ML22193A282

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Shine OL SER Chapter 9a.4.3 with No Open Items - Fire Protection Systems and Programs
ML22193A282
Person / Time
Site: SHINE Medical Technologies
Issue date: 07/12/2022
From: Gavello M
NRC/NRR/DANU/UNPL
To:
Gavello M
Shared Package
ML22073A179 List:
References
Download: ML22193A282 (19)
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Text

9a.4.3 Fire Protection Systems and Programs The NRC staff evaluated the sufficiency of SHINEs fire protection systems and programs, as described in SHINE FSAR Section 9a2.3, Fire Protection Systems and Programs, using the guidance and acceptance criteria from Section 9.3, Fire Protection Systems and Programs, of NUREG-1537, Parts 1 and 2.

SHINE FSAR Section 9a2.3.1 states that the applicants Fire Protection Program (FPP) ensures, through the application of the defense-in-depth (DID) concept, that a fire will not prevent the performance of necessary safety-related functions and that radioactive releases to the environment, in the event of fire, will be minimized. The SHINE FPP describes the overall program and references individual program elements, including the fire hazard analysis (FHA),

the safe shutdown analysis (SSA), administration controls, pre-fire plans, implementing procedures, etc.

SHINE FSAR Section 9a2.3.2 states that fire protection DID for the SHINE facility is designed to do the following:

  • Prevent fires from starting, including limiting combustible materials;
  • Detect, control, and extinguish those fires that do occur to limit consequences; and
  • Provide protection for SSCs important to safety so that a continuing fire will not prevent the safe shutdown of the IUs or cause an uncontrolled release of radioactive material to the environment.

During the NRC staffs review, the need for additional information was identified, resulting in an RAI dated June 23, 2021 (ADAMS Accession No. ML21162A318). In response, SHINE submitted letters dated December 30, 2021 (ADAMS Accession No. ML21364A055), and February 28, 2022 (ADAMS Package Accession No. ML22059A017). The additional information requested is intended to ensure that the operating license applicant has provided and developed sufficient analyses applicable to and commensurate with the risks of releases of radioactive material associated with fire hazards in the unrestricted environment at the site, and that any doses received by members of the public are within the regulatory limits of 10 CFR Part

20. Additionally, the RAI sought to confirm that SHINEs fire protection plan includes the applicable elements of 10 CFR 50.48 and satisfies SHINEs principal design criteria. As part of the staffs evaluation, its RAI and the applicants responses are summarized below.

In RAI 9-3(a), the NRC staff requested that the applicant discuss firefighting procedures for use in a moderation-controlled area and evaluate the use of moderator material. In its response to the RAI, the applicant stated that use of moderation as a controlled parameter, including firefighting procedure evaluation, is described in SHINE FSAR Section 6b.3 and is in accordance with ANSI/ANS-8.22-1997, Nuclear Criticality Safety Based on Limiting and Controlling Moderators. The applicant further stated that subsection 9a2.3.8 of the FSAR states, Fire response using water-based extinguishants [in the target solution preparation system (TSPS) and uranium receipt and storage system (URSS) rooms] is prohibited; elevated floors of the URSS and TSPS fire area are provided to prevent flooding of these rooms, and that pre-fire plans, developed in accordance with the FPP, note where water use is restricted due to a criticality hazard.

Based on the information provided by the applicant, the NRC staff concludes that the applicant satisfies the acceptance criteria described in NUREG-1537, Part 2, Section 9.3 because the 1

applicant has established firefighting procedures for use in a moderation-controlled area and has evaluated the use of moderator material.

In RAI 9-3(b), the NRC staff requested that the applicant discuss specific guidance in Rock County 911 Communications Centers SHINE-specific response information binder on the use of firefighting foam at the SHINE facility. In its response to the RAI, the applicant stated, in part, that:

[T]he SHINE specific response information binder to be provided to the Rock County 911 Communications Center will provide specific guidance on the use of firefighting foam at the SHINE facility. The response information binder will be developed and provided to the Communication Center as part of the development and implementation of the SHINE Emergency Plan Implementing Procedures (EPIPs). The SHINE EPIPs will be submitted to the NRC no less than 180 days before the scheduled issuance of the SHINE operating license in accordance with Section V of Appendix E to 10 CFR Part 50.

Based on the information provided by the applicant, the NRC staff concludes that the applicants response satisfies the acceptance criteria described in NUREG-1537, Part 2, Section 9.3 because the applicant stated that the Rock County 911 Communications Center response information binder will be developed and provided to the Communications Center as part of the development and implementation of the SHINE EPIPs and that the SHINE EPIPs will be submitted to the NRC no less than 180 days before the scheduled issuance of the SHINE operating license in accordance with Section V of Appendix E to 10 CFR Part 50.

In RAI 9-4(a), the NRC staff requested that the applicant discuss its fire protection organization, its staffing, and their responsibilities. In its response to the RAI, the applicant provided the requested information including discussions regarding responsibilities of the Safety Analysis Manager, the Operations Manager, the Maintenance Manager, the Fire Protection Staff, and the Fire Response Team. Based on the information provided by the applicant, the NRC staff concludes that the applicants response satisfies the acceptance criteria described in NUREG-1537, Part 2, Section 9.3 because the applicant described its fire protection organization, including its staffing and responsibilities, which provides reasonable assurance that the applicant has an acceptable organization, appropriate administrative controls, and qualified key management positions to satisfy the regulatory requirements for a license to possess and use radioactive material.

