ML073550021

NFPA 805 Transition Pilot Plant FAQ 06-0025, Revision 4

ML073550021
Person / Time
Site:	Harris
Issue date:	12/20/2007
From:	Holder A Progress Energy Carolinas
To:	Office of Nuclear Reactor Regulation
References
FAQ 06-0025, Rev 4
Download: ML073550021 (7)

Text

FAQ Number 06-0025 FAQ Revision 4 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 4 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 table is for reference only and not to be included in NEI 04-02. This FAQ provides clarification for continued use of this scope and content through inclusion in NEI 04-02, Appendix K.

During development of the FAQ, Regulatory Guide 1.189 Revision 1 was issued, 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 SSCs credited for safe shutdown (now nuclear safety performance criteria) is satisfied by NFPA 805, Section 3.4.2.1, and would be included in Pre-Fire Plans to the extent appropriate for fire fighting as described in bullets four and five.

Inclusion of communications is described separately in NFPA 805 Section 3.4.2.4.

This guidance is reflected in the sixth and tenth bullets of the specific clarification proposed below.

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FAQ Number 06-0025 FAQ Revision 4 FAQ Title Scope and Content of Pre-Fire Plans NUREG 0800 (BTPCMEB 9.5-1 Rev 3 July Generic Letter 77-02 NFPA 805 Appendix A 10CFR50, Appendix R (III.K.12) 1981) 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 and fighting fires in all safety-related should include a description of the areas presenting a hazard to areas presenting a hazard to areas and areas presenting a following:

safety-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 covered Identification of combustibles in by the specific pre-fire plans. by the specific pre-fire plans. each plant zone covered by the 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 controlling the fires associated controlling the fires associated Fire extinguisher locations with the fire hazards in that area with the fire hazards in that area with the combustible loadings in and the 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 Most favorable direction from Most favorable direction from Fire barriers which to attack a fire in each area which to attack a fire in each area which to attack a fire in each area, Fire doors in view of the ventilation direction, in view of the ventilation direction, in view of the ventilation direction, Locked doors access hallways, stairs, and doors access hallways, stairs, and doors access hallways, stairs and doors that are most likely to be free of that are most likely to be free of which are most likely to be fire- Inaccessible of limited access fire, and the best station or fire, and the best station or free, and the best station or areas elevation for fighting the fire. All elevation for fighting the fire. All elevation for fighting the fire. A access and egress routes that access and egress routes that specific identification system shall involve locked doors should be involve locked doors should be designate all hallways, stairs, specifically identified in the specifically identified in the doors fire equipment and system procedure with the appropriate procedure with the appropriate control locations, and other items precautions and methods for precautions and methods for described in the fire fighting access specified. access specified. procedures. This identification should be used in the procedures and the corresponding plant items should be prominently marked so Page 3 of 7

FAQ Number 06-0025 FAQ Revision 4 FAQ Title Scope and Content of Pre-Fire Plans NUREG 0800 (BTPCMEB 9.5-1 Rev 3 July Generic Letter 77-02 NFPA 805 Appendix A 10CFR50, Appendix R (III.K.12) 1981) FRACQA Letter (06/20/77) (FAQ 06-0025)

Section 9.5.1 C.2(o) that they can be recognized in 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.

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

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 Particularly hazardous fire. Critical equipment which are combustibles that need cooling combustibles that need cooling particularly hazardous should be designated. should be designated. combustible sources should be designated to receive cooling.

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FAQ Number 06-0025 FAQ Revision 4 FAQ Title Scope and Content of Pre-Fire Plans NUREG 0800 (BTPCMEB 9.5-1 Rev 3 July Generic Letter 77-02 NFPA 805 Appendix A 10CFR50, Appendix R (III.K.12) 1981) FRACQA Letter (06/20/77) (FAQ 06-0025)

Section 9.5.1 C.2(o)

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

with outside fire departments. with outside fire departments.

Potential radiological and toxic Potential radiological and toxic Identification radiological and toxic Radiological hazards hazards in fire zones hazards in fire zones. 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 ensures desired plant air ensures desired plant air pressure Methods of smoke and heat distribution when the ventilation distribution when the ventilation distribution when the ventilation removal should be identified for all flow is modified for fire flow is modified for fire flow is modified for fire fire areas in the pre-fire plans.

containment or smoke clearing containment or smoke clearing containment or smoke clearing These can include the use of operation. 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 Page 5 of 7

FAQ Number 06-0025 FAQ Revision 4 FAQ Title Scope and Content of Pre-Fire Plans NUREG 0800 (BTPCMEB 9.5-1 Rev 3 July Generic Letter 77-02 NFPA 805 Appendix A 10CFR50, Appendix R (III.K.12) 1981) FRACQA Letter (06/20/77) (FAQ 06-0025)

Section 9.5.1 C.2(o) 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 Instructions for plant operators Instructions for plant operators and general plant personnel and general plant personnel and general plant personnel during fire. during fire. during fire.

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FAQ Number 06-0025 FAQ Revision 4 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

• Ventilation system operation that ensures desired plant air distribution when the ventilation flow is modified for fire containment or smoke clearing operation.

• Operations requiring control room and shift engineer coordination or authorization.

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

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