ML080700157

NFPA 805 Transition Pilot Plant FAQ 06-0025, Revision 5

ML080700157
Person / Time
Site:	Harris
Issue date:	03/10/2008
From:	Holder A Progress Energy Carolinas
To:	Office of Nuclear Reactor Regulation
References
FAQ 06-0025
Download: ML080700157 (6)

Text

FAQ Number 06-0025 FAQ Revision 5 FAQ Title Scope and Content of Pre-Fire Plans Plant: Harris Nuclear Plan (HNP) Date: December 20, 2007 Contact: Alan Holder Phone: 919-546-3372 Email: alan.holder@pgnmail.com Distribution: (NEI Internal Use) 805 TF FPWG FPRATF Purpose of FAQ:

FAQ seeks clarification to define the minimum acceptable scope and content for Pre-Fire Plans.

Is this Interpretation of guidance? Yes / No Proposed new guidance not in NEI 04-02? Yes / No Details:

NEI 04-02 guidance needing interpretation (include section, paragraph, and line numbers as applicable):

NEI 04-02, Section 4.3.1, Fundamental Fire Protection Program and Design Elements Transition Review, should refer to a new appendix which lists interpretation of specific sections of NFPA 805 Chapter 3 Circumstances requiring guidance interpretation or new guidance:

Clarification of NFPA-805, Standard for Fire Protection for Light Water Reactor Electric Generating Plants (2001 Edition), Chapter 3, Section 3.4, Industrial Fire Brigade, section 3.4.2.1, The plans shall detail the fire area configuration and fire hazards to be encountered in the fire area, along with any nuclear safety components and fire protection systems and features that are present.

Due to the variance in formats, level of detail and content found in current pre-fire plans, desire for standardization and ease of product quality assessment and regulatory enforcement indicates the need for further guidance. Specifically, define the minimum acceptable scope and content for Pre-Fire Plans.

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FAQ Number 06-0025 FAQ Revision 5 FAQ Title Scope and Content of Pre-Fire Plans Detail contentious points if licensee and NRC have not reached consensus on the facts and circumstances:

NA Potentially relevant existing FAQ numbers:

FAQ #06-0007 Response Section:

Proposed resolution of FAQ and the basis for the proposal:

This FAQ seeks to define minimum acceptable pre-fire plan scope and content. Current guidance is found in regulatory documents such as 10CFR50, Appendix R, Section K, NUREG 0800 Section BTP CMEB 9.5-1 Rev 3 July 1981 Section 9.5.1 C.2(o) and Generic Letter 77-02 (FRAQA letter). See comparison table below (Note the table is for Deleted: (

reference only and will not be included in NEI 04-02). This FAQ provides clarification Deleted: s for continued use of this scope and content through inclusion in NEI 04-02, Appendix K. Deleted: )

Deleted: not During development of the FAQ, Regulatory Guide 1.189 Revision 1 was issued, Deleted: to while not a part of a transitioning plants CLB, this guidance included two additional topical areas for pre-fire plans.

Section 3.5.1.3(c) ii. SSCs credited for fire safe shutdown Section 3.5.1.3(c) xii. Communications between the fire brigade leader, fire brigade, offsite mutual aid responders, control room, and licensees emergency response organization Identification of components credited for safe shutdown (now nuclear safety Deleted: SS performance criteria) is satisfied by NFPA 805, Section 3.4.2.1, and would be Deleted: C included in Pre-Fire Plans to the extent appropriate for fire fighting as described in bullets four, five, and eleven (new) in the proposed NFPA 805, Section 3.4 Deleted: and Clarification. All components credited for the nuclear safety performance criteria are Deleted: SSC not specifically called out in the pre-fire plans. Due to the voluminous and highly Deleted: safe Shutdown detailed nature of such a list, this would be of little value and would be distracting for the fire brigade to attempt to use. However, nuclear safety performance criteria Deleted: safe shutdown components which require entry to the affected fire area should be listed. Deleted: systems and Deleted: directly impact operational Inclusion of communications is described separately in NFPA 805 Section 3.4.2.4. aspects of firefighting, This guidance is reflected in the sixth and tenth bullets of the specific clarification Deleted: re-proposed below. Deleted: a Deleted: involved area or may be impacted by specific fire scenarios within a fire area would be identified.

