f restore the inoperable station (s) to an OPERAEI.E status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, or within the next i hour provide equivalent suppressien capability in the affected area (s): after 7 days, establish a continuous fire watch in the affected area (s).
2 b.
The provisions of Specifications 3.0.3 and 3.0.4 are not applicable.
SURVEILLANCE REOUIREMENTS 4.7.11.5 Each of the fire hose stations shown in Table 3.7-5 shall be cemenstrated OPERAELE:
At 1 east once per 31 days, by a visual inspection of the fire hose
~
a.
stations accessible during plant operations to assure all required
~
equipment is at the station.
b.
At least once per 18 months, by:
1)
Visual inspection, of the stations not accessible duri,ng plant operations to assure all required equipment is at the station, 2)
Removing the hose for inspection and re-racking, and 3)
Inspecting all gaskets and replacing any degraded gaskets in the couplings.
c.
At least once per 3 years, by:
1)
Partially opening each hose station valve to verify valve OPERAEILITY and no flow blockage, and 2)
Conducting a' hose hydrostatic test at a pressure of 150 psig or at least 50 psig above maximum fire main operating pressure, whichever is greater.
W-STS 3/4 7-38
PLANT SYSTEMS YARD FIRE SYDRANTS AND HYDRANT. HOSE' HOUSES LIMITING CONDITION FOR OPERATION s
3.7.11.6 The yard fire hydrants and associated hydrant hose houses shown in Table 3.7-6 shall be OPERABLE.
ADPLICABILITY:
Whenever equipment in the areas protected by the yard fire hydrants is required to be OPERABLE.
ACTION:
With one or more of the yard fire hydrants or associated hydrant a.
hose houses shown in Table 3.7-6 inoperable, V tH - 1 5:gr h:;:
2 f'i i;r,t :.dditi:r. 1 kr.;th: :f 2 1/2 Ir.:h di ;.;t;r h;n k e :d *..
ph c, cdj:icr.t SE*"3LE hydr:r.t h:n h:=
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N restore the inoperable hydrant (s) and/or hose house (s) to an OPERABII status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, or within the next i hour provide equivalent suppression 7
gj s capability in the affected arca(s); after 7 days, establish a continuous,
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fire watch in the affected area (s).
M The provisions of Specifications 3.0.3 and 3.0.f are not applicable. l b.
SURVEILLANCE REOUIREMENTS 4.7.11.5 Each of the yard fire hydrants and associated ~ hydrant hose houses sh:wn in Table 3.7-6 shall be demonstrated OPERABLE:
At least once per 31 days, by visual inspection of the hydrant hose a.
house to assure all required equipment is at the hese house.
At least once per 6 conths (once during March, April, or May and b.
once during September, October, or November), by visually inspecting each yard fire hydrant and veri.fying that the hydrant barrel is dry and that the hydrant is not damaged, and At least once per 12 months by:
c.
1)
Conducting a hose hydrostatic test at a pressure of 150 psig or at least 50 psig above maximum fire main operating pressure, whichever is greater, j
2)
, Inspecting all the gaskets and replacing any degraded gaskets in the couplings, and 3)
Performing a flow check of each hydrant to verify its OPERABILITY.
STS 3/4 7-40 w.
,o e PROPOSED ACTION STATEMENTS FOR SECTIONS 3.7.11.2-4 AUTOMATIC FIRE SUPPRESSION SYSTEMS r
With the [ system] inoperable such that one train of a safety system is a.
not protected by automatic fire suppression, verify the functional capability of the. redundant safety system train (s) which would accomplish the intended fudction and its associated fire suppression system, and restore the [ system] to OPERABLE within 7 days or establish hourly fire watch patrols in the affected area (s).
b.
With the [ system] inoperable such that a safety function (i.e., both or all trains of the safety system) is not protected by automatic fire suppression;n : '* : : :: *:
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--"1, within one bour establish a continuous fire watch with eouivalent manual fire I(
suppression equipment in the affected area (s).
~
The provisions of Specifications 3.0.3 and 3.0.4 are net applicable.
c.
