ML21092A136

Rev 4 Public Comments ACRS Version

ML21092A136
Person / Time
Issue date:	05/05/2021
From:	Office of Nuclear Regulatory Research
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References
DG-1359, RG-1.189, Rev 4
Download: ML21092A136 (14)

Text

Draft Version for use at ACRS Full Committee Meeting on May 5, 2021 Response to Public Comments on Draft Regulatory Guide DG-1359 Fire Protection for Nuclear Power Plants Proposed Revision 4 of Regulatory Guide (RG) 1.189 On December 16, 2020, the NRC published a notice in the Federal Register (85 FR 73089) that Draft Regulatory Guide, DG-1359 (Proposed Revision 4 of RG 1.189), was available for public comment. The Public Comment period ended on December 31, 2020. The NRC received comments from the organizations listed below. The NRC has combined the comments and NRC staff responses in the following table.

Comments were received from the following:

Victoria K. Anderson Michael Keller Technical Advisor, Engineering & Risk 14713 Woodward St Nuclear Energy Institute (NEI) Overland Park, KS, 66223 1201 F Street NW, Suite 1100 ADAMS Accession No. ML21007A326 Washington DC 20004 Agencywide Document and Management System (ADAMS) Accession No. ML21007A325 Commenter Section of Specific Comment NRC Resolution DG-1359 Nuclear Energy Section A, Page 4 NUREG/CR-7135 CARMEN-FIRE is newly added The NRC staff agrees with this comment.

Institute (also Pages 20-21) to this section to discuss acceptable options for compensatory measures. This is not appropriate, as The NRC staff revised DG-1359 to delete this is not an official staff position. Industry had NUREG/CR-7135 CARMEN-FIRE from the substantial comments on NUREG/CR-7135, many guidance list in Section A (page 4), to delete the of which were not resolved due to the document paragraph on the NUREG/CR-7135 in Section being a research report, and not official agency position. 1.5, and to delete it from the references list.

Proposed resolution:

Remove the references to NUREG/CR-7135.

Draft Version for use at ACRS Full Committee Meeting on May 5, 2021 Commenter Section of Specific Comment NRC Resolution DG-1359 Nuclear Energy Section B, Page 9 The draft regulatory guide references the 2016 The NRC staff agrees with this comment and Institute (also Ref. 27, version of NEI 00-01, Revision 4, instead of the revised DG-1359 to refer to the December 2019 Page 115) 2019 version. version of NEI 00-04, Revision 4, in Section B (page 9) and the list of references.

Proposed resolution:

Revise to refer to the December 2019 version (ML19351D276)

Nuclear Energy Section 1.6.4.2, It is unclear what broadened training for The NRC staff disagrees with this comment. This Institute Page 25 firefighting within buildings is intended to convey. text was included in the initial issuance of Regulatory Guide 1.189 in 2001, and in the Proposed resolution: regulatory guides predecessor, Branch Technical Revise to provide clarity to this phrase. Position (BTP) CMEB 9.5-1, Guidelines for Fire Protection for Nuclear Power Plants, published in 1981.

The NRC staff made no changes to DG-1359 as a result of this comment.

Nuclear Energy Section 1.7.6, Page document or identify items does not fully The NRC staff agrees with this comment and Institute 28 clarify the intent. made the suggested change to DG-1359.

Proposed resolution:

Revise to identify and document items

Draft Version for use at ACRS Full Committee Meeting on May 5, 2021 Commenter Section of Specific Comment NRC Resolution DG-1359 Nuclear Energy Section 1.8.1.2, This section defines not adversely affect safe The NRC staff partially agrees and partially Institute Page 33 shutdown differently than GL 86-10 and GL 88-12 disagrees with this comment. The NRC staff did, by inserting new language about sufficient agrees that licensees are bound by their fire safety margins that did not exist in GL 86-10 and protection license condition, and not subsequent GL 88-12. guidance that licensees have not committed to follow or have been backfitted. Regulatory Existing licensees are bound by the meaning of the Guides provide one acceptable method to meet words not adversely affect safe shutdown that the NRC regulations, but other methods may be were understood at the time of their adoption of proposed.

their FP license conditions, and not bound by the new words here.

