NRC Generic Letter 1980-10

NRC Generic Letter 1980-100: Appendix R to 10 CFR Regarding Fire Protection - Federal Register Notice

ML070220242
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	11/24/1980
From:	Eisenhut D Office of Nuclear Reactor Regulation
To:
References
45FR76602, GL-80-100 NUDOCS 8101100061
Download: ML070220242 (20)

-INTL STATES

NUCLEAR REGULATORY COMMISSION

• '.- . WASHINGTON. D. C. 20555

0. November 24, 1980 7A

- r-*

Docket No. 50-344 F71 Plant Name: Trojan Nuclear Plant TO ALL POWER REACTOR LICENSEES WITH PLANTS -

LICENSED PRIOR TO JANUARY 1, 1979 U -

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

The provisions of Appendix R that are applicable to the fire protection features of your facility can be divided into two categories. The first category consists of those provisions of the Appendix that are required to be backfit in their entirety by the new rule, regardless of whether or not alternatives to the specific requirements of these Sections have been previously approved by the NRC staff. These requirements are set forth in Sections III.G, Fire Protection of Safe Shutdown Capability; III-J,

Emergency Lighting; and 111-0, Oil Collection Systems for Reactor Coolant Pump. The fire protection features of your-facility must satisfy the specific requirements of these three Sections by the dates established by Paragraph 50.48(c), unless an exemption from the Appendix R requirements is approved by the Commission. You should note the provisions for tolling the time for completing the modifications required by these three Sections of Appendix R set forth in Paragraph 50.48(c)(6).

The second category of Appendix R provisions applicable to the fire protection features of your facility consists of requirements concerning the "open" items of previous NRC staff fire protection reviews of your facility. An open item is defined as a fire protection feature that has not been previously approved by the NRC staff as satisfying the provisions of Appendix A to Branch Technical Position BTP PCSB 9.5-1, as reflected in a staff fire protection safety evaluation report. The fire protection features of your facility that are in this category must satisfy the specific requirements of Appendix R by the dates established by Paragraph 50.48(c), unless an exemp- tion from the Appendix R requirements on those features is approved by the Commi ssion.

Enclosure 2 is a summary listing of the open items concerning the fire protection features of your facility based on a review of our records. Also included is our position on the specific requirements that must be satisfied in order to resolve these open items. If you have any questions or disagree- ments with this enclosure, please advise us within 30 days of your receipt of this letter.

F

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

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

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

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

50.48(d).

All requests for Conmnission action resulting from this rule are subject to the schedule of fees specified in 10 CFR 170.21. If you have any questions concerning the subject matters of this letter, please contact the NRC Project Manager for your facility.

Sincerely, Darrell G. Eisenhut, Director Division of Licensing Office of Nuclear Reactor Regulation Enclosures:

1. Notice - Fire Protection Rule

2. Summary of Staff Require- ments to Resolve Open Items cc w/enclosures:

See next page

Portland General Electric Company cc: Mr. J. W. Durham, Esquire Donald W. Godard, Supervisor Vice President and Corporate Counsel Siting and Regulation Portland General Electric Conpany Oregon Department of Energy

121 S.W. Salmon Street Labor and Industries Building Portland, Oregon 97204 Room 111 Salem, Oregon 97310

Columbia County Courthouse Law Library, Circuit Court Room

'St. Helens, Oregon 97501 Michael Malmros, Resident Inspector U. S. Nuclear Regulatory Commission Trojan Nuclear Plant P. O. Box 0

Rainier, Oregon 97048 Robert M. Hunt, Chairman Board of County Commissioners Columbia County St. Helens, Oregon 97051 Director, Criteria and Standards Division Office of Radiation Programs (ANR-460)

U.S. Environmental Protection Agency Washington, D.C. 20460

Enclosure 1 Wednesday November 19, 1980

Part II

Nuclear Regulatory Commission Fire Protection Program for Operating Nuclear Power Plants.

76b1 Federal Register / Vol. 45, No. 225 / Wednesday, November 19, 1980 / Rules and Regulations NUCLEAR REGULATORY that the comment period should have ar*. already se- forth in General Design COMMISSION been extended. Criterion 3 of Appendix A to 10 CFR

The Commission does not agree. The Part 50 and in the NRC guidance

10 CFR Part 50 NRC has been developing fire protection documents. These general provisions requirements since 1975. The NRC gave rise to a number of disputes over Fire Protection Program for Operating published comprehensive fire protection whether specific methods adequately Nuclear Power Plants guidelines, Branch Technical Position accomplished the intended goal. The AGENCY: Nuclear Regulatory BTP APCSB 9.5-1, and its Appendix A in pr)posed rule is intended to provide Commission. 1976. Licensees have compared their fire sufficient specific guidance to ensure protection programs against these satisfactory resolution of these issues.

ACTION: Final rule. Tl-us, reverting to generalized guidance guidelines and have discussed their SUMMARY: The Nuclear Regulatory deviations from these guidelines with would not accomplish the intended Commission is amending its regulations the NRC staff for the past four years purpose of the proposed rule.

to require certain provisions for fire " during the NRC's fire protection reviews The second issue involved some protection in operating nuclear power of operating .ctors. A Safety instances in which the specific wording plants. This action is being taken to Evaluation Rep :t and, in most cases, used resulted in unnecessary and upgrade fire protection at nuclear power supplements to the Safety Evaluation unintended restrictions. For example, plants licensed to operate prior to Report, have been issued for each the proposed rule called for a "fresh January 1, 1979, by requiring resolution operating reactor. These reports water" supply. For firefighting purposes, of certain contested generic issues in describe fire protection alternatives that brackish water is satisfactory and a fire protection safety evaluation reports. have been proposed by the licensee and "fresh" water supply is unnecessary.

EFFECTIVE DATE- February 19, 1981. found acceptable by the staff as well as Similarly, the proposed rule called for Note.-The Nuclear Regulatory unresolved fire protection issues an "underground" yard fire main loop.

Commission has submitted this rule to remaining between the staff and the Often portions of a fire main loop run the Comptroller General for review as licensee. Proposed Appendix R provided above ground in and as they enter may hp qrnnrnrintpiindepr thp Pp.rl;ral the Commission's requirements for structures. The Commission had not Reports Act, as amended (44 U.S.C. resolving those issues. Thus, it concerns intended to prohibit running portions of

3512). The date on which the reporting only a limited number of issues derived a fire main loop above ground. Other requirement of this rule becomes from the use of the earlier guides. The similar changes are discussed in Section effective, unless advised to the contrary, Commission believes that a 30-day II. "Specific Requirements," of this reflects inclusion of the 45-day period comment period was adequate under preamble.

that statute allows for such review (44 these circumstances. The third issue relates to imposition of U.S.C. 3512(c)(2)). 2. Many licensees questioned the need requirements on plants with presently for backfitting all the requirements of installed or with existing commitments FOR FURTHER INFORMATION

CONTACT

to install fire protection features David P. Notley, Office, of Standards Appendix R. They commented that they had previously complied with staff fire previously determined by the staff to Development, U.S. Nuclear Regulatory satisfy the guidance of Appendix A to Commission, Washington, D.C. 20555, protection recommendations in "good BTP APCSB 9.5-1. The Commission phone 301-443-5921 or Robert L. faith" and have committed to or generally agrees that, except for three Ferguson. Office of Nuclear Reactor completed certain modifications. They sections that will be back fitted, Regulation, U.S. Nuclear Regulatory contend that the staff has properly Appendix R should not be retroactively Commission, Washington, D.C. 20555,

• determined that these modifications applied to features that have been phone 301-492-7096. provide at least the level of fire previously approved by the NRC staff as SUPPLEMENTARY INFORMATION: On May protection described by the guidance satisfying the provisions of Appendix A

29, 1980, the Nuclear Regulatory. *contained in Appendix A to Branch to BTP APCSB 9.5-1.

Commission' plublished in the Federal. Technical Position BTP APCSB 9.5-1. The NRC staff had intended, in its Register (45 FR 36082) a notice of They also contend that these original proposal for Appendix R, that proposed rulemaking inviting written modifications provide a level of the requirements be applicable only for suggestions or comments on the protection at least equivalent to that the resolution of unresolved disputed proposed rule by June 30,1980. The contained in the proposed rule. They fire protection features. Thus, the staff notice concerned proposed amendments express the concern that the proposed had not intended the provisions of to 10 CFR Part 50, "Domestic Licensing .rule was written in such specific Appendix R to require modification of of Production and Utilization Facilities," language that fire protection issues that previously approved features. This was which would require certain minimum were thought closed would be reopened not clearly described in the proposed provisions for fire protection in nuclear and new, but not necessarily better, rule as published for comment. In fact, power plants operating prior to January modifications would be required. These the Supplementary Information

1, 1979. Fifty-one comment letters were modifications could be accomplished published with the proposed arule received regarding the proposed only by the expenditure of considerable explicitly indicated that "[a]ll licensees amendments. A number of comments engineering, design, and construction will be expected to meet the pertained to specific requirements in the effort and at great undue expense. The requirements of this rule, in its effective proposed Appendix R, and these will be commenters request that the form, including whatever changes result dealt with below. However, there were requirements in the proposed rule be from public comments."

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

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

Federal Register / Vol. 45, No. 225 / Wednesday, November 19, 1980 / Rules and Regulations 76603

9.5-1. it is important to recognize that arr7ingements were accepted in some permitted either an oil collection system Appendix R addresses only a portion of early fire protection reviews. As a result or a fire suppression system. The staff the&specific items contained in the more of some separate effects tests, the staff has also accepted an automatic fire comprehensive document, Branch changed its position on this suppression system as an acceptable Technical Position BTP APCSB 9.5-1 configuration, and subsequent plans method of fire protection for this and its Appendix A. Appendix A to BTP have been required to provide application. The Commission has APCSB 9.5-1 has been the basic fire additional protection in the form of fire concluded that fire suppression systems protection guidance used by the staff in barriers or substantial physical do not give adequate protection for fires their fire protection reviews conducted separation for safe shutdown systems. that may be induced by seismic events.

for all operating plants during the past No credit for such coatings as fire The Commission therefore believes that several years. For many plants, barriers is allowed by Section III.G of previously approved suppression licensees proposed systems and features Appendix R. Appendix A to Branch systems should be replaced with oil that satisfactorily-achieved the fire Technical Position BTP APCSB 9.5.1 and collection syrtems that can Withstand protection criteria set forth in Appendix the proposed Appendix R recognized seismic events.