BASES The OPERABILITY of the fire suppression systems does not include the actuating instrumentation (detectors) because they are covered under 3/4.3.3.8.
When a fire suppression system is found to be inoperable, the action statement recognizes the importance of the safety functions being protected, consistent with the design approach for fire damage limits.
When one train of a safety system becomes vulnerable to fires, the functional capability of the redundant train must be verified.
This requirement is intended to provide assurance that a fire in the affected area will not result in a complete loss of the
ENCLOSURE 2 APR 12198S GENERIC LETTER ON FIRE PROTECTION TO ALL LICENSEES AND APPLICANTS FOR OPERATING LICENSES Gentlemen:
SUBJECT:
IMPLEMENTATION OF FIRE PROTECTION REQUIREMENTS
- Q In the Spring of 1984, the S---i h held a series of Regional Workshops on the implementation of NRC fire protection requirements at nuclear power plants.
At those workshops, a package of r:n.C-M;d NRC guidance was dis-tributed to each attendee which included NRC staff responses to industry questions and a document titled " Interpretations of Appendix R."
The cove memo for the package explained that it was a draft package which would be issued in final form via Generic Letter following the works, hops.
) The qu M =: app; a d y m L... Q S 2 appended to this letter.nad is in the same format as the draft package, i.e., " Interpretations of Appendix R" e-
~'hirdTesponseskhave been modified from the draft package, and a number of in-f dustry questions raised at or subsequent to the workshops have been added and O
- ' cTvered, and where this guidance differs from previously issued gu answered.
This_packaQ% represents the official agency position on all issues s
f Icluding Generic Letter 83-33) on this subject, this guidance takes precedence.
,In the lettered sections below, some additional topics are covered which also
[/'// ments. bear on the interpretation and implementation of NRC fire protection require-The topics are:
(A) schedular exemptions, (B) revised ins f.J program, (C) documentation required to demonstrate compliance, (D)pection appli-cability of GDC-1 to fire protection systems, and (E) notification of the NRC when deficiencies are discovered.
A.
Schedular Exemotions The Appendix R implementation schedule was established by the Commission in 10 CFR 50.48(c), prcmulgated together with Appendix R in November of 1980.
Allowing time to evaluate the need for alternative or dedicated shutdown systems, which~ require prior NRC approval before installation, and time for design af and NRC review of such systems, the Commission envisioned that implementation of Appendix R would be complete in four to five years, or approximately by the end of 1985.
Many schedule extensions were granted by the staff under the " tolling provision," S0.48(c)(6), and under 10 CFR 50.12, the longest of which now extends into 1987.
Some licensees have proceeded expeditiously to implement Appendix R and are now finished or nearly finished with that effort.
Others have engaged in lengthy negotiations with the staff while continuing to file requests for schedule extensions, and thereby have barely begun Appendix R modifications needed to. comply with Sections III.G e
O
and III.L.
Schedule extension requests have been received seeking implementa-tion dates of,1990 or beyond.
As the 50.48(c) schedule was intended to be a one-time schedule commencing in the 1980-1982 time ' frame and ending in the 1985 time frame, extensions well beyond this schedule (particularly where major modifications remain to be completed) undermine the~ purpose of the schedule..which was to achieve ex-peditious compliance with NRC fire protection requirements.
The NRC will therefore grant no further extensions to the 50.48(c) schedules d'.
When a licensee's schedule expires, compliance ir expected and appropriate enforce-ment action will be taken.
If compliance cannot be achieved by that date, the licensee will be required to submit and justify a minimum schedule for comple-tion of fire protection modifications, and to supply interim measures to compensate for the lack of compliance.
In submitting a schedule which goes beyond the current 50.48 deadline [ *-) the licensee will, be required to demon-strate that it has endeavored in good faith to complete modifications on schedule. A showing of good faith attempt to complete implementation on schedule may mitigate enforcement action for noncompliance with NRC requirements.
0>
The NRC is currently reviewing all dockets of plants covered by the 50.48 schedule to determine schedule deadlines.
each licensee will be informed of the deadlines.When this review is completed, i
B.