In RAI 9-4(b), the NRC staff requested that the applicant discuss fire protection engineering design bases. In its response to the RAI, the applicant stated that Appendix A to 10 CFR Part 50, General Design Criterion 3, has been adopted and revised for application to the SHINE facility to define the design bases for fire protection engineering, and that SHINE Design Criterion 3 is defined in Table 3.1-3 of the FSAR. Based on the information provided by the applicant, the NRC staff concludes that the applicants response satisfies the acceptance criteria described in NUREG-1537, Part 2, Section 9.3 because the applicant has adopted General Design Criterion 3, which ensures that the FPP is based on evaluation of potential fire hazards throughout the facility and the effect of postulated design basis fires relative to maintaining the ability to perform safe shutdown functions, to protect SSCs from fire and minimize radioactive releases to the environment.

In RAI 9-4(c), the NRC staff requested that the applicant provide a description of electrical cable construction. In its response to the RAI, the applicant stated that electrical cables selected for 2

use, to the extent practicable, are constructed to recognized flame spread test criteria and that plant cabling is selected and routed to minimize its contribution to combustible loading. Based on the information provided by the applicant, the NRC staff concludes that the applicants response satisfies the acceptance criteria described in NUREG-1537, Part 2, Section 9.3 because the applicant stated that the electrical cables are constructed to recognized flame spread test criteria and that cable trays are routed to minimize its contribution to combustible loading.

In RAI 9-4(d), the NRC staff requested that the applicant discuss the fire brigade and fire brigade training program. In its response to the RAI, the applicant stated that it does not employ a fire brigade, and consequently, does not have a fire brigade training program. Additional information regarding the applicants manual fire-fighting capability can be found in the discussions for RAIs 9-4(f), 9-4(g), and 9-7(e).

In RAI 9-4(e), the NRC staff requested that the applicant discuss its general employee fire protection training program. In its response to the RAI, the applicant stated that as part of the implementation of the FPP, general employee fire protection training will be provided to facility employees upon initial hire with refresher training performed periodically. The applicant further stated that this training covers general fire protection awareness, FPP introduction, fire prevention, fire reporting, and response to fire alarms. Based on the information provided by the applicant, the NRC staff concludes that the applicants response satisfies the acceptance criteria described in NUREG-1537, Part 2, Section 9.3 because the applicants general employee fire protection training program covers the appropriate topics.

In RAI 9-4(f), the NRC staff requested that the applicant discuss pre-fire planning and emergency planning considerations. In its response to the RAI, the applicant stated:

Pre-Fire Plans are developed for the main production facility to provide information for trained facility personnel and responding professional firefighters.

Pre-Fire Plans are designed to aid firefighting personnel in their response to fires through identification of hazards, process activities, access routes, and available firefighting equipment. Pre-Fire Plans provide the basis for development of firefighting strategies for responder training and incident command. Pre-Fire Plans contain the following information, as appropriate:

  • Area Identification
  • Fire Hazards
  • Radiation Hazards
  • Electrical Information (electrical disconnect)
  • Hazardous Substances
  • Physical Hazards
  • Communications
  • Access/Egress Routes
  • Fixed Fire Systems
  • Portable Firefighting Equipment
  • Safe Shutdown Guidance Off-site fire support is requested to respond to fires that progress beyond the incipient stage. SHINE has developed a memorandum of understanding (MOU) with the Rock County Sheriffs Office - Emergency Management Bureau, for 3

incident response at the SHINE facility. This MOU is designed to facilitate periodic training, fire and emergency incident command protocol, and to identify key SHINE Emergency Response contacts, in accordance with the SHINE Emergency Plan.

Based on the information provided by the applicant, the NRC staff concludes that the applicants response satisfies the acceptance criteria described in NUREG-1537, Part 2, Section 9.3 because the applicant demonstrated that it has developed adequate pre-fire plans and emergency planning considerations.

In RAI 9-4(g), the NRC staff requested that the applicant discuss manual firefighting capability.

In its response to the RAI, the applicant stated that manual firefighting is not credited for safe shutdown or the protection of safety-related equipment in the event of a fire. The applicant further stated that the SHINE facility does have portable fire extinguishers throughout the facility for use by SHINE personnel in the suppression of incipient-stage fires and that in the radiologically controlled area (RCA) there are Class I standpipes where firefighters responding to an emergency can get water for their hoses. The applicant further stated that exterior to the SHINE buildings, there are fire hydrants arranged around the fire water loop. Based on the information provided by the applicant, the NRC staff concludes that the applicants response satisfies the acceptance criteria described in NUREG-1537, Part 2, Section 9.3 because the applicant demonstrated that it has developed adequate manual fire-fighting capability to control or mitigate a fire.

In RAI 9-4(h), the NRC staff requested that the applicant discuss lighting and communications for operator actions. In its response to the RAI, the applicant stated that operator actions are not required to put the facility in a safe shutdown state in the case of a fire and that lighting, including emergency lighting, is provided to illuminate means of egress in accordance with the International Code Council, International Building Code (IBC), and National Fire Protection Association (NFPA) 101-2012, Life Safety Code. The applicant further stated that fire alarms throughout the facility will notify occupants of a detected fire and that alarm response is initiated by facility operators in accordance with site procedures. The applicant stated that additional communication systems in the facility include a public announcement system and sound-powered telephones for communication among operators in the facility. Based on the information provided by the applicant, the NRC staff concludes that the applicants response satisfies the acceptance criteria described in NUREG-1537, Part 2, Section 9.3 because the applicant demonstrated that operator actions are not needed to achieve safe shutdown in the event of fire and because emergency lighting is provided in accordance with applicable codes and standards.