A .to BTP APCSB 9.5-1 and began to that there were plant-uhique The technical basis on which these promptly implement such features and configurations that required fire three sections are based are further systems. protection features that are not identical discussed in Section 111, "Specific Satisfactory features and systems are to those listed in Section 111.C of Requirements," of this preamble.

already in place and in operation in Appendix R. For these cases, fire 3. Most commenters stated that the many plants. There is a reasonable protection features were developed by implementation schedule contained in'i.

degree of uniformity among most of the licensee and described in a fire the proposed rule is impossible to meet these approved features for all facilities hazards analysis, Some of these for any of the operating plants. The since they were reviewed against the arrangements were accepted by the staff commenters further stated that if the same criteria of Appendix A to BTP as providing equivalent protection to the implementation schedul in the effective APCSB 9.5-1. In general, the features requ-rements of Section i11.G to rule is the same as that in the proposed previously approved by the NRC staff in Appendix R. rule, the Commission must be prepared :

its reviews of fire protection using the Requirements that account for all of to either shutdown each operating criteria of Appendix A to BTP APCSB the parameters that are important to fire nuclear power plant, or process

9.5-1 provide an equivalent level of fire protection and consistent with safety exemption requests.

protection safety to that provided under requirements for all plant-unique The commenters then concluded that the specific provisions of Appendix R. configurations have not been developed. the implementation schedule should be Thus, the further benefit that might be In light of the experience gained in fire rewritten to allow an adequate time provided by requiring thatpreviously protection evaluations over the past four priod for compliance.The proposed rule approved features be modified to years, the Commission believes that the stated that "all fire protection and conform to the specific language set licensees should reexamine those modifications identified by the staff as forth in Appendix R is outweighed by previously approved configurations of necessary to satisfy Criterion 3 of the overall benefit of the early fire protection that do not meet the Appendix A to this part, whether

-implementation of such previously requirements as specified in Section contained in Appendix R to this part or approved features, which in many cases IILG to Appendix R. Based on this in other staff fire protection guidance are currently being installed. (except for alternate or dedicated reexamination the licensee must either shutdown capability) shall be completed Nevertheless, as a result of its meet the requirements of Section III.G of by November 1, 1980 unless, for good continuing review of fire protection Appendix R or apply for an exemption cause shown, the Commission approves matters, the NRC staff has indicated to that justifies alternatives by a fire an extension," (proposed paragraph the Commission that there are hazard analysis. However, based on present information, the Commission 50.48 1.(c)). The Commission went on to requirements in three sections in which state its intention in the Statement of the protection afforded by Appendix R. does not expect to be able to approve Consideration to the rule that"... no over and above that previously exemptions for fire-retardant coatings plant wouldbe allowed to continue to accepted, may be desirable. The used as fire barriers.

operate after November 1, 1980, or, Commission has decided that these The second relates to emergency beyond an extended date approved by requirements should be retroactively lighting.Section II.J of Appendix R calls the Comission, unless all modifications applied to all facilities. This decision is for 8-hour emergency lighting, whereas (except for alternate or dedicated not meant to reflect adversely on in some cases less than 8-hour shutdown capability) have been previous licensee or staff evaluations; emergency lighting has been accepted as implemented."

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

The first of these sections is related to added protection and would generally After reviewing the comments arid fire protection features for ensuring that involve only a small cost. The the information developed as a result of systems and associated circuits used to Commission therefore believes that completion of fire reviews over the past achieve and maintain safe shutdown are licensees should upgrade the previously 6 months, the staff has informed the free from fire damage. Appendix A to approved facilities to satisfy the 8-hour Commission that the date of November DTP APCSB 9.51 permits a combination lighting requirement of Appendix R. 1, 1980, is not possible because the of fire-retardant coatings and fire *The third relates to protection against effective date of the rule will be after

• detectionand supression systems fires in noninerted containments that date.

without specifying a physical separation involving reactor coolant pump - The staff has informed the distance to protection redundant lubrication oil (Section 111.0 of Commission that it would expect systems (Appendix A, D.1(2)), and such Appendix R]. The proposed rule virtually all licensees to request

76604 Federal Register / Vol. 45, No. 225 / Wednesday, November 19, 1980 / Rules and Regulations exemptions if the new implementation Section III, we provide a summary of the automatic water suppression system dates do not provide an appropriate Technical Basis for each requirement, throughout the plant.

period of time for complying with the followed by a summary of the public An ensured minimum volume of water requirements of Appendix R. The time comments and a statement of the staffs is set aside and dedicated for fire and manpower resources needed by the disposition of those comments. protection uses to be available at all licensees to prepare such requests and times regardless of other simultaneous by the staff to formulate Section I. Introduction and Scope water uses in the plant. This water recommendations on these requests is This section has been revised as a volume is dedicated for fire service by not warranted from the standpoint of result of comments to include a means of separate storage tanks or timely fire protection improvement. discussion of the importance of safe separate pump suctions from a large

- The revised implementation shutdown capability and the distinction body of water. When common tankage schedule provides a careful balance of between requirements for "safety- is employed for fire service needs and these considerations, calling for the related" equipment and equipment other water services, the fire pump remaining fire protection modifications needed for "safe shutdown." suctions must be at the bottom of the to be implemented and installed on a Section 11. GeneroalRequirements tank and other water supply suctions phased schedule that is as prompt as must be located at a higher level to can be reasonably achieved., This section has been substantially ensure that the minimum dedicated The revised schedules distinguish rewritten as a result of comments to water volume is set aside for fire between requirements imposed for the provide a concise summary of general protection needs. Administrative first time on the licensee by Appendix R requirements. The specific requirements controls by themselves, such as locked and those requirements already imposed were consolidated with the appropriate valves to ensure adequate water supply in license conditions or Technical parts of Section II, "Specific for fire fighting needs, are deemed Specifications issued prior to the Requirements," except that the credit unacceptable at nuclear power plants.

effective date of the rule. For given for 50-foot separation has been requirements imposed by Appendix R, dropped. Comment Resolution including the items "backfit" to all Many commenters stated that we

-- _ .l LL - -L _J__1 ~.... -' Section II. Specific Requirements Plns ubi scaleuluui proviues ai WVe.:. UULI. LUU IfL[tILIVt: Uy ULIPUILAUlb reasonable time after publication of the The requirements in this rule are an underground yard fire main loop and rule for completion of required based upon principles long accepted fre 31; wa., .applies. Our intent was modifications. For requirements already within that portion of American industry only that a yard fire main loop be imposed by license conditions providing that has been classified by their furnished. We have deleted the for implemention after November 1, insurance carriers as "Improved Risk" specification for an underground loop

1980, the Commission has reviewed or "Highly Protected Risk". In each of since special conditions may dictate that these schedules and has found that in these cases, the Commission has part of the loop be above ground or some instances the allotted time for decided that the overall interest of inside safety-related buildings. Such completion of the required modifications public safety is best served by arrangements are acceptable.

may be excessive. Thus, for fire establishing some conservative level of With regard to the specification for a protection features other than those fire protection and ensuring that level of fresh water supply, the staff was covered by Appendix R, although the compliance exists at all plants. The attempting to avoid potential plant Commission has extended the following is a list of the specific problems that are not associated with compliance dates beyond the November technical bases and resolution of public fire protection. From a fire protection

1, 1980, date in the proposed rule, the comments for each of the specific standpoint, salt or brackish water is Commission has added a requirement requirements in Appendix R. acceptable for fire suppression provided that limits the compliance schedule in A. Water Supplies for Fire the fire protection system is designed existing licenses if such schedules Suppression Systems Technical Basis. and maintained for salt or brackish extend beyond what we now believe One of the basic fire protection water. The requirement for fresh water should have been a reasonable schedule requirements for a modem industrial supplies is therefore dropped. Other initially. Relief from such limitation may site in the United States is a separate operational problems unrelated to fire be granted by the Director of Nuclear water distribution system for fire protection that may result from the use Reactor Regulation upon a showing that protection with dual water supplies. of Ealt or brackish water for fire there is good cause for extending such Duplicate water supplies are required to suppression activities are outside the date and that public health and safety is ensure uninterrupted fire suppression scope of this regulation.

not adversely affected by such capability allowing for single failures Several commenters took issue with extension. and periodic maintenance and repair of the requirement for two separate It should also be noted that for vital portions of the systems. Duplicate redundant suctions, stating that some licensees whose license conditions water supplies may consist of separate pla.its use a single large intake structure imposed a schedule with a compliance suctions for fire pumps from a large on a lake or a river for all water date of November 1, 1980, or other date body of water such as lake, river, or requirensents. The requirement for prior to the effective date of § 50.48, the pond or from two water storage tanks. separate intake structures was not Commission has suspended such For nuclear power plants, the intended and the rule has been clarified.

compliance dates by promulgating on distribution system is required to consist Several comments called for deleting October 29, 1980, a temporary rule of a loop around the plant with suitable the requirements for dedicated tanks or

§ 50.48 (45 FR 71589), which will be valves for isolating portions of the use of ,ertical standpipe for other water superseded by this rule. system for maintenance or repair services when storage tanks are used for To better understand the nature of the without interrupting the water supply to combined service-water/fire-water uses, public comments received and the staffs the various fire suppression systems in on the badis that this is overly restrictive resolution of these comments, the the plant. Thus, with dual supplies and a and other ways are available to ensure following section will consider each loop concept, an adequate water supply a dedicated supply such as weirs, section of Appendix R to this part. In can be ensured to each manual or suction location, etc. Two separate but

Federal Register / Vol. 45, No. 225 / Wednesday, November 19, 1980 / Rules and Regulations 76605 Federal Register / Vol. 45, No. 225 I Wednesday, November 19, 1980 / Rules and Regulations 76605 related issues are involved here. The hour water supply is considered by a visually indicating or key-operated first is the requirement for dedicated adequate. It should also be noted that (curb) valve," and there Was an water storage tanks for fire fighting this minimum dedicated water volume is opportunity to comment on this purposes. The suggestion that the based on maximum flow rates. Since document.