Revised Insoection Program In 1982, the NRC developed an inspection program to verify compliance with the requirements of 10 CFR 50, Appendix R.
This program was primarily oriented I
towards reviewing safe shutdown features of those pre-1979 licensees that i
had completed Appendix R mo'difications and selected NTOL plants.
From 1982 to the present, approximately seven Appendix R compliance inspections have been performed.
In a number of cases, these inspections have discovered that licensees had made significant errors in implementing a number of Appendix R requirements.
.k. ::moer'[o expedite compliance verification and to provide the NRC staff with earlier indication of problems associated with implementation of fire pro-tection features, the NRC will conduct fire protection inspections of opera-tingplantsandplantscurrentlyundergoingoperatinglicensereviewduring{
t f*
Licensees submitting "living schedules" for NRC approval should be I
aware that existing 50.48 schedules continue to apply.
Licensees in-I tending to include fire protection modifications within a "living schedule" are expected to assign within such schedules the relative I
safety priorities of remaining fire protection modifications.
If the NRC accepts a _ delayed implementation date in the context of a living schedule, this would provide the basis for a schedular exemption which would then be issued under 10 CFR 50.12.
I
1985 to include at least one site from each licensee who has not been subject to a previous,NRC fire protection inspection.
This inspection will review completed modifications and, in the case of incomplete modifications, review licensee plans and schedules for completing such modifications.
C.
Documentation Required to Demonstrate Compliance The " Interpretations" document attached to this letter states that, where the licenee chooses not to seek prior NRC review and approval of, for example, a fire area boundary, an evaluation must be performed by a fire protection engineer (assisted by others as needed) and retained for future NRC audit.
Evaluations of this type must be written and organized to facilitate review by a person not involved in the evaluation.
Guidelines for what such an evaluation should contain may be found in:
(1) Section B of Appendix R and (2) Section C.I.b of Branch Technical Position (BTP) CMEB 9.5-1 Rev. 2 dated July 1981. All calculations supporting the evaluation s50uld be available and all assumptions clearly stated at the outset.
[Fa44wre-te-have-sweh-an evaluatien-available-fer-an-area-where-eemplianee-with-Append 4x-R-4s-net re a dily-d eme R s t r a te d-will-be-ta ke n-a s-p rima-f a e f e-eV 4 de n e e-t h a t-t he-a re a d e e s -m e t -e emply-w i t h-NRG-req u i reme n ts y -a n d-may-re s u l t-i n -e n fe re eme n t-a e t i e n r ]
The NRC intends to initiate enforcement action where, for a given fire area, comoliance with Appendix R is not readily demonstrable Ord "~ 2 4-- : : 22:r
.- s m, m,43,u-
.a..~
n_
m---a
,,,ys k ' r tM c rn.
The term "readily demonstrable" includes situations where compliance is apparent by observation of tne Dotential fire hazard and the existing protective features.
D.
Quality Assurance Reouirements Applicable
[Five-preteet4en-systems-must-meet-the-requirements-ef-General-Gesign-Gr4ter4en 1-ef-Append 4x-A-te.10-GFR-part-59,--Fer-sweh-systems-the-14eensee-4s-therefere required-te-have-and-maintain-a-quality-assuranee-pregram-adequate-te-assure t h a t-t h e s e-sys t ems-will-p e rie rm-t h e i r-f u m e t ie n s -whe n-e a lled-hp e n t ] For fire protection systems the licensee should have and maintain a quality assurance program that provides assurance that the fire protection systems will be de-sianed, faor1cated, erected. tested, maintained and ODerated so that they will function as intended.
Fire protection systems are not " safety-related" and are tnerefore not within the scope of Appendix B to 10 CFR Part 50, unless the licensee has committed to include these systems under the Appendix B program for the plant.
NRC guidance for an acceptable quality assurance program for fire protection systems, given in Section C.4 of Branch Technical Position CMEB 9.5-1 Rev. 2 dated July 1981, has generally been used in the review and acceptance of approved fire protection programs for plants licensed after January 1, 1979.
For plants licensed prior to January _1, 1979, similar guidance was referenced in footnotes 3 and 4 to 10 CFR 50.46.