In RAI 9-4(i), the NRC staff requested that the applicant discuss its fire protection corrective action program and compensatory measures. In its response to the RAI, the applicant stated that its corrective action program applies to the FPP and fire protection related operations; and that identified failures, malfunctions, deficiencies, deviations, defective components, uncontrolled combustibles, and non-conformances are promptly identified and corrected in accordance with the corrective action program. The applicant further stated that compensatory measures are used to provide an added level of safety for areas where fire protection systems or equipment are out of service or degraded and that compensatory measures, such as fire watches, are intended to be temporary measures and may not be permanently relied on for fire protection. Based on the information provided by the applicant, the NRC staff concludes that the applicants response satisfies the acceptance criteria described in NUREG-1537, Part 2, Section 9.3 because the applicant demonstrated that its corrective action program applies to its 4

FPP and fire protection related operations and that its fire protection compensatory measures program is intended to be temporary and not permanently relied on for fire protection.

In RAI 9-4(j), the NRC staff requested that the applicant discuss fire testing, qualification reports, and data for fire-rated systems, barriers, and assemblies. In its response to the RAI, the applicant stated:

Installations of fire protection equipment are inspected by qualified personnel to validate critical parameters and provide assurance of construction/installation with design requirements. Personnel, independent of the activity performed are assigned inspection duties to verify:

  • Installation, maintenance, or modification of fire protection features, systems, or equipment.

Acceptance procedures/instructions are documented in design control packages.

Periodic inspection/surveillance, preventive maintenance, and system testing is conducted in accordance with approved plant administrative and maintenance procedures. Plant inspection and surveillance schedules are documented to demonstrate required surveillance, testing, and preventive maintenance is conducted within appropriate timeframes. These inspection, surveillance, maintenance, and system testing activities will be performed and documented in accordance with the requirements of the IBC and NFPA 801, Standard for Facilities Handling Radioactive Materials.

Based on the information provided by the applicant, the NRC staff concludes that the applicants response satisfies the acceptance criteria described in NUREG-1537, Part 2, Section 9.3 because the applicant demonstrated that its acceptance, inspection, testing, and maintenance programs provide a reasonable level of assurance that adequate fire protection quality assurance is maintained for fire protection systems and features.

In RAI 9-4(k), the NRC staff requested that the applicant discuss fire protection features of the facilitys emergency diesel generator room and battery room. In its response to the RAI, the applicant stated that the uninterruptible power supply system (UPSS) battery rooms and equipment rooms are separated from the rest of the facility by walls with a fire resistance rating of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> and that these rooms are protected by an automatic clean-agent fire detection and suppression system. Based on the information provided by the applicant, the NRC staff concludes that the applicants response satisfies the acceptance criteria described in NUREG-1537, Part 2, Section 9.3 because the facility does not have an emergency diesel generator room and because the UPSS battery rooms and equipment rooms are provided with adequate fire barriers and fire protection systems.

In RAI 9-4(l), the NRC staff requested that the applicant confirm that SHINE will follow 10 CFR 50.59 as the change control process for making changes to its fire protection features and program. In its response to the RAI, the applicant stated that it will follow 10 CFR 50.59 as the change control process for making changes to its fire protection features and program. Based on the information provided by the applicant, the NRC staff concludes that the applicants 5

response satisfies the acceptance criteria described in NUREG-1537, Part 2, Section 9.3 because the applicant will follow an acceptable change process for making changes to its FPP.

In RAI 9-5(a), the NRC staff requested that the applicant describe the facility construction elements related to the FPP. In its response to the RAI, the applicant stated:

The SHINE facility consists of non-combustible construction, of IBC Type II-B.

Fire-rated barriers separate the individual fire areas within the SHINE facility. Fire barriers in the SHINE facility have fire resistance ratings of 1, 2, or 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />. The fire resistance rating is determined by the Fire Hazards Analysis (FHA), and considers regulatory requirements (e.g., IBC fire barrier requirements) as well as assessments of fire area contents, means of egress considerations, and equipment separation considerations. The RCA is separated from the non-RCA portion of the building by a 3-hour-rated fire barrier. Exit stairways are protected by 2-hour-rated fire barriers. Fire barrier design and construction is in accordance with the IBC and NFPA 801.

Where fire-rated barriers are penetrated by pipes, ducts, conduits, raceways or other such penetrations, fire barrier penetration material is placed in and around the penetrations to maintain the fire-resistance rating of the barrier.

Fire doors and dampers are rated commensurate with the fire barrier in which they are installed and comply with the requirements of NFPA 80, Standard for Fire Doors and Other Opening Protectives and NFPA 90A, Standard for the Installation of Air-Conditioning and Ventilating Systems.

Based on the information provided by the applicant, the NRC staff concludes that the applicants response satisfies the acceptance criteria described in NUREG-1537, Part 2, Section 9.3 because the applicant described the facility construction elements related to the FPP and demonstrated that these elements were designed in accordance with applicable codes and standards.

In RAI 9-5(b), the NRC staff requested that the applicant discuss facility life safety features related to the FPP. In its response to the RAI, the applicant stated:

The SHINE facility life safety features are designed in accordance with NFPA 101, Life Safety Code and the IBC.

Automatic fire detectors are installed where required. In addition, manual pull stations are installed to allow personnel to activate the fire alarm system. Upon actuation of the fire alarm system, audible and visual indicating devices will provide notification to personnel to evacuate the building.

Emergency exits are available from all areas of the facility within the IBC allowed maximum travel distance of 200 feet. Common path of travel does not exceed the allowed maximum of 100 feet per the IBC. Dead-end corridors do not exceed the allowed maximum of 50 feet per the IBC.

The illumination of means of egress is provided in accordance with the life safety code and IBC.

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Based on the information provided by the applicant, the NRC staff concludes that the applicants response satisfies the acceptance criteria described in NUREG-1537, Part 2, Section 9.3 because the applicant described the facility life safety features related to the FPP and demonstrated that these features were designed in accordance with applicable codes and standards.