The cited text is identical to that included in Regulatory Guide 1.189 since Revision 1, which Proposed resolution:

was published in 2007. The cited language has Revise the language to the previous version for not prevented successful use of RG 1.189 by the consistency with GL 86-10 and GL 88-12.

industry and the staff.

The NRC staff made no changes to DG-1359 as a result of this comment.

Nuclear Energy Section 2.2.3, Page In the second paragraph, the use of the phrase The NRC staff agrees with this comment and Institute 43 Procedures and practices is not consistent with made the suggested change to DG-1359.

language used in the document.

Proposed resolution:

Replace with administrative controls Nuclear Energy Section 2.4.b, Page The use of where systems are disarmed is not The NRC staff agrees with this comment and Institute 44 sufficiently comprehensive. made the suggested change to DG-1359.

Proposed resolution:

Revise to where systems are disarmed or impaired

Draft Version for use at ACRS Full Committee Meeting on May 5, 2021 Commenter Section of Specific Comment NRC Resolution DG-1359 Nuclear Energy Section 3.5.1.4, The first paragraph should specify that drills are to The NRC staff agrees with this comment.

Institute Page 55 be conducted at least quarterly.

The NRC staff changed the first paragraph of Proposed resolution: Section 3.5.1.4 of DG 1359 to read:

Revise the first paragraph to read Drills should be performed at least quarterly Fire brigade drills should be performed in the plant so that the fire brigade can practice as a team. Drills should be performed at least quarterly for each shifts fire brigade. Each fire brigade member should participate in at least two drills annually that are not in the same quarter.

Nuclear Energy Section 3.5.1.4, The second paragraph should include more The NRC staff agrees with this comment.

Institute Page 55 information on conduct of unannounced drills.

The NRC staff added the following sentence to Proposed resolution: the second paragraph of Section 3.5.1.4 of DG-Unannounced drills should not be performed in a 1359:

pattern such that the shifts fire brigade can easily determine when the drill will occur (e.g. conducting Further, unannounced drills should not be a backshift drill after each day shift drill was performed in a pattern such that the shifts fire conducted.) brigade can easily determine when the drill will occur (e.g. conducting a backshift drill after each day shift drill was conducted.)

Nuclear Energy Section 3.5.1.4, This section should more explicitly discuss the The NRC staff agreed with this comment.

Institute Page 55 expectations for the drill team.

The NRC staff added the following sentence to Proposed resolution: the second paragraph of Section 3.5.1.4 of DG-At end of first sentence of the fifth paragraph, add 1359:

to include the performance of not only the fire brigade and response, but the ability of the drill to include the performance of not only the team to provide adequate simulation to elicit desired fire brigade and its response, but the ability of fire team response. the drill team to provide adequate simulation to elicit desired fire team response.

Draft Version for use at ACRS Full Committee Meeting on May 5, 2021 Commenter Section of Specific Comment NRC Resolution DG-1359 Nuclear Energy Section 3.5.2.1.b, The role of offsite fire departments should be better The NRC staff agrees with this comment.

Institute Page 56 articulated.

The NRC staff added the following sentence to Proposed resolution: the end of Section 3.5.2.1.b of DG-1359:

At the end of this section, add available and If adaptors are used, they should be available readily accessible to the offsite fire department.

and readily accessible to the offsite fire department.

Nuclear Energy Section 4.1.6.2, The emergency lighting and portable lighting The NRC staff agrees with this comment.

Institute Page 66 sections discuss sealed beam lamps. The term sealed beam specifically describes a specific type The NRC staff changed the first paragraph of of incandescent lamp manufacturing technology Section 4.1.6.2.a of DG-1359 to read:

that was predominant prior to the 1990s for automobile headlights. Retaining the term in the Fixed, self-contained lighting consisting of RG effectively prohibits modern lighting units with individual 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> minimum battery technology from being adopted. For example, power supplies should be provided in areas sealed beam would not permit a replaceable needed for operation of safe shutdown halogen bulb in a reflector. equipment and for access and egress routes to these areas.

Proposed resolution:

The term sealed beam should not be used in The NRC staff also changed Section 4.1.6.2.b of contemporary documents/standards, and a more DG-1359 to read:

inclusive term should be used.

Suitable battery-powered portable hand lights should be provided for emergency use by the fire brigade and other operations personnel required to achieve safe plant shutdown.