They are contained in BTP APC58 9.5-1 and Ap)endix A thereto and in " Nuclear Plant Fire Protection Functional Responsi)ilities, Administrative Control and Quality Assurance" dated June 14, 1977. M n,
y(
E.
Notification of the NRC When Deficiencies are Discovered Licensees are reminded of their obligation to notify the NRC of fire protection deficiencies which ' meet the criteria of 10 CFR 50.72 or 10 CFR 50.73 as i
applicable.
l 0
6
2.
Severity Cateoories t
A.
Severity I.
Violations of fire protection requirements estab-listed to protect or enable operation of safe hot shutdown equip-ment concurrent with an actual fire which damages that equipment such that safe hot shutdown could not be achieved or maintained using the equipment [dedfeated] identified in the fire hazards analyses for this purpose.
B.
Severity II.
- Violations of fire protection requirements established to protect or enable operation of safe cold shutdown equipment concurrent with an actual fire which damages that equipment such that safe cold shutdown could not have been achieved and maintained using the equipment [dediented] identified in the fire hazards analyses for this purpose in accordance with the applicable requirements.
[ Failure-te-have-a-written-evaluatien-available fe r-a n -a re a -wh e re-e emplia nc e -wi t h-Appe nd ix-R-i s-ne t-readily demenstrated-will-be-taken-as-prima-fasie-evidence-that-the-area dees-net-eemply-with-NRG-requirements-and-may-result-4n-enferee-ment-aetfen-at-the-severity-leveir]
C.
Severity III.
Violations of fire protection requirements established to protect or enable operation of safe shutdown equipment such that a fire in the area could damage that equipment to the extent that safe hot or cold shutdown could not have been achieved and maintained using the equipment [dedfeated) identified in the fire hazards analyses for this purpose in accordance with applicable requirements.
Itre-ftM 4 a t e nd: te 4"itiate anfnecamant.actica whara fne =
4 n 4 va n_.
area,-coms.liance With Appendix.Reis-no+ aeart41y demonstrable :nd th:
licensem dee r net-hae !"ai h bl c-wr4.tten evaluatinn. fnrmthe -->
Th: term-.4eadiW demons-trab.1eNinc-ludes-s.ituatiens where comoldawe is-apparent by observat4cn-of-tne octential fire. hazard anc. exist.ino
. protective features.
D.
Severity IV.
Violations of one,or more fire protection requirements that do not result in a Severity Level I, II or III violation and which have more than minor safety or environmental significance.
E.
Severity V.
Violations of one or more fire protection requirements that have minor safety or environmental significance.
ENCLOSURE 5 APR I 21985 FIRE PROTECTION LICENSE CONDITION r
1.
The licensee shall implement and maintain in offect all provisions of the approved fire protection Report for the facility (program as described in the Final Safety Analysis or as described in submittals dated--------) and as approved in the SER dated--------(and Supplements dated--------) subject to provisions 2 and,3 below.
2.
The. licensee may make no change to the approved fire protection program which would it; ' " ~ 'ir decrease the level of fire protection in the plant without prior approval of the Commission.
To make such a change the licensee must submit an application for license amendment pursuant to 10 CFR 50.90.
The licensee may make changes to features of the approved fire pro-tec 3.
protection without prior Commission approval provided (a) such changes do not otherwise involve a change in a license condition or technical specification or result in an unreviewed safety question (see 10 CFR 50.59), and (b) such changes do not result in failure to [earry-eut]
complete the fire protection program approved by the Commission prior to license issuance.
The licensee shall maintain, in an auditable form, a current record of all such changes, including an analysis of the effects of the change on the fire protection program, and shall make such records available to NRC inspectors upon request.
All changes to the approved program [made-witheut-prier-Gemmissien-appreval] shall be reported annually to the Director of the Office of Nuclear Reactor Regulation, [tegether-with-suppert4mg-analyses,] along with the FSAR revisions reovired by 10 CFR 50.71(e).