In RAI 9-5(c), the NRC staff requested that the applicant describe facility fire protection water supply systems. In its response to the RAI, the applicant stated:

The fire water distribution subsystem provides firefighting water to the main production facility and those outbuildings requiring fire water service. The system draws water from the municipal water supply and directly supplies water to the building sprinkler systems, and fire hydrants. The municipal water supply provides suction for two 100 percent capacity fire pumps that supply water to a fire water distribution loop and water-based fire suppression systems installed in the facility, including the fire hose standpipes in the RCA and automatic fire sprinklers in the administrative areas. Multiple hydrants are arranged around the main production facility, and fire water supply is sufficient to supply the greatest single suppression system demand plus a 500 gallons per minute (gpm) hose stream allowance for a period of 1-1/2 hours.

The fire water distribution supply loop is designed such that individual legs of the loop may be isolated for system maintenance or testing without interruption of supply to unaffected portions of the system. Fire hydrants are provided around the facility structures.

Based on the information provided by the applicant, the NRC staff concludes that the applicants response satisfies the acceptance criteria described in NUREG-1537, Part 2, Section 9.3 because the applicant described the facility fire protection water supply system and demonstrated that the system was designed to meet the fire protection design demands.

In RAI 9-5(d), the NRC staff requested that the applicant discuss fire protection active and passive fire suppression systems. In its response to the RAI, the applicant stated:

The main production facility contains a water-based, wet-pipe fire sprinkler subsystem, a standpipe subsystem, and a gaseous suppression subsystem.

Automatic water-based, wet-pipe fire sprinkler systems are designed to provide Fire suppression in several general/administrative areas of the facility. The system piping contains water provided by the fire water distribution subsystem at the static system pressure for the water distribution system. These systems maintain fire suppression water available at each sprinkler, with water spray provided immediately upon activation of a sprinkler.

The standpipe system is provided to facilitate manual firefighting capability in the RCA by responding professional firefighters. A Class I standpipe system is installed to provide 2-1/2 inch (in.) (65 millimeter [mm]) hose line connections for fire use by fire department personnel. This system allows distribution of firefighting water to the interior of the RCA from the fire water distribution subsystem. Manual dry standpipes are arranged to allow admission of 7

firefighting water to be piped into the RCA, as necessary, to support manual firefighting in these areas.

Gaseous suppression systems are used for fire hazards where a clean agent or inert gas is needed to protect sensitive electronic equipment or in areas where nuclear criticality or other hazards preclude the use of water for fire suppression.

These areas include the URSS and TSPS rooms, the Supercell, the radioactive liquid waste immobilization (RLWI) enclosure, the facility control room, the uninterruptible power supply equipment and battery rooms, and certain small rooms containing electrical and information technology (IT) equipment. These systems discharge a gaseous fire suppression agent from pressurized storage tanks into the protected volume/room achieving a predetermined concentration of agent required to accomplish fire suppression. The system can be activated by a signal from the area fire detection and alarm system and/or manually. Local pre discharge alarm and delay allow personnel evacuation before the suppression system actuates.

Based on the information provided by the applicant, the NRC staff concludes that the applicants response satisfies the acceptance criteria described in NUREG-1537, Part 2, Section 9.3 because the applicant described its active and passive fire suppression systems and demonstrated that they provide reasonable assurance to detect and control a fire and minimize radiological contamination in areas where fissile material is handled.

In RAI 9-5(e), the NRC staff requested that the applicant discuss facility fire detection and alarm/signaling systems. In its response to the RAI, the applicant stated:

The main production facility fire detection and alarm subsystems are designed to detect and provide early warning/notification of fire. These systems detect fire through the placement of signal initiating devices (e.g., smoke/heat detectors, manual pull boxes, supervisory switches) throughout the protected portions of the facility. Detection devices communicate via a communications loop and local fire alarm panels with the master fire alarm panel located in the facility control room.

Alarm, supervisory, and trouble signals are received at the facility control room and alarms are annunciated within the protected space for occupant notification.

Alarm response is initiated by facility operators in accordance with site emergency or standard operating procedures.

Based on the information provided by the applicant, the NRC staff concludes that the applicants response satisfies the acceptance criteria described in NUREG-1537, Part 2, Section 9.3 because the applicant described its facility fire detection and alarm/signaling systems and demonstrated that they provide reasonable assurance to detect and provide notification of a fire.

In RAI 9-5(f), the NRC staff requested that the applicant discuss the codes of record for the facility lightning protection system, including justification for the choice of code and any deviations. In its response, the applicant stated that the facility grounding and lightning protection system adheres to the requirements of NFPA 780-2014, Standard for the Installation of Lightning Protection Systems, without deviation and that adherence to NFPA 780-2014 is consistent with the guidance provided in Section 5.12 of NFPA 801. Based on the information provided by the applicant, the NRC staff concludes that the applicants response satisfies the acceptance criteria described in NUREG-1537, Part 2, Section 9.3 because the applicant 8

demonstrated that its lightning protection system is designed in accordance with applicable codes and standards.

In RAI 9-6, the NRC staff requested that the applicant:

a. Summarize the safe shutdown performance goals and the safe shutdown analysis methodology.
b. Identify the functions required for safe shutdown. Such functions may include inventory control, process monitoring, and reactivity control. Include any auxiliary equipment or cables required to support a safe shutdown function (e.g., room cooling).
c. Identify any required safe shutdown function that has only a single train and justify how such a configuration can ensure safe shutdown in the event of a fire.
d. Describe the separation criteria for redundant trains of a safe shutdown function located in the same fire area.
e. Describe and justify any deviations from the separation criteria described in item (d).
f. Identify the fire area(s) that contain equipment or cables from all trains of a required safe shutdown function. If such area(s) exist, describe how safe shutdown is ensured for a fire occurring in that fire area(s).
g. Identify any fire areas where fire damage could prevent safe shutdown. If such areas exist, justify how safe shutdown is ensured for a fire occurring in those fire areas.
h. Identify the entry conditions for the facility fire safe shutdown procedure.
i. Identify the guidance used to perform any safe shutdown-related circuit analysis.