requirement for dedicated tanks be most fires are controlled and D. Manual FireSuppression Technical deleted was rejected for the reasons extinguished with much smaller flow Basis. Considerable reliance is placed stated in the preceding Technical Basis. rates, this requirement realistically on automatic fire suppression systems The other point deals with ensuring represents a dedicated water volume far throughout a nuclear power plant.

minimum water storage capacity for fire in excess of two hours. However, manual fire fighting activities suppression activities when storage B. SectionalIsolation Valves. often can control and extinguish slowly tanks are used for combined service- C. Hydrant Isolation Valves developing fires before an automatic fire water/fire-water uses. The term Technical Basis. These two suppression system is actuated. In

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

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

"vertical standpipe" referred only to Valves are similarly required to permit suppression available for these areas;

pipes inside the tank, this is not the isolation of outside yard hydrants from thus, it is important that manual fire case. In fact a standpipe exterior to the the water distribution system for fighting capability be present in all sLtoJrag taLln 50

-.1 moe aeirable since any maintenance or repair without leakage would be immediately evident. interrupting water supply to fire and hose stations be located throughout On an internal standpipe a leak in the suppression systems inside the plant. the plant; The standpipe and hose pipe could actually allow depletion of. Visually indicating valves such as post stations are to be located so that at least the water otherwise to be reserved for indicator valves are preferred so that one effective hose stream can be fire uses. The rule has been clarified to the position of the valve can be readily brought to bearat any location in the allow physical alternatives for water determined. However, key-operated plant containing or presenting a hazard supply dedication but to preclude valves (commonly known as curb to structures, systems, or components exclusive use of administrative controls valves) are acceptable for these importantto safety. They are to be purposes where plant-specific for this purpose. supplied from the fire water supply conditions warrant their use. system except for those inside Some commenters objected to the B. Section Control Valves-Comment requirement that other water systems Resolution. Many commenters stated containment, which may be connected used as a backup water supply for fire that the requirement for "approved to other reliable water supplies if a protection should be permanently separate penetration into containment visually indicating" sectional control connected to the fire main system and valves was overly restrictive, cannot be made for fire water service suggested that it would besufficient to unnecessary, and not specific with needs.

provide a water supply capable of being respect to who should give the approval. Comment Resolution connected to the fire main system within The Commission has accepted this ten minutes: of the loss of normal water suggestion; the rule now requires that Several commenters suggested adding supply or pumps. The rule does not sectional control valves shall be a sentence reading "Standpipe and hose address backup water supplies. The provided toisolate portions of the fire stations are not required if sufficient requirement means that, if another main for maintenance or repair without justification can be provided that water system is used as one of the shutting off the entire system. Post adequate fire protection features have redundant water supplies, it must satisfy indicator or key-operated valves are been provided to account for a given fire all of the requirenments of the fire mentioned as two examples of area." This suggestion was rejected. The protection water supplies. Additional acceptable valves. staff has taken the position that the backup supplies need not meet these C. Hydrant Block Valves-Comment minimum requirements are that at least requirements. Resolution. A number of commenters one effective hose stream that will be One commenter asked why only a made suggestions for rewording this able to reach any location that contains two-hour water supply is required when section. This section has been clarified or could present an exposure fire hazard the Browns Ferry Fire lasted well over to state the requirement for capability to to the safety-related equipment. The two hours. All of the investigations of isolate hydrants from the fire main Commission concluded that no analyses the Browns Ferry Fire clearly show that without disrupting the water supply to can identify hazards so carefully that if water had been used immediately, the automatic or manual fire suppression this minimum requirement can be fire would have been extinguished much systems in any area containing or further reduced.

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

could threaten safe shutdown capability process." This suggestion was rejected No. 196 (National Fire Protection could not be controlled and extinguished on the basis that Appendix A to BTP Association Standard No. 196- within two hours with any combination APCSB 9.5-1 contains the following Standard for Fire Hose), a nationally of manual and automatic fire sentence: "The lateral to each hydrant recognized consensus standard. This suppression activities. Therefore, a two- from the yard main should be controlled standard contains other guidance for the

76606 Federal Register / Vol. 45, No. 225 / Wednesday, November 19, 1980 / Rules and Regulations use and care of fire hose that most system in all such areas should be I. Fire Brigade Training Technical industries find useful. retained. The fire hazards analysis may Basis. Most modern industrial plants call for a separate suppression system, with replacement cost values Comment Resolution approachingthose of a modern nuclear but this would be in addition to the fire Many commenters pointed out the detection system. powered electric generating station have erroneous usage of the term "service G. Protection of Safe Shutdown a full-time fully equipped fire "

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

terminology is "operating pressure." The it is not possible to predict the specific However, manual fire response rule has been so changed. In addition, conditions under which firesmay occur capability is required at a nuclear plant the staff added a specific minimum test and propagate, the design basis and a properly equipped and fully pressure requirement of 300 psi to meet protective features are specified rather trained fire brigade will satisfy this the NFPA standard. than the design basis fire. Three need. The Commission has determined One commenter also pointed out that different means for protecting the safe that a brigade of five persons constitutes hoses should be inspected for mildew, shutdown capability outside of the minimum size sufficient to perform rot, cuts, or other damage. Although this containment are acceptable. The first the actions that may be required by the is a valid comment, it is not an means is separation of redundant safe brigade during the fire and to provide unresolved issue with any licensee so it shutdown trains and associated circuits some margin for unanticipated events. 1 need not be covered by this rule. In by means of 3-hour fire rated barriers. Similarly, the training requirements addition, such inspections are already LsHe SeGunU IneURs 15 d cUsUIUtLt Uo lietprl arPrnnnqirhrP.d the minimum being performed in accordance with the separation of redundant safe shutdown needed to ensure that the fire brigade plant's Technical Specificaitons. trains and associated circuits by a 1- will be able to function effectively F. Automatic FireDetection Technical during a fire emergency.

hour fire rated barrier 'and automatic fire

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

safety-related systems or components redundant trains and associated circuits The rule has been modified to specify follows generally accepted fire are separated by 20 feet or more of clear the personnel for whom such apparatus

• protection practice. Installation of such is to be provided and to specify reserve fire detection capability is independent space, requires automatic fire air requirements.

of any requirements for automatic or suppression and detection systems in H. Fire Brigade-Comment manual fire suppression capability in an the area. An alternative or dedicated Resolution. Many commenters suggested area. The purpose of these detection safe shutdown capability independent of changing this requirement to a simple systems is to give early warning of fire the fire area is required if fire protection statement that a trained and equipped, conditions in an area so that the fire for safe shutdown capability cannot be nominal size, site fire brigade of five brigade can initiate prompt actions to provided as outlined above. For cables persons be provided on each shift unless minimize fire damage within the plant. and equipment needed for safe a lesser number is justified. This shutdown located inside of noninerted Comment Resolution recommended change was rejected by containments, a lesser degree of fire the Commission for the reasons stated Many commenters suggested that the protection is permitted because in the Technical Basis..

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

"automatic fire detection systems" on operation. Section IlI.M, "Fire Barriers," the fire brigade. The commenters felt the basis that, as worded, the discusses the technical basis for the 3- that the shift supervisor should go to the requirements are too limiting. They hour barrier, and Section III.L, fire and provide the benefit of his stated that an automatic sprinkler "Alternative and Dedicated Shutdown expertise and authority. The rule would system with appropriate alarm check Capability," discusses the technical not prevent this. However, the shift valves pnd central alarm features basis for safe shutdown capability. supervisor may have to go elsewhere provides acceptable detection/alarming Comment Resolution during the course of a fire that adversely capability. Several commenters claimed affects plant operation. The fire brigade that a separate detection system is not Many commenters suggested that the leader must stay with the fire brigade needed in areas covered by sprinkler first paragraph be changed slightly and and be assigned no other systems equipped with fusible link the rest of this section deleted. The responsibilities during a fire'emergency, sprinkler heads. A fusible link has a basis for their contention is that the rule therefore, the shift supervisor must be time delay before it actuates. However, should state simply the requirement to excluded from membership on the fire more importantly, a smoldering protect cables or equipment of systems brigade.

localized fire that could do damage may necessary for safe shutdown of the plant I. Fire Brigade Training-Comment not generate enough heat to melt the and leave specific implementation Resolution. Many commenters have fusible link. While we do not disagree details in some other type of document.

• thatthe alarm from an automatic fire We have modified this section by IThis is discussed at length in the NRC staff's suppression system serves as removing the listing of considerations, "Evaluation of Minimum Fire Brigade Shift Size".

deleting Table I, and revising the dated June B. 1970: copies are available from David notification that a fire exists, we P. Notley, Office of Standards Development, U.S.

concluded that the minimum wording to provide clarification. Nuclear Regulatory Commission, Washington, D.C.

requirement for a separate fire detection H. FireBrigade. 20555.

Federal Register / Vol. 45, No. 225 / Wednesday, November 19, 1980 / Rules and Regulations 76607 stated that NRC used unnecessary detail fire emergency and operators involved modifications to provide alternative in spelling out specific requirements for in safe plant shutdown should not also shutdown systems are extensive, a classroom instruction, fire fighting have to be concerned with lighting in the dedicated system that is essentially a practice, and fire drills. Some area. The small cost differential minimum capability safe shutdown train commenters felt that these requirements between 2-hour supply and the and is independent of those already were more detailed than anything the substantial additional protection existing may be provided. This minimum Commission has published with regard afforded by the 8-hour supply does not capability is required to maintain the to operator training. The Commission warrant reducing this requirement. The process variables within those values here points out that most of the Commission has decided to require an 8- predicted for a loss of offsite power. The investigations of the TMI accident hour battery power supply in all areas case of loss of offsite power is assumed identified inadequately trained needed for operation of safe shutdown because fires in certain circumstances operators as an important factor and equipment and in access and egress (e.g., electrical distribution systems)

that work is now being done in this routes. could caupe or be related to such a loss.

area. The fact is, not that the training K. Administrative Controls Technical Fire damage to cold shutdown capability requirements sfelled out here for the fire Basis. The fire protection program uses is limited to damage that can be brigade members are excessivewhen administrative controls for fire repaired within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to provide a compared to training requirements for prevention and prefire planning. The margin in achieving cold shutdown reactor operators, but that fire brigade items listed in this section are generally conditions. Consideration is given to training is further along in development, accepted within the fire protection associated circuits because most plants and training parameters that are community as minimum requirements were not designed with this concept in essential to a comprehensive program for an effective administration of the fire mind. Should either the alternative or have been identified. .protection program. Controls are placed dedicated capability be required to J. Emergency Lighting Technical on the storage and use of combustible function because of a fire, it must not be Basis. Emergency iighning is required in materitais o reduce lire