6 m
3.2.2 Deviations from Tested Configurations QUESTION Due to obstructions and supports, it is often impossible to achieve exact duplication of the specific tested configuration of the one-hour fire barriers which are to tie placed around either conduits or cable trays.
For each specific instance where exact replication of a previously tested configuration is not and cannot be achieved, is an exemption necessary in order to avoid a citation for a violation?
RESPONSE
No.
Where exact replication of a tested configuration cannot be achieved, the field installation should meet all of the following criteria:
1.
The continuity of the fire barrier material is maintained.
2.
The thickness of the barrier is maintained.
3.
The nature of the support assembly is unchanged from the tested configuration.
4.
The application or "end use" of the fire barrier is unchanged from the tested configuration.
For example, the use of a cable tray barrier to protect a cable tray which differs in configuration from those that were tested would be acceptable.
However, the use of structural steel fire proofing to protect a cable tray assembly would not be acceptable.
5.
,The configuration has been reviewed by a qualified fire protection engineer and found to' provide an equivalent level of protection.
3.2.3 Fire Door Modifications 00ESTION Where labeled and rated fire doors have been modified to incorporate security hardware or for flooding protection, is an exemption from Appendix R required?
RESPONSE
{
Where a dcor is part of a fire area boundary, and the modification does not' effect the fire rating (for example, installation of security " contacts"), no further analysis need be performed.
If the modifications could reduce the fire rating (for example, installation a vision panel), the fire rating of the door should be reassessed to ensure that it continues to provide adequate l
margin considering the fire loading on both sides.
An exemption is required if fire doors installed in a fire barrier used to satisfy Section III.G.2 are modified such that the fiabeied rating no-ionger.
applies-3ftTOUndary margWeuuteu, cannoc.ve estaDiisnedTy aT"\\
anu it
,hTrcrTVif1TNhith consider,Vthe fire loading ondoth sides of the-boundary, that )
f an adequate margin recains.
-. '. ~.
APPENDIX R QUESTIONS & ANSWERS 12
Cables that are in EcoverId3 cable _ trays "'i:' d-r,m W %Ly \\
bottom, sides and top should also be considered as intervening combustible-Coated cables with a fire retardant material are also conside combustibles.
i E
3.6.3 Unexposed Combustibles 00ESTION Are unexposed combustibles, such as oil in sumps, closed cans, or sealed dr or electrical cable in conduits, considered as " intervening combustibles?"
RESPONSE
Only oil in closed containers which are in accordance with NFPA 30 or elec cables in metal conduits _f^!
- '^"
- r ^-
2 2 J._.
al ht"-
- W 1 0 are not considered as intervening combustibles.
~.
m oil in open sumps is~ considered to be an intervening tombustible; in-situ o In/ situ N in closed sumos eauivalent to NFPA Standard 30 containers i be an intervenino combustible.
o 3.7 Radiant Eneray Shield 3.7.1 Fire Rating OUESTION should be tested against ASTM-TO-E-119 based, app of BTP CMEB 9.5-1, Rev. 3, a document issued after Appendix R was promu This new requirement would not appear to be required by Appendix R or BTP APCSB 9.5-1 Appendix A.
Could the Staff clarify'the requirements in this area?
ANSWER During the Appendix A reviews, we observed that inside some containments there were large concentrations of cables converging at electrical penetration In some cases, where the penetrations were grouped by division, shields areas.
were placed between the divisions so that radiant energy from a fire involvin
.the cables' of one division would not degrade or ignite cables of the other divisions.
away from the surviving division.These shields also directed the convective energ of 1/2-inch marinite board in a metal frame.These shields were usually constructed to these shields as "a noncombustible radiant energy shield." Appendix R,Section III.G a fire rating of 1/2 hour.in BTP CMEB 9.5-1, Section C.7.a(1)b. indicate that the The guidelines should be capable of performing the required function.In our opinion any mate The guidelines of BTP CMEB 9.5-1 relating to a firerated radiant energy shield are being considered in our current reviews of NTOL plants.
achieve an equivalent level of safety, we have been accep However, to the have not been tested against the acceptance criteria of ASTM E-119.