In its response to the RAI, the applicant provided additional details regarding its fire SSA.

The applicant identified the following safe shutdown criteria and goals in the event of a fire:

Safe Shutdown Criteria Safe Shutdown Goal Reactivity control maintain the target solution subcritical Combustible gas control maintain the functionality of the combustible gas control system Target solution cooling maintain the target solution cooling system to prevent boiling Radioactive material barriers prevent the uncontrolled release of radiation The applicant also identified the following safe shutdown functions that support the identified safe shutdown criteria:

Reactivity control 9

The applicant identified that reactivity control is achieved using the IU Cell Safety Actuation system, which is initiated by the TSV reactivity protection system (TRPS). This involves the opening of the TSV dump valves and the closing of the TSV fill valves.

Combustible gas control The applicant identified that combustible gas control is achieved using the active function of TOGS and nitrogen purge via the nitrogen purge system (N2PS), initiated by TRPS and ESFAS.

SHINE further stated that to maintain hydrogen concentrations at acceptable levels TOGS must be powered for 5 minutes after an IU Cell Safety Actuation. The UPSS is the safety-related source of this power.

Target solution cooling The applicant identified that target solution cooling is achieved using natural convection cooling of the TSV dump tank through the dump tank wall via the passive light water pool system.

Radioactive material barriers The applicant identified that the uncontrolled release of radioactive material to the environment is prevented by the IU Cell Safety Actuation initiated by TRPS and RCA Isolation initiated by ESFAS. These actuations move appropriate valves, ventilation dampers, and circuit breakers to their safe positions.

The applicant stated that none of these safe shutdown functions rely on a single train of equipment.

The applicant described its safe shutdown strategy in its response to RAI 9-6. Based on this description, the NRC staff identified the following key aspects of SHINEs safe shutdown strategy:

  • Reliance on redundant or fail-safe components to perform safe shutdown functions;
  • Automatic fire suppression and fire detection systems;
  • Spatial separation of redundant cables and equipment by at least 20 feet where automatic fire suppression is provided and at least 40 feet where automatic fire suppression is not provided;
  • Where separation cannot be provided, the use of fire modeling analysis to determine whether both trains of components can be damaged by a single fire;
  • Cables in conduit embedded in structural concrete;
  • Consideration of levels of fire area occupancy (continuous/restricted/none);

and

  • Administrative controls The applicant stated that there are no fire areas where the separation criteria could not be met.

For fire areas that contain only a single train of safe shutdown components for a safe shutdown function, the opposite train is available to achieve the safe shutdown function.

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The applicant identified seven areas that contain more than one train of safe shutdown components for at least one safe shutdown function.

Fire Area 1 - RPF General Area The applicant stated that based on the separation of Divisions A and B cables, the Division A cables being mostly embedded in concrete, and the limited combustible loading in the area, a single fire would not damage both redundant trains. The applicant further stated that this conclusion was supported by modeling results for hot gas layer temperatures for potential fire scenarios and that each redundant component in this area moves to the safe position on loss of power and has a redundant component in the opposite train that can fulfil the function in the case the first is spuriously powered.

Fire Area 2 - IU and TOGS Cells (8 cells each)

The applicant stated that the physical and fire protection features of this area (limited oxygen supply due to the sealed nature of each cell, limited combustible load, and early warning fire detection capabilities in each cell exhaust duct) would prevent a single fire from damaging components in redundant TOGS trains. Regarding the other (non-TOGS) redundant safe shutdown components, the applicant stated that they each move to the safe position on loss of power and each has a redundant component in the opposite train that can fulfil the function in the case the first is spuriously powered.

Fire Area 2 - Irradiation Facility General Area Mezzanine The applicant stated that the fire protection features of this area (limited combustible load, very early smoke detection, manual fire suppression capability, and transient combustible controls) would keep a single fire from damaging components in redundant trains. The applicant further stated that each redundant component in this area moves to the safe position on loss of power and has a redundant component in the opposite train that can fulfil the function in the case the first is spuriously powered.

Fire Area 2 - Tritium Purification System (TPS) Room The applicant stated that the fire protection features of this area (limited combustible load, very early smoke detection, manual fire suppression capability, and transient combustible controls) would keep a single fire from damaging components in redundant trains. The applicant further stated that each redundant component in this area moves to the safe position on loss of power and has a redundant component in the opposite train that can fulfil the function in the case the first is spuriously powered.

Fire Area 2 - TOGS Motor Control Center (MCC) Hallway The applicant stated that fire modeling demonstrates that both trains of TOGS MCC cannot be damaged by a single fire and that all train A TOGS cables are imbedded in concrete.

Fire Area 15 - Facility Control Room The applicant stated that based on the spatial separation of redundant systems (UPSS, ESFAS, and TRPS panels), continuous occupancy leading to prompt fire detection and suppression, and 11

the installed automatic clean agent suppression system, a single fire would not damage both trains of a redundant safe shutdown function.

Fire Area 19 - Ship/Receive Alcove The applicant stated that this area has transient and combustible controls in place and installed smoke detection and that each redundant component in this area moves to the safe position on loss of power and has a redundant component in the opposite train that can fulfil the function in the case the first is spuriously powered.