. .e.uduii in disabled by fire damage to associated all nuclear power plants. Battery- safety-related areas and on ignition circuits. Also, this capability does not powered lights with capacities of 11/2 to sources to avoid careless operations. have to meet the single failure criterion

2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> is usually sufficient for Procedures are used to control actions because it is only one of several levels emergency egress. However, the postfire to be taken by individuals who discover of defense. Seismic Category I criteria is emergency lighting requirements in a a fire and by the fire brigade for the not imposed because fires that would nuclear power plant are of a different development of preplanned fire fighting require the installation of alternative or kind. The need is for lighting that aids strategies and actual fire fighting dedicated shutdown capability are not the access to equipment and techniques. seismically induced.

components that must be manually Comment Resolution Comment Resolution operated by plant personnel to effect safe.plant shutdown during plant Many commenters stated that this Many of the commenters stated that emeregdh'cies. Because such activities requirement was much too detailed for a this requirement exceeded the scope of may extend over a considerable period regulation. Some stated that the Appendix R by defining alternative of time both during and after the fire, it requirements should apply only to those shutdown requirements. They stated is prudent to provide 8-hour battery areas having safe shutdown equipment. that the time requirements are excessive emergency lighting capability to allow Other commenters stated that a simple and should be dropped. They also sufficient time for normal lighting to be statement that administrative contend that this regulation does not restored with a margin for unanticipated procedures should be established to take into account the many plant.

events. control the various fire hazards reviews being conducted under the throughout the plant was sufficient, and Systematic Evaluation Program (SEP).

Comment Resolution that the details could be spelled out in a It is generally understood that cold Many commenters stated that the regulatory guide or some other similar shutdown is the ultimate safe shutdown requirement for emergency lighting is document. condition and that, for each fire area, overly restrictive in three specifics: first, Minor changes have been made in the different means may be used and may that emergency lighting is unnecessary wording of this requirement for be necessary to achieve cold shutdown.

in many of the designated areas: second, clarification. Because a fire in certain areas at some that the requirement for sealed beam or L. Alternative and Dedicated plants would have the capability of fluorescent units is overly restrictive; Shutdown Capability. disabling systems required to achieve third, that the requirement for individual TechnicalBasis. In some locations both hot and cold shutdown, it is

8-hour battery power supply is (such as the cable spreading room) necessary to specify the minimum excessive. Three commenters within operating nuclear power plants, it capability and time requirement for each recommended a 2-hour battery power is not always possible or practicable to condition necessary to achieve safe supply; five commenters recommended a protect redundant safe shutdown shutdown. We agree that evaluations plant-specific power supply; and one systems against adverse effects of fire or being made under the Systematic commenter recommended that there be fire suppression activities only through Evaluation Program (SEP) may also call no permanent installation. the use of fire protection featuires for alternative or dedicated shutdown These suggestions have been accepted because the redundant safe shutdown capability for reasons other than fire in part. Lighting units with 8-hour systems in a given fire area are too close protection. For example, seismic, battery supplies are to be provided in all to each other. Alternative shutdown flooding, or emergency core cooling areas needed for operation of safe capability has usually been required to *requirements resulting from the SEP may shutdown equipment and in access and be independent of the control room, require additional modifications. Each egress routes thereto. The reasoning cable spreading room, switchgear rooms licensee should be aware of the status of behind the requirement for an 8-hour and cable riser areas because redundant the SEP so that the requirements battery power supply is that there can systems in these areas are not resulting from SEP can be effectively be a great deal of other activity during a adequately separated. When plant integrated with those relating to fire

76608 Federal Register / Vol. 45, No. 225 / Wednesday, November 19, 1980 / Rules and Regulations protection to the extent possible. required to ensure safe shutdown the national consensus standard used However, the Commission has decided capability. The use of a 1-hour barrier in for testing and rating these cable that the modifications required to conjunction with automatic fire penetration seals. Since the cables complete the fire protection program suppression and detection capability for conduct the heat through the barrier, should not be deferred until the SEP each redundant train of safe shutdown and since the cable insulation is review is completed. equipment is based on the following combustible, the acceptance criteria of M. Fire Barriers. considerations. Automatic suppression the ASTM Standard E-119 relating to TechnicalBasis. The best fire is required to ensure prompt, effective temperature on the unexposed side must protection for redundant trains of safe application of suppressant to a fire that be appropriately modified.

shutdown systems is separation by could endanger safe shutdown unpierced fire barriers-walls and Comment Resolution capability. The activation of an ceiling-floor assemblies. Because these automatic fire detection or suppression Some commenters suggested that this barriers are passive fire protection system does not occur until sufficient entire section be deletedand replaced features, they are inherently reliable smoke or heat has been developed by with the following two sentences:

provided they are properly installed and the fire. Therefore, the Commission is "Penetration seals shall provide the maintained. Fire barriers have been requiring a 1-hour barrier to ensure that equivalent protection which is required used successfully for many years to fire damage will be limited to one train of the fire barrier. Evaluation of the subdivide large potential fire losses into until the fire is extinguished. penetration seals based upon a design smaller, more acceptable risks. Even fire These requirements have now been review and relevant test data or barriers with openings have successfully incorporated in Section III.G, "Fire qualification tests may be made." The interrupted the progress of many fires Protection of Safety Functions." commenters felt that sufficient test data provided the openings were properly are available to permit evaluation of protected by fire doors or other Comment Resolution design requirements without full-scale acceptable means. Several commenters made a number mockup testing and that many of the Fire barriers are "rated" for fire of suggestions of an editorial nature. items spelled out in the regulation, such resistance by being exposed io a '*.jnc DU~CL nu;~g.LL

tQOD LU C*,L*,L UkJ *t&AkoC

"standard test fire". This standard test other fire protection features have been detailed and did not belong in the fire is defined by the American Society provided to ensure equivalent regulation. The Commission has for Testing and Materials in ASTN E- protection" in the first paragraph, where reconsidered this issue and revised the

119, "Standard for Fire Resistance of three-hour rated fire barriers were rule to (a) require the use of Building Materials." Fire barriers are stipulated unless a lower rating was noncombustible materials only in the commonly rated as having a fire justified by the fire hazards analysis. construction of fire barrier penetration resistance of from 1 to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. Most The Commission feels that this adds seals, (b) require fire barrier penetration

"Improved Risk" or "Highly Protected nothing in the way of clarification and seals to be qualified by test; and (c)

Risk" (as classified by insurance the suggestion was not adopted. The require such tests to satisfy certain carriers) industrial properties in the second paragraph requires that acceptance criteria.

United States require fire barriers to .structural steel forming a part of or 0. Fire Doors.

have a resistance rating of 2 to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. supporting any fire barrier have a fire Technical Basis. Door openings in fire While a nuclear power plant has a resistance equivalent to that required of walls constitute another breach that low fire load, the potential the barrier. An example was given of must be protected. Fire doors that have consequences of fire are serious. metal lath and plaster covering as being been tested and rated for certain fire Therefore, the Commission has selected one means of providing equivalent exposures are installed to protect these

3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> has been as an acceptable protection. Several commenters stated openings. Fire doors frequently fail to minimum fire resistance rating for fire that they thought this was too narrow protect the openings in which they are

-barriers separating redundant trains for and would be interpreted by some installed because they are not fully safe shutdown systems. This will give people as the only acceptable method closed. Various methods are available to ample time for automatic and manual permitted. Since the example seemed to licensees to ensure that fire doors are in fire suppression activities to control any be confusing, a decision has been made proper operating condition and that they potential fire and for safe shutdown to eliminate it. Other comments to the will be closed during a fire. These activities to properlywontr6l the reactor. effect that the requirement was options are listed in Appendix R.

Many operating plant's, or plants that excessively restrictive with regard to are already built but that are not yet fire barrier penetrations, including fire Comment Resolution operating, have both trains of safe doors and their associated frames and Many commenters stated that this shutdown equipment located in close hardware, and ventilation systems have requirement is too detailed and should proximity and a single fire could been acted upon by the staff and the be deleted. Minor editorial changes have damage or destroy the functional requirement, as it had affected these been made in order to more clearly state capability of both redundant trains. If items, was deleted. the requirements.

specific plant conditions preclude the N. Fire BarrierCable PenetrationSeal P. Reactor Coolant Pump Lubrication installation of a 3-hour fire barrier'to Qualification. System.

separate the redundant trains, a 1-hour Technical Basis.Unpierced fire Technical Basis. Each reactor coolant fire barrier and automatic fire barriers offer the best protection for pump motor assembly typically contains suppression system for each redundant separating redundant trains of safety- 140 to 220 gallons of lube oil. Oil leaking train will be considered the equivalent related or safe shutdown equipment. from some portions of the lube oil of 3-hour barrier. However, these barriers must be pierced system may come in contact with If the 1-hour fire barrier and automatic for both control and power cables. surfaces that are hot enough to ignite the fire suppression for each redundant- These penetrations must be sealed to oil. The resulting fire could be large, and train cannot be provided because of achieve a degree of fire resistance access to the fire would be delayed plant-specific conditions, alternative or equivalent to that required of the barrier because of the time required to enter the dedicated shutdowns capability will be that is pierced. ASTM Standard E-119 is containment. Containent air temperature

Federal Register / Vol. 45, No. 225 / Wednesday, November 19, 1980 / Rules and Regulations 76609 would increase, severe localized pump oil collection system is covered by Capability.") In the fire hazards analysis environments would develop in the area paragraph C.2 because its function is for a plant, the equipment relied upon to of the fire, and a large amount of smoke required to protect safety-related perform both functions must be would be generated. These conditions systems rather than to perform a safety identified for each fire area. It. follows could affect operability of safety-related function. Because the failure of the oil that any associated non-safety circuits equipment inside containment. collection system for a seismically in the fire area that could adversely Therefore, an oil collection system is induced oil fire should not prevent a affect the identified shutdown necessary to confine any oil discharged safety-related system from performing equipment by feeding back potentially due to leadkage or failure of the its safety function (Regulatory Guide disabling conditions (e.g., hot shorts or lubrication system and to prevent it 1.29, "Seismic Design Classification," shorts to ground) to the power supplies from becoming a fire hazard by draining paragraph C.2), the oil collection system or control circuits of that equipment it to a safe location. These occurrences should be designed, engineered, and must also be evaluated. Of course such could be random or could be seismically installed so that its failure will not lead disabling conditions must be prevented induced because the existing lube oil to a fire affecting safety-related to provide assurance that the identified system piping and oil collection systems equipment as a result of an earthquake.