3 APPENDIX R QUESTIONS & ANSWERS i
19
]
~
In our Appendix R r views, we h:.v2 accepted non-fire rated radiant energy shields that have been demonstrated by fire hazards analysis to provide an acceptable level of protection against the anticipated hazard of a localized fire within the containment.
We have also accepted fire-rated metal-sheathed mineral insulated cables, as a radiant energy shield in specific configurations.
t 3.8 Design Bases 3.8.1 Fire Protection Features NFPA Conformance -
QUESTION Should the fire protecti,on features required by Section III.G conform to the NFPA Codes?
RESPONSE
Yes.
For example,Section III G.2 requires an automatic suppression system.
Our guidelines would recommend that the system be in accdrdance with an NFPA Code.
If deviations are made from the Code, they should be identified in the FSAR or FHA.
3.8.2 Design Basis Fire OUESTION Why isn't the industry allowed to design to protect against a design basis fire?
RESPONSE
Neither the industry nor the Staff has been able to develop criteria for ess blishing design basis fire conditions _for a sinole " design basis fire" beca-the in-situ and ootential transient combustibles vary widely in different areas
_of the olant. flowever, tneeestao 61snmentAt a -cesim, u m 3 eire-for specitic'
' fire / areas or Jones is aA5rereauisite to'oerformance of a valid fire hazard (
ana4ysis (See ADDendix4 Section II.Ptl) and BTP CliES 9.5-1 Sectiens C.b(7) ar.d ( 2)).
/
J J
3.8.3 Redundant Trains / Alternate Shutdown QUESTION Confusion exists as to what will be classified as an alternate shutdown system and thus what systems might be required to be protected by suppression and detection under Section III.G.3.b.
For example, while we are relying upon the turbine-building condensate system for a reactor building fire and the RHR system for a turbine building fire, would one system be considered the alterna-tive to the other.
If so, would suppression and detection be required for oither or both systems under III.G.3.b?
needs to be advanced for all licensees.
An explanation of alternative shutdown APPENDIX R QUESTIONS & ANSWERS 20
"9.5 Fire Protection Program (Section 9.5, SER) e licensee shall implement and maintain in effect all provisions a.
the oved fire protection program as described in the Final Safet ap Repo t for the facility Ethreagh amendment-----3 (or as desc ' ed in sub-nalysir.
mittai dated
) and as approved Ethrough amendment----
dated in the SER C d supplements dated
) subject to provis' ns b & c below, b.
The licensee make no change to the approved f' e protection program which would dec ase the level of fire protec 'on in the plant without prior approval of e Commission.
To make ch.a change the licensee must submit an appl 1 tion for license ndment pursuant to 10 CFR 50.90.
The licensee may make chan s to f ures of the approved fire protection c.
program which do not sianifi nt _
without prior Commission appr decrease the level cf fire protectian
[after-such-features-have-been-ins (aiied as approved 3 provided (a) ch cha es do not otherwise involve a cha, in a license condition.o technical s cification o,r result in an unreviewed
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safety question (cee CFR 50.59)., E ever-3 and (b) such changes do g[ hot result in failu _ to complete the fire the Commission prj$r to license issuance.
otection program approved by licensee shall maintain, i
in an auditabl form, a current record of all su changes including an analysis of e effects of the change on the fire p ection program, and shall mak such records available to NRC inspectors up request.
All changes o the approved program Emade withoct. prior-Eomm ion-approvai3 shal e reported annually to the Director of the Office of clear Reactor Re p(visions required by 10 CFR 50.71(e).ation, Etegether-with supporting a
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8.3 III G, J and 0 Exemotions for Future Modifications QUESTION Is an exemption required from Appendix R Sections other than III.G, III.J and III.0 for future modifications that do not comply with such sections?
RESPONSE
Yes, _for those modifications which deviate from the previously accepted fire protection confiourations.
The exclusion of the applicability of Sections of Appendix R other than III.G, III.J, and III.0 is limited to those features
" accepted by the NRC staff as satisfying the provisions of Appendix A to Branch Technical Position BTP APCSB 9.5-1 reflected in staff fire protection safety evaluation reports issued prior to the effective'date of the rule."