Draft Version for use at ACRS Full Committee Meeting on May 5, 2021 Commenter Section of Specific Comment NRC Resolution DG-1359 Nuclear Energy Section 5.0, Page 75 This final paragraph of this section includes new The NRC staff notes the comment. However, Institute language suggesting that there will be two the NRC staff disagrees with the suggested redundant trains, that they will perform the same resolution. This version consolidates text that safe shutdown functions, and that they are only has been in Regulatory Guide 1.189 since differentiated by electrical power division. That is Revision 1, published in 2007. The commenter appears to be confusing the concept of safe not the case in BWRs, where ECCS system shutdown system function (for example, functions and capacities are very diverse, there are inventory control or process monitoring) and many possible safe shutdown success paths, and capability (for example, gallons per minute of safe shutdown paths can be made from high- water flow). In order to clarify the intent, the capacity high pressure systems, low capacity high text has been changed to read:

pressure systems, low pressure systems, etc.

For the application of fire protection regulatory Proposed resolution: requirements, redundant trains of systems may Revise to remove the implication that there are only be two or more similar trains of equivalent two paths to safely shutdown a reactor, and that capacity in the same system powered by those two paths must have the same capabilities. separate electrical divisions, or they may be two or more separate systems that achieve the same post-fire safe shutdown function.

Nuclear Energy Section 5.3, Page Substantial discussion on MSOs has been added to The NRC staff agrees with this comment and Institute 76-77 Section 5.3 before the fundamental concepts of safe made the suggested changes to DG-1359.

shutdown have even been discussed. Discussing MSO before discussing fundamental safe shutdown criteria is very confusing to the reader.

Proposed resolution:

Move the new MSO endorsements to a suitable point after the fundamental concepts of safe shutdown have been discussed.

Draft Version for use at ACRS Full Committee Meeting on May 5, 2021 Commenter Section of Specific Comment NRC Resolution DG-1359 Nuclear Energy Section 5.3, Page 78 There is discussion on NEI 00-01, Revision 4, The NRC staff agrees with this comment.

Institute Chapter 3 in conjunction with the RG as being acceptable. A lot of the detail supporting Chapter 3 The NRC staff added the following sentence to is in Appendix J of NEI 00-01, Revision4, but there the beginning of Section 5.3.1 of DG-1359:

is no clear reference to Appendix J in this portion of the draft regulatory guide.

Chapter 3 and Appendix J of NEI 00-01, Proposed resolution: Revision 4, provides an acceptable deterministic Make a clear reference to Appendix J in conjunction methodology for the analysis of post-fire with Chapter 3 as it defines important and applicable safe-shutdown circuits, when applied in concepts such as incredible, plausible, etc. for circuit conjunction with this RG.

types. Recommend moving the endorsement sentence of NEI 00-01 Chapter 3 and Appendix J to the beginning of Section 5.3 because of its importance.

Draft Version for use at ACRS Full Committee Meeting on May 5, 2021 Nuclear Energy Section 5.3, Page 78 In Section 5.3, last paragraph, the discussion in The NRC staff agrees with this comment and Institute Section 5.3 contains criteria that has been refined deleted the cited criteria from DG-1359. As and changed by the NUREG/CR-7150 Vol. 3 noted in response to the previous public criteria, and by the NEI 00-01, Revision 4, criteria comment, Chapter 3 and Appendix J of NEI 00-in Chapter 3 and Appendix J, such that the stated 01, Revision 4, have been referred to in Section 5.3.

criteria are no longer comprehensive or fully accurate.

Proposed resolution:

These criteria should either be removed or described as one acceptable approach, along with NEI 00-01 Chapter 3 and Appendix J as another acceptable approach.:

For circuits not sealed in or latched for equipment important to safe shutdown, licensees should consider multiple fireinduced circuit failures in at least two separate cables. For circuits not sealed in or latched for equipment important to safe shutdown that involves high-low pressure interfaces, licensees should consider circuit failures in at least three cables. This applies when there are defense-indepth features, such as automatic suppression and limits on ignition sources and combustibles. When there are no defensein-depth features, the number of cables to consider should not be limited to two or three as described above. In addition, for multiconductor cables, all circuit faults that could occur within the cable should be assumed to occur.