The proposed rule permitted two safe shutdown equipment will function may not be designed to withstand a as designed. These requirements have design basis seimic event. alternatives-an oil collection system or an automatic fire suppression system. now been incorporated in Section MI.L

Appendix A to BTP APCSB 9.5-1 "Alternative and Dedicated Shutdown We have deleted the alternative of the states that for operating plants, Capability."

"postulated fires or fire protection suppression system because system failures need not be considered unacceptable damage may result to the Comment Resolution safety-related systems from the burning concurrent with other plant accidents or of oil before the suppression system is Many commenters stated that this the most severe natural phenomena."

The basis for that statement is two fold. supply system is not designed to many older plant designs did not First, nuclear power plants are massive withstand seismic events. In addition, consider associated circuits and this is, structures, and essential services are these pumps are located within the therefore, a new design requirement.

designed to withstand earthquakes and biological shield inside containment, The commenters felt that the analysis other natural phenomena. Second, the therefore, timely fire brigade action that will be required to satisfy this history of many fires associated been with would be difficult if the suppression recent earthquakes have system malfunctions. Further, if the requirement. will be both long and complicated and the requirement should evaluated. These evaluations showed suppression system becomes inoperable therefore be deleted.

that such fires usually are due to failure during operation, a fire watch or patrol of piping or tanks of flammable gasses The Commission rejected these cannot enter the area during operation. suggestions for the following reasons.

or liquids such as municipal natural gas distribution systems or gasoline storage Comment Resolution 1. Virtually all of the fire protection and/or dispensing stations. Where such A number of commenters suggested modifications made to date have been potential fire hazards exist in nuclear that this section is too detailed and required to correct deficiencies that power plants (e.g., hydrogen for should be substantially modified. This resulted from lack of consideration of generator cooling, or oil fuel for the requirement was changed to delete the certain specific items during initial emergency diesel generator or station option of protecting the reactor coolant design and construction.

space heating boilers) they are designed pump lubrication system with an 2. The Browns Ferry fire showed the and installed to withstand the damaging automatic fire suppression system. We necessity of divisional separation of the effects of various natural phenomena, have modified the rule to indicate that associated circuit of the control cables and other special fire protection features the requirement that the oil collection to prevent the disabling of'safety are provided as necessary. However, system be designed to provide systems by a single fire. This has been General Design Criterion 2.DesignBases reasonable assurance thatit will discussed with licensees during for ProtectionAgainst Natural withstand the Safe Shutdown evaluations of alternative and dedicated Phenomena requires that structures, Earthquake can be met by satisfying shutdown capability and is necessary to systems, and components important to paragraph C.2. of Regulatory Guide 1.29, ensure that safe shutdown systems will safety be designed to withstand the "Seismic Design Classification," as. be able to function properly in the event effects of earthquakes without loss of described above. of fire.

capability to perform their safety Q. Associated Circuits.

function. Regulatory Guide 1.29, TechnicalBasis. When considering 3. The staff considers incomplete any

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

power plants that should be designed to train of equipment that can be used As indicated above, as a result of the withstand the effects of the Safe immediately to bring the reactor to a hot .comments received on this issue, it is Shutdown Earthquake. In this guide, shutdown condition remains unaffected unclear that associated circuits have in paragraph C.1 applies to systems that by that fire. The staff must also be able fact been adequately considered by are required to remain functional to to conclude that damage to one train of licensees in their reviews using the ensure heat removal capability; equipment used for achieving cold guidance of Appendix A to BTP APCSB

paragraph C.2 applies to systems that do shutdown will be limited so that the 9.5-1. To ensure that the ass6ciated not have to remain frunctional for that equipment can be returned to an circuits are considered, all operating purpose, but whose failure could reduce operable condition within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. (See nuclear power plants will be required to the functioning of those systems covered Technical Basis for Section II.G, meet the requirements of Section ll.G of by paragraph C.I. The reactor coolant "Protection of Safe Shutdown Appendix R.

76610 Federal Register / Vol. 45, No. 225 / Wednesday, November 19, 1980 / Rules and Regulations Genera] Comments Resolution: shutdown capability. The Commission comments received on the proposed Several commenters contended that does not agree. We believe that the regulations, other commenters Commission regulations mandate that Commission's overall fire protection demonstrated a thorough understanding an adjudicatory hearing be conducted program involving extensive plant- of the proposed requirements.

prior to a final decision. One commenter" specific fire protection modifications Pursuant to the Atomic Energy Act of labeled the regulation an "order" within that are based on guidance set forth in 1954, as amended, the Energy the meaning of the Administrative Branch Technical Position BTP APCSB Reorganization Act of 1974, as amended, Procedure Act (5 U.S.C. 551(6)) (APA) 9.5-1 and its Appendix A andthe and Sections 552 and 553 of Title 5 of the and asserted that 10 CFR 2.204 of the specific requirements of Appendix R to United States Code, notice is hereby *

Commission's regulations, "Order for resolve disputed issues provide given that the following amendments to Modification of License," applies to this adequate fire protection. Title 10, Chapter I, Code of Federal rulemaking proceeding. One commenter stated that the Regulations, Part 50, are published as a The Commission disagrees with these ambiguity of the proposed regulation document subject to codification.

comments. A "rule" is defined in the with regard to critical items requires 1. A new § 50.48 is added to read as APA to mean "the whole or a part of an that it be renoticed. The commenter follows:

agency statement of general or referenced three portions of the proposed Appendix R as examples of § 50.48 Fire Protection.

particular applicability and future effect (a) Each operating nuclear power designed to implement *

• or such ambiguity. They were Section III.G,

Section II1.N, and Section III.Q. We have plant shall have a fire protection plan prescribe law or policy .... (5 U.S.C. that satisfies Criterion 3 of Appendix A

551(4)). The agency action questioned reviewed these examples.

In reference to the first example, the to this part. This fire protection plan here is clearly one that treats similarly shall describe the overall fire protection situated licensees equally and that commenter stated that the first paragraph of Section 1II.G identifies program for the facility, identify the prescribes future conduct or various positions within the licensee's requirements. For those licensees who alternative shutdown capability as an UjLturia.l JiULCLLLVe fCaLtur. M,,U L*ASLL nraniratinn that arp rp.nnnqihilp fnr the have not already provided an equivalent program, state the authorities that are level of fire protection, certain specific paragraph III.G.2.c then identifies alternative shutdown capability as a delegated to each of these positions to fire protection features are required. implement those responsibilities, and Various of these requirements would minimum fire protection feature. We do not agree with this statement. The first outline the plans for fire protection, fire apply to approximately 40 facilities. The detection and suppression capability, commenter's characterization of the rule paragraph of Section II.G identifies alternative shutdown capability as one and limitation of fire damage. The plan as an order, along with the assertion option in a combination of fire shall also describe specific features that 10 CFR 2.204 mandates a hearing protection features for a specific fire necessary to implement the program before the rule becomes final is area. Paragraph 11.G.3 indicates when described above, such as administrative incorrect. On its face, that regulation this option should be used. controls and personnel requirements for (which does grant a hearing right) In reference to the second example. fire prevention and manual fire applies only to Commission orders that the commenter stated that Section III.N suppression activities, automatic and modify a license." It does not apply to requires a pressure differential across manually operated fire detection and requirements promulgated through a the test specimen during the testing of suppression systems, and the means to rulemaking action conducted in fire barrier penetration seals but fails to limit fire damage to structures, systems, accordance with the requirements of define the pressure differential. This or components important to safety so applicable law. comment is incorrect. The pressure that the capability to3 safely shut down Several commenters contended that differential called for by the proposed the plant is ensured.

the environmental impact had not been provision was the maximum pressure (b) Appendix R to this part establishes adequately addressed. One commenter, differential that the barrier would fire protection features required to citing the requirements in Section III.A experience in the specific plant satisfy Criterion 3 of Appendix A to this of Appendix R for two water supplies installation. In any event, the part with respect to certain generic and two separate redundant sections as requirement for pressure differential issues for nuclearpower plants licensed examples of requirements involving during such testing has been deleted to operate prior to January 1, 1979.

environmental issues, contended that since only noncombustible material is Except for the requirements of Sections the Commission relied upon its staffs now being used for such seals. III.G, III.J, and m.O, the provisions of

"unsupported determination that, In reference to the third example, the Appendix R to this part shall not be pursuant to 10 CFR § 51.5(d), an commenter stated that Section III.Q is applicable to nuclear power plants environmental impact statement, totally lacking in definition. We do not licensed to operate prio~rto January 1, appraisal, or negative declaration is not agree. Footnote 6 references Regulatory 1979, to the extent that fire protection required." The Commission has Guide 1.75 and IEEE StdW407. The features proposed or implemented by considered Section I1I.A and has further latter document is a commonly used considered the remaining requirements industry standard that defines I Basic fire protection guidance for nuclear power of Appendix R and remains convinced associated circuits and provides plants is contained in two NRC documents:

that the regulations are not substantive guidance for ensuring that such circuits - Branch Technical Position Auxiliary Power and are insignificant from the standpoint do not compromise the independence of Conversion System Branch BTP APCSB 9.5-1.

of environmental impact. "Guidelines for Fire Protection for Nuclear Power the shutdown circuits they are Plants." for new plants docketed after July 1. 1976, One commenter suggested that all associated with. dated May 1976.

plants be required to install dedicated Based on the above examples and our - Appendix A to BTP APCSB 9.5-1. "Guidelines review of the other provisions of the for Fire Protection for Nuclear Power Plants

'It should also be noted that § 2.204 is codified in proposed rule, we do not believe that Docketed Prior to July 1. 1976," for plants that were Subpart B of 10 CFR Part 2. The scope of Subpart B operating or under various stages of design or the rule as proposed was ambiguous so construction before July 1, 1976, dated August 23.

is specifically limited to "cases initiated by the staff

• *

• to impose requirements by order on a as to require renoticing. Moreover, it 1976.

licensee" (10 CFR 2.200[(a}. (Emphasis supplied.) should be noted that, based on other Also see Note 4.