No re-analysis is required except for proposed modifications which would alter pre-viously aoproved features.
This position is based directly E
References:
3 SLn CFR 50.48(b).
Also see response to Question 8.2.
8.4 Future Changes QUESTION Will future changes (no matter how minor) to approved configurations be required to be reviewed by the Staff in an exemption request? At what point may the process of 10 CFR 50.59 be invoked?
APPENDIX R QUESTIONS & ANSWERS 34
The NRC has fou'nd during insp;ctions that some licensees da not cor-sider tha Appendix A to BTP APCSB 9.5-1 items cf their fire pro-tection programs as binding and have either changed them or ignored them.
For plants licensed after January 1, 1979, while all such plants have a license condition regarding fire protection, the scope of what is covered by the condition and the wording of.the condition vargies widely.
This results in varying degrees of compliance and uneven enforcement. Therefore, we believe that a " standard license condition" is necessary for consistent and fair regulation.
How-ever, the license condition has been revised to include specific identification of the documents providing the basis for the license condition.
Regarding the applicability of 10 CFR 50.59, in many cases,' includ-ing all plants licensed prior to January 1,1979, the fire protection program and the fire hazards analysis are not described in the FSAR.
Therefore, the provisions of 10 CFR 50.59 are not directly appli-Accordingly, the license condition has been revised to cable.
specify the applicability of 10 CFR 50.59 for the evaluation pro-Addi-cess and 10 CFR 50.71(e)(2) for the reporting process.
tional revisions are described in coninent re' solutions 1.1.10 and 1.1.11.
Regarding the comment on Question 8.3, this comment is not con-sidered valid.
The cited Statement of Considerations does not address the applicability of Appendix R in regard to modifica-tions made to features previously apprpved by the staff. The staff position in this regard is clearly supported by 10 CFR 50.48(b).
A revision to the response to Question 8.3 has been made to clarify this point.
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1.1.10 Comment (D.2): Hearing Requirements Under the proposed license condition, any change to the program must be analyzed for its effect on overall fire protection safety.
Even minor modifications such as adding one cable to a room or a 1
change in the location of a fire extinguisher would have to be i
analyzed, and, if found to lower the level of fire protection, no matter how minor, would require a license amendment with full notice and hearing rights, an expensive and time-consuming process with-out a commensurate benefit to safety. Therefore, the proposed license condition should not be adopted.
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0' Resolution:
TFelr'oposed-Air.ense condition has been revised te maWiCclear f W~Ti~cTIon program that that only those cha'ri'g&-te*" level of TiYe protect, ion would require "significantly" Infe cn approval and a license amendment; changes-wb.ich do prior'significantly" decrease the level of fire protection may bd%
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- ..u r M ted annually with FSAR re w n cTI c P_50.M ( A 1.1.11 Comment (D.3)
- Section 50.59 In r:egard to paragraph 3 of the proposed license condition the comment states:
a)
---that the requirement to submit the supporting analyses 1
would impose an undue paperwork burden on both the licensees and the Staff.
Significantly, Section 50.59 does not' require actual submittal of the analyses performed in accordance with that section.
Instead, licensees report to the NRC annually pursuant to 10 C.F.R. 5 50.71(e) (2) on what Section 50.59 changes have been made.
We would recommend that a similar procedure be used for fire protection changes, and therefore would recommend not imposing a requirement for actual submittal of the analyses."
b)
---there is no safety reason to require that "All changes to the approved program" be reported to the NRC annually.
For example, changing the location of a fire extinguisher or adding one cable to a room may have no practical bearing on safety.
Yet, pursuant to the license condition as postured, it may need to be reported.
We maintain that such a requirement is unjusti-fied and unwarranted."
Resolution:
L a) The proposed license condition has been revised t; c seve=the raqWement.-for-sttbsttaJ 4f-the analyses-and to specify the applicability of 10 CFR 50.59 and 10 CFR 50.71(e).
b)
It is not intended that changes that "---have no practical bear-ing on safety" be reported; it is expected that licensees would exercise reasonable judgment in this regard.