The analysis should address all circuits for which fire-induced failure could prevent safe shutdown, and appropriate protection should be provided.

Draft Version for use at ACRS Full Committee Meeting on May 5, 2021 Commenter Section of Specific Comment NRC Resolution DG-1359 Nuclear Energy Section 5.3.2, Page Section 5.3.2 does not explicitly include DC The NRC staff agrees with this comment.

Institute 82-83 compound motors.

The NRC staff revised the first sentence of the Proposed resolution: last paragraph of Section 5.3.2 of DG-1359 to Include an explicit reference to DC compound read:

motors in Section 5.3.2.

The electrical expert PIRT panel, as documented in NUREG/CR-7150, Volume 3, has determined that the potential for a fire to cause hot shorts on all three phases in proper sequence of an AC power circuit to cause a spurious operation of a motor or two shorts of proper polarity on a DC compound-wound motor is incredible and need not be considered in the evaluation.

Nuclear Energy Section 5.3.2, Page There is also discussion on high impact components The NRC staff agrees with this comment.

Institute 82-83 in NUREG/CR-7150 and NEI 00-01, Revision 4, that provides more detailed guidance. The NRC staff revised Section 5.3.2 of DG-1359 to add the following at the end of the section:

Proposed resolution:

Include a reference to these treatments of high NUREG/CR-7150, Volume 3, also identified a impact components and circuit failure criteria as an set of high impact components whose fire-acceptable approach. induced failure could pose a significant threat to plant safety. Appendix J of NEI 00-01, Revision 4, identifies the circuit failure criteria and provides an acceptable approach for the treatment of these high impact components.

Draft Version for use at ACRS Full Committee Meeting on May 5, 2021 Commenter Section of Specific Comment NRC Resolution DG-1359 Nuclear Energy Section 5.4.3, Page The discussion on HLP circuit failures in the first The NRC staff agrees with this comment.

Institute 87 paragraph of this section has not been updated to reflect the latest information available. The NRC staff revised the paragraph in Section 5.4.3.b of DG-1359 to read:

Proposed resolution:

Include updates from NUREG/CR-7150 and NEI For consideration of spurious actuations, the 0001, Revision 4, based on credibility licensee should evaluate all possible functional determinations on three-phase AC/DC motors and failure states; that is, the component could be guidance in Appendix J of NEI 00-01 R4. energized or deenergized by one or more circuit failure modes (i.e., hot shorts, open circuits, and shorts to ground). Therefore, valves could fail open or closed, pumps could fail running or not running, or electrical distribution breakers could fail open or closed. For three-phase AC circuits, the probability of getting a hot short on all three phases in the proper sequence to cause spurious actuation of a motor is considered incredible and no further evaluation is required. Similarly, for ungrounded DC circuits, two shorts of proper polarity on DC compound-wound motors is considered incredible and no further evaluation is necessary.

Nuclear Energy Section 5.4.3, Page There is also discussion on high impact components The NRC staff agrees with this comment.

Institute 87 in NUREG/CR-7150 and NEI 00-01, Revision 4, that provides more detailed guidance. The NRC staff added the following to the end of Section 5.4.3.b of DG-1359:

Proposed resolution:

Include a reference to these treatments of high For high impact components, Appendix J of impact components and circuit failure criteria as an NEI 00-01, Revision 4, provides an acceptable acceptable approach. approach for treatment of circuit failure criteria.

Draft Version for use at ACRS Full Committee Meeting on May 5, 2021 Commenter Section of Specific Comment NRC Resolution DG-1359 Nuclear Energy Section 5.4.3, Page The Section 5.4.3 discussion on hot short duration is The NRC staff agrees with this comment.

Institute 87 not consistent with DG-1359 Section 5.3, Item e.

The NRC staff revised the sentence in Section Proposed resolution: 5.4.3.b of DG-1359 to read:

Update the second paragraph of this section to reflect 20 min/40 min AC/DC from NUREG/CR- Hot short conditions are assumed to exist for 7150 and NEI 0001, Revision 4. the durations outlined in Regulatory Position 5.3.1.e of this guide or until action has been taken to isolate the circuit from the fire area or other appropriate actions have been taken to negate the effects of the spurious actuation.