Federal Register / Vol. 45, No. 225 / Wednesday, November 19, 1980 / Rules and Regulations 76611 the licensee have been accepted by the after the effective date of this-section determines, upon a showing by the NRC staff as satisfying the provisions of and Appendix R to this part: licensee, that there is good cause for Appendix A to Branch Technical (i) the first refueling outage; extending such date and that the public Position BTP APCSB 9.5-14 reflected in (ii) another planned outage that lasts health and safety is not adversely staff fire protection safety evaluation for at least 60 days; or affected by such extension. Extensions reports issued prior to the effective date (iii) an unplanned outage that lasts for of such date shall not exceed the dates of this rule, or to the extent that fire at least 120 days. determined by paragraphs (c)(1) through protection features were accepted by (4) Those fire protection features that (c)(4) of-this section.

the staff in comprehensive fire require prior NRC approval by (1] Those fire protection features that protection safety evaluation reports paragraph (c)(5) of this section, shall be involve revisions of administrative issued before Appendix A to Branch implemented within the following controls, manpower changes, and Technical Position BTP APCSB 9.5-1 schedule: Dedicated shutdown training shall be implemented within 4 was published in August 1976. With systems-30 months after NRC months after the date of the NRC staff respect to all other fire protection approval; modifications requiring plant Fire Protecti6h Evaluation Report features: covered by Appendix R, all shutdown-before startup after the accepting or requiring such features.

nuclear power plants licensed to operate earliest of the events given in paragraph (2) Those fire protection features prior to January 1. 1979 shall satisfy the (c)(3) commencing 180 days after NRC involving installation of modifications applicable requirements of Appendix R approval; modifications not requiring not requiring prior approval or plant to this part, including specifically the plant shutdown--6 months after NRC shutdown shall be implemented within requirements of Sections M.G, 1114., and approval. 12 months after the date of the NRC

(5) Licensees shall make any staff Fire Protection Safety Evaluation (c) All fire protection modifications modifications necessary to comply with Report accepting or requiring such re,,, f.a

,.* a tia tho nrritricainne nf these requirements in accordance with features.

the above schedule without prior review ([3 Those fire protection features, Appendix R to this part or directly and approval by NRC except for including alternative shutdown affected by such requirements shall be modifications required by Section III.G.3 capability, involving installation of completed on the following schedule: of Appendix R to this part. Licensees modifications requiring plant shutdown

(1) Those fire protection features that shall submit plans and schedules for shall be implemented before the startup.

involve revisions of administrative meeting the provisions of paragraphs after the earliest of the following events controls, manpower changes, and (c)(2), (c)(3), and (c)(4) within 30 days commencing 9 months or more after the training, shall be implemented within 30 after the effective date of this section date of the NRC staff Fire Protection days after the effective date of this and Appendix R to this part. Licensees Safety Evaluation Report accepting' or section and Appendix R to this part. shall submit design descriptions of requiring such features:

(2) Those fire protection features that modifications needed to satisfy Section (i) The first refueling outage;

involve installation of modifications that [I.G.3 of Appendix R to this part within (ii) Another planned outage that lasts do not require prior NRC approval or 30 days after the the effective date of for at least 60 days; or plant shutdown shall be implemented this section and Appendix R to this part. (ill) An unplanned outage that lasts within 9 months after the effective date (6) In the event that a request for for at least 120 days.

of this section and Appendix R to this exemption from a requirement to comply (4) Those fire protection features part. with one or more of the provisions of involving dedicated shutdown capability

(3) Those fire protection features, Appendix R filed within 30 days of the requiring new buildings and systems except for those requiring prior NRC effective date of this rule is based on an shall be implemented within 30 months approval by paragraph (c)(5) of this assertion by the licensee that such of NRC approval. Other modifications section, that involve installation of required modifications would not requiring NRC approval prior to modifications that do require plant enhance fire protection safety in the installation shall be implemented within shutdown, the need for which is justified facility or that such modifications may 6 months after NRC approval.

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

4 Clarification and guidance with respect to provided a sound technical basis for licenses.

permissible alternatives to satisfy Appendix A to such assertion that warrants further 2. A new Appendix R is added to BTP APCSB 9.5-1 has been provided in four other staff review of the request. 10 CFR Part 50 to read as follows:

NRC documents. (d) Fire protection features accepted

- "Supplementary Guidance on Information by the NRC staff in Fire Protection Appendix R-Fire Protection Program for Needed for Fire Protection Evaluation," dated Nuclear Power Facilities Operating Prior to October 21, 1976. Safety Evaluation Reports referred to in January 1, 1979

• "Sample Technical Specification," dated May paragraph (b) of this section and

12, 1977. supplements to such reports, other than I. Introduction and Scope

- "Nuclear Plant Fire Protection Functional features covered by paragraph (c), shall This Appendix applies to licensed nuclear Responsibilities Administrative Control and be completed as soon as practicable but power electric generating efations that were Quality Assurance," dated June 14, 1977. operating prior to January 1, 1979, except to no later than the completion date

- "Manpower Requirements for Operating the extent set forth in paragraph 50.48(b) of Reactors," dated May 11, 1978. currently specified in license conditions this part. With respect to certain generic A Fire Protection Safety Evaluation Report that or technical specifications for such issues for such facilities it sets forth fire has been issued for each operating plant states how facility, or the date determined by protection features required to satisfy 5 these guidelines were applied to each facility and paragraphs (d](1) through (d)(4) of this Criterion 3 of Appendix A to this part.

identifies open fire protection issues that will be resolved when the facility satisfies the appropriate section, whichever is sooner, unless the requirements of Appendix R to this part. Director of Nuclear Reactor Regulation 'See footnote 4.

76612 Federal Register / Vol. 45, No. 225 / Wednesday, November 19, 1980 / Rules and Regulations Criterion 3 of Appendix A to this part program shall establish the fire protection D. Alternative or DedicatedShutdown specifies that "Structures, systems. and policy for the protection of structures, Capability components important to safety shall be systems, and components important to safety In areas where the fire protection features designed and located to minimize, consistent at each plant and the procedures, equipment, cannot ensure safe shutdown capability in with other safety requirements, the and personnel required to implement the the event of a fire in that area, alternative or probability and effect of fires and program at the plant site. dedicated safe shutdown capability shall be explosions." The fire protection program shall be tinder provided.

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

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

Appendix R as applying to all safety with the following objectives: pump, piping, and appropriate isolation and functions. The phrase "safe shutdown" will " to prevent fires from starting; control valves. Two separate redundant be used throughout this Appendix R as " to detect rapidly, control, and extinguish suctions in one or more intake structures applying to both hot and cold shutdown promptly those fires that do occur; from a large body of water (river, lake, etc.)

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

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

safety, the need to limit fire damage to B. Fire HazardsAnalysis period of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> the maximum expected systems required to achieve and maintain A fire hazards analysis shall be performed water demands as determined by the fire >

safe shutdown conditions is greater than the by qualified fire protection and reactor hazards analysis for safety-related areas or need to limit fire damage to those systems systems engineers to (1) consider potential in other areas that present a fire exposure required to mitigate the consequences of situ and transient fire hazards; (2] determine hazard to safety-related areas.

design basis accidents. Three levels of fire the consequences of fire in any location in When storage tanks are used for combined damage limits are established according to the plant on the ability to safely shut down service-water/fire-water uses the minimium the safety functions of the structure, system, the reactor or on the ability to minimize and volume for fire uses shall be ensured by or component: control the release of radioactivity to the means of dedicated tanks or by some environment; and (3) specify meazures for physical means such as a vertical standpipe Safety function Fire damage limits fire prevention, fire detection, fire for other water service. Administrative suppression, and fire containment and controls, including locks for tank outlet Hot Shutdown ............. One train of equipment necessary to alternative shutdown capability as required valves, are unacceptable as the only means achieve hot shutdown from either for each fire area containing structures, to ensure minimum water volume.

the control room or emergency con- systems, and components important to safety trol station(s) must be maintained Other water systems used as one of the free of fire damage by a single fire, in accordance with NRC guidelines and two fire water supplies shall be permanently including an exposure fire.' regulations. connected to the fire main system and shall Cold Shutdown ......... Both trains of equipment necessary to C. Fire Prevention Features achieve cold shutdown may be be capable of automatic alignment to the fire damaged by a single tire, including Fire protection features shall meet the main system. Pumps, controls, and power an exposure fire, but damage must following general requirements for all fire supplies in these systems shall satisfy the be limited so that at least one train areas that contain or present a fire hazard to requirements for the main fire pumps. The can be repaired or made operable within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> using onsite capabii. structures, systems, or components important use of other water systems for fire protection fly. to safety. shall not be incompatible with their functions Design Basis Both trains of equipment necessary 1. In situ fire hazards shall be identified required for safe plant shutdown. Failure of Accidents. for mitigation of consequences ftl- lowing design basis accidents may and suitable protection provided. the other system shall not degrade the fire be damaged by a single exposure 2. Transient fire hazards associated with main system.

fire. normal operation, maintenance, repair, or B. Sectional Isolation Valves modification activities shall be identified and Sectional isolation valves such as post I Ekposure Fire. An exposure fire is a fire in a given area eliminatedwhere possible. Those transient indicator valves or key operated valves shall that involves either in situ or transient combustibles and is external to any structures, systems, or components located fire hazards that can not be eliminated shall be installed in the fire main loop to permit in or adjacent to that same area. The effects of such fire be controlled and suitable protection (e.g., smoke, heat, or ignition) can adversely affect those isolation of portions of the fire main loop for structures, systems,. or components important to safety. provided.. maintenance or repair without interrupting Thus, a fire involving one train of safe shutdown equipment 3. Fire detection systems, portable may constitute an exposure fire for the redundant train the entire water supply.

located in the same area, and a fire involving combustibles extinguishers, and standpipe and hose C. Hydrant Isolation valves other than either redundant train may constitute an exposure stations shall be installed.

fire to both redundant trains located In the same area. Valves shall be installed to permit isolation

4. Fire barriers or automatic suppression of outside hydrants from the fire main for The most stringent fire damage limit shall systems or both shall be installed as maintenance or repair without interrupting apply for those systems that fall into more necessary to protect redundant systems or the water supply to automatic or manual fire than one category. Redundant systems used components necessary for safe shutdown. suppression systems in any area containing to mitigate the consequences of other design 5. A site fire brigade shall be eltablished, or presenting a fire hazard to safety-related basis accidents but not necessary for safe trained, and equipped and shall be on site at or safe shutdown equipment.

shutdown may be lost to a single exposure all times. D. ManualFire Suppression fire. However, protection shall be provided so 6. Fire detection and suppression systems Standpipe and hose systems shall be that a fire within only one such system will shall be designed, installed, maintained, and installed so that at least one effective hose not damage the redundant system. tested by personnel properly qualified by stream will be able to reach any location that experience and training in fire protection contains or presents an exposure fire hazard II. General Requirements systems. to structures, systems, or components A. Fire ProtectionProgram 7. Surveillance procedures shall be important to safety.