Safe Shutdown Procedure Entry The applicant stated that procedures and training will direct operators to manually actuate (if not already automatically actuated) the TRPS and ESFAS systems under any of several conditions, including a fire that cannot be controlled or requires offsite assistance, deteriorating control room habitability, or at the discretion of the operator in the event of loss of control of the facility, power loss, erratic indication, or evidence of spurious operation.

Based on the information provided by the applicant, the NRC staff concludes that the applicants response to RAI 9-6 satisfies the acceptance criteria described in NUREG-1537, Part 2, Section 9.3 because the applicant appropriately addressed safe shutdown of the facility by establishing safe shutdown criteria and goals, identifying safe shutdown functions and equipment, developing a safe shutdown strategy, evaluating fire areas containing redundant components of safe shutdown functions, and identifying safe shutdown procedure entry conditions.

In RAI 9-7(a), the NRC staff requested that the applicant discuss fire protection systems design criteria. In its response to the RAI, the applicant stated:

a. Design criteria for the facility fire protection systems include:
  • Fire water loop system flow requirement: 1,500 gpm at 100 pounds per square inch (psi)
  • Manual dry standpipes are located such that they will provide 100 percent coverage of the RCA assuming a 100-foot (ft.) (30.5 meter [m]) hose and 30-ft. (9.1 m) hose stream.
  • Minimum Density for Automatic-Sprinkler Piping Design:

o Light-Hazard Occupancy: 0.10 gpm over 1500 square foot (sq. ft.)

area.

o Ordinary-Hazard, Group 1 Occupancy: 0.15 gpm over 1500-sq. ft.

area.

In addition:

  • The fire detection and alarm systems are designed, installed, tested, and maintained in accordance with NFPA 72, National Fire Alarm and Signaling Code.
  • The automatic wet-pipe fire sprinkler system is designed, installed, tested and maintained in accordance with NFPA 13, Standard for the Installation of Sprinkler Systems.
  • The standpipe system is designed, installed, tested, and maintained in accordance with NFPA 14, Standard for the Installation of Standpipe and Hose Systems.

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  • The automatic gas-based fire suppression systems are designed, installed, tested, and maintained in accordance with NFPA 2001, Standard on Clean Agent Fire Extinguishing Systems.

Based on the information provided by the applicant, the NRC staff concludes that the applicants response satisfies the acceptance criteria described in NUREG-1537, Part 2, Section 9.3 because the applicant described its fire protection systems design criteria, which is in accordance with applicable codes and standards.

In RAI 9-7(b), the NRC staff requested that the applicant discuss control of ignition sources. In its response to the RAI the applicant stated:

Administrative controls are established to manage hot work (i.e., welding, cutting, grinding, and open flames) in facility areas that are not designated for such operations. These controls are developed in accordance with NFPA 51B, Standard for Fire Prevention During Welding, Cutting, and Other Hot Work.

The procedure for hot work is designed to ensure hot work is adequately controlled to mitigate the potential for ignition of combustibles and to provide immediate response if a fire does occur.

Locations designated for the performance of hot work are designated as permanent hot work locations in accordance with the ignition control procedures.

Hot work performed outside of designated locations is conducted under permit and in accordance with the ignition control procedures.

Based on the information provided by the applicant, the NRC staff concludes that the applicants response satisfies the acceptance criteria described in NUREG-1537, Part 2, Section 9.3 because the applicant described its control of ignition sources program and demonstrated that it is in accordance with applicable codes and standards.

In RAI 9-7(c), the NRC staff requested that the applicant discuss fire prevention methods intended to control handling, use, and disposal of combustible materials. In its response to the RAI, the applicant stated:

Combustible loading of fire areas and fire zones that contain safety-related equipment are carefully managed to maintain combustible loading as low as reasonable without impeding normal facility operations. In accordance with SHINE Design Criterion 3, noncombustible and heat resistant materials are used wherever practical throughout the facility and particularly in locations containing safety-related equipment.

Combustible loading control is managed in accordance with FHA-assigned fire load limits. Combustible loading for each area containing safety-related equipment is tracked in the combustible loading calculation. This calculation is used to determine the baseline (in-situ) combustible loading for each affected fire area or zone. The difference in the baseline loading and the maximum allowable loading for the fire loading category assigned in the FHA identifies the maximum available transient combustible loading for the area under consideration.

The combustible control procedure identifies requirements and restrictions for the use, handling, storage, and disposal of combustible materials, including:

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  • Spacing and separation requirements for transient combustible storage;
  • Housekeeping requirements, including disposal requirements for combustible wastes (supplementing the housekeeping procedure);
  • Requirements for the use, handling, and storage of lumber and plastic;
  • Requirements for the use, handling, and storage of combustible and flammable liquids and gases; and
  • Requirements for the use of transient combustible permits.

The combustible control procedure requires an engineering evaluation to be performed when a variance from procedure requirements is needed, or work activities require significant amounts of flammable or combustible liquids outside of approved storage rooms or storage cabinets.

Based on the information provided by the applicant, the NRC staff concludes that the applicants response satisfies the acceptance criteria described in NUREG-1537, Part 2, Section 9.3 because the applicant described adequate fire prevention methods intended to control handling, use, and disposal of combustible materials.