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FAQ Number 06-0025 FAQ Revision 5 FAQ Title Scope and Content of Pre-Fire Plans Formatted Table NUREG 0800 Generic Letter 77-02 NFPA 805 Appendix A (BTPCMEB 9.5-1 Rev 3 July 1981) 10CFR50, Appendix R (III.K.12)

FRACQA Letter (06/20/77) (FAQ 06-0025)

Section 9.5.1 C.2(o)

Define the strategies for fighting Define the strategies for fighting The strategies established for As a minimum, the pre-fire plans fires in all safety-related areas and fires in all safety-related areas fighting fires in all safety-related should include a description of areas presenting a hazard to safety- and areas presenting a hazard to areas and areas presenting a the following:

related equipment. These safety-related equipment. These hazard to safety-related strategies should designate: strategies should designate: equipment. As a minimum the following subjects should be covered:

Fire hazards in each area covered Fire hazards in each area Identification of combustibles in by the specific pre-fire plans. covered by the specific pre-fire each plant zone covered by the plans. specific fire fighting procedures.

Fire extinguishants best suited for Fire extinguishants best suited for Fire extinguishants best suited for Available fire protection systems controlling the fires associated with controlling the fires associated controlling the fires associated Fire extinguisher locations the fire hazards in that area and the with the fire hazards in that area with the combustible loadings in nearest location of these and the nearest location of these that zone and the nearest location extinguishants. extinguishants. of these extinguishants.

Most favorable direction from which Most favorable direction from Most favorable direction from Fire barriers to attack a fire in each area in view which to attack a fire in each area which to attack a fire in each Fire doors of the ventilation direction, access in view of the ventilation direction, area, in view of the ventilation Locked doors hallways, stairs, and doors that are access hallways, stairs, and direction, access hallways, stairs most likely to be free of fire, and the doors that are most likely to be and doors which are most likely to Inaccessible of limited access best station or elevation for fighting free of fire, and the best station or be fire-free, and the best station areas the fire. All access and egress elevation for fighting the fire. All or elevation for fighting the fire. A routes that involve locked doors access and egress routes that specific identification system shall should be specifically identified in involve locked doors should be designate all hallways, stairs, the procedure with the appropriate specifically identified in the doors fire equipment and system precautions and methods for access procedure with the appropriate control locations, and other items specified. precautions and methods for described in the fire fighting access specified. procedures. This identification should be used in the procedures and the corresponding plant items should be prominently marked so that they can be recognized in Page 3 of 6

FAQ Number 06-0025 FAQ Revision 5 FAQ Title Scope and Content of Pre-Fire Plans Formatted Table NUREG 0800 Generic Letter 77-02 NFPA 805 Appendix A (BTPCMEB 9.5-1 Rev 3 July 1981) 10CFR50, Appendix R (III.K.12)

FRACQA Letter (06/20/77) (FAQ 06-0025)

Section 9.5.1 C.2(o) dim light. All access and egress routes that involve locked doors should be specifically identified in the procedure with the appropriate precautions and methods for access specified. Deleted: ¶

¶ Plant systems that should be Plant systems that should be Designation of plant systems that Safe shutdown equipment managed to reduce the damage managed to reduce the damage should be managed to reduce the potential during a local fire and the potential during a local fire and damage potential during a local location of local and remote controls the location of local and remote fire; location of local and remote for such management (e.g., any controls for such management controls for such management hydraulic or electrical systems in the (e.g., any hydraulic or electrical (e.g., any hydraulic or electrical zone covered by the specific fire systems in the zone covered by systems in the zone covered by fighting procedure that could the specific fire fighting procedure the specific fire fighting procedure increase the hazards in the area that could increase the hazards in that cold increase the hazards in because of overpressurization or the area because of the area because of electrical hazards). overpressurization or electrical overpressurization or electrical hazards). hazards). Deleted: ¶

¶ Vital heat-sensitive system Vital heat-sensitive system Designation of vital heat-sensitive components that need to be kept components that need to be kept system components that need to cool while fighting a local fire. cool while fighting a local fire. be kept cool while fighting a local Particularly hazardous combustibles Particularly hazardous fire. Critical equipment which are that need cooling should be combustibles that need cooling particularly hazardous designated. should be designated. combustible sources should be designated to receive cooling.