A fire protection program shall be established to ensure that fire barriers are in Access to permit effective functioning of established at each -nuclear power plant. The place and that fire suppression systems and the fire brigade shall be provided to all areas components are operable. that contain or present an exposure fire

Federal Register / Vol. 45, No. 225 / Wednesday, November 19, 1980 / Fules and Regulations 76613 Fetieral Register I Vol. 45, No. 225 / Wednesday, November 19, 1950 I RuIe~ and Regulations 76613 hazard to structures, systems, or components hour rating, In addition, fire detectors and an Institute for Occupational Safety and important to safety. automatic fire suppression system shall be Health-approuva formterly given by the U.S.

Standpipe ond hose stations shall be inside installed in the fire area; Bureau of Mizneu) shall he provided for fire PWR containments and BWR containments Inside noninerted containments one of the brigade, damage control, and control room that are not inerted. Standpipe and hose fire protectibn means specified above or one personnel. At least 10 masks shallbe stations inside containment may be of the following fire protection means shall available for fire brigade personnel. Control connected to a high quality water supply of be provided: room personnel may be furnished breathing sufficient quantity and pressure other than d. Separation of cables and equipment and air by a manifold system piped from a the fire main loop if plant-specific features associated non-safety circuits of redundant storage reservoir if practical. Service or rated prevent extending the fire main supply inside trains by a horizontal distance of more than operating life shall be a minimum of one-half containment. For BWR drywells, standpipe 20 feet with no intervening combustibles or hour for the self-contained units.

and hose stations shall be placed outside the fire hazards: At least two extra air bottles shall be dry well with adequate lengths of hose to e. Installation of fire detectors and an located on site for each self-contained reach any location inside the dry well with automatic fire suppression system in the fire breathing unit. In addition, an omite 5-hour an effective hose stream. area; or supply of reserve air shall be provided and E. HydrostaticHose Tests f. Separation of cables and equipment and arranged to permit quick and complete Fire hose shall be hydrostatically tested at associated non-safety circuits of redundant replenishment of exhausted supply air bottles a pressure of 300 psi or 50 psi above trains by a noncombustible radiant energy as they are returned. If compressors ae used maximum fire main operating pressure, shield. as a source of breathing air, only units whichever is greater. Hose stored in outside 3. Alternative or dedicated shutdown approved for breathing air shall be urede, hose houses shall be testedannually. Interior capability and its associated circuits," compressors shall be operable assuming a standpipe hose shall be tested every three independent of cables, systems or loss of offaite power. Special cam must be years. components in the area, room or zone wider taken to locate the compressor in areas free F. Automatic Fire Detection consideration, shall be provided: of dust and contaminants.

Automatic fire detection systems shall be a. Where the protection of systems whose I. FYre Brigade Training i.at a_alltd in-r1-nar nf thenplant that contain function is required for hot shutdown does The fire brigade training pra 'am shall or present an exposure fire hazard to safe not satisfy the requirement of paragraph G.2 ensure that the capability to B&ght potential shutdown or safety-related systems or of this section; or fires is established and naintaini The components. These fire detection systems b. Where redundant trains of systems program shall consist of = initi clasmm shall be capable of operating with or without required for hot shutdown located in the instruction program followed by periodic.

offsite power. same fire area may be subject to damage classroom instruction, fire fighti practi G. FireProtection of Safe Shutdown " ,nr fire suppression activities or from the and fire drills:

Capability rupture or inadvertent operation of fire 1. Instruction

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

important to safe shutdown. These features suppression system shall be installed in the (1) Indoctrination of the plant fire fighting shall be capable of limiting fire damage so area, room, or zone under consideration. plan with specific identification of each that- H. Fire Brigade individual's responsibilities.

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

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

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

can be repaired within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. sufficient training in or knowledge of plant including access and egress routes to each

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

this section, where cables or equipment, effects of fire and fire suppressants on safe (5) The proper use of available fire fighting including associated non-safety circuits that shutdown capability. The qualification of fire equipment and the conect method of fighting could prevent operation or cause brigade members shall include an annual each type of fire. The types of fir covered maloperation due to hot shorts, open circuits, physical examination to determine their should include fires in energized electrical or shorts to ground, or redundant trains of ability to perform stenuous fire fighting equipment, fires in cables and cable trays.

systems necessary to achieve and maintain activities. The shift supervisor shall not be a hydrogen fires, fires involving flammable and hot shutdown conditions are located within member of the fire brigade. The brigade combustible liquids or haadpus process the same fire area outside of primary leader shall be competent to assess the chemicals, fires resulting from construction or containment, one of the following means of potential safety consequences of a fire and modifications (welding), and record file fires.

advise control room personnel. Such (6) The proper use of communication.

ensuring that one of the redundant trains Is free of fire damage shall be provided:

competence by the brigade leader may be lighting, ventilation, and emergency breathing a. Separation of cables and equipment and evidenced by possession of an operator's equipment.

associated non-safety circuits of redundant license or equivalent knowledge of plant (7) The proper method for fighting fires trains by a fire barrier having a 3-hour rating. safety-related systems. inside buildings and confined spaces.

The minimum equipment provided for the (8) The direction and coordination of the Structural steel forming a part of or brigade shall consist of personal protective supporting such fire barriers shall be fire fighting activities (fire brigade leaders equipment such as turnout coats, boots, only).

protected to provide fire resistance gloves, hard hats, emergency communications equivalent to that required of the barrier: (9) Detailed revie'w., of fire fighting equipment, portable lights, portable strategies and procedures.

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

20 feet with no intervening combustible or fire fighting plans.

masks approved by NIOSH (National fire hazards. In addition, fire detectors and an Note.-Itenms (9) and (10) may be .deleted automatic fire suppression system shall be 6 Alternative shutdown capability is provided by from the training of no more than two of installed in the fire area; or non-operations personnel who may be rerouting, relocating or modificpting of existing c. Enclosure of cable and equipment and systems; dedicated shutdown capability is provided assigned to the fire brigade.

associated non-safety circuits of one by installing new structures and systems for the b. The instruction shall be provided by redundant train in a fire barrier having a 1- function of post-fire shutdown. qualified individuals who ae knowledgeable,

76614 Federal Register / Vol. 45, No. 225 / Wednesday, November 19, 1950 / Rules and Regulations experienced, and suitably trained in fighting brigade, and selection, placement and use of required additional fire protection in the the types of fires that could occur in the plant equipment, and fire fighting strategies. work activity procedure.

and in using the types of equipment available 12) Assessment of each brigade member's 5. Govern the use of ignition sources by use in the nuclear power plant. knowledge of his or her role in the fire of a flame permit system to control welding.

c. Instruction shall be provided to all fire fighting strategy for the area assumed to flame cutting, brazing, or soldering brigade members and fire brigade leaders. contain the fire. Assessment of the brigade operations. A separate permit shall be issued d. Regular planned meetings shall be held member's conformance with established for each area where work is to be done. If at least every 3 months for all brigade plant fire fighting procedures and use of fire work continues over more than one shift, the members to review changes in the fire fighting equipment, including self-contained permit shall be valid for not more than 24.

protection program and other subjects as emergency breathing apparatus, hours when the plant is operating or for the necessary. communication equipment, and ventilation duration of a.particular job during plant e. Periodic refresher training sessions shall equipment, to the extent practicable. shutdown.

be held to repeat the classroom instruction (3) The simulated use of fire fighting 6. Control the removal from the area of all program for all brigade members over a two- equipment required to cope with the situation waste, debris, scrap, oil spills, or other year period. These sessions may be and type of fire selected for the drill. The combustibles resulting from the work activity concurrent with the regular planned area and type of fire chosen for the drill immediately following completion of the meetings. should differ from those used in the previous activity, or at the end of each work shift,

2. Practice drill-so that brigade members are trained in whichever comes first.

Practice sessions shall be held for each fighting fires in various plant areas. The 7. Maintain the periodic housekeeping

.shift fire brigade on the proper method of situation selected should simulate the size inspections to ensure continued compliance fighting the various types of fires that could and arrangement of a fire that could with these administrative controls.

occur in a nuclear power plant. These reasonably occur in the area selected, 8. Control the use of specific combustibles sessions shall provide brigade members with allowing for fire development due to the time in safety-related areas. All wood used in experience in actual fire extinguishment and required to respond, to obtain equipment, and safety-related areas during maintenance, the use of emergency breathing apparatus organize for the fire, assuming loss of modification, or refueling operations (such as u.nder strenuous conditions encountered in automatic suppression capability. lay-down blocks or scaffolding) shall be fire fighting. These practice sessions shall be (4) Assessment of brigade leader's treated with a flame retardant. Equipment or provided at least once per year for each fire direction of the fire fighting effort as to supplies (such as new fuel) shipped in brigade member. thoroughness, accuracy, and effectiveness. untreated combustible packing containers

3. Drills 4. Records .may be unpacked in safety-related areas if a. Fire brigade drills shall be performed in Individual records of training provided to required for valid operating reasons.

the plant so that the fire brigade can practice each fire brigade member, including drill However, all combustible materials shall be as a team. critiques, shall be maintained for at least 3 removed from the area immediately following Sb. Drills shall be performed at regular years to ensure that each member receives the unpacking. Such transient combustible intervals not to exceed 3 months for each training in all parts of the training program. material, unless stored in approved shift fire brigade. Each fire brigade member These records of training shall be available containers, shall not be left unattended should participate in each drill, but must for NRC review. Retraining or broadened during lunch breaks, shift changes, or other participate in at least two drills per year. training for fire fighting within buildings shall similar periods. Loose combustible packing A sufficient number of these drills, but not be scheduled for all those brigade members material such as wood or paper excelsior, or less than one for each shift fire brigade per whose performance records show polyethylene sheeting shall be placed in year, shall be unannounced to determine the deficiencies. metal containers with tight-fitting self-closing fire fighting readiness of the plant fire J.Emergency Lighting metal covers.