Nuclear Energy Section 5.5.2, Page This section mentions HIFs in two places. With the The NRC staff notes the comment. However, the Institute 90 addition of Section 5.3.3 providing blanket NRC staff disagrees with the suggested endorsement of NEI 00-01 Appendix B.1 for resolution.

MHIFs, it should no longer be necessary to discuss HIFs in Section 5.5.2. Section 5.5.2 of DG-1359 emphasizes the requirement to compensate for spurious Proposed resolution: actuations and HIFs in alternate or dedicated Remove reference to HIFs in Section 5.5.2. procedures.

The NRC staff moved the discussion of NEI 00-01 Appendix B.1 and Kaptan cables to the end of DG-1359 Section 5.3.3.

Draft Version for use at ACRS Full Committee Meeting on May 5, 2021 Commenter Section of Specific Comment NRC Resolution DG-1359 Nuclear Energy Section 6.1.1.3, Page This section calls for detection in containment, The NRC staff notes the comment. However, the Institute 92 however it provides no exception for plants with NRC staff disagrees with the suggested inerted containments. This puts this section in resolution. DG-1359 Section 3.1.i clearly states direct conflict with section 3.1.i, which says that that the detection requirements are only for detection is only required in noninerted noninerted containments and cites Regulatory containments. Position 6.1.1.3 for the relevant guidance.

Proposed resolution: Further, this text was included since the initial Clarify that this is for noninerted containments only. issuance of Regulatory Guide 1.189 in 2001.

The NRC staff made no changes to DG-1359 as a result of this comment.

Draft Version for use at ACRS Full Committee Meeting on May 5, 2021 Commenter Section of Specific Comment NRC Resolution DG-1359 Nuclear Energy Table of Contents, Section 1.8.3 refers to Appendix A, which has been The NRC staff notes the comment. However, the Institute Section removed from DG-1359. NRC staff disagrees with the suggested 1.8.3, Appendix A Appendix A contains important information on resolution.

engineering evaluations to demonstrate equivalency and situations that are adequate for the hazard that The information contained in the previous are very important concepts with origin in GL 86- Appendix A consisted of material from items 1,

10. 4, and 5 of Enclosure 1, Interpretations of Appendix R, to Generic Letter 86-10. Based on Proposed resolution: NRCs guidance for development of regulatory Retain the relevant information in Appendix A to guides, Appendix A was removed because of is avoid potential misinterpretation of this guidance in redundancy to Generic Letter 86-10. The NRC the future. staff continues to consider this information as valid guidance.

As a result, the NRC staff added a reference to Enclosure 1 of Generic Letter 86-10 to Section 1.8.3 of DG-1359. The NRC staff also deleted the last sentence of Section 1.8.3 of DG-1359 to remove the erroneous reference to Appendix A and made editorial corrections to the table of contents.

Draft Version for use at ACRS Full Committee Meeting on May 5, 2021 Commenter Section of Specific Comment NRC Resolution DG-1359 Michael Keller General Unclear how this guide can be applicable to The NRC staff partially agrees and partially passively safe advanced reactors. disagrees with this comment.

The guide should state that it is limited to those The staff agrees that not all fire protection water cooled reactors that employ active measures regulations or guidance applies to all possible (e.g. pumping water, electrical power) to protect the nuclear power plant designs. This is described in public from hazardous radiation. the Applicability section of part A of DG-1359: Since not all of the fire protection Applicability to passively fail safe advanced reactors regulations promulgated by the NRC apply to all should be along the lines of reliance on passive plants, licensees should refer to their plant protection measures and automatic mitigation specific licensing bases to determine the measures. applicability of a specific regulation to their plant.

For advanced reactors, the extent of the guide should also be limited to areas housing Safety-Related equipment, including structures and equipment that Guidance for all possible plant designs is beyond protect Safety-Related equipment. the scope of DG-1363. Applicability of or exemption from particular regulations for Some form of general statement should be included passive fail safe advanced reactors would be on expectations for fire protection measures reviewed by the NRC staff during the licensing associated with passively safe advanced reactors. review stage on a case-by-case basis depending The statement might merely note that the matter on the design.

needs further review.

The NRC staff made no changes to DG-1359 as a result of this comment.