Organization of fire fighting brigades Organization of fire fighting Organization of fire fighting Communication equipment and the assignment of special brigades and the assignment of brigades and the assignment of duties according to job title so that special duties according to job special duties according to job all fire fighting functions are covered title so that all fire fighting title so that all fire fighting by any complete shift personnel functions are covered by any functions are covered by any complement. These duties include complete shift personnel complete shift personnel Page 4 of 6

FAQ Number 06-0025 FAQ Revision 5 FAQ Title Scope and Content of Pre-Fire Plans Formatted Table NUREG 0800 Generic Letter 77-02 NFPA 805 Appendix A (BTPCMEB 9.5-1 Rev 3 July 1981) 10CFR50, Appendix R (III.K.12)

FRACQA Letter (06/20/77) (FAQ 06-0025)

Section 9.5.1 C.2(o) command control of the brigade, complement. These duties complement. These duties transporting fire suppression and include command control of the include command control of the support equipment to the fire brigade, transporting fire brigade, fire hose laying, applying Deleted: p scenes, applying the extinguishant suppression and support the extinguishant to the fire, to the fire, communication with the equipment to the fire scenes, advancing support supplies to the Deleted: p control room, and coordination with applying the extinguishant to the fire scene, communication with outside fire departments. fire, communication with the the control room, coordination control room, and coordination with outside fire departments.

with outside fire departments.

Potential radiological and toxic Potential radiological and toxic Identification radiological and Radiological hazards hazards in fire zones hazards in fire zones. toxic hazards in fire zones. Special hazards Pre-fire plans should detail radiologically hazardous areas and radiation protection barriers.

Ventilation system operation that Ventilation system operation that Ventilation system operation that Ventilation capabilities ensures desired plant air distribution ensures desired plant air ensures desired plant air Methods of smoke and heat when the ventilation flow is modified distribution when the ventilation pressure distribution when the removal should be identified for for fire containment or smoke flow is modified for fire ventilation flow is modified for fire all fire areas in the pre-fire plans.

clearing operation. containment or smoke clearing containment or smoke clearing These can include the use of operation. operations. dedicated smoke and heat removal systems or use of the structures heating ventilating and air-conditioning (HAC) system if it can operate in the 100 percent exhaust mode.

Operations requiring control room Operations requiring control room Operations requiring control room Areas subject to flooding and shift engineer coordination or and shift engineer coordination or and shift engineer coordination or Water drainage methods should authorization. authorization. authorization. be reviewed and included in the pre-fire plan for each area.

Instructions for plant operators and Instructions for plant operators Instructions for plant operators general plant personnel during fire. and general plant personnel and general plant personnel during fire. during fire.

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FAQ Number 06-0025 FAQ Revision 5 FAQ Title Scope and Content of Pre-Fire Plans If appropriate, provide proposed rewording of guidance for inclusion in the next Revision:

Clarification of specific sections of NFPA 805 as applied under 10 CFR 50.48(c), will be included in a new Appendix K, to NEI 04-02 (final formatting to be provided by NEI).

Include the following information in Appendix K:

NFPA 805, Section 3.4 Clarification:

As a minimum, the pre-fire plans should define the strategies for fighting fires in all areas in which a fire could jeopardize the ability to meet the performance criteria described in Section 1.5. These pre-fire plans should designate:

• Fire hazards in each area covered by the specific pre-fire plans.

• Fire extinguishants best suited for controlling the fires associated with the fire hazards in that area and the nearest location of these extinguishants.

• Most favorable direction from which to attack a fire in each area in view of the ventilation direction, access hallways, stairs, and doors that are most likely to be free of fire, and the best station or elevation for fighting the fire. All access and egress routes that involve locked doors should be specifically identified in the procedure with the appropriate precautions and methods for access specified.

• Plant systems that should be managed to reduce the damage potential during a local fire and the location of local and remote controls for such management (e.g., any hydraulic or electrical systems in the zone covered by the specific fire fighting procedure that could increase the hazards in the area because of overpressurization or electrical hazards).

• Vital heat-sensitive system components that need to be kept cool while fighting a local fire. Particularly hazardous combustibles that need cooling should be designated.

• Organization of fire fighting brigades and the assignment of special duties according to job title so that all fire fighting functions are covered by any complete shift personnel complement. These duties include command control of the brigade; transporting fire suppression and support equipment to the fire Deleted: p scenes, applying the extinguishant to the fire, communication with the control room, and coordination with outside fire departments.

• Potential radiological and toxic hazards in fire zones Deleted: Safe Shutdown

• Ventilation system operation that ensures desired plant air distribution when the Deleted: systems or c ventilation flow is modified for fire containment or smoke clearing operation. Deleted: in the affected fire area

• Operations requiring control room and shift engineer coordination or Formatted: Bullets and Numbering authorization. Deleted: present an operational

• Instructions for plant operators and general plant personnel during fire. impact to the fire brigade, which Deleted: re-

• Components necessary to achieve the nuclear safety performance criteria which require entry to the affected fire area, Deleted: , or which are affected by fire area specific fire conditions or extent of fire damage within the affected area Page 6 of 6