brigade, brigade leader, and fire protection Emergency lighting units with at least an 8- 9. Control actions to be taken by an systems end equipment. Persons planning hour battery power supply shall be provided individual discovering a fire, for example, and authorizing an unannounced drill shall in all areas needed for operation of safe notification of control room, attempt to ensure that the responding shift fire brigade shutdown equipment and in access and extinguish fire, and actuation of local fire members are not aware that a drill is being egress routes thereto. suppression systems.

planned until it is begun. Unannounced drills K. Administrative Controls 10. Control actions to be taken by the shall not be scheduled closer than four Administrative Controls shall be control room operator to determine the need weeks. established to minimize fire hazards in areas for brigade assistance upon report of a fire or At least one drill per year shall be containing structures, systems, and receipt of alarm on control room annunciator performed on a "back shift" for each shift fire components important to safety. These panel, for example, announcing location of brigade. controls shall establish procedures to: fire over PA system, sounding fire alarms, c. The drills shall be preplanned to 1. Govern the handling and limitation of the and notifying the shift supervisor and the fire establish the training objectives of the drill use of ordinary combustible materials, brigade leader of the type, size, and location and shall be critiqued to determine how well combustible and flammable gases and of the fire.

the training objectives have been met. liquids, high efficiency particulate air and 11. Control actions to be taken by the fire Unannounced drills shall be planned and charcoal filters, dry ion exchange resins, or brigade after notification by the control room critiqued by members of the management other combustible supplies in safety-related operator of a fire, for example, assembling in staff responsible for plant safety and fire areas. a designated location, receiving directions protection. Performance deficiencies of a fire 2. Prohibit the storage of combustibles in from the fire brigade leader, and discharging brigade or of individual fire brigade members safety-related areas or establish designated specific fire fighting responsibilities including shall be remedied by scheduling additional storage areas with appropriate fire selection and transportation of fire fighting training for the brigade or members. protection. equipment to fire location, selection of Unsatisfactory drill performance shall be 3. Govern the handling of and limit protective equipment, operating instructions followed by a repeat drill within 30 days. transient fire loads such as combustible and for use of fire suppression systems, and use d. At 3-year intervals, a randomly selected flammable liquids, wood and plastic of preplanned strategies for fighting fires in unannounced drill shall be critiqued by products, or other combustible materials in specific areas.

qualified individuals independent of the buildings containing safety-related systems 12. Define the strategies for fighting fires in licensee's staff. A copy of the written report or equipment during all phases of operating. all safety-related areas and areas presenting from such individuals shall be available for and especially during maintenance, a hazard to safety-related equipment. These NRC review.I modification, or refueling operations. strategies shall designate:

e. Drills shall as a minimum include the 4. Designate the onsite staff member a. Fire hazards in each area covered by the following: responsible for the inplant fire protection specific prefire plans.

(1) Assessment of fire alarm effectiveness, review of proposed work activities to identify b. Fire extinguishants best suited for time required to notify and assemble fire potential transient fire hazards and specify controlling the fires associated with the fire

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

of these extinguishants. BWRs and be within the level indication in conduits containing associated circuits of one c. Most-favorable direction from which to the pressurizer for PWRs. safe shutdown division and trays and attack a fire in each area in view of the c. The reactor heat removal function shall conduits containing associated circuits or ventilation direction, access hallways, stairs, be capable of achieving and maintaining safe shutdown cables from the redundant and doors that are most likely to be free of decay heat removal. division, or the isolation of these associated fire, and the best station or elevation for d. The process monitoring function shall be circuits from the safe shutdown equipment;

fighting the fire. All access and egress routes capable of providing direct readings of the shall be such that a postulated fire involving that involve locked doors should be process variables necessary to perform and associated circuits will not prevent -safe specifically identified in the procedure with control the above functions. shutdown.,

the appropriate precautions and methods for e. The supporting functions shall be M. Fire BarrierCable PenetratiOhSeal access specified. capable of providing the process cooling, Qualification d. Plant systems that should be managed to lubrication, etc., necessary to permit the Penetration seal designs shall utiliz;.e only reduce the damage potential during a local operation of the equipment used for safe noncombustible materials and shall be'

fire and the location of local and remote shutdown functions. qualified by tests that are comparable to tests controls for such management (e.g., any 3. The shutdown capability for specific fire used to rate fire barriers. The acceptance hydraulic or electrical systems in the zone areas may be unique for each such area, or it criteria for thetest shall include: "

covered by the specific fire fighting procedure may be one unique combination of systems 1. The cable fire barrier penetration seal that could increase the hazards in the area for all such areas. In either case, the has withstood the fire endurance test without because of overpressurization or electrical alternative shutdown capability shall be passage of flame or ignition of cables on thd hazards). independent of the specific fire area(s) and unexposed side for a period of time e. Vital heat-sensitive system components shall accommodate postfire conditions where equivalent to the fire resistance rating that need to be kept cool while fighting a offaite power is available and where offaite required of the barrier, ,..  : . I.....

local fire. Particularly hazardous power is not avfailable for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. 2. The temperature levels recordedfor the combustibles that need cooling should be Procedures shall be In effect to implement unexposed side are. analyzed and.

unto" Uc.. n...JI'..

ue ffigne..

Lu. deine*nte'~ that th_ mnirnmm temperature f. Organization of fire fighting brigades and 4. If the capability to achieve and maintain is sufficiently below the cable insulatlon..

the assignment of special duties according to cold shutdown will not be available because ignition temperature; and  :' : '

job title so that all fire fighting functions are of fire damage, the equipment and systems 3.The fire barrier penetration seal remains covered by any complete shift personnel comprising the means to achieve and intact and does not allow projection:of water complement. These duties include command maintain the hot standby or hot shutdown beyond the unexposed surface during the control of the brigade, transporting fire condition shall be capable of maintaining hose stream test.

suppression and support equipment to the fire such conditions until cold shutdown can be N. Fire Doom scenes, applying the extinguishant to the fire, achieved. If such equipment and systems will Fire doors shall be self-closing or provided communication with the control room, and not be capable of being powered by both with closing mechanisms and shall be coordination with outside fire departments. onsite and offsite electric power systems inspected semiannually to verify that g.Potential radiological and toxic hazards because of fire damage, an independent automatic hold-open, release, and closing in fire zones. onsite power system shall be provided. The mechanisms and latches are operable.

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

containment or smoke clearing operations. be on site at all times. 1. Fire doors shall be kept closed and i.Operations requiring control room and 5. Equipment and systems comprising the electrically supervised at a continuously shift engineer coordination or authorization. means to achieve and maintain cold manned location;

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

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

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

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

conditions within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and maintain cold independnet onsite power system shall be Areas protected by automatic total flooding shutdown conditions thereafter. During the provided. Equipment and systems used after gas suppression systems shall have postfire shutdown, the reactor coolant system 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> may be powered by offsite power electrically supervised self-closing fire doors process variables shall be maintained within only. or shall satisfy option I above.

those predicted for a loss of normal s.c. 6. Shutdown systems installed to ensure

0. Oil Collection System for Reactor power, and the fission product boundary postfire shutdown capability need not be Coolant Pump integrity shall not be affected; i.e., there shall designed to meet seismic Category I criteria, The reactor coolant pump shall be be no fuel clad damage, rupture or any single failure criteria, or other design basis equipped with an oil collection system if the primary coolant boundary, or rupture of the. accident criteria, except where required for containment is not inerted during normal containment boundary. other reasons, e.g., because of interface with operation. The oil collection system shall be

2.The performance goals for the shutdown or impact on existing safety systems, or so designed, engineered, and installed that functions shall be: because of adverse valve actions due to fire failure will not lead to fire during normal or a. The reactivity control function shall be damage. design basis accident conditions and that capable of achieving and maintaining cold 7. The safe shutdown equipment and shutdown reactivity conditions. systems for each fire area shall be known to NAn acceptable method of complying with this b. The reactor coolant makeup function be isolated from associated non-safety alternative would be to meet Regulatory Guide 1.75 position 4 related to associated circuits and IEEE

shall be capable of maintaining the reactor circuits in the fire area so that hot shorts, Std 384-1974 [Section 4.5) where trays from open circuits, or shorts to ground in the redundant safety divisions are soprotected that

7As defined in the Standard Technical associated circuits will not prevent operation postulated fires affect trays from only one safety Specifications. of the safe shutdown equipment. The division.

76616 Federal Register / Vol. 45, No. 225 / Wednesday, November 19, 1980 / Rules and Regulations there is reasonable assurance that the system:

will withstand the Safe Shutdown Earthquake Such collection systems shall be capable of collecting lube oil from all potential pressurized and unpressurized leakage sites in the reactor coolant pump lube oil systems.

Leakage shall be collected and drained to a vented closed container that can hold the entire lube oil system inventory. A flame arrester is required in the vent if the flash point characteristics of the oil present the hazard of fire flashback. Leakage points to be protected shall include lift pump and piping, overflow lines, lube oil cooler, oil fill and drain lines and plugs, flanged connections on oil lines, and lube oil reservoirs where such features exist on the reactor coolant pumps.

The drain line shall be large enough to accommodate the largest potential oil leak.

(Sec. 161b, Pub. L 83-703, 68 Stat. 948; sec. 201, Pub. L 93-438, 88 Stat. 1242 (42 U.S.C.

Z201(b), 5841))

Dated at Washington, D.C.. this 17th day of November 1980.

For the Nuclear Regulatory Commission..

Samuel J. Cbilk,.

Secretary of the Commission.

l*Ft Doe. a3.0-17s Filed 8:-is-.a

45 am]

BILLING CODE 76901-U

9 See Regulatory Guide 1.29--"Seismic Design Classification" Paragraph C.2.

Enclosure 2 SUMMARY OF STAFF REQUIREMENTS

TO RESOLVE OPEN ITEMS

TROJAN NUCLEAR PLANT

DOCKET NO. 50-344 No open items.