In RAI 9-7(d), the NRC staff requested that the applicant discuss fire protection procedures, instructions, and design drawings. In its response to the RAI, the applicant stated:

The FPP elements are controlled by administrative, engineering, maintenance, and operations procedures. The topics of these procedures include:

  • Ignition control;
  • Control of combustibles;
  • Housekeeping;
  • Surveillance, inspection, maintenance, and testing of fire protection systems;
  • Compensatory measures for out of service or degraded fire protection systems;
  • Fire watches; and

General area drawings are prepared to depict important fire protection information. These fire protection drawings document general arrangement of fire areas, fire zones, fire barriers and ratings, extinguishers, fire suppression system coverage, fire detection system coverage, hose connections, fire doors, fire dampers, fire hydrants, and other key fire protection equipment. In addition to general area drawings, information on individual fire protection systems and components is depicted on detailed drawings (e.g., component drawings, piping and instrumentation diagrams [P&IDs]).

Based on the information provided by the applicant, the NRC staff concludes that the applicants response satisfies the acceptance criteria described in NUREG-1537, Part 2, Section 9.3 because the applicant described adequate fire protection procedures, instructions, and design drawings.

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In RAI 9-7(e), the NRC staff requested that the applicant discuss manual fire suppression actions. In its response to the RAI, the applicant stated that incipient stage fire suppression is provided by trained SHINE personnel using fire extinguishers and that for fires beyond the incipient stage, firefighting by professional firefighters is managed via pre-fire planning and interface with on-shift operations personnel. Based on the information provided by the applicant, the NRC staff concludes that the applicants response satisfies the acceptance criteria described in NUREG-1537, Part 2, Section 9.3 because the applicant demonstrated appropriate manual fire suppression actions.

In RAI 9-8(a), the NRC staff requested that the applicant provide a list of the building and fire codes and standards that it considered in the design of the facility as related to the development of the FPP and implementing procedures, including identification of the edition (year). For codes and standards where more than one edition is used, the NRC staff requested that the applicant identify which edition pertains to which areas of the facility. In its response to the RAI, the applicant stated:

SHINE applies the following building and fire codes and standards in the design of the SHINE facility, as related to the development of the FPP and implementing procedures:

  • [IBC], 2015 Edition, and codes listed therein, as amended by the Wisconsin Administrative Code
  • International Fire Code (IFC), 2015 Edition, as amended by the Wisconsin Administrative Code
  • NFPA 1, Fire Code, 2012 Edition, as amended by Wisconsin Administrative Code
  • NFPA 801, Standard for Fire Protection for Facilities Handling Radioactive Materials, 2014 Edition, and codes listed therein There are no instances where SHINE applies more than one edition of a code or standard to the design of the SHINE facility, as related to the development of the FPP and implementing procedures.

Based on the information provided by the applicant, the NRC staff concludes that the applicants response satisfies the acceptance criteria described in NUREG-1537, Part 2, Section 9.3 because the applicant identified the building and fire codes and standards that it considered in the design of the facility and also identified other applicable codes of record in its FHA.

In RAI 9-8(b), the NRC staff requested that the applicant identify and justify any deviations from the codes and standards for the design and installation of fire protection systems identified in RAI 9-8(a). In its response to the RAI, the applicant identified the following deviation and provided the following justification:

Deviation: Section 903.2.4 of the IBC requires an automatic sprinkler system for group F-1 occupancies; however, the SHINE facility does not provide an automatic sprinkler system in the RCA.

Justification: SHINE will not install an automatic sprinkler system in the RCA because the release of water into the RCA could cause a nuclear criticality hazard or lead to the spread of radioactive contamination. Section 903.3.1.1.1 of 15

the IBC provides exemption from the automatic sprinkler system requirements for certain rooms or areas protected by an approved automatic fire detection system where, in part, application of water, or flame and water, constitutes a serious life or fire hazard. SHINE will seek approval of the exempted condition for the RCA as part of the fire protection plan review for the SHINE facility by the Wisconsin Department of Safety and Professional Services.

Based on the information provided by the applicant, the NRC staff concludes that the applicants response satisfies the acceptance criteria described in NUREG-1537, Part 2, Section 9.3 because the applicant justified the code deviation by demonstrating that the use of water in the RCA has the potential to create a nuclear criticality hazard and spread radioactive contamination.

In RAI 9-9, the NRC staff requested that the applicant:

a. Discuss means of egress for fire areas and zones and means of egress protection.
b. Describe the types of combustibles found in each fire area.
c. Describe combustible loading in fire areas and zones.
d. Discuss fire hazards and ignition sources that were considered for facility fire areas.
e. Describe the types of fire-resistant coatings and electric raceway fire barriers systems used for the protection of electrical cables and structural steel.
f. Identify the fire modeling tools or methods used in the development of the fire hazard analysis including how these tools or methods were applied. Describe the process to validate and verify the fire models, including any calculational and numerical methods used, used in support of fire hazard analysis. Discuss how the fire modeling uncertainties were accounted in the fire modeling calculations.
g. Describe how the installed cabling in the fire areas was characterized. Specifically, describe the critical damage threshold temperatures and heat fluxes for thermoset and thermoplastic cables consistent with the use of these cables in the facility. Include an explanation of how exposed temperature-sensitive equipment was treated in the fire modeling and justify the damage criteria that was used for such equipment.

Alternatively, justify why this information is not necessary.

In its response to the RAI, the applicant:

a. Discussed means of egress for fire areas and zones and means of egress protection;
b. Described the types of combustibles found in each fire area;
c. Described combustible loading in fire areas and zones;
d. Discussed fire hazards and ignition sources that were considered for facility fire areas; 16
e. Described the types of fire-resistant coatings and electric raceway fire barriers systems used for the protection of electrical cables and structural steel;
f. Identified the fire modeling tools or methods used in the development of the FHA including how these tools or methods were applied, discussed the process to validate and verify the fire models used in support of the FHA, and discussed how the fire modeling uncertainties were accounted for in the fire modeling calculations; and
g. Described how the installed cabling in the fire areas was characterized including specifically describing the critical damage threshold temperatures and heat fluxes for thermoset and thermoplastic cables consistent with the use of these cables in the facility and included an explanation of how exposed temperature-sensitive equipment was treated in the fire modeling and justified the damage criteria that was used for such equipment.