A revision was not considered necessary.
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1.1.12 Comment (E): Standard Technical Specifications The comment supports the Steering Committee effort to revise the fire protection Technical Specifications to the extent that it is directed toward simplifying and generalizing them to be more workable.
It recommends that any proposed TS changes be reviewed as part of the overall staff consideration of Technical Specifications in general, and requests an opportunity to comment on proposed changes.
-g-1.1.13 Comment (F.1): Question 3.2.3 (Fire Door Modifications) t)
The comment notes that according to FL and FM any modification of X
j a fire door will invalidate its label.
Therefore, the following portion of the response to Q3.2.3, "An exemption is required if fire doors installed in a fire barrier used to satisfy Section III.G.2 are modified such that the labeled rating no longer applies," could be interpreted to require an exemption for modifi-cations to incorporate security hardware or flooding protection.
It is recomended that the response be revised to state that an exemption is required only after a boundary analysis.which considers the fire loading on both sides of the boundary shows that adequate margin no longer exists.
Resolution:
The comment is valid.
The requested revision has been made.
1.1.14 Comment (F.2): Question 3.6.2 (Intervening Combustibles)
The comment notes that the response to Q3.6.2 classifies cables in covered cable trays as " intervening combustibles" while the response to Q3.6.3 states that cables in conduit cre' not considered inter-vening combustibles.
It is recommended that the response to Q3.6.2 be revised to state that "--cable in fully enclosed cable trays does not constitute an intervening combustible for Appendix R purposes."
Resolution:
d The response to Q3.6.2 has been revised to state that cables in cabl
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trays which do not have solid sheet metal bottom sides and top are Q
~php-considered intervening combustibles.
The response to Q3.6.3 has been revised to. state that cables in metal conduits or in cable trays or g
raceways which have solid sheet metal bottom, sides and top are not considered intervening combustibles.
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1.1.15 Comment (F.3): Question 3.6.3 (Unexposed Combustibles)
"The response to this question states that oil in closed containers that conform to NFPA Standar'd 30 is not considered an intervening combustible, while oil in sumps is so considered.
The Group believes that oil in closed sumps should be treated as equivalent to oil in NFPA Standard 30 containers, and therefore should not be classified as an intervening combustible.
The Group does not object, however, to classifying oil in open sumps as an intervening combustible."
Cables in cable trays are usually in a grouped cable configuration which may be capable of sustaining combustion and contributing to fire growth.. Covers on the trays only reduces the burning rate.
(See Invest.igation of Twenty-foot Separation Distance as a Fire Protection Method as Specified in 10 CRF 50, Appendix R, NUREG/CR-3192, October 1983, and Fires in Covered Cable Trays, BNL-NUREG-23816, January 1978).
Recommendation
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2.0 NRC Regional and Office Comments 2.1 Regi8on I: Memorandum from Thoma's E. Murley, Regional Administrator, RI, to Victor Stello, DEDR0GR, dated November 27, 1984.
2.1.1 Comment 1: Technical Specifications This comment objected to the " clutter" in all plants Tech Specs created by the many fire protection specifications, such as hundreds of fire detectors.
Resolution:
This comment should be resolved as part of the activity being performed by the Technical Specification Improvement Project.
2.1.2 Comment 2:
Fire Protection Review Responsibility "We believe it would be more efficient if all fire protection review activ.ities were consolidated in the Division of Licensing in NRR."
Resolution:
~
The activities involved in the review of fire protection programs cover a wide spectrum of technical disciplines.
This fact makes it inappropriate to organize the required technical expertise (QA, training, fire protection, systems for shutdown, electrical, instru-s mentation and control) into one Division.
There is not sufficient activity in some of these areas to have a reviewer dedicated to solely fire protection.
2.1.3 Comment 3: Consistent Definitions "The Steering Committee documents should be carefully edited to be sure the terms are defined and consistently used and to be sure the Interpretation and Q&A documents are internally consistent."
Resolution:
We made a determined effort to do this. Without specific examples [
of inconsistencies, we don't know whether we have resolved this e
commenter s concerns.
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