Based on the information provided by the applicant, the NRC staff concludes that the applicants response satisfies the acceptance criteria described in NUREG-1537, Part 2, Section 9.3 because the applicant adequately responded to each question and demonstrated that its answers were in accordance with applicable codes and standards and standards of good practice for fire protection.

In RAI 9-10, the NRC staff requested that the applicant describe that:

  • The plans for preventing fires ensure that the facility meets local and national fire and building codes;
  • The systems designed to detect and combat fires at the facility can function as described and limit damage and consequences at any time;
  • The potential for radiological consequences of a fire will not prevent safe shutdown, and any fire-related release of radioactive material from the facility to the unrestricted environment has been adequately addressed in the appropriate sections of the facility emergency plan; and
  • Any release of radioactive material as a result of fire would not cause radiation exposures that exceeded the requirements of 10 CFR Part 20.

In its response to the RAI, the applicant stated:

Accident scenarios related to fire and internal flooding due to fire water are described in Subsections 13a2.1.11 and 13a2.2.11 of the FSAR. These scenarios are prevented or mitigated to an acceptable level of risk, in accordance with the SHINE Safety Criteria, including the limit on the total effective dose equivalent to an individual member of the public not exceeding 1 rem over the duration of the event.

A description of the internal flooding event is provided in Section 3.3 of the FSAR. Liquid firefighting related effluents are prevented from exiting the RCA through the use of 2-inch berms or ramps at each exit from the RCA.

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The radiological ventilation (RV) systems include isolation dampers that close on radiation detection through the engineered safety features actuation system (ESFAS) and target solution vessel (TSV) reactivity protection system (TRPS). If the gaseous firefighting related effluents contain radiological materials, these systems automatically initiate an RCA Isolation, Supercell Area Isolation, Tritium Purification System (TPS) Process Vent Actuation, TPS Train Isolation, or Irradiation Unit (IU) Cell Actuation depending on the impacted region of the facility. These isolations provide confinement of gaseous effluents, including contaminated smoke, for as long as postulated accident conditions require. In this way, gaseous firefighting effluents, including smoke, that contain radiological materials are contained within facility boundaries and prevent accident consequences from exceeding the SHINE Safety Criteria.

The RV systems also contain smoke detectors downstream of the air filters and ahead of any branch connections in air supply systems, per NFPA 90A, Standard for the Installation of Air-Conditioning and Ventilating Systems. These smoke detectors automatically stop their respective fan(s) on detecting the presence of smoke.

Based on the information provided by the applicant, the NRC staff concludes that the applicants response satisfies the acceptance criteria described in NUREG-1537, Part 2, Section 9.3 because the applicant adequately responded to each question and demonstrated that its answers were in accordance with applicable codes and standards and standards of good practice for fire protection.

In its response to RAI 9-10, the applicant also described how contaminated gaseous and liquid fire-fighting effluents will be contained within the facility. The applicant described the automatic isolation feature of the radiological ventilation system, which will provide the containment of contaminated gaseous effluents to within the RCA. The applicant further stated that the ramps and berms will confine any fire-fighting water to within the RCA, and that because contaminated effluents are confined within the RCA, the public radiological exposure will be bounded by the DBA fire scenarios.

Based on the information provided by the applicant, the NRC staff concludes that the applicants response satisfies the acceptance criteria described in NUREG-1537, Part 2, Section 9.3 because the applicant demonstrated that it has a program in place to contain contaminated gaseous and liquid fire-fighting effluents.

Based on the information contained in the SHINE FSAR and RAI responses, the NRC staff finds that there is reasonable assurance that a release of radioactive material as a result of fire will not cause radiation exposures that exceed the requirements of 10 CFR Part 20.

Conclusion The NRC staff reviewed the fire protection portion of the applicants operating license application; the procedures for maintaining an acceptable level of fire protection; and the design basis of fire protection systems and their components including the safety function, system descriptions, safety assessments, and other related information that the applicant provided to demonstrate that it is prepared to prevent and/or control/extinguish fires. The NRC staffs review also encompassed design basis considerations, such as redundancy, independence, reliability, and quality. The NRC staff used Section 9.3 of NUREG-1537, Parts 1 and 2, as 18

guidance in performing the review and various nationally recognized codes and standards, as appropriate, in evaluating the reasonable assurance of facility fire protection.

The NRC staff reviewed the applicants design basis for fire protection, its SSA, its FHA, and fire-related administrative control procedures as described in the operating license application.

The NRC staff concludes that fire protection-related SSCs and DID controls are designed, constructed, and used consistent with good engineering practice, which dictates that certain minimum requirements be applied as design and safety considerations for any new nuclear material process or facility. Based on its evaluation, the NRC staff concludes that there is reasonable assurance that the applicants fire protection systems and programs are in conformance with the guidelines of NUREG-1537, Parts 1 and 2, and that there is reasonable assurance that the facility meets the requirements of 10 CFR 50.48(a) and Criterion 3 of Appendix A to 10 CFR Part 50 with respect to fire protection. In addition, the NRC staff concludes that there is reasonable assurance that a fire in any plant area during any operational mode and plant configuration will not prevent the plant from achieving safe shutdown and maintaining a safe and stable condition, and will also not cause radiation exposures that exceed the requirements of 10 CFR Part 20.

Based on the above, the Commission has concluded that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner; (2) there is reasonable assurance that such activities will be conducted in compliance with the Commissions regulations; and (3) the issuance of the operating license will not be inimical to the common defense and security or to the health and safety of the public.

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